Effective Date: March 12, 2019

This Privacy Policy describes how Viggo collect, use, disclose and otherwise process personal information, and what choices you have with respect to the information.

When we refer to “Viggo”, we mean Viggo HQ ApS (registration number: 40308350), a corporation situated at Nelson Mandelas Allé 12, 2450 København SV, Denmark (hereinafter referred to as the “Viggo”) which is the controller of Customer Data.

Applicability Of This Privacy Policy

This Privacy Policy applies to Viggo’s systems and platform, including the associated Viggo mobile applications (collectively, the “Services”), viggo.com and other Viggo websites (collectively, the “Websites”) and other interactions (e.g., customer service inquiries, surveys, etc.) you may have with Viggo. If you do not agree with the terms, do not access or use the Services, Websites or any other aspect of Viggo’s business.

The individual that entered into the Customer Agreement (“Customer”) by registering an account through Services control their account and any associated Customer Data. In addition, a separate agreement governs delivery, access and use of the Services (the “Terms of Service”), including the processing of any requests, orders, ride, payments or other information submitted through Services accounts or generated automatically when using the Service (collectively, “Customer Data”).

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Information We Collect And Receive

Viggo may collect and receive Customer Data in a variety of ways:

• Account Information. To create or update an account, you supply Viggo with an email address, phone number, photo, first name, last name and/or similar account details. Customers provide Viggo (or its payment processors) with billing details such as credit card information, payment or banking information and/or a billing address. In addition, Customers may configure, provide and/or enable various account settings and preferences.
• Usage Information. Customers routinely submit information to Viggo when using the Services, including the type of services requested, order details such as pickup and destination addresses, pickup date and other request-related information. In addition, Viggo keeps a record of date and time the service was provided, amount charged, distance and duration traveled, route, payment method, rating and other ride-related information.
• Automatically Generated Information. Viggo may collect information that is automatically generated when Customers use the Services:
  • Services Metadata. When a Customer interacts with the Services, metadata is generated that provides additional context about the way Customer use the Services. For example, Viggo logs access dates and times, user interactions such as screen views and button clicks. Customers can choose if they want to send this type of information through account settings.
  • Log Data. As with most websites and technology services delivered over the Internet, our servers automatically collect information when you access or use our Websites or Services and record it in log files. This log data may include the Internet Protocol (IP) address, the address of the web page visited before using the Website or Services, browser type, and settings, the date and time the Services were used, information about browser configuration and plugins, language preferences and cookie data.
  • Device Information. Viggo collects information about devices accessing the Services, including hardware type, make and model of the device, operating system information, device settings, application IDs, application version, preferred languages, unique device identifiers and crash data. Whether we collect some or all of this Customer Data often depends on the type of device used and its settings.
• Location Information. Depending on the Service that you use, and Viggo app settings or device permissions, we may collect your precise or approximate location information as determined through your device’s GPS data. We use this information to determine your pickup location; to find addresses near you; and to keep track of ride progress.
• User Content. Viggo may collect information that you submit when you contact Viggo customer support, provide ratings or compliments for other users, or otherwise contact Viggo.
• Demographic Information. Viggo may collect demographic information if you participate in a focus group, survey or questionnaire, or provide us feedback in other manner or through a different medium.
• Cookie Information. Viggo uses cookies and similar technologies in our Websites and Services that create and maintain unique identifiers, which may collect information about you via the Websites and Services and across other websites and online services. For more details about how we use these technologies, please see our Cookie Policy.
• Contact Information. In accordance with the consent process provided by your device, any contact information that a Customer chooses to import (such as an address book from a device) is collected when using the Services.
• Communications Information. Viggo enables users to communicate with each other and Viggo through the Viggo apps, Websites, and other services. To provide this service, Viggo receives some information regarding the calls or texts, including the date and time of the call/text, and the content of the communications. Viggo may also use this information for customer support services, including dispute resolution between users, safety and security purposes, and to improve the Services.
• Third Party Information. Viggo may receive data about organizations, industries, Website visitors, marketing campaigns and other matters related to our business from parent corporation(s), affiliates and subsidiaries, our partners or others that we use to make our own information better or more useful. This data may be combined with Customer Data we collect and might include aggregate level data, such as which IP addresses correspond to zip codes or countries. Or it might be more specific: for example, how well an online marketing or email campaign performed.
• Additional Information Provided to Viggo. We receive Customer Data when submitted to our Websites or if you participate a contest, activity or event, apply for a job, interact with our social media accounts or otherwise communicate with Viggo.

