Privacy Policy
Privacy Policy
Effective Date: 31st January 2020 (31.01.20)
VIA and VIA IOM ("us", "we", "our", the “Company”) operates the website viaiom.co.uk and the VIA IOM and VIA IOM Driver mobile applications, in connection with providing VIA’s online platform that connects Passengers and Drivers in the Isle of Man (the "Service"). This Service is provided by VIA LTD a company incorporated in the Isle of Man (Company number 130294C) having its registered office at SUITE 3, 1ST FLOOR, THE JET CENTRE, ISLE OF MAN AIRPORT, IM9 2RJ, Isle of Man (“the Company”) and is intended for use as is. VIA and VIA IOM are registered business names of the Company
This privacy policy informs you of VIA’s policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data
Defined terms
“Booking” means a reservation made by a Passenger with a Driver via the Service “Driver” means any persons licensed to carry out private hire bookings in accordance with section 40 of the Road Transport Act 2001 of the Isle of Man “Passenger” means a user of the Service other than the Driver “Ride” means a ride taken through a Booking “Trips” means the completed and paid for rides “VIA app” means the software applications VIA IOM and VIA IOM Driver and related services provided by VIA to you pursuant to the Terms and Conditions of Use “Website” means viaiom.co.uk
You must register to make or accept a Booking through the Service. By using the Service, you agree to the collection and use of information in accordance with this privacy policy
All those subject to this privacy policy are referred to as “users” for the purposes of this policy which is incorporated by reference into the Terms and Conditions of Use
Unless otherwise defined in this privacy policy the terms used have the same meanings as in our Terms and Conditions of Use, which are accessible via the VIA app or Website
VIA’s approach to personal information
VIA complies with the Data Protection Act 2002 of the Isle of Man and the EU General Data Protection Regulation (“GDPR”) regarding the collection, use, and retention of personal information from European Union member countries. VIA adheres to the Data Protection Bill 2018 implementing GDPR into Isle of Man domestic law by way of the Data Protection Act 2018, the Data Protection (Application of GDPR) Order 2018, the Data Protection (Application of LED) Order 2018 and GDPR and LED Implementing Regulations 2018 (the “IOM GDPR Legislation”) and upholds the principles of lawfulness, fairness and
transparency, notice, choice, accountability for onward transfer, security, data minimisation, data Integrity and confidentiality, purpose limitation, storage limitation, accuracy, access and re-course, enforcement and liability VIA believe in and uphold the right to the privacy of all users of our Services. We respect your confidentiality and will not disclose any information we have to third parties without your express consent. We will endeavor to be open and transparent with you when processing your personal data
We will not use or share your information with anyone except as described in this privacy policy
Collection and use of personal information
VIA uses the data we collect to provide and improve our Service to you. For a better experience, while using our Service, we may require you to provide us with certain personally identifiable information (“personal information”). The information that we request will be retained by us and used as described in this privacy policy
We may collect your personal information in a number of ways, such as:
● From the information, you provide to us when you use our Services, such as your name, phone number and email address. You may also provide other optional information through your communications with us;
● When you make a Booking, we may store your transaction history, such as the time, date and duration of your use of the Service, your location and destination, including Ride start and end times and pick-up and drop-off addresses for your Trips;
● When you communicate with us or when we communicate with you by email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
● Documents and information provided by you at our request to fulfill any legal obligations we have with respect to undertaking due diligence on you and verifying your identity;
● From publicly available sources or from third parties where we need to conduct background checks about you
● When you make card payments for using our Service, VIA may collect or store any payment information such as your credit card number. When you make payments through the Service, you may also need to provide personal information to our third-party service providers, such as your billing address and credit card information. VIA and our service providers may store this information for your convenience
When we collect your personal information, we will:
● only collect what we need and no more
● keep your information secure
● tell you how we will use your information
● delete your information when it is no longer needed
● only process your information in line with the rules set out in the Data Protection Act 2002 of the Isle of Man and the Isle of Man GDPR Legislation
Your rights
GDPR gives you enhanced rights to access the data that we hold on you and more control over how your personal information is used. In relation to the personal information we process, you have the following rights:
● to be informed about what information we hold on you
● to access the information that we hold on you
● to rectify any inaccurate information that we hold on you
● to have any information that we hold on you erased, subject to our legal obligations to retain data for a prescribed period of time
● to restrict us processing data on you, subject to our legal requirements
