Global Privacy Notice for Drivers

Global Privacy Notice for Drivers

Hopp (a registered business name and trading name operated by Hopp Services CA Inc) is the controller of personal data of drivers and has appointed a Data Protection Officer (privacy@bolt.eu).

This privacy notice for drivers provides information about how Hopp Services CA Inc (hereinafter “Hopp”, “we”, “us”), its parent company (Bolt Technology OÜ, an Estonian company with registration code 14532901), group companies, and third party partners collect and use the personal data of persons providing transportation services via the Hopp platform, i.e., drivers. More information about Hopp and its parent company is set out here ↗.

This privacy notice describes what data we process and why, how we keep personal data safe and what choices and controls are available to the data subjects (hereinafter also “you”). You can also find information about your privacy rights in this privacy notice.

If you are a driver on the Hopp platform, please read this privacy notice as it contains important information about the processing of your personal data as well as information about our requirements when you process passengers’ personal data.

Please note that our personal data processing activities may be subject to differing applicable laws and regulations in the places in which we operate. This means that we engage in the personal data processing activities described in this privacy notice in a particular country only if permitted under the laws of that country. For further information about the jurisdictional disclosures and differences that may apply to you, please refer to Section 8 ‘Jurisdictional Disclosures’ below.

Please note, that our websites and apps may contain links to other third-party websites. If you follow a link to any of those third-party websites, know that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or their processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.

1. Personal data we process

We may process different categories of driver’s personal data. The data categories are as follows and are provided by you and/or collected by Hopp when you access and use the Hopp app:

General data such as name, e-mail, phone number, place of residence (data is provided to us by the driver).
Geolocation data such as geolocation of drivers and driving routes (data is gathered via Hopp system when driver uses Hopp app.
Information about vehicles (including registration number and compliance status) (data is provided to us by the driver).
Usage data such as driver's engagement, interactions on the marketplace and driver ratings including Driver Score.
Identification/verification data such as driver's license, photo, and identity documents. Offences data such as data about criminal convictions and offences, where permitted under local laws and regulations.
Communication and correspondence records such as: when the driver engages with our in-app chat ("Send a Message" option), or speaks with our customer service agents, the date and time of the communication, and its content.
Information required under applicable law for taxation purposes: such as your Business Number (your 9-digit registration number issued by the Canada Revenue Agency (CRA) that identifies your business for tax purposes), VAT ID, place of birth, financial account identifier, information of each Member State in which you are a resident.
User generated content: such as audio recordings generated during the trip (as part of our safety toolkit trip audio recording feature, where such feature is available), or any other content submitted like pictures, videos or files in connection with a customer support request.

In addition to above mentioned sources, we may collect and receive your data from other sources, which include:

Fleet partners;
Service providers who conduct vehicle and driver compliance checks, and criminal background checks;
Passengers and third parties who provide information and content in connection to the service or in regard to possible claims and disputes; and
Users who participate in our referral campaigns. In that case we receive the referred person’s information from that user.

2. Purposes of the processing

We process driver’s personal data for different purposes. The main purposes are as follows:

For our service provision, we collect and process personal data for the purpose of connecting passengers with drivers to help them move around cities more efficiently.
For our service provision, geolocation and driving routes are processed to analyse the geographical area and give suggestions to the drivers. If you do not want to disclose your geolocation for passengers, you must close the Hopp app or indicate in the Hopp app that you are offline and currently are not providing transportation services.
Driver's license, profession, identity documents and criminal convictions and offences are processed to determine the compliance with the legal requirements and the suitability of pursuing a profession as a driver.
For our service provision, the Hopp app displays driver's photo, name and vehicle details for the passengers to identify driver and vehicle.
You will receive summaries from the Hopp Driver Portal, which will include your efficiency and ratings as a driver. Summary and ratings about driver are necessary to provide reliable services for passengers.
Personal data related to instant messages directly in the Hopp app is processed in order to provide service and customer support (including resolving disputes between driver and rider), for security purposes as well as to improve our products and services, and for analysis (fraud, safety and security purposes).
We collect and use information about a driver’s engagement and interaction on the marketplace, and their ratings (including Driver Score) to encourage user safety, ensure drivers comply with the Driver Terms, and make sure we’re providing a quality and enjoyable service to everyone. Where the Driver Score drops below a specified threshold, we may issue the driver with a notification or request to, for example, digest some further guidance. If your score continues to drop, you may be temporarily suspended from accessing the Hopp platform. You may appeal any decision to suspend your account.
We may process all personal data about you for the establishment, exercise or defence of legal claims.
Please see additional purposes under legitimate interest (see Clause 3 below).

