Privacy Policy
1. General
Mukesh Marketing Private Ltd. (whose
registered office is at 16th mile post road, Kaluwanchikudy, Sri
Lanka.) (“MmTourpool”, “we”, “our” or “us”), acting as data controller, is committed
to protecting and respecting your privacy. This notice (the “Privacy Notice”)
is designed to tell you about our practices regarding the collection, use and
disclosure of information that you may provide via this website or
our mobile applications (the “Platforms“).
We may collect and process the following
data about you:
2.1. Information you give us
2.1.1. Mandatory information required
to register for the service we provide on our Platforms or to access other
services provided by us, including your name, email address, date of birth,
gender, mobile phone number and a password. All these fields are mandatory. MmTourpool
will not be able to provide you with the services offered on our Platforms if
the required information is not provided, consequently you will not be able to
register for a user account on our Platforms;
2.1.2. A photograph;
2.1.3. A postal address;
2.1.4. Details on your vehicle;
2.1.5. Your mini-biography;
2.1.6. A record of any correspondence
between you and us;
2.1.7. A record of any bookings you
have made or trip related advertisements you have placed with or through our
Platforms;
2.1.8. Details of accounting or
financial transactions including transactions carried out through our Platforms
or otherwise. This may include information such as your payment card or bank
account details, details of trips or legs you have booked or offered through
our Platforms;
2.1.9. Details of your visits to our
Platforms and the resources that you access;
2.1.10. Your replies to any surveys or
questionnaires, such as your reviews on the trips you have shared with other
members of our community. Such information may be used for analytic & user
understanding purposes;
2.1.11. Information we may require
from you when you report a problem with our Platforms or our service, such as
the subject of your request for support;
2.1.12. Location information when you
have given consent to the collection and processing of these data; and
2.1.13. Passport, Driving Licence, NIC,
biometric data, real time geolocation data which can identify an individual,
business secrets deemed highly confidential (e.g., highly confidential business
strategies and communications, sensitive attorney-client privileged and
confidential communications). and such other documents that you have agreed to
provide to us.
2.1.14. Authentication/authorization
credentials, information under strict regulatory or contractual handling
requirements (e.g., PCI, HIPAA, and state and federal data security laws) such
as, credit card information, credit card numbers, CIV numbers (three digit
codes for Visa and MasterCard, four digit code for American Express) and
magnetic stripe information
2.2. Information we collect automatically
2.2.1. If you sign up via social media
authentication methods, MmTourpool will access certain Personal Data (e.g.
first name, surname, picture, email, number of Facebook friends, etc.) in your
social media account pursuant to the applicable terms and conditions of these
social media platforms. We may also collect some of your Personal Data when you
interact with third party social media features, such as “Like” functions.
2.2.2. With regard to each of your
visits to our Platforms we may collect, in accordance with applicable laws and
where required with your consent, information relating to the devices you use
and the networks you are connected to when using our services. This may include
the following information: your IP address, log-in information, browser type
and version, browser plug-in types and versions, operating system and platform,
advertising identifier, information about your visit including the URL clickstream
to, through and from our Platforms, products you viewed or searched for,
download errors, length of visits to certain pages, page interaction and any
phone number used to call our customer service number. We collect this
information through the use of various technologies including cookies (for
further information please refer to our Cookie Notice).
2.2.3. We also collect aggregated
information regarding your activity on our Platform (such as the amount of
rides offered, your message response rate, etc.). Such information may be
published on your public profile on our Platform.
2.3. Data retention
2.3.1. Except regarding the categories
of Personal Data mentioned in clauses 2.3.2 and 2.3.3 below, your Personal Data
will be stored for the duration of your relationship with us and then put
beyond use:
5 years after your last use of our
Platform, if you did not close your account;
1 year after the closing of your account,
except if you received a negative rating or report, in which case your Personal
Data is stored for either (i) a 2-year period following the latest negative
rating or report, or (ii) 1 year after the closing of your account, whichever
is longer.
2.3.2.The following categories of Personal
Data may be stored for different durations:
Financial data (e.g. payments,
reimbursements, etc.) is stored for the duration required by applicable tax and
accounting laws;
All user-generated content (e.g. comments
and ratings) is anonymised but remains available on our Platforms.
2.3.3. In the event that your account
is suspended or blocked, we will keep your data for a period of between 2 and
10 years in order to prevent you from circumventing the rules applying to our
Platforms.
3. How do we use the information we
collect from you?
We will use the information we collect:
PURPOSES LEGAL BASIS
3.1. to carry out our obligations
arising from any contracts entered into between you and us and to provide you
with the information and services that you requested from us; This processing
is necessary for the performance of our mutual contractual obligations.
3.2. to send you service-related
information by email and/or text message and/or any other communication means
(e.g. your booking confirmation); This processing is necessary for the
performance of our mutual obligations and/or
carried out with your consent.
carried out with your consent.
(ii) carried out with your consent and/or
(iii) necessary for the establishment,
exercise or defence of legal claims.
