Wilma Privacy Statement

When you use Wilma, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.

This privacy statement describes the personal data we collect, how it is used and shared, and your choices regarding this data. We recommend that you read this carefully.

Scope

This privacy statement applies to Members of Wilma’s services anywhere in the world, including Member of Wilma’s apps, websites, features, or other services.

This privacy statement describes how Wilma and its affiliates, collect and use personal data. It applies to all Members of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy statement. This privacy statement specifically applies to:

  • Members: individuals who have become Members of the Wilma community, whether Drivers or Riders
  • Riders: Individuals who request or receive transportation, including those who receive transportation requested by another individual.
  • Drivers: individuals who provide transportation to Riders.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us at privacy@getwilma.app or through the addresses below with any questions regarding our practices in a particular country or region.

I. Data collections and uses

A. The data we collect

Wilma collects:

  • Data provided by Members to Wilma, such as during the member’s account (“Member Account”) creation
  • Data created during use of our services, such as location, app usage, and device data
  • Data from other sources, such as Wilma partners and third parties that use Wilma APIs

The following data is collected by or on behalf of Wilma:

1.   Data provided by Member. This includes:

  • Member profile: We collect data when Members create or update their Member Accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), Driver’s license and other government identification documents (which may indicate document numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of Drivers, emergency contact information, Member settings, and evidence of health or fitness to provide services using Wilma apps.
  • Photos: We may use the photos submitted by Members to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data”
  • Background check and identity verification: We collect background check and identity verification information for Drivers. This may include information such as Driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Wilma’s behalf.
  • Demographic data: We may collect demographic data about the Member, including through Member surveys. In some countries, we may also receive demographic data about Member from third parties.
  • Member content: We collect the information the Member submits when they contact Wilma customer support, provide ratings or compliments for other Member or restaurant partners, or otherwise contact Wilma. This may include feedback, photographs or other recordings collected by Member.

2.   Data created during use of our services. This includes:

  • Location data (Driver): Wilma collects this data when the Wilma app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
  • Location data (Members): We collect precise or approximate location data from Members mobile devices if they enable us to do so. Wilma collects this data from the time a ride is requested until it is finished, and any time the app is running in the foreground of their mobile device. We use this data to enhance your use of our apps, including to improve pick-up locations, enable safety features, and prevent and detect fraud.

Wilma collects Driver location data, and links location data collected during a trip with their Rider’s Member Account, even if the Member has not enabled us to collect location data from their device. This enables us to offer services to the Member like receipt generation and customer support.

  • Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
  • Member data: We collect data about how Members interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.
  • Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.
  • Communications data: We enable Members to communicate with each other and Wilma through Wilma’s mobile apps and websites. For example, we enable Drivers and Members, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Wilma receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Wilma may also use this data for customer support services (including to resolve disputes between Member), for safety and security purposes, to improve our products and services, and for analytics.

3.   Data from other sources. This includes:

  • Members participating in our referral programs: For example, when a Member refers another person, we receive the referred person’s personal data from that Member.
  • Other Members: Member Account owners who request services for or on behalf of other Members, or who enable such Member to request or receive services through their Member Accounts. This includes owners of Wilma for Business Member Accounts.
  • Other data:
    •  Member feedback, such as ratings, feedback, or compliments.
    • Members or others providing information in connection with claims or disputes.
    • Member business partners through which Members create or access their Member Account, such as payment providers, social media services, or apps or websites that use Wilma’s APIs or whose APIs Wilma uses.
    • Vendors who help us verify Members’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.
    • Insurance, vehicle, or financial services providers for Drivers.
    • Publicly available sources.
    • Marketing service providers, where permitted by applicable privacy laws.

Wilma may combine the data collected from these sources with other data in its possession.

B. How we use personal data

Wilma collects and uses data to enable reliable and convenient transportation, and other products and services. We also use the data we collect:

  • for customer support;
  • for research and development;
  • to enable communications between Members;
  • to send marketing and non-marketing communications to Members;
  • in connection with legal proceedings; and
  • to enhance the safety and security of our Member and services.

