Introduction

Welcome to Goochil! When you use the Goochil app, we take your personal data seriously and are committed to keeping you safe and private.

This communication describes the personal data we collect, and how we use and share it. We recommend you read this.

This policy describes our approach to processing the personal data of Goochil users. It applies when you use Goochil's websites, mobile applications, products, content, or services, or when you communicate with us. The policy does not cover how we handle information about our customers, employees, or business partners.

This policy applies wherever Goochil is available, except in countries where a jurisdiction-specific privacy policy exists. We will comply with applicable local laws in connection with all practices described in this policy. If there is an inconsistency between this policy and local law, we will comply with local law to the extent of the inconsistency.

Users who request or receive transportation, logistics, or courier services through Goochil are referred to as "Passengers," and individuals who provide these services to Passengers are referred to as "Drivers."

What Information Do We Collect?

We collect three categories of information about you:

• Information you provide

• Information we collect automatically

• Information we obtain from other sources

We do not collect information about your racial or ethnic origin, political opinions, or membership of any political association, religious or philosophical beliefs, trade union membership, genetic data, or data relating to a person's sex life or sexual orientation.

Information You Provide

Check-in and passenger information may include name, phone number, email, country, and city. Where permitted or required by law, we may collect your selfie image for life checks, national identification numbers, and social media accounts for security purposes, as well as emergency contact numbers. Without providing this information, you will not be able to use Goochil or some of its features. If you wish, you can also provide your last name and profile picture.

Driver information may include the driver's full name, profile picture, license data and status, information about the vehicle (type, make, model, year of manufacture, color, registration certificate data, license plate, vehicle inspection report, vehicle image), proof of identity, state identification numbers, identification document (including driver's license, passport), proof of residence, address, date of birth, gender, tax identification number, relevant insurance, right to work, driving record, banking or payment information, and other documents that may be required by applicable regulations. Where permitted or required by law, we may additionally collect background checks and criminal background information. This information may be processed by authorized vendors on our behalf. Without providing such information, you will not be able to register as a Driver.

User-generated content that you choose to upload to Goochil, such as comments, ratings, and reviews.

The information in correspondence you send to us may include chat messages, emails with attachments, recordings of phone calls you make to us, and related metadata.

Information for promotions. From time to time, we may run car brand programs, referrals, and other promotional programs. If you wish to participate in such programs and receive bonuses, payments, or other benefits, we may ask you to provide information such as your name, email, user ID, phone number, banking or payment information, home address, social media account, vehicle type and image.

Information We Collect Automatically

Location information. We collect location data from users to enable travel, provide user assistance, ensure safety, detect fraud, and comply with legal requirements. We collect location information (including GPS coordinates and WiFi data) based on the Goochil app settings and device permissions.

We may also collect precise location for a limited time after you exit Driver mode to detect and investigate incidents on the ride.

Transaction Information. We collect transaction information related to services provided through Goochil, including the amount charged, payment transaction information, date and time the service was provided, route, and distance traveled.

Usage Information. We collect data about your use of our platform, such as access dates and times, features or pages visited, platform failures, and other system activity. We may also collect and use for marketing purposes data related to third-party services that you used before interacting with Goochil.

Communications Information. We allow users to communicate with each other and with us through the platform. To facilitate this, we receive data about the date and time of communications and content. We may use this data to provide user support and resolve disputes between users, identify violations of Goochil rules, ensure security, and improve our Platform.

Device Information. We collect information about the device you use to access Goochil, such as your device name, make, and model, user agent, IP address, mobile carrier, network type, time zone setting, language settings, advertising identifiers, browser type, operating system and version, display parameters, battery status, and installed applications that may be used for authentication and anti-fraud purposes. We may also collect data from mobile sensors, such as speed, direction, altitude, acceleration, deceleration, and other technical data.

User ID and trip. We automatically assign you a user ID when you create a Goochil account and a travel ID for each trip.

Cookies and Tracking Technologies. We collect information through the use of cookies, pixels, tags, and other similar tracking technologies ("cookies"). 

Information We Obtain From Other Sources

Third-Party Services. We may receive information about users from our service providers, which include background and identity check providers, insurance partners, financial service providers, and marketing service providers. If you choose to use a third-party communication application (such as WhatsApp) or register using a third-party service (such as Facebook), where this functionality is available, we may collect information from these services.

State authorities. We may receive information about users from law enforcement agencies and other government authorities as required or authorized by law.

Other Users or Third Parties. Third parties may provide us with information about you, for example, in connection with referral programs or through user support (such as information related to an incident or complaint, including audio, video, images, and documents).

