Privacy Policy

I. Introduction / II. Overview / III. Data collections and uses IV. Choice and transparency / V. Updates to this notice

I. Introduction

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

This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

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II. Overview

A. Scope

This notice applies to users of FULA’s services anywhere in the world, including users of FULA’s apps, websites, features, or other services.

This notice describes how FULA and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice, such as the  FULA Freight Privacy Notice or Careem Privacy Policy. This notice specifically applies to:

  • Riders: individuals who request or receive transportation, including those who receive transportation requested by another individual
  • Drivers: individuals who provide transportation to Riders individually or through partner transportation companies
  • Delivery recipients: individuals who request or receive food, or other products and services, including via  FULA EatsPostmates and Cornershop
  • Delivery persons: individuals who provide delivery services

This notice also governs FULA’s other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by FULA for Business customers, or of owners or employees of restaurants or other merchants; personal data of those who start but do not complete applications to be drivers or delivery persons; or other personal data in connection with our mapping technology and features.

All those subject to this notice are referred to as “users” in this notice.

In addition, please note the following:

  • For users in Argentina: The Public Information Access agency, in its role of Regulating Body of Law 25.326, is responsible for receiving complaints and reports presented by any data subjects who believe their rights have been impacted by a violation of the local data protection regulation.
  • For users in Brazil: Please see here for information regarding FULA’s privacy practices required under Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados - LGPD).
  • For California users: Information regarding FULA’s privacy practices related to the California Consumer Privacy Act (CCPA) is available here.
  • For users in Colombia: This notice also applies for the lessors and lessees. For the purposes of this notice, lessors will be considered drivers and lessees will be considered riders.
  • For users in Mexico: Please see here for information regarding FULA’s privacy practices required under Mexico’s Mexican Personal Data Protection Law (Ley Federal de Protección de Datos Personales en Posesión de los Particulares).
  • For users in Nigeria: FULA does not process the personal data of users in Nigeria for purposes of the legitimate interests of FULA or other parties. Instead, FULA processes such personal data on the grounds that it is necessary to fulfill our obligations to users under our Terms of Use or other agreements with users, or based on users’ consent.
  • For users in South Korea: Please see here for information about FULA affiliate UT LLC's privacy practices.
  • For Guest Users: The personal data of those who order or receive trips or deliveries via partner websites or apps (such as when ordering from a restaurant or other merchant), or arranged by other account owners (collectively “Guest Users”) is used solely to provide such trips, deliveries, or other services requested through a third party, and for purposes of safety and security, customer support, research and development, enabling communication between users, and in connection with legal proceedings and requirements, each as described in “How we use personal data” below. Guest User personal data may be shared with third parties for these purposes. Such data may be associated with, and accessible by, the owner of that account. This specifically includes Guest Users who receive rides/deliveries ordered by owners of FULA Health, FULA Central, FULA Direct or FULA for Business accounts, or who receive rides or deliveries ordered by friends, family members or others. To submit questions, comments or complaints regarding Guest User data, or to submit requests regarding such data, please visit here.

Our 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 here or through the addresses below with any questions regarding our practices in a particular country or region.

 

B. Data controller and transfer

FULA (PTY) LTD is the data controllers for the personal data collected in connection with use of FULA’s services in South Africa.

FULA (PTY) LTD. is the data controller for the personal data collected in connection with use of FULA’s services everywhere else.

 

FULA operates, and processes personal data, nationally. We may also transfer such data to countries other than the one where our users live or use FULA’s services. We do so in order to fulfill our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

Questions, comments, and complaints about FULA’s data practices can be submitted here. You may also use this form to submit a question to FULA’s Data Protection Officer.

III. Data collections and uses

A. The data we collect

FULA collects personal data:

  • provided by users to FULA, such as during account creation
  • created during use of our services, such as location, app usage, and device data
  • from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities

The following personal data is collected by or on behalf of FULA:

1. Data provided by users. This includes:

  • User profile: We collect data when users create or update their FULA 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 and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using FULA apps.