Wilma does not sell or share Member personal data with third parties for their direct marketing, except with Members’ consent.

Wilma uses the data it collects for purposes including:

1. Providing services and features. Wilma uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:

  • create and update Members’ Member Accounts;
  • verify Drivers’ identity, background history, and eligibility to work;
  • enable transportation, deliveries, and other services;
  • offer, process, or facilitate payments for our services;
  • track and share the progress of rides;
  • enable features that allow Member to share information with other people, such as when Members submit a compliment about a Driver, refer a friend to Wilma, split fares, or share ETA and location with their contacts; and
  • perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2. Providing services and features. Wilma uses the data we collect to provide, personalize, maintain, and improve our products and services. This includes using the data to:

  • screen Members and Drivers, and before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe Drivers and/or Members;
  • use device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities;
  • use Member ratings and feedback to encourage compliance with our Community Guidelines [insert link] and as grounds for deactivating Drivers with low ratings or who otherwise violated such guidelines in certain countries.

3. Customer Support. Wilma uses the information we collect to provide customer support, including to:

  • direct questions to the appropriate customer support person;
  • investigate and address Member concerns; and
  • monitor and improve our customer support responses and processes.

4. Research and development.  We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the Member experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Enabling communications between Members. For example, a Driver may message or call a Rider to confirm a pickup location, or a Rider may contact a Driver to retrieve a lost item.

6. Marketing. Wilma may use the data we collect to market our services to our Member, where permitted by you. This includes sending Member communications about Wilma services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

Where you have agreed, we may also send communications to our Member about products and services offered by Wilma partners. Although we may send Member communications about Wilma partners’ products and services, we do not sell Members’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with Members’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on Member location, past use of Wilma’s services, and Member preferences and settings.

7. Non-marketing communications. Wilma may use the data we collect to generate and provide Member with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Wilma or its partners.

8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Wilma’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9. Automated decision-making. We use personal data to make automated decisions relating to use of our services. This includes:

  • enabling dynamic pricing, in which the price of a ride is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of Members and Drivers using Wilma at a given moment;
  • matching available Drivers to Members requesting services. Member can be matched based on availability, proximity, and other factors;
  • determining Driver ratings, and deactivating Drivers, and Members with low ratings;
  • deactivating Members who are identified as having engaged in fraud or activities that may otherwise harm Wilma, its Members, and others. In some cases, such as when a Member is determined to be abusing Wilma’s referral program, such behavior may result in automatic deactivation.
  • using Driver location information, and communications between Members and Drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a Driver is delaying a Rider pickup in order to induce a cancellation, we will not charge the Rider a cancellation fee and will adjust the amounts paid to the Driver to omit such a fee. To object to such adjustment, please contact Wilma customer support.

To object to a deactivation resulting from these processes, please contact Wilma customer support.

C. Cookies and third-party technologies

See our Cookie Policy for more information about cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

D. Data sharing and disclosure

Some of Wilma’s products, services, and features require that we share data with other Member or at a Member’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Wilma may share the data we collect:

1.   With other Members. This includes sharing:

  • Members’ first name, rating, and pickup and/or drop-off locations with Drivers;
  • for Drivers, we may share data with your Riders, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by Member; total number of trips; length of use of the Wilma app; contact information (depending upon applicable laws); and Driver profile, including compliments and other feedback submitted by past Member;
  • receipts containing information such as a breakdown of amounts charged, Driver first name, photo, route map, and such other information required on invoices in the country or region where the Driver person operates; and
  • for those who participate in Wilma’s referral program, certain personal data of referred Member, such as trip count, with the Member who referred them, to the extent relevant to determining the referral bonus.

2. At the Member’s request. This includes sharing data with Wilma business partners. For example, if a Member requests a service through a partnership or promotional offering made by a third party, Wilma may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurant partners or other Wilma business partners and their Member in connection with promotions, contests, or specialized services.