How We Use Your Information

We use personal information for the following purposes:

1. To allow you to use Goochil

• to allow users to maintain a Goochil account, request and provide services through Goochil;

• verify the right and ability of drivers to provide services through Goochil;

• prevent and combat unsafe or illegal behavior, fraud, and other violations of Goochil's rules, suspend and deactivate users who engage in prohibited activities;

• provide support to users, manage user complaints;

• send non-commercial communications (such as invoices, receipts, or notifications about your trip);

• maintain the accessibility, security and stability of our platform, prevent and resolve incidents and technical problems.

• Legal basis: performance of our contract with you, the need to comply with our legal obligations and our legitimate interest in making Goochil a safe space.

2. Improve and develop features and products.

• testing, research, data analysis, development, and machine learning;

• Collect your feedback.

• Legal basis: Our legitimate interest in providing you with the best Goochil experience. Where express consent is required for certain uses, we will obtain it separately.

3. Promote Goochil

• send you marketing communications and announcements and make marketing calls to you;

• provide you with personalized content and advertising on Goochil and third-party platforms;

• organize contests, events, car brands and referral programs and other promotions.

• Legal basis: our legitimate interest in promoting Goochil. Where express consent is required for certain forms of direct marketing, we will obtain it separately.

4. To protect rights and comply with legal requirements

• comply with license or permit requirements and any other applicable laws and regulations;

• respond to law enforcement requests, government inquiries, subpoenas, court orders, legal claims;

• protect the rights and interests of the Goochil group, our users or the public.

• Legal basis: the need to comply with our legal obligations and legitimate interests.

Automated decision-making

We use personal information to make automated decisions related to your use of our platform:

• connecting Drivers and Passengers, based on factors such as availability and proximity;

• determine user ratings and deactivate users with low ratings;

• flag or temporarily suspend users who are identified as being involved in fraud, unsafe or harmful activities. In some cases, such activities may result in deactivation;

• Recommend an average rate, based on factors such as distance, location, and time.

Where required by law, actions (including deactivation) based on such processing occur only after human review and/or the possibility of appeal. To object to a decision resulting from these processes, please contact us at [email protected]. 

How We Share Your Information

With Other Users. We share certain information about users to enable travel scheduling and provisioning:

• Passenger information shared with the Driver includes name, profile picture (if uploaded), rating, pick-up and drop-off locations, number of rides, fare offered, reviews, and contact information. In regions where we require Passengers to submit a national identification number, we may also share with the Driver if the Passenger has submitted this number (but we will not share the identification number as such).

• Driver information shared with the Passenger includes full name and profile picture, information about the vehicle and its photo, location before and during the trip, ratings and reviews, number of trips, age (for certain functions), and contact information.

Where it is necessary to provide receipts and invoices to Passengers, we may share information about the origin and destination of the trip, the total duration and distance of the trip, the breakdown of the total fare, the driver's name, the tax identification number, and other information required by law.

If you sign up for Goochil through a referral link, we may share certain information about you, such as your name and trip count, with the user who referred you. This is to allow the referring user to check if they are eligible for the referral bonus.

For purposes of services other than transportation services provided through Goochil, we will share information with other users that is necessary for the provision of such services.

With service providers. We may share your personal information for a business purpose with providers of the following services:

• payment processing and transaction fulfillment;

• technical and user support;

• background checks, identity checks;

• insurance;

• cloud storage;

• content delivery, in-app messaging, in-app calling, push notifications; fraud;

• advertising, marketing, and analytics;

• research and surveys;

• payment of bonuses and provision of other benefits related to our promotions;

• consultants, lawyers, accountants, auditors and other professional services;

• airports.

The following partners process data for their own purposes as independent controllers and we do not control such processing:

- Google, in connection with the use of Google Maps;

- social media companies (including Meta), in connection with our use of their tools.

Within the business group. We can share your information with a parent, subsidiary, or affiliate of our corporate group as part of our global operations.

In connection with a business transfer. We may transfer personal information in connection with a substantial corporate transaction in which personal information is among the assets to be transferred.

For legal reasons. We may disclose your personal information when necessary to protect rights and comply with legal obligations.

With your consent. We may share your personal information for other purposes in accordance with your consent or at your direction.

When you're depersonalized. We may share aggregated or anonymized information that is no longer personally identifiable.

Cross-border data transfers

To support our global operations, we may share your information with members of the Goochil corporate group and other entities outside of your country of residence as described in the "How We Share Your Information" section. We do this for the performance of our contract with you, or based on consent, adequacy decisions for the relevant countries, or other appropriate transfer mechanisms and safeguards under applicable law.