    This also includes gender and/or occupation (when required for certain
    FULA services or programs, such as FULA Cash or features that enable women to provide services or receive services to/from other women).

    We may use the photos submitted by users to verify their identities, such as through facial verification technologies. For more information, please see the section titled “How we use personal data.”
  • Background check and identity verification (drivers and delivery persons). This may include information such as driver history or criminal record (where permitted by law), license status, known aliases and prior addresses, and right to work. This information may be collected by an authorized vendor on FULA’s behalf. We also verify the identities of riders, and of delivery recipients who request alcohol delivery.
  • Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.

    We may also infer demographic data from other data collected from users. For example, where necessary to enable features that allow women to provide or receive services from other women, we may infer gender using their first name. In such cases, we enable users to change their gender if necessary via in-app settings.
  • User content: We collect the data submitted by users when they contact FULA customer support (including at FULA Greenlight Hubs, or via videoconferencing tools), provide ratings or compliments for other users, restaurants or merchants, or otherwise contact FULA. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with FULA.
  • Travel information: We collect travel itinerary information, including the times and dates of upcoming flight, lodging or car rental reservations, from users of our FULA Travel feature. We collect such information: (i) when users manually input their information into an FULA Travel itinerary; or (2) if authorized by users to access their Gmail accounts, from traveled-related email confirmations. If so authorized, FULA will only access users’ Gmail accounts to collect travel itinerary information to enable the FULA Travel feature, and will adhere to Google’s API Services User Data Policy, including the limitations on use of data collected from users’ Gmail accounts.

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

  • Location data (driver and delivery person): We collect drivers’ and delivery persons’ precise or approximate location data, including to enable rides and deliveries, to enable ride/delivery tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. FULA collects this data when the FULA 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 (riders and delivery recipients). We collect riders’ and delivery recipients’ precise or approximate location data to enable and enhance use of our apps, including to improve pick-ups, facilitate deliveries, enable safety features, and prevent and detect fraud. Please see our Rider Location Help page for detailed information on how we use this data.

    We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how riders and delivery recipients can enable location data collection).
    FULA collects such data from the time a ride or delivery is requested until it is finished (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and any time the app is running in the foreground (app open and on-screen) of their mobile device.

    Riders and delivery recipients may use the
    FULA apps without enabling FULA to collect precise location data from their mobile devices. However, this may affect features in the FULA apps. For example, a user who has not enabled location data collection will have to manually enter their pick-up address. In addition, the location data collected from a driver during a trip will be linked to the rider’s account, even if the rider has not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.
  • Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (such as a restaurant’s or merchant's name and location and amount of transaction), delivery information, 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.
  • Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see "How We Use Data" below for more information on how we market our services to users).

    In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our 
    Cookie Notice.
  • Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
  • Communications data: We enable users to communicate with each other and FULA through FULA’s mobile apps and websites. For example, we enable drivers and riders, and delivery persons and delivery recipients, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, FULA receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. FULA may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.
  • Safety recordings: In certain jurisdictions, and where permitted by law, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In app recordings are encrypted and stored on users’ devices, and are only shared with FULA if submitted to customer support by the users in connection with safety incidents. Please see here more information.

3. Data from other sources. These include:

  • Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
  • FULA account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of FULA for Business accounts.
  • users or others providing information in connection with claims or disputes.
  • FULA business partners through which users create or access their FULA account, such as payment providers, social media services, or apps or websites that use FULA’s APIs or whose APIs FULA uses.
  • FULA business partners in connection with debit or credit cards issued by a financial institution in partnership with FULA to the extent disclosed in the terms and conditions for the card.
  • vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements
  • insurance, vehicle, or financial services providers for drivers and/or delivery persons
  • partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company)
  • publicly available sources
  • marketing service providers or data resellers whose data FULA uses for marketing or research