Global Privacy Notice for Passengers and Riders

  1. Preamble :

    In accordance with Law No. 18-07 of 25 Ramadan 1439 corresponding to July 10, 2018, relating to the protection of natural persons in the field of the processing of personal data and mentioned in the official journal of the country of extension of service (Algeria) under the preceding reference and in accordance with the regulatory and legislative laws in force in the Country, in accordance with what is indicated in the Global Privacy Notice for FILAR’s Passengers and Riders, we aim in this regard to establish a Global Privacy Policy for Passengers and Riders.

    Filar Transportation is the Controller of your personal data unless otherwise stated below.

    Our postal address is: : Neighborhood of Ain Allah, Cooperative of Elbouroudj Group of Propriety Number 425 class 02, Ground Floor, Algiers, Algeria.

    We have nominated a Data Protection Officer, and you can contact him at contact@filar.app

    The term “us” or “we” refers to Filar Transportation, a private limited company incorporated and registered under the laws of the Republic of Algeria with registration code : 23B1018870-00/16.

    The term “you” or “your” refers to the passenger or rider who requests, hires, and/or receives a transportation service through their Filar app account.

  2. Personal data we process for Filar:

    We only process information that we need, so we can provide you with the best service on our transportation marketplace.

  3. Purposes of the processing :

    We process your personal data so we can provide you with one or more of our transportation services:

  4. Legal basis :

    We are allowed to use personal information in the ways described above if we have a proper reason to do so. We always make sure we have a good reason for doing anything with your data.

    Personal data is generally processed in order to provide the services contracted through the Filar app with you. This means that to give you the service we promised you, and to meet our terms and conditions, we’ll process your personal data to meet those obligations.

    We generally in other circumstances process your personal data relying on legitimate interest grounds. Legitimate interests include our commercial interests in providing an innovative, personalised, safe and profitable service to our passengers and partners, unless

    those interests are overridden by other interests. Our legitimate interests also include things like investigating and and other malicious activities, maintaining the security of our network and systems, and responding to suspected or actual criminal acts.

    We may from time to time rely on alternative legal bases when:

    it is necessary to comply with a legal obligation such as for processing data when the law requires it, including, for example, if there is a valid legal request to disclose personal information to a third party such as a Court or regulatory authority;

    to protect your vital interests, or those of others, for example in the event of an emergency or an imminent threat to life; or

    you have given us clear consent to do so for another specific purpose in which you have been fully informed.

    If you choose not to give us personal information it may prevent us from fulfilling the contract with you, or stop us doing something expected of us in law. It may also mean that we cannot operate your account. For example, we collect and process the personal data submitted by you in the course of installing and using the Filar app; refusing to share geolocation data via the App means we cannot direct a driver to your location for pick-up, nor can we show you one of our own vehicles close to you for hire. We will not be able to fulfil our obligations to you in other circumstances, for example, should you refuse to undertake an identity verification check to ensure the integrity of your account, then the account may be suspended or blocked to prevent fraud.

  5. Recipients :

    We only work with trusted partners and authorities. We only share when there is a proper reason to do so. We limit sharing to only that which is required. We do not sell your personal information.

    The personal data of the passenger is only disclosed to the ride- hailing drivers when they engage with a ride on in the Filar app; in such a case, the driver will see the name, phone number , rating and geolocation data of the passenger.

    Feedback given by passengers regarding the quality of the ride- hailing service is anonymous. Your rating is private between you and Filar.

    Depending on the location of the passenger, the personal data may be disclosed to the Filar Transportation and partners (local subsidiaries, representatives, affiliates, agents, etc.). Processing of personal data by Filar company and partners will occur under the same strict conditions as established in this privacy notice.

    In some circumstances we are legally obliged to share information with external recipients. For example, under a Court Order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We can also respond to requests, such as those from law enforcement agencies, when we have a good-faith belief that the response is required by law in that jurisdiction or furthers a public interest task, affects users in that jurisdiction, and is consistent with internationally recognized standards. In any scenario, we'll always satisfy ourselves that we have a lawful basis on which to share the information, and we'll make sure that we document our decision.

  6. Security and access :

    Any personal data collected in the course of providing our services is transferred to and stored in our data centers. Only authorized employees of Filar companies and partners have access to the personal data, and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).

    Filar company and partners can access personal data to the extent necessary to provide customer support in the respective country.

