PRIVACY POLICY OF GETTRANSFER SERVICE

1. GENERAL PROVISIONS

1.1. This Privacy Policy (hereinafter referred to as the "Policy") describes the procedure implemented by GETTRANSFER LTD, company registered at the address: 57 Spyrou Kyprianou, Bybloserve Business Center, 2nd floor, 6051, Larnaca, Cyprus, and its affiliates and authorized representatives (hereinafter referred to as the "Company") to collect and use the personal data in relation to use the service for search of a provider of private passenger automobile and any other transportation services (the "Carriers"), available at https://gettransfer.com (hereinafter referred to as the "Service"), including the contents, purpose of use and disclosure of the collected information to the third parties, as well as the rights of the Users with respect to such information. This Policy covers all persons, providing information in connection with the use of the Service (hereinafter referred to as the "Users"), including: users of the Service, passengers, Carriers (including any representatives, employees and drivers thereof), while they use the Service through the site, mobile applications, any additional functions and services throughout the world.

1.2. The Company reserves the right to make at its own discretion any amendments to this Policy at any time and without any special notice to this effect. The new version of this Policy shall come into effect upon posting of the same on the Site. Continuing using the Service, the User confirms its consent to comply with the terms and conditions of the Policy in its current version. The Company recommends the Users to review the Policy more often in order to make sure that the User understands the terms, while using the Service. If the User does not agree with the terms of the Policy amended by the Company, he/she shall not be entitled to use the Service.

1.3. Any timeframes set forth herein, are stated according to time zone UTC+0, unless otherwise stated in the text of this Policy. The beginning and the end of calendar dates set forth herein, including those used to determine the duration of a term, shall be determined according to the beginning and the end of respective days in time zone UTC+0.

1.4. Unless this Policy expressly states otherwise, any terms used in the text, shall have meaning determined in Service License Agreement or Service Use Agreement.

1.5. This version of the Policy shall come into effect on February 19, 2024 and remain valid until approval of a new version.

2. COLLECTION OF INFORMATION

2.1. The Company receives the following information on the Users during the Service use: 2.1.1. When the transfers are ordered through the Service or the Service is used by the passenger, the information on the Users may include:

• name (nickname),
• photographs,
• company or sole entrepreneur name,
• details of the company or sole entrepreneur registration (including TIN and VAT numbers),
• e-mail address,
• telephone number,
• details of registration in social media,
• login and password in the Service,
• current and previous settings of Personal Account,
• information on devices used for access to the Service and cookie files,
• addresses and information of the current location,
• information on submitted Transfer requests,
• information on previously ordered Transfers,
• details of the loyalty cards of the airlines or other partners of the Service that may be specified at the - - transfer order,
• records of communication with the Service support and/or driver,
• marks assigned to drivers and/or the Service, comments, reviews, etc.

The Service shall not in any way get access to and process the payment information of the Users (bank cards details, bank account details etc.) at the transfer booking or use of the Service as passenger by the Users.

• name (name of the company or sole entrepreneur, conventional name of the Carrier in the Service),
• images,
• e-mail addresses,
• telephone numbers,
• login and password in the Service,
• registered address,
• details of registration as the legal entity (sole entrepreneur, including TIN and VAT numbers),
• information on licenses,
• information of the vehicles used to perform the Transfers (including technical data, registration information, photographs),
• details of driver’s licenses of the Carrier’s drivers,
• information on the Carriers drivers knowledge of foreign languages,
• payment details (including information on the banking or payment systems’ accounts necessary and sufficient for making payments to such accounts),
• regions where the Carrier may render services via the Service,
• web-site address, social media accounts or other description of Carrier’s business activity,
• information on devices used for the Service use and cookie files,
• current and previous settings of Personal Account,
• positions and names of the Carrier’s representatives,
• information on location of the Carrier’s drivers during the Transfers,
• details of the placed orders, completed and non-completed Transfers,
• records of communication with the Service support and/or passengers,
• marks assigned to the Carrier in the Service (reviews, comments, etc.).

• filling out respective forms in sections of Personal Account by the Users,
• submitting respective data to e-mail of the Company by the Users,
• collection of information during the use of the Service, including by placement of orders for the Transfers and completion of the same.

2.2. As an offer for the Transfer is placed by the User, the Carrier gets access to the following information: place and time of the beginning and the end of the Transfer, number of passengers for the Transfer, flight number (if any). Upon agreeing the terms of the specific Transfer details of the Users using the Service as passengers shall be available to the Carrier to the following extent: name (nickname or other information to be placed at the greeter sign), contact phone number. The Carrier is not be entitled to use the above details of the passengers for any purposes other than for completion of the Transfer.

2.3. The Company may collect and process information through provision of information on the Users to its affiliates, subsidiaries or contractors under the respective service agreements between such third parties and the Company. The Company may collect and process data placed in the Service both in and out of the territory of the European Union. Irrespective of where the data are processed, the Company shall implement the same actions for security of the same, which actions are described herein.