● to move your data to another organization – data portability
● to object to your data being collected or used
● to opt out of automated decision making and profiling
● to require us not to send you direct marketing communications
VIA will provide you with access to your personal information upon request, unless, and to the extent necessary, that the right of access is restricted
A right of access to personal information
If we do hold information about you, you can ask us to correct any mistakes. You also have the right, subject to any statutory limitations, to object to processing, to erasure or restriction of processing, and to data portability. VIA does not make automated decisions or undertake to profile
Accessing, updating or deleting your personal information
If you would like to access, update or correct any information that you have provided to us through your use of the Service or otherwise, or if you would like to delete your personal information maintained by VIA please send an email to contact@viaiom.co.uk
Following your request, we will take reasonable steps to correct, update, amend or delete your personal information. We may not be able to permanently delete your personal information in all instances, such as when the information has been shared with the third party
Retaining your personal information
In order to meet our regulatory and legal obligations, VIA may retain your personal information for 6 years after the termination of your user Services
VIA reserves the right to extend this period where legal claims or other circumstances dictate that it is in VIA’s best interests to do so, provided that such retention is legitimate, reasonable and proportionate
New uses of personal information
From time to time VIA may use personal information for uses not previously disclosed in our privacy policy. If VIA’s practices change regarding previously collected personal information in a way that would be materially less restrictive than stated in the version of our privacy policy in effect at the time that the information was collected, VIA will make reasonable efforts to provide reasonable notice and obtain consent to any such uses as may be required by law
Internal and service related usage
VIA uses information, including personal information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. VIA may use and retain any data we collect to provide and improve our services
Third party service providers
The Website may use third party services to provide features of the Website or additional functionality. Since these are run by third-party services they may add cookies to your computer, especially if you are logged in to a related account
The VIA app does use third-party services that may collect information used to identify you
Please use the links below to find out more details about the privacy policies of third party service providers used by the VIA app:
● Google Play Services
● Apple Store
● AWS
● Google Maps
● GoDaddy
● SumUp
● MailChimp
VIA may use a third party service, such as Google Analytics, to collect standard internet log information and details of user behavior patterns. We do this to find out things such as the number of visitors to the various parts of our Website. This information is only processed in a way which does not identify you. We do not make and do not allow the third party service provider to make, any attempt to find out the identities of anyone using our Services
VIA employ third party companies and individuals for the following reasons:
● To facilitate our Service;
● To provide the Service on our behalf;
● To perform Service-related services, such as making payments; or
● To assist us in analyzing how our Service is used
We want to inform users of this Service that these third parties have access to your personal information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose
Links to external websites
VIA is not responsible for the privacy practices or the content of any external website listed or linked to from our Website. If you click on a third party link, you will be directed to that website. These external sites are not operated by VIA and you may be supplying information to a third party. We encourage you to read the privacy notices and statements made on other websites you visit. VIA has no control over and assumes no responsibility for the content, privacy policies, or practices of any third party websites or services
Log data, location and other information from your mobile device
Whenever you use our Service, in the case of an error in the VIA app we collect data and information (through third-party products) on your phone (“Log Data”)
VIA collects and stores your location information when you enable your mobile device to send it to us to use our Service
VIA may also collect information that identifies the mobile device you are using. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our Service, the time and date of your use of the Service, and other statistics. Collection of this information improves the provision of our Service to you
Your account information and settings
You may update your account information and email preferences at any time by logging into the VIA app and changing your settings under Edit profile or emailing us at contact@viaiom.co.uk
Your Consent
VIA is legally required in instances where we have no statutory reason to use or hold your information (known as "processing"), to ask you for your explicit consent. We have to provide you with all the information we can about what we will do with your information in order that you can make an informed decision as to whether or not you agree to VIA having your information by giving you the opportunity to "opt-in" and just as easily “unsubscribe”. This will automatically remove you from our mailing list and prevent us from processing your personal information any further