How We Use Information

Viggo collects and uses Customer Data to enable reliable and convenient transportation services, including any applicable terms in the Terms of Service functionality, and as required by applicable law.

Viggo uses Customer Data in furtherance of our legitimate interests in operating our Services, Websites, and business. More specifically, Viggo uses Customer Data:

• To provide, update, maintain and protect our Services, Websites, and business. This includes the use of Customer Data to support delivery of the Services under a Customer Agreement, prevent or address service errors, security or technical issues, analyze and monitor usage, trends and other activities or Customer’s request.
• To Communicate with You. To respond to your requests, comments, and questions. If you contact us, we may use your Customer Data to respond. To enable communications between other users. For example, a driver may text or call you to confirm the pickup location. To send emails and other communications. We may send you service, technical and other administrative emails, ride receipts, messages and other types of communications. We may also contact you to inform you about changes in our Services, our Services offerings, and important Services-related notices, such as security and fraud notices. These communications are considered part of the Services and you may not opt out of them.
• To personalize Customer experience when using the Services. For example, we may provide Service suggestions based on historical use and predictive models, identify trends and insights, to enable bookmarks for your favorite places, and to enable quick access to previous destinations. To enable features that allow Customers to share information with others, such as when you submit a compliment about a driver, refer a friend to Viggo, split fares, or share your ETA. To provide recommendation to the users about most efficient routes, which is based on analysis of geographic coverage and historic ride data and other features that may improve your experience while using the Service.
• For billing, account management, payment processing and other administrative matters. Viggo may need to contact you for invoicing, account management and similar reasons and we use account data to administer accounts and keep track of billing and payments.
• For research and development. We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, create new features and products.
• To investigate and help prevent security issues, fraudulent activity and abuse. We may use the information we collect to investigate or address claims or disputes relating to your use of Services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.
• As required by applicable law, legal process or regulation.

If Information is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person, Viggo may use it for any business purpose. To the extent information is associated with an identified or identifiable natural person and is protected as personal data under applicable data protection law, it is referred to in this Privacy Policy as “Personal Data.”
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How We Share And Disclose Information

Except as described in this Privacy Policy, we do not share the personal information that you provide to us with other organizations. We disclose personal information to third parties under the following circumstances:

• Displaying Services. Customer Data may be displayed to other authorized users. For example, Customer’s first name and photo may be displayed to the driver that is carrying out the request. Feedback given by Customers regarding the quality of the service is anonymous and drivers do not receive names and telephone numbers of the Customer who provided rating and feedback.
• Service Providers. We may employ third party companies and individuals to administer and provide the Services on our behalf (such as training, customer support, hosting, email delivery and database management services). These third parties may use your information only as directed by Company and in a manner consistent with this Privacy Policy, and are prohibited from using or disclosing your information for any other purpose.
• Corporate Affiliates. We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.
• During a Change to Viggo’s Business. If Viggo engages in a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of Viggo’s assets or stock, financing, public offering of securities, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence), some or all Customer Data may be shared or transferred, subject to standard confidentiality arrangements.
• Aggregated or De-identified Data. We may disclose or use aggregated or de-identified Customer Data for any purpose. For example, we may share aggregated or de-identified Customer Data with prospects or partners for business or research purposes, such as telling a prospective Viggo customer the average price for a ride, duration of a ride, etc.
• Compliance with Laws and Law Enforcement, Protection and Safety. Company may disclose information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Service; (d) protect our rights, privacy, safety or property, and/or that of you or others; and (e) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
• To enforce our rights, prevent fraud, and for safety. To protect and defend the rights, property or safety of Viggo or third parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud or security issues.
• With Your Consent. We may use or share your personal information with your consent, such as when you consent to let us post your testimonials or endorsements on our Sites, you instruct us to take a specific action with respect to your personal information, or you opt into third party marketing communications.
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Security

Viggo takes the security of data very seriously. Viggo works hard to protect Customer Data you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the Customer Data we collect, process and store, and the current state of technology.

