Conigital understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits our websites (www.conigital.com, www.conigital.io, www.conigital.co.uk, www.conigitalgroup.com, www.conigitalgroup.co.uk), “Our Sites”, and/or uses our applications/services (i.e. ConAPP™, ConOP™, Connie™), “Our Services”, together “Our Systems”, and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.
In this Policy the following terms shall have the following meanings:
Account: means an account required to access and/or use certain areas and features of Our Systems;[
Cookies: means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in Part 16, below; and
Cookie-Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003
Our Systems are owned and operated by Conigital Limited, a limited company registered in England under company number 09696591.
- Registered address: Icentrum Faraday Wharf, Holt Street, Birmingham, England, B7 4BB.
- VAT number: 245 3450 19.
- Data Protection Officer: Hargiven Singh.
- Email address: firstname.lastname@example.org.
- Telephone number: +44 (0) 843 289 0874.
- Postal address: Data Protection Officer, Icentrum Faraday Wharf, Holt Street, Birmingham,
- England, B7 4BB.
- We are regulated by the Information Commissioner’s Office (ICO).
Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
- The right to access the personal data we hold about you. Part 15 will tell you how to do this.
- The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 17 to find out more.
- The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Part 17 to find out more.
- The right to restrict (i.e. prevent) the processing of your personal data.
- The right to object to us using your personal data for a particular purpose or purposes.
- The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
- Rights relating to automated decision-making and profiling.
For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Part 17.
It is important that your personal data is kept accurate and up to date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Part 17.
We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children without your consent.
|Data Collected||How We Collect the Data|
|Identity Information including name, title, date of birth, device token, and profile picture.||Entered by you when registering as a user of our service using Our Systems. Profile picture selected from gallery or by camera.|
|Driver Information including driver licencing information, insurance status, vehicle registration, vehicle characteristics.||Entered by you when registering as a driver using Our Systems.|
|Contact information including address, email address, mobile telephone number.||Entered by you when registering as a user of our service using Our Systems.|
|Business information including business name, business address, trading locations, hours of operation, product and services offered, product and service prices, contact name and number.||Entered by you when registering or using Our Systems and captured when purchases are made.|
|Payment information including bank account and card payment details.||Entered by you when registering to use or making payments from Our Systems.|
|Profile information including journey preferences, interests, login details, journey history, purchase history.||Entered by you when registering or using Our Systems and captured when purchases are made.|
|Data from third parties including ticket and onward travel information, receipts and third party bookings.||Entered by you when using Our Systems and captured when purchases and bookings are made.|
|Sensor data captured by autonomous vehicles including video footage.||Recorded by the autonomous vehicle when operating in autonomous mode.|
We do not access any ‘special category’ or ‘sensitive’ personal data or personal data relating to children without your consent.
|Data Accessed||How We Access the Data|
|Device Data including contacts, other applications installed on device.||Accessed locally by Our Systems when using “Share” functionality or when specifying a “Recipient” .|
|Telemetry including current location.||Accessed when Our Systems are open or running in the background when on a journey.|
|Audio including microphone access.||Processed into text but not stored when using speech control.|
|Device status information including network and WiFi connection state.||Accessed while using Our Systems to maintain best connection.|
Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
|What We Do||What Data We Use||Our Lawful Basis|
|Registering you on Our Services.||Identity and Contact information.||Contract|
|Registering you on Our Services as a Driver.||Driver information.||Contract|
|Providing and managing your Account.||Identity, Driver and Contact information.||Contract|
|Providing and managing your access to Our Services.||Identity, Driver and Contact information.||Contract|
|Personalising and tailoring your experience on Our Services.||Profile information and Data from third parties.||Contract|
|Administering and Supplying Our Services and business.||Profile information and Data from third parties.||Contract|
|Managing payments for our services.||Payment and Profile information.||Contract|
|Communicating with you.||Contact and Profile information.||Contract|
|Providing Autonomous Control as part of Our Services.||Sensor data.||Legal obligation.|
With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email and/or text message with information, news, and offers on our and/or third party services and products. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out.
We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
Third Parties (including transport operators and vendors relevant to your journey) whose content appears on Our Services may use third-party Cookies, as detailed below in Part 16. Please refer to Part 16 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We use the following automated systems for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 17.
