Privacy Policy

Island RYDE Limited trading as RYDE, 'we' or 'our' is committed to protecting the privacy and security of your personal information.

This Privacy Notice describes how we collect and use personal information about you during and after your relationship with us according to the Data Protection (Jersey) Law 2018 ("DPJL").

RYDE is a "Data Controller", meaning we are responsible for deciding how we hold and use personal information. We are also registered with the Jersey Office of the Information Commissioner ("JOIC") – Registration No. 100518.

We will comply with data protection law, the principles of which say that the personal information we hold about you must be:

• Used lawfully, fairly and in a transparent way.
• Collected only for valid purposes that we have clearly explained to you and not used in any way incompatible with those purposes.
• Relevant to the purposes we have told you about and limited only to those purposes.
• Accurate and kept up to date.
• Kept only for as long as necessary for the purposes we collected it.
• Kept securely.

The Data Protection Manager ("DPM")

We have appointed a DPM to oversee compliance with this Privacy Notice. If you have any questions about this Privacy Notice or how we handle your personal information, contact the DPM at dataprotection@ryde.je.

You have the right to make a complaint at any time to the JOIC. Contact details are outlined at the bottom of this Privacy Notice.

The Kind of Information We Hold About You

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). The types of personal information we collect may vary depending on how you interact with our services.

How Is Your Personal Information Collected?

We collect personal information about you when you contact us, engage us to provide a service or provide us with your data for another specific purpose.

What information do we collect about you?

Category A	Category B
Name / Title Current location Login details	Telephone number Email address Payment methods Destination address

What Special Category Data do we collect about you?

RYDE does not routinely collect Special Category Data unless it is necessary for the provision of the service.

Certain passengers may provide information which constitutes Special Category Data under the DPJL, including information relating to disability, health, mobility, accessibility requirements, or other care-related needs. This may include:

• Information indicating that a passenger requires a wheelchair-accessible vehicle
• Information relating to disability or mobility limitations
• Health or care-related information provided in booking notes or email communications to support the passenger's safety, comfort, accessibility, or wellbeing during travel

This information is only collected where necessary to provide services safely and appropriately and will be processed in accordance with the DPJL using an appropriate lawful basis and special category condition where required.

CCTV Data

At RYDE, we value the safety of our customers and our drivers. For this reason, we have installed CCTV in all our vehicles. This CCTV records images externally and images and audio internally. CCTV footage is retained on a rolling overwrite basis using a fixed storage capacity system (512GB), resulting in automatic deletion of older footage after approximately 14 days, unless retained longer for incident investigation, safeguarding, or legal obligations.

The reasons we have installed CCTV are to:

• Detect and prevent criminal activity.
• Protect the safety of our customers and drivers.
• Support driver training purposes.
• Address any internal disciplinary issues arising out of complaints about one of our drivers.
• Provide evidence of inappropriate behaviour of a driver or customer.

How We Will Use Information About You

We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:

• Contract: When you have entered into a contract with us to provide you with a service; for example, when you open an account with RYDE. In certain circumstances, this may include limited information relating to health, disability, mobility, or accessibility voluntarily provided during the booking process.
• Legitimate Interests: Where it is necessary for our legitimate interests (or those of a third party), and your interests and fundamental rights do not override those interests. Where permitted by applicable law, we may contact you about services, offers or updates which may be relevant to you. Where consent is required for marketing communications, you may withdraw this at any time.
• Legal Obligation: When we need to comply with a legal obligation; for example, when we retain client account information for tax purposes.
• Vital Interests: In an emergency, it is in your vital interest to share your information when we have it recorded; for example, if there was an incident with one of our drivers and we had to provide emergency services with the personal data of people in one of our vehicles.

Marketing Communications

Where you have provided your consent, or where otherwise permitted by applicable law, we may use your personal information to send you marketing communications about our services, promotions, offers, discounts, competitions, partnership campaigns, newsletters, and updates that may be of interest to you.

Marketing communications may be sent by email and push notifications. Where applicable, users may be given the option during the app sign-up process to opt in to receive marketing communications and promotional notifications from RYDE.

We may also use email analytics to understand the effectiveness of our communications, including whether emails are opened, links are clicked, and general engagement trends.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in marketing emails
• Adjusting your marketing or notification preferences within the Passenger App via the toggle feature
• Contacting us directly using the details provided in this Privacy Notice

Push Notifications

We will send service-related push notifications through the Passenger App where necessary to provide the service, including booking confirmations, driver arrival updates, cancellations, receipts, and journey information.

We may also send marketing push notifications, such as offers, promotions and updates, where you have enabled marketing or notification preferences within the app via the app registration process.

You can manage push notification preferences within the app and through your device settings at any time.

Please note that even if you opt out of marketing communications, we will still send operational or service-related communications where necessary to provide the services you have requested.

