PTG Travel Limited (“we”,“our”, “us”) are committed to protecting and respecting your privacy

PTG Travel is a private hire taxi and courier company with over 12 years of experience and knowledge.  This privacy policy explains how we use any personal information we collect about you, as a past, present employee, a service user, Driver or when you use our website or applications.

Please read this notice carefully so that you understand your rights in relation to your personal data, and how we will collect, use, and process your personal data. If you do not agree with this Privacy Notice in general or any part of it, you should not access the Websites, the Apps or use our services.

CONTROLLERS’ CONTACT INFORMATION

PTG Travel is the controller for the personal information we process, unless otherwise stated via contracts.  PTG Travel is the data controller for the purposes of the General Data Protection Regulation and any relevant local legislation (“Data Protection Laws”).

WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT YOU?

Web Collection:

You may provide information by contacting us via our Websites, Apps or by email, telephone, social media or otherwise, or by signing up for our newsletters or alerts, or by creating an account and then using our services.  This personal information always requires the user’s confirmation before it is submitted, and the user can refuse to provide this. However, in this case they will be unable to engage in the website activity as we would not have the contact details to send the requested information.

B2B Data Collection:

If you use our services through your company, information provided to us by your employer. In the case of our corporate customers only, your employer may provide us with information about you when it signs up to use our services, for example your name, contact number and business email address.

Contact List:

If you give us permission to use your phones's phone book/contacts, then ability to share address information from your telephone's contact book is supported.

Job applicants, current and former PTG Travel employees

When individuals apply to work at PTG Travel , we will only use the information you supply to us to process your application.  Where we want to disclose information to a third party, for example where we want to take up a reference or obtain a ‘disclosure’ from the Disclosure and Barring Service we will not do so without informing you beforehand unless the disclosure is required by law. Once a person has taken up employment with PTG Travel , we will compile a file relating to their employment. The information contained in this will be kept secure and will only be used for purposes directly relevant to that person’s employment. Once their employment with us has ended, we will retain the file in accordance with the requirements of our retention schedule and then delete it.

Drivers for PTG Travel

PTG Travel will collect the following personal data about you while you provide services to us:

• identity information such as title, full name, date of birth, photograph, public service vehicle licence, drivers licence details, or proof of eligibility to enter into the driver contract.
• contact details such as home and work address, phone number(s), email address(es), emergency contacts and next of kin;
• data with respect to the driver contract, including commencement date, participation in driver training programmes, background checks (good conduct,).
• data regarding the location of the vehicle, rate of travel and other similar information transmitted from GPS trackers, telematics devices, Wi-Fi routers, forward-facing cameras, the PTG Travel -provided communications device, and similar devices which are fitted to the vehicle, whether the vehicle is being used for the provision of passenger services or for personal.
• financial data, including payments for bookings, your bank details and tax numbers (KRA Pin).
• information about your physical or mental health or condition.
• information relating to any background check, any criminal proceedings in which you have been involved or the commission of any potential criminal or civil offence for insurance or trust purposes, or when we have been notified of any relevant potential vehicle or driving offences or where there is an allegation of parking, speeding, toll or other traffic-related

For further details, please check the Driver Portal for your Driver Type

Site Visits

We ask all visitors to sign in and out at reception and show a form of ID. The ID is for verification purposes only, we don’t record this information.

Closed-circuit television (CCTV) operates inside and outside the building for security purposes. The information is viewed by our IT department only.

The purpose for processing this information is for security and safety reasons. We have Guest Wi-Fi on site for the use of visitors. We’ll provide you with the address and password on request.

Criminal Activity

Information provided to us by a third party and/or collected from public records in the case of fraud or suspected fraud. In the case of fraud or suspected fraud, we may obtain information from third parties and from public records to prevent and detect fraud.

Technical usage information.

When you visit our Websites or use our Apps, we automatically collect the information sent to us by your device, which includes your computer, mobile phone and tablets. This information includes:

• your IP address;
• device information including, but not limited to, identifier, name, and type of operating system (including versions);
• mobile network information.
• standard web information, such as your browser type and the pages you access on our Websites;
• mobile device UUID (Unique Download ID) and/or mobile device fingerprint; and
• hardware models, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, and device motion information.

THE LAWFUL BASIS WE USE TO PROCESS YOUR DATA

We will only ever process your information if we have a lawful basis to do so. The lawful bases we rely on are;

• Contract – This is where we process your information to fulfil a contractual arrangement, we have made with you.
• Consent – This is where we have asked you to provide explicit permission to process your data for a particular purpose.
• Legitimate Interests – This is where we rely on our interests as a reason for processing, generally this is to provide you with the best service in the most secure and appropriate way.
• Legal Obligation – This is where we have a statutory or other legal obligation to process the information.