You will always know if you are opting-in to VIA using your information. The opt-in options where we request to use your information and the purposes for us wanting to use your information are very clearly set out. You cannot accidentally provide VIA with information or consent to us using your information
Communications
VIA may send email, text messages, private messages on social media such as Messenger or other social media messages to the email address, mobile phone number or social media platform you provide to us or contact us to verify your account and for informational and operational purposes, such as account management, customer service, and promotions, or system maintenance and to facilitate our communications to you and improve our Service. Email and other electronic communications are stored securely on our systems and third-party cloud storage and such messages will only be shared with your knowledge and only in order to address your inquiry or request and for the provision or improvement of our Service to you
If you choose to provide us with personal information on our social media platform we ask that you also check the platform’s privacy policy and terms of service prior to communicating with us in this way
You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. VIA make every effort to process all unsubscribe requests promptly
You may not “opt-out” of Service-related communications such as account verification, texts informing you of where your vehicle is located and the status of your live rides, receipts, reminders, changes/updates to features of the Service, technical and security notices
The information you provide about a third party
If you use our referral program to tell a friend, relative or someone you know about our Service (a “Referred Person”), we will ask you to provide the Referred Person’s name and email address. VIA automatically sends the Referred Person an email inviting them to try our Service. We may also send a follow-up email or e-mails, at our discretion. If a Referred Person no longer wants to receive communications from VIA, they can click on the “unsubscribe link” provided in such communications or email contact@viaiom.co.uk with their request and we will discontinue further communications
Promotions
VIA may conduct or sponsor competitions and other promotions that users may enter, register for or otherwise participate in through the Service. If you enter a promotion via our Service, your personal information may be disclosed to third party partners or the public in connection with the administration of the promotion, including, in connection with the winner selection, prize fulfillment, and publication of a list of winners, as required by law or permitted by the rules of the promotion
Online advertising
VIA may permit the third-party online advertising networks to collect information about your use of our Website over time so that they may play or display ads that may be relevant to your interests on our Service as well as on other websites or apps. The information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including clickstream information, browser type, time and date you visited the website and other information
Marketing
VIA may use information, including personal information, to facilitate transmittal of information that may be useful, relevant, valuable, or otherwise of interest to you, and to serve you personalized advertising content that may be relevant to your interests
Security
VIA values your trust in providing us with your personal information and implements security measures designed to protect your information from unauthorized access. All personal information is kept with the highest standards and safeguards in place, including technical security, preventing unauthorized access and maintaining data backups in conjunction with VIA’s disaster recovery plan
We protect your information from potential security breaches by implementing certain technological security measures including encryption, firewalls and secure server software. In this regard, VIA has secure socket layer technology (SSL) certificates in place to safeguard your personal information by establishing encrypted links between our web and mail servers and your use of our website and your email communications with VIA so that your information may be sent securely over the internet. Emails are stored electronically on our system and backed by our third-party cloud storage providers and all electronic communications and attachments received by VIA are monitored for viruses or malicious software
VIA does not routinely store manual records, however, where we are required to retain any manual records these will be stored onsite or in a third-party storage facility with whom we have data protection agreements in place
Whilst we continuously aim to use commercially acceptable means to securely store and protect your personal information, we cannot guarantee its absolute security. You are reminded before using our Service or providing any information that no method of transmission over the internet or electronic storage is completely secure and reliable By using the Service or providing personal information to us, you agree that VIA may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If we learn of a security system breach, we may attempt to notify you electronically by posting a notice on the Service or sending an email to you. To withdraw your consent from receiving electronic notice, please notify us at contact@viaiom.co.uk
Special category personal information
VIA is required by law to put additional measures in place if we plan to process any special category personal data, including ethnic origin or religion VIA does not process any special category personal information
