HBSS CONNECT CORP

QRYDE is a mobile platform developed by HBSS Connect Corp. and dedicated to connecting people through transportation and to bring communities together. We recognize the importance of protecting your personal information and are committed to processing it responsibly and in compliance with applicable data protection laws in all countries in which we operate.

In the normal course of our business activities, QRYDE collects, uses, and sometimes shares personal information of various individuals and organizations to run its day-to-day operations effectively and to provide a quintessential ride experience. We collect the information about you when you use our mobile applications, websites, and other online products and services (collectively, the “Services”) and through other interactions and communications you have with us.

This Privacy Notice describes QRYDE’s general privacy practices that apply to such personal information collection and use. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it. This is important; we hope you will take time to read it carefully. This policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage. And remember, you can find controls to manage your information and protect your privacy and security at My Account.

I. Scope and Application

This Privacy Statement (“Statement”) covers our treatment of personally identifiable information (“Personal Information”) that we gather when you are accessing, viewing or using the QRYDE apps, Website and/or Services to request transportation, delivery, or other on-demand services (“Users”). We get some of it by recording how you interact with our products by, for example, using technologies like cookies, and receiving error reports or usage data from software running on your device. We also obtain data from third parties. This Statement also applies to information we collect from or about drivers, couriers, partner transportation companies, or any other persons who use the QRYDE platform under license (collectively “Drivers”). If you interact with the Services as both a User and a Driver, the respective privacy statements apply to your different interactions.

We do not knowingly collect or solicit personal information from anyone under the age of 13 or knowingly allow such persons to register for the Services. If you are under 13, please do not attempt to register for the Services or send any information about yourself to us, including your name, telephone number, or email address. No one under age 13 may provide any Personal Information to us or through the Services. In the event that we learn that we have collected Personal Information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under age 13, please contact us at privacy@qryde.com.

II. Collection of Information

1. We collect information you provide directly to us, such as when you create or modify your QYRDE account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, postal address, profile picture, payment method, items requested (for delivery services), delivery notes, and other information you choose to provide.
2. When you use our Services, app or website, we collect information about you in the following categories:
   • Location Information: When you use the Services for transportation or delivery, we collect precise location data about the trip from the QRYDE app used by the Driver. If you permit the QRYDE app to access location services through the permission system used by your mobile operating system (“platform”), we may also collect the precise location of your device when the app is running in the foreground or background. We may also derive your approximate location from your IP address.
   • Contacts Information: If you permit the QRYDE app to access the address book on your device through the permission system used by your mobile platform, we may access and store names and contact information from your address book to facilitate social interactions through our Services and for other purposes described in this Statement or at the time of consent or collection.
   • Transaction Information: We collect transaction details related to your use of our Services, including the type of service requested, date and time the service was provided, amount charged, distance traveled, and other related transaction details. Additionally, if someone uses your promo code, we may associate your name with that person.
   • Usage and Preference Information: We collect information about how you and site visitors interact with our Services, preferences expressed, and settings chosen. In some cases we do this through the use of cookies, pixel tags, and similar technologies that create and maintain unique identifiers.
   • Service Information: We may collect information about your mobile device, including, for example, the hardware model, operating system and version, software and file names and versions, preferred language, unique device identifier, advertising identifiers, serial number, device motion information, and mobile network information.
   • Call and SMS Data: Our Services facilitate communications between Users and Drivers. In connection with facilitating this service, we receive call data, including the date and time of the call or SMS message, the parties’ phone numbers, and the content of the SMS message.
   • Log Information: When you interact with the Services, we collect server logs, which may include information like device IP address, access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and the third-party site or service you were using before interacting with our Services.

3. We may also receive information from other sources and combine that with information we collect through our Services. For example:
   • If you choose to link, create, or log in to your QRYDE account with a payment provider, or social media service, or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
   • If your employer uses one of our solutions, we may receive information about you from your employer.
   • When you request on demand services, our Drivers may provide us with a User rating after providing services to you.
   • If you also interact with our Services in another capacity, for instance as a Driver or User of other apps we provide, we may combine or associate that information with information we have collected from you in your capacity as a User or rider.

III. Use of Information

We may use the information we collect from all Users to:

• Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Drivers, develop safety features, authenticate users, and send product updates and administrative messages;
• Perform internal operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
• Send or facilitate communications (i) between you and a Driver, such as estimated times of arrival (ETAs), or (ii) between you and a contact of yours at your direction in connection with your use of certain features, such as referrals, invites, split fare requests, or ETA sharing;
• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Uber and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
• Respond to safety issues that may arise, such as accidents, disputes between User and Driver, and requests from government authorities;
• Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

We also use the information we collect from Drivers related to their use of and/or providing driving services through the QRYDE platform to (i) determine your eligibility to drive under the QRYDE platform; (ii) communicate with you  regarding feedback received for Services you provided; (iii) notify you about ride demand, pricing and service updates; and (iv) analyze usage patterns for safety and better Service.