The following automated decision-making method(s) may be used:
- Automated journey re-routing based on the current journey being undertaken as well as profile information including preferences and journey history, as well as third party information associated with your profile and journey. The lawful basis under which these services are provided is that of a Contract. The data used is to enable optimisation of journeys. The intent is to provide more efficient and relevant passenger experiences.
The following automated profiling may take place:
- Automated filtering of journey and product recommendations based on profile information including preferences, journey and purchase history as well as third party information associated with your profile and journey. The lawful basis under which these services are provided is that of a Contract. The data used is to enable optimisation of journey plans as well as tailored recommendations for product purchases. The intent is to provide more efficient and relevant passenger experiences.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 17.
If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept
|Type of Data||How Long we Keep It|
|Identity Information including name, title, date of birth, device tokens.||12 months from account last login.|
|Driver Information including driver licencing information, insurance status, vehicle registration, vehicle characteristics.||10 years from account last use.|
|Contact information including address, email address, mobile telephone number.||12 months from account last login.|
|Business information including business name, business address, trading locations, hours of operation, product and services offered, product and service prices, contact name and number.||10 years from account last use.|
|Business payment information including bank account details.||10 years from account last use.|
|Payment information including bank account and card payment details.||12 months from account last login.|
|Profile information including journey preferences, interests, login details, journey history, purchase history.||12 months from account last login.|
|Data from third parties including ticket and onward travel information, receipts and third party bookings.||12 months from account last login except where longer period required by third party policies.|
|Sensor data captured by autonomous vehicles including video footage.||10 years from account last use.|
We will store some of your personal data within the European Economic Area (the “EEA”). The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein. This means that your personal data will be fully protected under the EU GDPR and/or to equivalent standards by law. Transfers of personal data to the EEA from the UK are permitted without additional safeguards.
We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:
We will use specific approved contracts which ensure the same levels of personal data protection that apply under the Data Protection Legislation. For further information, please refer to the Information Commissioner’s Office.
Please contact us using the details below in Part 17 for further information about the particular data protection safeguards used by us when transferring your personal data to a third country.
The security of your personal data is essential to us, and to protect your data, we take a number of important measures, including the following:
- limiting access to your personal data to those employees, agents, contractors, and other third parties with a legitimate need to know and ensuring that they are subject to duties of confidentiality;
- procedures for dealing with data breaches (the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, your personal data) including notifying you and/or the Information Commissioner’s Office where we are legally required to do so
We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.
In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
We may share your personal data with other companies in our group for research, development and operational purposes. This includes subcontractors, subsidiaries and/or research partners.
We may sometimes contract with the following third parties to supply certain products and/or services.
|Recipient||ICAV Tech Pvt Ltd – data processor and controller||Conigital Pty Ltd – data controller|
|Activity Carried Out||research and development, operational maintenance||operational maintenance|
If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 11.
If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 11.
- In addition to your rights under the Data Protection Legislation, set out in Part 6, when you submit personal data via Our Services, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
- You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
You may access certain areas of Our Services without providing any personal data at all. However, to use all features and functions available on Our Services you may be required to submit or allow for the collection of certain data.
If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 17.
There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
We will respond to your subject access request within one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
By using Our Services, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. Third-party Cookies may be used by Our Services for third party service support. For more details, please refer to the table below. These Cookies are not integral to the functioning of Our Services and your use and experience of Our Services will not be impaired by refusing consent to them.
All Cookies used by and on Our Services are used in accordance with current Cookie Law.
Before Cookies are placed on your computer or device, you will be shown a pop-up informing you of the purposes of cookies used and allowing you to adjust permissions for these cookies requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Services may not function fully or as intended. You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.
Certain features of Our Services depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Services may not work properly if you do so. we have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||conigital.io|
|Name of Cookie||Session management, screen resolution matching, time settings|
and the following third-party Cookies may be placed on your computer or device:
|Name of Cookie||YouTube|
|Purpose||Access tracking, Using your YouTube account to access and play embedded videos|
Our Services uses analytics services provided by Google. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how Our Services is used. This, in turn, enables us to improve Our Services and the services offered through it.
The analytics service(s) used by Our Services use(s) the following Cookies:
|Name of Cookie||Google Analytics|
|First / Third Party||Third|
|Purpose||Usage analytics monitoring|
In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.
It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
- Email address: email@example.com.
- Telephone number: +44 (0) 843 289 0874.
- Postal Address: Data Protection Officer, Icentrum Faraday Wharf, Holt Street, Birmingham, England, B7 4BB.
We may change this Privacy Notice from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.