Children’s privacy
VIA’s Services are not directed to anyone under the age of 13. VIA does not knowingly collect, maintain or use personal information from anyone under 13 or process personal information of persons under 13 for marketing purposes, competitions or registering for services or user profiles. In the case we discover that a child under 13 has provided us with personal information, we will take steps to delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us at contact@viaiom.co.uk so that we will be able to take necessary action. If we learn that we have collected any personal information from anyone under 13, we will promptly take steps to delete such information and terminate the child’s account, in compliance with the Children’s Online Privacy Protection Act (COPPA)
Websites and Cookies
Cookies are small computer files that are used to track your use of a website
There are a number of different types of website cookie. They contain no name or address information or any information that will enable anyone to contact you via telephone, email or any other means. The cookies used are listed below:
Personalization Cookies
Our Website does not make use of any cookies used to personalize your user experience
Analytics Cookies
These types of cookies are used to monitor how people use our Website and how they reached the Website. These cookies do not track any personal information and are used to analyze and improve the performance of the Service
E-Commerce
Our Website does not use any e-commerce cookies
Ad Management
Our Website does not make use of ad banner management services
Any information VIA receives from cookies is for the administration of the associated website and we will only use cookies when it is necessary for the efficient operation of that particular website. Any emails or addresses communicated to us are used only for the purpose intended by the sender
Whenever you request a page through your browser, data such as:
● your IP address
● browser and version
● operating system
● time and date
● the site from which you came
is stored in a log file and/or database. This information cannot be used to identify specific individuals, and is only used for:
Information supplied via our Website will not be disclosed to any unauthorized third party
The Service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device
Blocking Cookies
If you do not wish to accept any cookies then you can change the cookie policy of your web browser to not accept cookies
Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Note that disabling cookies may disable some features available through the Service
To learn more about cookies, clear gifs/web beacons and related technologies, and to learn how you may be able to opt-out of interest-based advertising from many online advertising networks, you may wish to visit http://www.allaboutcookies.org and/or the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org). You may also manage certain advertising cookies by visiting the EU-based Your Online Choices at www.youronlinechoices.com/uk/your-ad-choices. If you access our Service on your mobile device, you may not be able to control tracking technologies through changing your settings in your profile
Jurisdiction
By using the Service, your data will be transferred to the Isle of Man and stored by our data storage providers at their server locations
By choosing to use the Service or otherwise provide information to VIA, you agree that any dispute over privacy or the terms contained in this privacy policy will be governed by the laws of the Isle of Man and the adjudication of any disputes arising in connection with VIA or the Service will be in accordance with the Terms and Conditions of Use
Data compliance and contact
For any privacy inquiries or to exercise any of your rights, you may contact us at the contact details provided below
We may require additional information in order to identify you or verify the information requested. You may also contact the Isle of Man Information Commissioner, the Isle of Man supervisory authority for data protection issues. For more information please visit www.inforights.im
Contact us
For everything else or if you have any questions or suggestions about our privacy policy or improving our procedures or Services to you, you can contact VIA
By email: contact@viaiom.co.uk
By post: SUITE 3, 1ST FLOOR, THE JET CENTRE, ISLE OF MAN AIRPORT, IM9 2RJ.
By phone: +44 (0) 1624 653783
Resolving complaints
In compliance with the Data Protection Act 2002 and the Isle of Man GDPR Legislation, VIA commits to resolve complaints about your privacy and our collection or use of your personal information
If you have any questions about VIA’s privacy policy, the information that VIA collects from you, or our Services or if you believe that VIA’s collection or use of your personal data is unfair, misleading or inappropriate, please bring your concern to our attention
If you believe that any information VIA holds on you is incorrect or incomplete, please contact us as soon as possible. We will correct any information which was found to be incorrect promptl You also have the right to make a complaint at any time to the Isle of Man Information Commissioner at https://www.inforights.im/complaint-handling/how-to-make-a-complaint-to-the-information-commissioner/
Changes to this privacy policy
VIA keeps its privacy policy under regular review and we may update our privacy policy from time to time. You are advised to review this page periodically for any changes. We will notify you of any changes by posting the new privacy policy on this page. These changes are effective immediately after they are posted on this page This privacy policy was last reviewed on 31st January 2020 (31.01.20)