IV. Sharing of Information

We share your personal data with your consent or as necessary to complete any transaction or provide any product you have requested or authorized. We also share data with QRYDE -controlled affiliates and subsidiaries; with vendors working on our behalf; when required by law or to respond to legal process; to protect our customers; to protect lives; to maintain the security of our products; and to protect the rights or property of QRYDE platform.

We may share the information we collect about you as described in this Statement ,  including and not limited to as follows:

• Between User and  Drivers to enable them to provide the Services you request. For example, we share your name, photo (if you provide one), average User rating given by Drivers, and pickup and/or drop-off locations with Drivers;
• With other riders if you use a ride-sharing service; and with other people, as directed by you, such as when you want to share your estimated time of arrival or split a fare with a friend;
• With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us;
• With the general public if you submit content in a public forum, such as blog comments, social media posts, or other features of our Services that are viewable by the general public;
• With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate; and
• With a Corporate Account used by you or your employer account (or similar entity) and any necessary third parties engaged by us or the Corporate Account or your employer (e.g., an expense management service provider), if you participate in any of our business to business solutions.
• Although, the QRYDE platform assist User and Drivers communicate with one another for a Service (pick-up or drop-of), we do not share your actual phone number or other contact information with other Users.

We may share information with Third Parties having a business relationship with QRYDE, as follows:

• API and Integration Partners. If you connect to the QRYDE Platform through an integration with a third-party service, we may share information about your use of the QRYDE Platform with that third party. We may share your information with our third-party partners in order to receive additional information about you. We may also share your information with third party partners to create offers that may be of interest to you.
• Third Party Services. The QRYDE Platform may allow you to connect with other websites, products, or services that we don’t have control over. If you use these services, we will provide the third party within formation about you to allow them to provide the service to you. We can’t speak to the privacy practices of these third parties, and we encourage you to read their privacy policies before deciding whether to use their services.
• Service Providers. We work with third party service providers to perform services on our behalf, and we may share your information with such service providers to help us provide the QRYDE Platform, including all of the things described above.
• Corporate Partners. If you participate in an corporate program and charge a ride to your organization’s billing method or credits, we will provide your organization’s account holder with information about your use of the QRYDE Platform, including ride details such as date, time, charge, and pick up and drop off locations.

We may also share your information:

• With QRYDE subsidiaries and affiliated entities that provide Services or conduct data processing on our behalf, or for data centralization and / or logistics purposes;
• With vendors, consultants, marketing partners, and other service providers who need access to such information to carry out work on our behalf;
• In response to a request for information by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;
• With law enforcement officials, government authorities, or other third parties if we believe your actions are inconsistent with our User agreements, Terms of Service, or policies, or to protect the rights, property, or safety of QRYDE or others;
• In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company;
• If we otherwise notify you and you consent to the sharing; and
• In an aggregated and/or anonymized form which cannot reasonably be used to identify you.

V. Social Sharing Features

The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them.

VI. Analytics and Advertising Services Provided by Others

QRYDE may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services.

VII. Account Information

You may correct your account information at any time by logging into your online or in-app account. You may also request the correction, updating, or deletion of your Personal Information on our Websites by emailing us at privacy@qryde.com. We will respond to all such requests within 30 days.

If you wish to cancel your account, please email us at support@qryde.com. If you request that your Personal Information be deleted from our records, there may be a brief delay in our processing that request, while we verify that the request is valid and originates from you as opposed to an unauthorized third party. If you request that your Personal Information be deleted, we reserve the right to terminate and/or limit your access to the Websites and/or Services. In some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms, we may seek to resolve the issue before deleting your information.

Access Rights. We will comply with individual’s requests regarding access, correction, and/or deletion of the personal data it stores in accordance with applicable law. We will respond to all such requests within 30 days.

Location Information. We request permission for our app’s collection of precise location from your device per the permission system used by your mobile operating system. If you initially permit the collection of this information, you can later disable it by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services. Additionally, disabling our app’s collection of precise location from your device will not limit our ability to collect your trip location information from a Driver’s device nor our ability to derive approximate location from your IP address.

Contact Information: We may also seek permission for our app’s collection and syncing of contact information from your device per the permission system used by your mobile operating system.

Promotional Communications: You may opt out of receiving promotional messages from us by following the instructions in those messages. If you opt out, we may still send you non-promotional communications, such as those about your account, about Services you have requested, or our ongoing business relations.

Your Privacy Rights: Certain states law permits residents of the state to request certain details about how their information is shared with third parties for direct marketing purposes. QRYDE complies with all state laws and regulations and will not share your personally identifiable information with third parties for the third parties’ direct marketing purposes unless you provide us with consent to do so.

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of Personal Information which we share with our affiliates and/or third parties for marketing purposes and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: privacy@qryde.com.