3. With the general public. Questions or comments from Members submitted through public forums such as Wilma’s blogs and Wilma social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a Member.

4. With another Member Account owner. If a Member requests transportation or places an order using a Member Account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that Member Account.

5. With Wilma subsidiaries and affiliates. We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Wilma processes and stores data in Canada on behalf of its international subsidiaries and affiliates.

6.   With Wilma service providers and business partners. Wilma provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners, solely for and on behalf of Wilma. These include:

  • payment processors and facilitators;
  • background check and identity verification providers (for Drivers);
  • cloud storage providers;
  • Google, in connection with the use of Google Maps in Wilma’s apps (see Google’s privacy policy [insert link] for information on their collection and use of data);
  • Facebook, in connection with the use of the Facebook Business Tools in Wilma’s apps and websites (see Facebook’s privacy policy for information on their collection and use of data);
  • data analytics providers;
  • research partners, including those performing surveys or research projects in partnership with Wilma or on Wilma’s behalf;
  • vendors that assist Wilma to enhance the safety and security of its apps;
  • consultants, lawyers, accountants, and other professional service providers; and
  • insurance and financing partners.

7. For legal reasons or in the event of a dispute. Wilma may share Members’ personal data if we believe it is required by applicable law, operating license, legal or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, Member agreements, or other policies; to protect Wilma’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent. Wilma may share a Member’s personal data other than as described in this notice if we notify the Member and they consent to the sharing.

E. Data retention and deletion

Wilma retains Member data for as long as necessary for the purposes described above.

Members may request deletion of their Member Accounts at any time. Wilma may retain Member data after a deletion request due to legal or regulatory requirements or for the reasons stated in this privacy statement.

Wilma retains Member data for 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 category of Member to whom the data relates, the type of data, and the purposes for which we collected the data.

Member may request deletion of their Member Account at any time through the Settings > Privacy menus in the Wilma app, or through Wilma’s website. Following a Member Account deletion request, Wilma will delete the Member Account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the Member Account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to Drivers this generally means that we retain certain of their Member Account and data for a minimum of 7 years after a deletion request. For Members, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

F. Grounds for processing

We only collect and use personal data where we have lawful grounds to do so. These include processing Member personal data to provide requested services and features, for purposes of Wilma’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our Member are located, but generally include processing personal data:

A- To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

  • Member profile data, which we use to establish and maintain Member Accounts; verify Member identity; communicate with Member\s about their trips, orders, and Member Accounts; and enable Member to make payments or receive promotional credits;
  • background trip information, which is used to verify an applicant’s eligibility to be a Driver;
  • Driver data, which we use to track trips and assist with navigation;
  • usage data, which is necessary to maintain, optimize, and enhance Wilma’s services, including to determine incentives, connect Members and Drivers, and calculate costs of trips and Driver earnings;
  • transaction information; and
  •  information relating to customer support.

B- For purposes of the legitimate interests and reasonable purposes of Wilma or other parties

This includes using personal data to maintain and enhance our Members’ safety and security. For example, we use personal data to prevent use of our services by Member who have engaged in inappropriate or dangerous behaviour, such as by retaining data of banned Member to prevent their future use of Wilma’s apps. We also use usage data to prevent matching of Member and Drivers for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other Member).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Member’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

C- To fulfill Wilma’s legal obligations

For example, Wilma is subject to laws and regulations in many cities and countries that require it to collect and retain data about our Members’ trips and deliveries, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

Wilma may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes. Wilma may also share information with public health authorities where required or permitted by law.

D- With consent

Wilma may collect and use personal data based on the Member’s consent. For example, we may collect personal data through voluntary surveys or consents to receive commercial electronic messages. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A Member who has provided consent to a collection or use of their personal data can revoke it at any time. However, the Member will not be able to use any service or feature that requires collection or use of that personal data.

II. Choice and transparency

Wilma enables Members to access and control the data that Wilma collects, including through:

  • in-app settings;
  • device permissions;
  • in-app ratings pages; and
  • marketing opt-outs and opt-ins.