    For our research and scientific purposes, all data, like bulk geolocation data, is anonymized so you can never be identified from it.

  7. Your rights and controls :

    We want you to stay in control of your personal data. Filar provides you with controls through the app where you can view your personal information, including your profile data and trip history. We also offer in-app settings like marketing opt-ins, and transparent cookie consent controls on our website.

    Your right of access

    You can access your personal data via the Filar app. You have the right to ask us for copies of your personal information. There are some exemptions, such as when we have to balance the rights of others, which means you may not always receive all the information we process. Your right to rectification

    You can access and update your personal data via the Filar app. You have the right to ask us to rectify information you think is otherwise inaccurate. You also have the right to ask us to complete information you think is incomplete. Your right to erasure

    You have the right to ask us to erase your personal information in certain circumstances. Your right to restriction of processing

    You have the right to ask us to restrict the processing of your information in certain circumstances. This means that your data can only be used for certain things, such as legal claims or to exercise legal rights. Your right to object to processing

    You may have the right to object to processing if we are processing your information on the basis of legitimate interests. You may submit an objection to any automated decision we have made, and ask that a person reviews it. Your right to data portability

    You have the right to ask that we transfer the information you gave us from one organization to another, or give it to you, in certain circumstances. This only applies to information you have given us.

    The retention period for the data about instant messages directly in the Filar app messages is 120 days, except cases where

    messages are related to a reported incident - in which case we will store them for 9 months.

  8. Retention:

    Filar retains user data for only as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the transportation service it relates to, and the purposes for which we collected the data.

    Your personal data will be stored as long as you have an active passenger account with Filar. If your account is closed, personal data will be deleted (according to our retention schedule and rules), unless such data is still required to meet any legal obligation, or for accounting, dispute resolution or fraud prevention purposes.

    Financial data regarding transportation services provided to passengers will be stored for three years after the last journey. Data required for other accounting purposes will be stored for seven years after the last journey.

    In the event that there are suspicions of a criminal offense, fraud, or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.

    In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.

    Journey history data and the data about usage of transportation services will be stored for three years, after which the data will be anonymized.

    Please note that the deinstallation of Filar app in your device does not cause the deletion of your personal data. If the Filar app has not been used for three years, we’ll get in touch and ask you to confirm whether you wish to keep your account active for future use. If no reply is received in a reasonable time, the account will be closed and personal data will be deleted unless

    such data is required for any purpose mentioned earlier in this privacy notice.

  9. Direct marketing :

    Filar may send direct marketing messages to your e-mail address and/or phone number when you have given us permission to do so, or under a soft opt-in basis. We may personalize direct marketing messages using information on how you use Filar's services, such as how frequently you use the Filar app, and your transportation preferences.

    If you no longer wish to receive direct marketing messages, please click the "Unsubscribe" link in the footer of one of our emails, or opt-out in the profile section of the Filar app. Easy

  10. Automated decision making :

    Filar uses the help of automated decision-making in case of issuing warnings and implementing ride-hailing service suspensions. Utilizing automated decision-making is less prone to errors, more efficient, and safer than relying solely on our employees. Data about your usage of the transportation services, including journey status (e.g., cancellations, no-shows) and conduct as assessed by drivers, is taken into consideration when assessing the need for a warning or suspension. You can find more information about our automated decision-making process here. Ride-hailing suspensions will remain in effect for 9 months, after which access to the ride-hailing service will be restored.

    We may also utilize automated decision-making for fraud checks, which are necessary for us to perform our services, ensure payment for services rendered, and protect riders from fraudulent transactions on their payment cards.

    Automated decision-making may also be used for verification purposes, ensuring the safety of our platform and enforcement of our terms and conditions.

    Please note that you always have the right to request human review of any decision and contest the decision, express your

    point of view, and obtain an explanation by contacting our customer support through our app.

  11. Dispute resolution :

    Disputes relating to the processing of personal data are resolved through customer support (contact@filar.app) or by contacting Filar's Office at the Folowing address: Neighborhood of Ain Allah, Cooperative of Elbouroudj Group of Propriety Number 425 class 02, Ground Floor

  12. Making this notice great :

We hope you have found this privacy notice from Filar easy to understand.

Data protection laws are crucial as they establish rules and enhance your information rights. While some of these rules may seem complex, they are mostly based on common sense. We take your data protection responsibilities seriously at Filar and are committed to making changes to this privacy notice to further protect your privacy and provide you with increased transparency.

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