3.8. to send you, in accordance with
applicable laws and where required, with your consent, marketing materials and
information necessary to facilitate the service or the booking process and to
make you suggestions and recommendations about goods or services related to our
services that may interest you. We also use your data to target you in order to
serve our ads on social media platforms. You can learn more about how these
features work, and the data that we obtain about you, by visiting the relevant
sections of the third party social media platforms; and This processing is
based on your consent and/or our legitimate interest (i.e. providing you
with meaningful advertising).
3.9. to notify you about changes to
our services; This processing is necessary (i) for the performance of our
mutual contractual obligations, (ii) for compliance with our legal obligations
and/or (iii) the establishment, exercise or defence of legal claims.
3.10. to verify the information
contained in your Passport, Driving Licence, NIC and other identity documents
that may be collected from you at the time of registration or at any other time
during your use of our Platforms; This processing is based on (i) your consent,
(ii) carried out for the establishment, exercise or defence of legal claims
and/or (iii) for compliance with our legal obligations.
3.11. to administer our Platforms and
for internal operations, including troubleshooting, data analysis, testing,
research, analytic and survey purposes; This processing is based on our
legitimate interest (i.e. ensuring the security of our Platforms and improving
its features).
3.12. to improve our Platforms to
ensure that content is presented in the most effective manner for you and for
your device; This processing is based on our legitimate interest (i.e.
providing you with meaningful content).
3.13. to allow you to participate in
interactive features of our service, when you choose to do so; This processing
is necessary (i) for the performance of our mutual contractual obligations
and/or (ii) based on your consent.
3.15 to measure or
understand the effectiveness of advertising we serve to you and others, and to
deliver relevant advertising to you. This processing is based on (i) our
legitimate interest (i.e. measuring and optimising the efficiency of our
advertising campaigns) and/or (ii) your consent.
4. Who are the recipients of the
Information we collect from you and for which purposes?
4.1. When you use our services, some information
about you is shared with the members of our communities, either on your public
profile or during the booking process (e.g. we give your telephone number to
the members with whom you will share a ride).
4.2. We may receive and send
information about you, including your Personal Data, if you use any of the
platforms we operate or from other MmTourpool entities and affiliates, for the
purposes outlined in this Privacy Notice.
4.3. We are also working closely with
third parties which may be the recipients of your Personal Data such as: our
business partners who are social media platforms and which may provide you with
connecting services, such as the connection of the information of your profile,
from their social media platforms to our Platforms;
our business partners who may advertise
their services on our Platforms and to which you may decide to sign up for:
these services may be any service related to our services such as insurance
services, banking services, rental services, etc. For instance, we may provide
insurance companies with some of your information in order to confirm that you
are eligible for insurance cover;
our business partners who may advertise our
services on their websites;
our sub-contractors in technical, payment,
identity
4.4. We only share your Personal
Data with any of these third parties in the following cases:
4.4.1. Where it is necessary to
involve a third party service provider, for the performance of any contract we
enter into with you in order to facilitate or extend our services (e.g. if we
charge you any fees or collect any money from you in relation to any services
on the Platforms);
4.4.2. As part of the booking process
and in order to provide the requested services, information such as your name,
photography, mobile phone number and/or email address, may be displayed on the
Platforms and/or passed on to a passenger (if you are a driver) or a driver (if
you are a passenger);
4.4.3. As part of our rating system,
the reviews you write will be published on the Platforms. The reviews including
your abbreviated name and photography are visible to all visitors of the
Platforms;
4.4.4. We use analytics and search
engine providers to assist us in the improvement and optimisation of our
Platforms;
4.4.5. It is explicitly requested by
you (e.g. with when using social media authentication methods);
4.4.6. We may distribute parts of our
Platforms (including the trips you have posted) for display on our business
partners’ websites through API or widgets. In these cases, some information
from your public profile may be displayed on these websites;
4.4.7. MmTourpool may also disclose
your information if required to do so by law or in a good faith belief that
such access, preservation or disclosure is reasonably necessary to (i) respond
to claims asserted against MmTourpool, (ii) to comply with legal proceedings,
(iii) to enforce any agreement with our users such as our Terms and Conditions
and our Privacy Notice, (iv) in the event of an emergency involving the danger
of public health, death or physical injury to a person (v) in the framework of
investigation or (vi) to protect the rights, property or personal safety of MmTourpool,
its members or others ;
4.4.8. In the event that we sell or
buy any business or assets, in which case we may disclose your Personal Data to
the prospective seller or buyer of such business or assets; and
4.4.9. If MmTourpool or all or part of
its assets are acquired by a third party, in which case Personal Data held by
it about its members will be one of the transferred assets.
4.5. In accordance with applicable
laws and where required with your consent, we may combine information about
you, including your Personal Data and cookie information, we send to and
receive from our business partners. We may use this information and the
combined information for the purposes set out above.