Use of Social Media

We may wish to share images or videos for marketing on our social media platforms (e.g., Facebook) to showcase our services. Our social media may have options for leaving feedback which could then be used for advertising purposes.

Change of Purpose

We will only use your personal information for the purposes we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and explain the legal basis that allows us to do so.

Data Sharing

We do not pass on information gained from your engagement with us without a clear legal basis for doing so. However, we may disclose your personal information to meet legal obligations, regulations, or valid governmental requests.

We use certain third-party service providers ("Processors") to provide or support our services. We have appropriate agreements in place with those processors to ensure the safety of your information.

The current data processors used by RYDE are:

Processor	Description of processing	Privacy Notice
Propelfwd	Data Protection Managers. They provide advice and assistance with our data protection requirements and have no access to your data. They will only access data if you put in a data rights request or if we have a data incident/breach.	Privacy Policy
YourDataSafe	SaaS platform to manage all our data protection requirements in compliance with the relevant data protection law.	Privacy Policy
Autocab	Provider of the taxi dispatch platform including passenger app, driver app, booking and dispatch platform, customer account functionality and related communication services, including operational and marketing-related messaging functionality used within the Passenger App.	Privacy Policy
Judopay	Payment service provider. This is the payment gateway we currently use; we do not store any payment data.	Privacy Policy
Stripe	Payment service provider. This is the payment gateway we will use in the future; we do not store any payment data.	Privacy Policy
Webreality	Website design, hosting, and management of website forms including marketing sign-up forms used to collect customer details for email marketing purposes. If you use the 'Contact Us' form your personal information will be stored by Webreality.	Privacy Policy
Xero	Accounting tool to support Accountable.je. Your personal information will be held here if you are an account client.	Privacy Policy
Campaign Monitor (via Webreality)	Email marketing and communications platform used to manage newsletters, promotions, customer updates and marketing subscriptions. This may include storing customer names, email addresses and marketing preferences.	Privacy Policy

Processors are organisations/services carefully chosen by RYDE to process your information correctly and securely. In the case of organisations outside of Jersey, the United Kingdom and the European Economic Area (EEA):

• We have prior written instructions for the transfer, or
• We have entered into specific contractual terms with them to ensure that they treat your personal data in a way equivalent to that which would be required if they were established in Jersey.

The only Processor we use that transfers data outside the EEA is Xero. Their data hosting servers are located in the United States of America. Please read their privacy notice (link provided above). If you have any questions or concerns, contact our DPM at dataprotection@ryde.je.

Data Security

We have put in place appropriate security measures to prevent your personal information from being accidentally lost, altered or disclosed, or accessed in an unauthorised way. We limit access to your personal information to those staff, agents, contractors and other third parties on a need-to-know basis.

They will only process your personal information on our strict instructions and are subject to a duty of confidentiality. Details of these measures may be obtained from our DPM.

We have put in place procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.

Data Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including to satisfy any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process your data, and the applicable legal requirements.

You can request our Data Retention Schedule from our DPM. In some circumstances, we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you.

Rights of Access, Correction, Erasure, and Restriction

The personal information we hold about you must be accurate and current. Please keep us informed if your information changes during your relationship with us.

Under certain circumstances, by law, you have the right to:

• Request access to your personal information (commonly known as a "data subject access request"). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data corrected.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal data where there is no good reason for us to continue to process it.
• Object to processing your personal information where we rely on a legitimate interest (or those of a third party), or where we process your personal information for direct marketing purposes.
• Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it.
• Request the transfer of your personal information to another party.

To exercise any of these rights, contact our DPM at dataprotection@ryde.je. You will not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your request is unfounded or excessive.

How to Request Your Information

You can use the Data Subject Access Request form, available on our Cookie Banner or by clicking here to access our direct data rights request portal.

If you have any questions about this process or any of your rights, contact our DPM at dataprotection@ryde.je. You can also email your request, or make your request over the telephone verbally to one of our team.

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information. We will respond to your request without undue delay, but certainly within four weeks after satisfactory verification of your identity. In some circumstances, we can apply an eight-week extension when the request is complex in nature — if this is the case, we will inform you as soon as possible.

Right to Withdraw Consent

In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.

To withdraw your consent, contact our DPM at dataprotection@ryde.je. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to unless we have another legitimate basis for doing so in law.

Changes to this Privacy Notice

We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you from time to time about the processing of your personal information or ask you to confirm that the information we hold about you remains accurate.

Complaints

We want the chance to resolve any complaints you have about how we process your information. You have the right to complain to the JOIC about how we have used your data.

Island RYDE Limited
First Floor, Tower House, La Route es Nouaux, St. Helier, JE2 4ZJ, Jersey
Telephone: +44 (0) 1534 666333 or email dataprotection@ryde.je

Jersey Office of the Information Commissioner
2nd Floor, 5 Castle Street, St Helier, Jersey JE2 3BT
Telephone: +44 (0) 1534 716530 or email enquiries@jerseyoic.je