PRIVACY STATEMENT (MEXICO)

Effective Date: February 1, 2018

This Privacy Policy (“Policy”) describes the practices of VOOM VFI México S. de R.L. de C.V. ("Voom") in Mexico regarding its collection, use and storage of personal and other information concerning individuals (“Users” or “you”) who use our mobile applications, websites and other online products and services (collectively, the “Services”) including interactions and communications Users have with operators of helipads and helicopters in our network (collectively, “Operators”). This Policy should be considered along with Voom’s Terms of Use.

By accessing or using the Services you agree with and consent to be bound by the terms and conditions of this Policy. We may update this Policy from time to time in our sole discretion; however, we will provide you the updated Policy through the Services or by some other means.

BY USING THE SERVICES, OR PROVIDING INFORMATION TO US, EACH USER CONSENTS TO THE COLLECTION, USE AND STORAGE OF HIS OR HER PERSONAL DATA AND OTHER INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Important Note Regarding Minors.

Minors under 18 (or the legal age of majority – if less than 18 – in the place where the Services are provided) may not use the Services, except through their parents or guardians. We do not knowingly collect any personal information from children under 13. If we become aware that an individual submitting information is under 13, we will delete such information as soon as reasonably practicable.

BY USING THE SERVICES, EACH USER REPRESENTS THAT HE OR SHE IS AT LEAST 13 YEARS OLD.

I. Types of Information and Information collected

A. Information You Provide to Voom:

We collect information you provide directly to us, such as when you create or modify your account, request on-demand services, contact customer support, or otherwise communicate with us. This information may include: name, email, phone number, passport information or other similar government-issued ID, weight, postal address, customer profile, picture, payment method, items requested (for delivery services), delivery notes and other information you choose to provide. This information may be required to use our Services. You may also provide information to us and our partners implicitly by using the service, such as location information, IP address and other digital signatures, as described below.

B. Information We Collect Through Your Use of Our Services:

We collect information about you in the following general categories:

Geolocation Information: When you use the Services to request transportation or delivery, we collect precise location data about the trip from the Voom app (or mobile website) (the “Voom App”). By requesting a Service that would require that you (or your designee or guest) be picked up from a specific location, you allow us to collect your (or your designee or guest’s) precise geographic location and to retain such information until the journey is completed. If you permit the Voom App to access location services through the permission system used by your mobile operating system or browser, we may also collect the precise location of your device when the Voom App is running in the foreground or background.

Contacts Information: If you permit the Voom 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 Policy or at the time of consent or collection.

Transaction Information: We collect transaction details related to the use of our Services, including the type of service requested by a specific User, date and time the service was provided, amount charged, distance traveled and other related transaction details. This information will also be provided back to you in the form of a receipt.

Usage and Preference Information: We collect information about how Users 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.

Device Information: We collect information about a User’s 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 Operators. 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 a User interacts with the Services, we collect server logs, which may include information such as 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.

Travel Companion Information: When you use the Service to request transportation for someone else, we will request detailed personal information and special requirements for each such individual. You should obtain the consent of other individuals prior to providing us with their personal information and travel preferences, as any access to view or change their information will be available only through your account.

C. Platform Permissions

If you are accessing our Services via an installed mobile app, most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. These platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Voom App wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Voom App seeks before you first use the app and your use of the app constitutes your consent. Sometimes these permissions require more explanation than the platforms themselves provide and the permissions we request will change over time, so we’ve created these pages to serve as authoritative and up-to-date resources for our Users. If you are accessing our Services via a web browser, you will not be shown these access screens or permissions.

D. Information From Other Sources

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 sign in to your Voom account with a payment provider (e.g., Stripe) or social media service (e.g., Facebook), 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 you also interact with our Services in another capacity, for instance as an Operator 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.

If you choose not to share with us this information, you can change it through your privacy settings on the third party’s service control.

II. Use of Information

A. General

With your authorization, we may use the information we collect about other Users, Operators and travel companions to:

Provide, maintain and improve our Services, including, for example, schedule a journey, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Operators, 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 a User and an Operator, such as estimated times of arrival (ETAs); or (ii) between a User and a User’s contact at the User’s direction in connection with a User’s use of certain features, such as referrals, invites, split fare requests, or ETA sharing;

Send Users and operations communications we think will be of interest to them, including information about products, services, promotions, news and events of Voom 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; and

Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals and advertisements.