4.6. We draw your attention on the
fact that if you decide to share your information, including Personal Data,
with us through our business partners’ connecting services, any of our business
partners’ privacy policies and/or notices may also be applicable to you, in
addition to this Privacy Notice. We do not control the collection and/or the
processing of your information eventually made by our business partners on
their own platforms.
5. How do we use and moderate your
messages?
5.1. We may review, scan, or analyse
the messages you exchange with other members of our community through our
Platforms for fraud prevention, service improvement, customer support purposes,
enforcement of the contracts entered into with our members (such as our Terms
and Conditions). For example, in order to prevent the circumventing of our
online booking system, we may scan and analyse messages sent through our
Platforms to check that they do not include any contact details or references
to other websites.
5.2. We will never scan or analyse
your messages with other members of our community for commercial and
advertising purposes. We may use automated methods to carry out the moderation
of these messages, but no automated individual decision-making is performed in
this regard.
In accordance with applicable laws and
where required with your consent, we may use the information you give us on our
Platforms for electronic direct marketing purposes (e.g. (i) receiving our
newsletters, invitations to our events or other communications that we think
may interest you or (ii) serving you with targeted advertising on social media
platforms or third parties websites).
For electronic marketing communications:
You can withdraw your consent at any time by (i) unticking the relevant box in
your member account, (ii) clicking on the unsubscribe link we provide in each MmTourpool
communication sent to your attention or (iii) contacting us using the contact
details provided in section 13 below.
For targeted ads and content:
on social media (e.g. Facebook and
Twitter): you can object at any time by configuring your settings regarding
advertisement via your social media account;
on third party websites: please refer to
our Cookie Policy to see how to object.
In principle, we store the Personal Data
that we hold about you in Taiwan. However, since for example some of our
service providers are based in countries outside of the Taiwan (“third
countries”), we also transfer some of your data to third countries. This may
include third countries where the Taiwan Commission has not taken the decision
that such third country ensures an adequate level of protection (for example
the United States). In that case, we ensure that the transfer is performed in
accordance with the applicable legislation and that appropriate safeguards have
been put in place (especially standard contractual clauses as issued by the
Taiwan Commission) in order to guarantee a sufficient level of protection of
individuals’ private life and fundamental rights.
By sending a request to the Group Data
Protection Officer (dpo-Taiwan@MmTourpool.com), we can provide you with the
details regarding such appropriate safeguards
8.1. You are entitled to receive a
copy of your personal data that is in our possession (your right of data
access).
8.2 You may request the deletion of
personal data or the correction of inaccurate personal data (your right to
erasure and rectification). Please note that we may keep certain information
concerning you, as required by law, or when we have a legal basis to do so
(e.g., our legitimate interest to keep the platform safe and secure for other
users).
8.3 You have the right to object at
any time (i) to the processing of your personal data for the purpose of direct
marketing, or (ii) to the processing of your personal data for other purposes
on grounds relating to your particular situation (your right to object to
processing). Please note that in the latter case, this right only applies if
the processing of your personal data is based on our legitimate interest.
8.4 You have the right to restrict the
processing of your personal data (your right to restriction of processing).
Please note that this only applies if (i) you contested the accuracy of your
personal data and we are verifying the accuracy of the personal data, (ii) you
exercised your right to object and we are still considering, as foreseen by the
applicable law, whether our legitimate grounds to process your personal data in
that case override your interests, rights and freedoms; or (iii) your personal
data has been processed by us in an unlawful way but you either oppose the
erasure of the personal data or want us to keep your personal data in order to
establish, exercise or defend a legal claim.
8.5 You have the right to receive
and/or have us transfer to another data controller a subset of personal data,
that concern you and that you provided us with, and which we process for the
performance of our contract or because you previously consented to it, in a
structured, commonly used and machine-readable format (your right to data
portability).
8.6 To exercise your rights, please
contact the Group Data Protection Officer (see under Artticle 13).
8.7. You also have the right to make a
complaint to the relevant data protection supervisory authority or to seek a
remedy through the courts if you believe that your rights have been breached.
9. Cookies & similar technologies
To find out more, please see
our Cookie Notice.
10. Confidentiality of your password
Where you have chosen a password which
enables you to access certain parts of our Platforms, you are responsible for
keeping this password confidential. We ask you not to share a password with
anyone.
11. Links to other websites and social
media
Our Platforms may, from time to time,
contain links to and from the websites of our partner networks, advertisers and
affiliates. If you follow a link to any of these websites, please note that
these websites have their own privacy practices and that we do not accept any
responsibility or liability for these policies. Please check these policies
before you submit any Personal Data to these websites.
Any changes we may make to our Privacy
Notice in the future will be posted on this page. Where appropriate, we will
notify you or seek your consent. Please check back frequently to see any
updates or changes to our Privacy Notice.
13. Contact & Data Protection
Officer
If at any time you would like to contact us
with your views about our privacy practices, or with any enquiry relating to
your Personal Data, please use one of the following means:
via email to our Data Protection Officer
under dataprotection@MmTourpool.com
Version dated 20 March 2025
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