3. INFORMATION USE AND TRANSFER

3.1. The Company shall be entitled to use information provided by the Users for communication with the Users, in order to check the data kept in Personal Account, ensure completion and payment of the Transfers, and for mailing and posting information and marketing messages by any means and in any media.

3.2. The Company shall be entitled to transfer information to its suppliers, consultants, marketing partners, research entities and any other service providers or business partners. During the transfer of information hereunder, the Company shall take steps to process information in compliance with the guidelines and Privacy Policy of the Company, as well as any other applicable regulations on confidentiality and security. In particular, such third parties may include:

• Carriers (only with respect to data on passengers for the purposes of Transfers completion);
• Passengers or persons ordering the transfers through the Service (with respect to data on Carriers, performing their orders, including for the purposes of conflict situations settlement);
• Operators of payment receipt and processing;
• Entities performing the verification of documents (only with respect to data provided by the Carriers);
• Cloud storage providers;
• Marketing partners and marketing platform providers;
• Providers of data analysis systems;
• Research entities, including companies taking the polls or conducting research together with the Company or on behalf of the latter;
• Providers assisting the Company in increasing safety and improvement of protection of its applications;
• Affiliates of the Company, including subsidiaries and dependent companies;
• Consultants, lawyers, accountants, auditors and any other providers of professional consulting services;
• Partners in the scope of insurance and financial services;
• Airports, airlines.

3.3. The Company may transfer data on the Users, if it believes that it is required by applicable law, regulation, valid contract, court proceedings or request issued by a public authority, or if such information needs to be disclosed for the settlement of conflict situations (in particular, with respect to completion and/or payment of the Transfers), ensuring security to the Users or the Service, in case of any claims and disputes, related to getting services under the Service and others by the Users.

3.4. The information on the Users may be provided by the Company to the third parties in connection with such events as merger or sale of the Company’s assets, amalgamation and restructuring, financing and acquisition of a business as a whole or in part, or during the negotiations of such matters.

3.5. The Company may disclose information to the third parties in situations, which are not expressly stated hereby, subject to obtaining the User’s consent to disclosure of information pertaining to him/her.

3.6. Any data transfer by the Company mentioned in this section includes possibility of cross-border data transfer. For the purposes of Transfers completion the personal data may be also transferred via the Service in and out of the European Union, including transferring to or from USA and/or third countries that cannot ensure an adequate level of personal data protection.

3.7. Any information provided by the Users while using the Service may be checked or provided by the Company to the third parties, including the local governmental authorities, for the purposes of sanctions compliance in accordance with the EU regulations following Russia’s military aggression against Ukraine.

4. STORAGE AND ERASURE OF INFORMATION

4.1. The Company keeps the information available in the User’s Personal Account and any other data about the User until the Personal Account is not deleted by the User or until the Service gets the User’s request for deletion of Personal Account.
In order to comply with any legal, fiscal, insurance and any other requests, which are effective in compliance with applicable law, User support, improvement of the service quality, research and analytics with respect to the Service use, direct marketing and for any other operational purposes, the Company keeps all the information about the Users that may be received in accordance with this Privacy Policy, including information on payments of Transfers and License Fees, as well as of the devices used for the use of the Service within all the term of use of the Personal Account, during 7 (seven) years after the Personal Account is deleted. Upon expiry of this term the Company shall delete or anonymize such information in compliance with applicable legislation.

4.2. The Users may at any time send the request for deletion of Personal Account. Upon receipt of such request, the Company shall delete all information on the User, except for the information that must be kept and shall restrict access of any third parties, including the Service Users, to data on such User which remains in the Service. The Users hereby accept and agree, that even in case of deletion of Personal Account, the information on the User may be provided by request of the third parties, in particular, if any conflict situation, related to completion or payment of the Transfer needs to be settled, for the purposes of ensuring security of the Users or the Service, prevention or investigation of any cases of fraud, etc.

5. ACCESS TO AND CHANGE OF INFORMATION

5.1. The Users may change name, telephone number and e-mail address that were specified in the Personal Account. Personal Account also contains the history of the placed orders and agreed Transfers (completed and non-completed due to any reasons), as well as the rating of the User in the Service.

5.2. The requests for receipt of any User information (including purposes of its processing, categories of information processed, information recipients or types of recipients), change of information mentioned in Personal Account in case of its unreliability, deletion of Personal Account and refusal to receive marketing information from the Company may be sent to info@gettransfer.com.

6. COOKIES

6.1. The website of the Company uses "cookies". Information that the Company gets through the cookies helps to deliver services in the most convenient way.
By using this website, the User agrees with the placement of cookies in his device under the terms of this Agreement.
If the User doesn’t agree with the using cookies by the Company, the User need either to customize respectively the settings of his browser for control or disabling of the cookies in his device or not to use this website and exit it.