B. Financial Information

We do not store Users or Operators’ financial information, nor does it pass through our servers. We rely on a third-party PCI compliant vendor for this purpose, Stripe. We will never share financial information (credit cards) or government ID information (Passport) except as required by applicable law.

C. Sharing of Information

According to applicable regulations, Voom acknowledges its capacity as a Data Controller by virtue of this Privacy Statement. To the extent needed to provide services, Voom may transfer Personal Data to the Operator or third parties prior written and express consent obtained from data holders, such as the following cases:

With Operators to enable them to provide the Services that a User request. For example, we share a User’s and travel companion’s name, photo (if you provide one) and pickup and/or drop-off locations with Operators;

With other riders if a User uses a ride-sharing service; and with other people, as directed by the User, such as when a User wants to share his/her estimated time of arrival or split a fare with a friend;

With third parties to provide a User or operator with a service that he/she requested through a partnership or promotional offering made by a third party or us;

Domestic or international transfers of personal data may be carried out without the consent of the data owner in the following cases:

With third parties including apps or websites that integrate with our API or Services, or those with an API or Service with which we integrate;

With our 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 issued by a competent authority if we believe disclosure is in accordance with, or is otherwise required by, any applicable law, regulation, or legal process;

If we believe a User’s, Operator’s, or travel companion’s actions are inconsistent with our Terms of Use, or to protect the rights, property, or safety of Voom or others;

In connection with, during negotiations of, or as part of the implementation 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.

D. Third Party Websites and Social Media

The Services may contain links (for example, to view an article) or social networking buttons (for example, Facebook or Twitter) that link to other websites or services that are not owned, operated or controlled by Company. We have no control over and are not responsible for the data collection and/or handling practices of such other websites. The display, on the Services, of a link to a third party’s website or app does not imply our endorsement of such website or app. We encourage you to be aware when you leave our Services and to read the privacy statements of each website or app on which you land after you click on a link or social networking button. This Policy does not address the information practices of any third party, including any Operators. In particular, the inclusion of a link on the Service(s) to a third party’s website or service does not imply endorsement of the third party’s data handling practices and does not imply that their practices are covered by this Policy.

E. Cross-Border Transfer of Information

We may transfer the information described in this Policy to and process and store it in, the United States and other countries considering the rules established by law and Our Policy. Where this is the case, we will take appropriate measures to protect your personal information in accordance with this Policy.

III. Protection of Information

A. Security

We limit access to information about Users, operators and travel companions only those employees and authorized parties who reasonably need access to it to perform the activities attached to their job responsibilities. We seek to use reasonable technical, organizational and administrative measures to protect such information within our organization against unauthorized or unlawful access or processing and against accidental loss, theft, disclosure, copying, modification and destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody.

B. Retention

We retain information about Users for as long as necessary to perform the activities described in this Policy or comply with a legal request unless a longer retention period is required or permitted under applicable law. We may choose to anonymize some of the information in our custody so that it can no longer be attributed to a particular individual if we would like to retain it for longer periods of time.

IV. Corrections and Deletions

Voom will comply with a User, operator or travel companion’s requests regarding access, rectification, cancellation and/or objection of the personal data it stores in accordance with applicable regulations and upon presentation of appropriate proof of identity. Please note that some of this information is required to provide the Services and removal of it may render the requesting party ineligible for receiving the Services. Please also note that in some cases we may retain certain information about you, even if you delete it, or close your account, to meet our obligations in accordance with applicable regulations or for legitimate business purposes to the extent permitted by law.

V. Changes to this Policy

We may change this Policy from time to time. If we make significant changes in the way we treat your personal information, or to the Policy, we will provide you the updated Policy through the Services or by some other means, such as email. We encourage you to periodically review the Policy for the latest information on our privacy practices.

YOUR CONTINUED USE OF THE SERVICES AFTER WE HAVE POSTED CHANGES TO THIS PRIVACY STATEMENT ON THIS PAGE IN ACCORDANCE WITH APPLICABLE LAW, AND WITH A NEW EFFECTIVE DATE, WILL CONSTITUTE YOUR CONSENT TO THE CHANGES.

Contact Us

If you have any questions about this Policy, please contact us at [email protected].