Cookies & Similar Technologies: QRYDE uses cookies (small text files placed on your device) and similar technologies to provide our websites and online services and help collect data. Cookies allow us, among other things, to store your preferences and settings; enable you to sign-in; provide interest-based advertising; combat fraud; and analyze how our websites and online services are performing. QRYDE apps use other identifiers, such as the advertising ID in Windows, for similar purposes.

We also use web beacons to help deliver cookies and gather usage and performance data. Our websites may include web beacons and cookies from third-party service providers.

You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons. Your browser and other choices may impact your experiences with our products

VIII. Your Choices

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our special features.

You may be able to add, update, or delete Personal Information as explained in Section VII above. When you update information, however, we may maintain a copy of the unrevised information in our records. Please note that some information may remain in our private records after your deletion of such information from your account. We may use any aggregated data derived from or incorporating your Personal Information after you update or delete it, but not in a manner that would identify you personally.

We will also provide EU or Swiss individuals with opt-out or opt-in choice before we share their data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To limit the use and disclosure of your personal information, please submit a written request to privacy @ qryde.com.

IX. Information Security

We work hard to protect QRYDE platform and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular: (i) We encrypt many of our services using SSL; (ii)  We offer you two step verification when you access your QRYDE Account; (iii) We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems; and (iv)  We restrict access to personal information to QRYDE employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

QRYDE is committed to protecting the privacy of its Users, including the User’s personal health information. QRYDE complies with the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), which requires us to take additional measures to protect personal information and to inform our members about those measures.

X. EU-US and Swiss-US Privacy Shield

We comply with the EU-US and Swiss-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of Personal Information from European Union member countries and Switzerland. We have certified that we adhere to the Privacy Shield principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability. If there is any conflict between this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

In addition to self-assessment, as a participant in the EU-US and Swiss-US Privacy Shield program, we are subject to the investigatory and enforcement powers and authority of the U.S. Federal Trade Commission with respect to maintenance of, and adherence to, this Privacy Policy.

In compliance with the EU-US and Swiss-US Privacy Shield Principles, we commit to resolve complaints about your privacy and our collection or use of your Personal Information. European Union and Swiss individuals with inquiries or complaints regarding this Privacy Policy should first contact us as directed in the Contact Information clause of this Privacy Policy.

We have further committed to refer unresolved privacy complaints under the EU-US and Swiss-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Among other legal rights and remedies, you have a right to invoke binding arbitration process between you and us to resolve a dispute related to our collection, use or disclosure of your Personal Information.

In particular, we will maintain compliance with the Privacy Shield principles by adhering to the following practices:

• Notice. When we collect your Personal Information, we’ll give you timely and appropriate notice describing what Personal Information we’re collecting, how we’ll use it, and the types of third parties with whom we may share it. This Privacy Policy serves as such notice, and any changes to our collection, use or disclosure of your Personal Information will be reflected in revisions to the Privacy Policy posted on our Websites.
• Choice. As established and described in this Privacy Policy, we’ll give you choices about the ways we use and share your Personal Information, and we’ll respect the choices you make.
• Accountability for Onward Transfer. If we transfer your Personal Information to another country, we may remain liable and will take appropriate measures to protect your privacy and the Personal Information we transfer.
• Security. We’ll take appropriate physical, technical, and organizational measures to protect your Personal Information from loss, misuse, unauthorized access or disclosure, alteration, and destruction, as further-specified in the Is Personal Information About Me Secure? clause of this Privacy Policy.

In certain situations, HBSS Connect Corp. and QRYDE may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

• Data Integrity and Purpose Limitation. We’ll collect only as much Personal Information as we need for specific and identified purposes, and we won’t use it for other purposes without obtaining your consent. We’ll take appropriate steps to make sure the Personal Information in our records is accurate.
• Access. If you wish to confirm the accuracy of your Personal Information or have it removed from our systems and records, you may contact us at the email address, telephone number or postal address provided in the Contact Information clause of this Privacy Policy.
• Recourse, Enforcement, and Liability. We’ll regularly review our continued adherence to our privacy obligations, and we’ll provide and maintain the independent mechanism specified in this Privacy Policy as a way of resolving complaints or concerns about our privacy practices.

XI. Questions or Concerns; Contact Information

If you have any questions or concerns regarding our Privacy Statement or privacy related complaint, please send us a detailed message to privacy@qryde.com. Alternatively, you may contact us by telephone or postal service as follows. We will make every effort to resolve your concerns.

Address:                      Attn. General Counsel, HBSS Connect Corp.

1212 Hancock Street Quincy, Massachusetts, 02139 USA

Phone (US only):         1978.379.0010

Email:                          privacy @ qryde.com

 If you are a resident of EU, you also have a right to file a complaint with the applicable data protection agency (“DPA”). You can find a list of DPA at www.dataprotection.ie.

XII. Changes to the Statement:

We may change this Statement from time to time. If we make significant changes in the way we treat your personal information, or to the Statement, we will provide you notice through the Services or by some other means, such as email. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review the Statement for the latest information on our privacy practices.

Updated: November 1, 2018