6.2. Information on cookies.
Cookies are the small text files downloaded by internet browser of the User to his PC/tablet computer, telephone or any other device used by the User for access to the website.
Cookies are used in order to ensure a personalized experience of the site use and convenient site navigation. They help to track the most visited web pages, determine the efficiency of advertising and web searches, and give an indication of the User behavior, thereby contributing to improvement of communication means and products offered to Users. The cookies also help the User not to lose data inserted into the request form, when the site page is refreshed.
Cookies that the Company saves through the website do not contain any data enabling to identify the User.
Please note that the Company do not guarantee a correct work of the Company’s website in the User’s browser, should the User disable the option of cookies storage.

6.3. Used cookies.
The Company uses the cookies of the following types: (1) Performance cookies.
These cookies collect information on using of the websites such as, for example, information on the most visited by User pages of the site. They can be used by the Company for optimization of the websites and navigation facilitation. These cookies are also used by the Company’s affiliates to establish a fact of visit to the site from the site of affiliates; a fact of use of the website’s services. The performance cookies are not used for collection of personal data of the website User. All information collected with such cookies is intended for the purposes of statistics and remains anonymous.(2) Functionality cookies.
These cookies help the websites to remember the choice made by the User, when browsing the website. Such cookies can also be used to remember the settings like a font type and font size of the text, and any other adjustable parameters of the website. The functionality cookies can be used to track the recommended services and videos of the Company in order to prevent the repetition of the same. The functionality cookies help the User not to lose the data inserted into the request form in the website. The information provided by the functionality cookies does not enable User identification and tracking of the User’s experience in the websites, which are not related to the Company.(3) Advertising cookies.
These cookies record data on User actions in the web, including visits to the sites and pages, and data on the links and advertisements clicked by the Users for browsing. This is necessary to display on the websites the content, which is the most targeted for the User, and to ensure the opportunity to provide the advertising or any other information, which is the most compliant with the User’s interests. The Company, together with the third parties, including the technological partners and service providers, participates in advertising targeted to the interests of Users, delivering the advertisement and the personalized content, which, in Company’s opinion, will be of interest for the User.

6.4. Cookies management.
Most web browsers are preset to accept cookies. The User may change settings to block the cookies by the browser or to get notifications, when such files are sent to the device. There are several ways to manage cookies. Read the browser manual please to learn more about how to adjust or change the browser settings.
Please keep in mind that some personal services can’t be delivered to the User and the User selecting such settings can’t get a full access to all sections of the website.

6.5. Term of storage of cookies.
Some cookies operate from the moment of the User’s access to the site till the end of a particular session in the browser. These files become useless and they are automatically deleted upon closing the browser. Such files are called session cookies.
Some cookies are also saved on device between the sessions in browser and they are not deleted after the browser closing. Such cookies are called persistent cookies.

6.6. Additional terms and conditions.
THE TERMS OF THIS POLICY APPLY WITHOUT REGARD TO HOW THE USER GETS ACCESS TO THE NETWORK AND/OR TO THE COMPANY’S WEB-SITE. BY ACCESSING THE WEBSITE THE USER AGREES WITH THE TERMS OF POLICY EACH TIME THE USER VISITS THE SITE WITH ANY DEVICE. ANY AMENDMENTS MADE TO THE POLICY WILL BE PUBLISHED HERE.
This Policy may be amended and/or supplemented by the Company on its own discretion without any special notification. This Policy is an open and public document. The valid version of Policy is available in the web at https://gettransfer.com/privacy_policy. The Company recommends the Users to check regularly the terms and conditions of this Policy for any amendments and/or supplements.

7. APPLICABLE LAW AND GLOBAL OPERATING

7.1. As the Service is globally operating, the Users’ personal data may be processed by the Company, its partners and service providers based in Europe, Asia Pacific and North and South America under the local legislation which may differ from the laws applicable to a User’s country of residence. Some of these countries are subject to a European Commission adequacy decision, such as Japan, New Zealand, Switzerland, the United Kingdom, Canada, and Israel. For other countries, the Company takes pursuant measures to comply with applicable data protection law.

7.2. For the Users residing in the European Economic Area and Switzerland GETTRANSFER LTD (57 Spyrou Kyprianou, Bybloserve Business Center, 2nd floor, 6051, Larnaca, Cyprus) is the controller for any User information under this Privacy Policy as in the terms of European Union General Data Protection Regulation 2016/679.

7.3. Personal data of Users residing in UK is processed under the Data Protection Act 2018, and GETTRANSFER LTD (57 Spyrou Kyprianou, Bybloserve Business Center, 2nd floor, 6051, Larnaca, Cyprus) is the controller for such information.

7.4. Personal information of Users residing in the USA is processed in accordance with the relevant state legislation (California Consumer Privacy Act, Delaware Online Privacy and Protection Act, etc.).