Wilma also enables Members to request access to or copies of their data, changes or updates to their Member Accounts, deletion of their Member Accounts, or that Wilma restrict its processing of Member personal data.

A- Privacy settings

Settings menus in the Wilma app for Members give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Wilma. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

  • Location data. Wilma uses Members’ device location services to make it easier to get a ride whenever they need one. Location data helps improve our services, including pickups, navigation, and customer support.
  • Share Live Location (Members). Members who have enabled Wilma to collect location data from their mobile device may also enable Wilma to share their location with their Driver from the time the ride is requested to the start of the trip. This can help improve pickups for both Drivers and Members, particularly in crowded areas. Member may enable or disable this feature through the Settings > Privacy menus in the Wilma app.
  • Emergency Data Sharing (Members). Members who have enabled Wilma to collect location data from their mobile device may also enable the Emergency Data Sharing feature, if available, that shares data with emergency police, fire, and ambulance services. Such data includes approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the Rider’s name and phone number; pickup and drop-off locations; and the Driver’s name. Members may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the Wilma app.
  • Notifications: Member Account and trip updates. Wilma provides Members with trip status notifications and updates related to activity on their Member Account. These notifications are a necessary part of using the Wilma app and cannot be disabled. However, Members may choose the method by which they receive these notifications through the Settings > Privacy menus in the Wilma app.
  • Notifications: discounts and news. Member may enable Wilma, including through its service providers, to send push notifications about discounts and news from Wilma. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Wilma app.

B- Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify Members the first time the Wilma app requests permission to access certain types of data and gives Members the option to grant or refuse permission. Android devices notify Members of the permissions that the Wilma app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

C- Ratings look-up

After every trip, Drivers and Member are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a Member’s Member Account and is displayed to other Members for whom they provide or receive services. For example, Rider ratings are available to Drivers from whom they request transportation, and Driver ratings are available to their Members that request transportation.

This 2-way system holds every Member accountable for their behaviour. Accountability helps create a respectful, safe environment for all Members.

Riders can see their average rating in the main menu of the Wilma app. Drivers can see their average rating after tapping their profile photo in the Wilma Driver app.

D- Marketing opt-outs

Subject to having obtained prior consent where required, Member may opt out of receiving promotional emails from Wilma. Member may also opt out of receiving emails and other messages from Wilma by following the unsubscribe instructions in those messages. We may still send Members who have opted out non-promotional communications, such as receipts for rides or information about their Member Account.

E- Member data requests

Wilma provides Members with a variety of ways to learn about, control, and submit questions and comments about Wilma’s handling of their data.

  • Accessing data: Members can ask for an explanation of the data we collect from them and how we use it.
  • Receiving data: Members can ask for a copy of data that Wilma collects from them with their consent or as necessary to provide our services.
  • Changing or updating data: Members can edit the name, phone number, email address, payment method, and photo associated with their Member Account through the Settings menu in Wilma’s apps or Driver portal. They may also ask that Wilma change or update their data, including if they believe such data is inaccurate or incomplete.
  • Deleting data: Members may request deletion of their Member Account at any time through the Settings > Privacy menus in the Wilma app, or through Wilma’s website, subject to retention requirements set out in this privacy statement.
  • Objections, restrictions, and complaints: Members may request that we stop using all or some of their personal data, or that we limit our use of their data. Wilma may continue to process data after such objection or request to the extent required or permitted by law.

III. Updates and Modifications

We may occasionally update this notice. If we make significant changes, we will notify Member in advance of the changes through the Wilma apps or through other means, such as email. We encourage Member to periodically review this notice for the latest information on our privacy practices.

IV. Questions or Concerns

Wilma’s compliance with this Privacy Policy and with applicable privacy laws is overseen by our Privacy Officer.  If you have any questions or concerns regarding this Privacy Policy or our privacy practices, please contact our Privacy Officer at privacy@getwilma.app.

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