We will take reasonable steps to ensure that any overseas recipient treats your personal information in a manner consistent with the way we treat it.

Your Rights and Options

Access, receive, and update your information. You can access, review, and update your information either in your account settings in the app or by contacting us at [email protected].  You can also request a copy of all the information about you that we process. You can receive your data in a structured, commonly used and machine-readable format to the extent that such data has been processed by automated means.

Deleting your account and data. You can delete your account through the app's settings or request the deletion of your account and data by contacting us at [email protected]. You may be asked to verify your account and identity. We will not be able to delete your account if there is an outstanding debt or unresolved issue related to your account (for example, an unresolved complaint). We may retain certain information after your account is deleted, provided that there is a legitimate basis for such retention (see the "How We Store Your Information" section).

Share location information. Your device may have controls that determine what information we collect. For example, you can prevent your device from sharing location information through your device's system settings.

Oppositions and withdrawal of consent. You have the right to object to our processing of your information where the processing is based on our legitimate interests. You may also withdraw your consent to processing at any time where the processing is based on your consent. In particular, you may exercise these rights by:

• Opting out of receiving push notifications. You can opt out of receiving push notifications through your device settings or app settings.

• Unsubscribing from marketing emails and messages. You may opt out of receiving marketing emails and messages by using the "unsubscribe" link or the mechanism provided in such emails and messages.

• Opting out of receiving marketing calls. You can opt out of receiving marketing calls during a call or by contacting us at [email protected].

• Cookie management. You can delete cookies and modify your cookie settings in your web browser settings.

Restrictions. You can ask us to limit our use of your data. We may continue to process your data after such a request to the extent required or permitted by law.

Right to complain to the supervisory authority. Under local law, you may have the right to lodge a complaint with your local supervisory authority.

How We Store Your Information

We retain your personal information for as long as you have an account with us. We may retain certain information after account termination for legitimate reasons:

• We will retain transactional information (such as travel and payment data) for as long as necessary to comply with our tax obligations. Tax law generally requires us to retain information for 10 years.

• We will retain the information for the period required by the licensing regulator (where applicable). The retention period will vary depending on your location and the type of data.

• We will retain correspondence and other documentation for as long as necessary to comply with legal document retention obligations. Business law generally requires us to keep business correspondence for 6 years.

• If there is a legal claim or dispute or any possibility thereof, we will retain the relevant information until the claim is satisfied/the dispute is resolved or the statute of limitations expires. The statute of limitations will depend on your location, but it will generally require withholding for 3 to 7 years.

• We will also retain relevant data to prevent fraud, ensure the safety of users and comply with our legal obligations for the period necessary to fulfil these purposes.

How We Protect Your Information

We take reasonable and appropriate technical, legal, and organizational security measures to protect your personal information from unauthorized action including, but not limited to, accessing, disclosing it, altering, or destroying your data that leads to the loss, theft, or misuse of your data.

We make every effort to affirm our commitment to safeguarding your information. We regularly review our security measures to consider new technologies and methods available. Since absolute security does not exist either on or off the internet, we cannot guarantee the absolute security of your information, especially against malicious acts by third parties where the cost of a successful attack multiplies several times the value of the possibly compromised data. However, we make commercially reasonable efforts to keep your information secure.

General Disclosures

Protecting children. Goochil is not directed to children (as defined in local laws). If we discover that we have personal information about a child, we will make reasonable efforts to delete this data and ensure that it is no longer used or shared. If you believe that a child has provided us with personal information, please contact us at [email protected].  

Telephone monitoring. Telephone conversations may be monitored and recorded for quality control and training purposes.

Do not follow up. Some browsers transmit "do not track" signals to websites. Due to differences in how browsers incorporate this feature, we do not currently take action in response to these signals.

Third-party collections. Certain third parties may use automatic information collection technologies, including cross-site tracking technologies, to collect personal information. These third parties may include your internet service provider, web browser, mobile service provider, mobile device manufacturer, online advertisers, and data analytics companies. In addition, our platform may contain links to third-party platforms. Clicking on such links means that the respective platform may collect your personal information. We are not responsible for the privacy practices of third parties.

 

Changes

We may update this policy from time to time to reflect changes in the laws or in the way we operate. When we update this policy, we will notify you by updating the "Last Updated" date at the top of this page and posting the new Privacy Policy and providing you with any other notices required by applicable law. When you use Goochil, you agree to the most recent terms of this policy.

Contact Information

If you have any questions, concerns, or requests regarding your personal information or this Privacy Policy, please contact:

Email: [email protected]  

Mail: Goochil LLC

27663 Equestrian Drive 

Salisbury, MD 21801