HOW WE USE YOUR INFORMATION

We take your privacy very seriously. The Privacy Policy details what to expect when PTG Travel collects your personal information.  In most cases, any personal information provided, for example Contact Form submissions, are stored on servers in our Kenyan Data Centres. We use a third party provider to help manage and maintain the security and performance of our corporate websites.

To perform our contract with you, we will use your information:

• to communicate with you;
• to provide you with ground transportation and/or courier services.
• to create records of bookings and to send you booking acknowledgments, confirmations, receipts and invoices; and
• to maintain records of lost property.

As it is in our legitimate interests to be responsive to you and to ensure the proper functioning of our services and organisation, we will use your information:

• to detect and prevent fraud and crime;
• for reporting and data analysis purposes;
• to administer our membership and loyalty scheme(s);
• for insurance purposes;
• to comply with our legal and regulatory obligations
• to meet customer service requirements and for complaint handling and feedback;
• to monitor and assess the quality of our service;
• to host events for our customers;
• to pass on feedback such as ratings or compliments about our drivers;
• to sign you up for our newsletters or alerts;
• to contact you via telephone, email, SMS or via our Apps;
• to identify our users;

• to personalise our services for you, for example, to provide you with an accessible vehicle where you request such a vehicle and if you have opted in to marketing, to send you promotions and offers tailored to your use of the services, for example, discounts on airport bookings where you frequently make airport bookings;

• to enforce our terms and conditions;

• if you have opted in to marketing, to communicate with you about products, services, promotions, events and other news and information we think will be of interest to you; or

• to provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information).

PROFILING

• Fraud prevention: We use a combination of risk screening tools and manual intervention to ensure that customer profiles are not fraudulent. To do this, we match the personal data provided by customers against data fields such as name, email address, mobile phone number, and we use this to accept or decline bookings.

• Marketing: We manually carry out customer segmentation for marketing purposes based on journey history. We use this to make our advertisements more relevant for market segments, such as promoting relevant journey types.

SHARING YOUR INFORMATION?

We do not sell, rent or lease your personal information to others except as described in this Privacy Notice. We share your information with selected recipients. These categories of recipients include:

• IT Services providers that provide us with SaaS services, who we use to store our customer relationship management information.
• fraud prevention tools located in Kenya for the purposes of preventing fraud;
• Partner drivers based in the territory in which you request services;
• IT support service providers who support and maintain our booking platform and have access at our premises working on a secure server; and
• Our insurance company and claims handling companies, for the purpose of investigating and settling any insurance claims.

We will share your information with law enforcement agencies, public authorities or other organisations if legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:

• comply with a legal obligation, process or request.
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

We will also disclose your information to third parties:

• in the event that we sell any business or assets, in which case we will disclose your data to the prospective buyer of such business or assets; or
• if we or substantially all of our assets are acquired by a third party, in which case information held by us about our users will be one of the transferred assets.

THE SECURITY OF YOUR PERSONAL DATA

Unfortunately, the transmission of information via the internet or email is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your information transmitted through the Websites, Apps, over email or via our contact centres; any transmission is at your own risk. Once we have received your information, we will take appropriate technical and organisational measures to safeguard your personal data against loss, theft and unauthorised use, access or modification.

We will, from time to time, host links to and from the websites of our affiliates or third parties. If you follow a link to any of these websites, these websites will have their own privacy policies and we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to those websites.

HOW LONG DO WE STORE YOUR PERSONAL DATA?

To determine the retention period of your personal data, we consider several criteria to make sure that we do not keep your personal data for no longer than is necessary or appropriate. These criteria include:

• the purpose for which we hold your personal data;
• our legal and regulatory obligations in relation to that personal data
• whether our relationship with you is ongoing, for example, you have an active account with one or more of our brands, you continue to receive marketing communications, or you regularly browse or purchase off our Websites/Apps);

• whether you are no longer actively participating or engaging with our brands, for example, you do not open our emails, visit our Websites, or share user generated content;

• any specific requests from you in relation to the deletion of your personal data; and

• our legitimate business interests in relation to managing our own rights, for example the defence of any claims.

YOUR RIGHTS AS A DATA SUBJECT

You have rights in relation to the personal data we hold about you. Some of these only apply in certain circumstances. We have described these situations below, as well as how you can exercise your rights. To exercise any of your rights, please contact us at support@ptgtravels.com

• Access: You have the right to ask us to access the personal data we hold about you and be provided with certain information about how we use your personal data and who we share it with.

• Correction: You also have the right to ask us to correct your personal data where it is inaccurate or incomplete.
• Erasure: In certain circumstances, you have the right to ask us to delete the personal data we hold about you.
• Restriction: In certain circumstances, you have the right to ask us to restrict (stop any active) processing of your personal data, save for storage.