We place strict controls over our employees’ access to the data you and your users make available via the Viggo services, as more specifically defined in your agreement with Viggo covering the use of the Viggo services ("Customer Data"), and are committed to ensuring that Customer Data is not seen by anyone who should not have access to it. They may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).

We're committed to making Viggo a highly-available service that you can count on. Our infrastructure runs on systems that are fault tolerant, for failures of individual servers or even entire data centers. The Viggo services support the latest recommended secure cipher suites and protocols to encrypt all traffic in transit.

Viggo maintains an extensive, centralized logging environment in its production environment which contains information pertaining to security, monitoring, availability, access, and other metrics about the Viggo services. In addition to sophisticated system monitoring and logging, we have implemented two-factor authentication for all server access across our production environment.

Age Limitations

To the extent prohibited by applicable law, Viggo does not allow the use of our Services and Websites by anyone younger than 18 years old. If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.
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Data Retention

Your personal data will be stored as long as you have an active account. If your account is closed, personal data will be deleted (according to the policies set out in this document) from all of our databases, unless such data is required to be retained for accounting, criminal offence, dispute resolution or fraud prevention purposes.

Viggo may retain Customer Data pertaining to you for as long as necessary for the purposes described in this Privacy Policy. This may include keeping your Customer Data after you have deactivated your account for the period of time needed for Viggo to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes and enforce our agreements.

In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
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Data Deletion

You should bear in mind that any request to delete your personal data is possible only if we delete your account. As a result of that you will not be able to use Viggo app via an account which has been deleted.

You may delete your account through the applicable functionality available on the Service. The deletion of Customer Data and other users of the Services by Customer may result in the deletion and/or de-identification of certain associated Customer Data.

Please note that the de-installation of Viggo app in your device does not cause the deletion of your personal data.

Data Portability

You may download Customer Data through the applicable functionality available on the Service. Please note that gathering all of your information may take a while.

A file with Customer Data will be sent to the email address associated with the account that has submitted the request. Data exports request are limited to once per day.

Direct Marketing

We inform Customers about new product features, promotional communications or other news about Viggo by sending an email, SMS message or push notification. We will only use your email address and/or phone number to send direct marketing messages if you have given us permission to do so via the Website or via the Viggo App. We may personalize direct marketing messages using Customer Data.

You can control whether you want to receive these direct marketing messages through the settings in Viggo App or by clicking “Unsubscribe” link in the footer of our email.

Access And Correction

You can access and update your personal data via the Viggo mobile app. If Viggo has information about you that you believe is inaccurate, you have the right to request correction by sending an email to support@viggo.com.

Changes To This Privacy Policy

Viggo may change this Privacy Policy from time to time. Laws, regulations and industry standards evolve, which may make those changes necessary, or we may make changes to our business. We will post the changes to this page and encourage you to review our Privacy Policy to stay informed. If we make changes that materially alter your privacy rights, Viggo will provide additional notice, such as via email or through the Services. If you disagree with the changes to this Privacy Policy, you should deactivate your Services account. Contact the Customer if you wish to request the removal of Personal Data under their control.

Your Rights

You may ask us to take the following actions in relation to your personal information that we hold:
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• Opt-out. Stop sending you direct marketing communications. You may continue to receive service-related and other non-marketing emails.
• Access. Provide you with information about our processing of your personal information and give you access to your personal information.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information.
• Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
• Restrict. Restrict the processing of your personal information.
• Object. Object to your reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.

You can usually do this using the settings and tools provided in your Services account. If you cannot use the settings and tools, contact us by sending an email to support@viggo.com for additional information and assistance. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described above or submit a complaint to the data protection regulator in your jurisdiction.

Contacting Viggo

Feel free to contact Viggo if you have any questions about this Privacy Policy or Viggo’s practices, or if you are seeking to exercise any of your statutory rights. Disputes related to the processing of personal data are resolved through customer support as well.

You may contact us at support@viggo.com or at our mailing address below:

Viggo HQ ApS (registration number: 40308350) Tømmergravsgade 4, 2450 København SV, Denmark

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