3. Legal basis

As set out in Section 8 (Jurisdictional Disclosures) below, the legal bases we rely on to process your personal data may vary. We mainly use following legal bases to process driver’s personal data:

Performance of Contract: Personal data is processed for the performance of the contract concluded with the driver. The prerequisite for the use of the Hopp services is the processing of driver's identification and geolocation data. In addition, in order to provide our service to the driver, we process general data, vehicle data, usage data, communications data.
Legitimate Interest: Personal data (excluding special categories of personal data) may be processed on the ground of legitimate interest if we have concluded a legitimate interest assessment, including for the following purposes:
- investigating and detecting fraudulent payments, fraud and other malicious or unlawful activities and/or safety or security incidents: general data, identification/verification data, communication data and usage data may be processed;
- making recordings and logs: depending on your location, we may record messages and orders given both on our premises and/or using means of communication (e-mail, phone calls to customer support and riders, the Hopp app, etc.) as well as information and other activities we have performed. If necessary, we use these recordings for investigations, proof and protection against claims, and/or for quality assurance.
- technical and cyber security reasons: for example measures for combating piracy and ensuring the security of the service, website, Hopp platform and app as well as for making and storing back-up copies and preventing/repairing technical issues (depending on the issue, all data may be processed); and
- establishing, exercising or defending legal claims, including: (i) supporting our own internal investigations; (ii) the assignment of claims and the use of debt collecting agencies; and (iii) the use of legal advisors (depending on the claim all data may be processed).
Depending on the particular circumstances, we may, from time to time rely on alternative legal basis when it is more appropriate to do so, these may include:
- when it is necessary to comply with a legal obligation such as for processing data when the law requires it, including, for example, if there is a valid legal request to disclose personal information to a third party such as a Court or regulatory authority;
- when it is necessary to protect your vital interests, or those of others, for example in the event of an emergency or an imminent threat to life; and/or
- when you have given us clear consent to do so for another specific purpose for which you have been fully informed.

Please remember that depending on your country of residence, certain jurisdictional disclosures and differences may apply to your personal data that is processed by Hopp as set out above (please see Section 8 ‘Jurisdictional Disclosures’ for more information):

Where personal data is processed for a new purpose other than that for which the personal data are originally collected and the processing is not based on the data subject’s consent, we carefully assess the permissibility of such new processing. We will, in order to ascertain whether processing for a new purpose is compatible with the purpose for which the personal data are initially collected, take into account, inter alia:

any link between the purposes for which the personal data are collected and the purposes of the intended further processing;
the context in which the personal data are collected, in particular regarding the relationship between you and us;
the nature of the personal data, in particular whether special categories of personal data are processed or whether personal data related to criminal convictions and offences are processed;
the possible consequences of the intended further processing for you; and
the existence of appropriate safeguards, which may include encryption or pseudonymisation.

4. Recipients

Your name and photo is disclosed to passengers, when you have received their order. When you have accepted the passenger’s order, passengers will see driver's name, vehicle, phone number, photo and geolocation data. Passengers also see driver's personal data in the receipt.
Depending on your location, your personal data may be disclosed to Hopp local subsidiaries, representatives, affiliates, agents, fleet owners etc). Processing of personal data by will occur under the same conditions as established in this privacy notice.
Your personal data will be transferred (or otherwise made available) to certain third parties that provide services on our behalf. We use service providers to provide services such as service providers who provide email or moreover electronic communication services, tax, legal and accounting services, product fulfillment, background checks and identity/verification processes, payment processing, and facilitation, insurance coverage (data sharing with insurers, where you, or a family member in your absence request for a claim to be processed, for the purposes of facilitating the processing of insurance claims and for reporting purposes due to contractual requirements from the insurers) and financial instruments, customer support, fraud prevention and detection, data enhancement, web hosting and cloud storage, research, including surveys, analytics, crash reporting, performance monitoring and artificial intelligence, machine learning and statistical services. In addition, we will share data like your geolocation and your driving routes with Google in connection with the use of Google maps in our apps and data like your license plates or other data with airports in case it is required by the airport as a condition for operating at the airport. Our service providers are only provided with the information they need to perform their designated functions and are not authorized to use or disclose personal information for their own marketing or other purposes. Our service providers may be located (or may access your personal information) outside your country (and outside your jurisdiction, as applicable), including in the U.S. or other foreign jurisdictions. For further information about our use of service providers outside of your jurisdiction, please contact our Privacy Team using the contact details in the “How do you contact us?” section below.
We may disclose information under a court order or where we cooperate with a data protection supervisory authority in handling complaints or investigations. We may also share your personal data with law enforcement or other public authorities (such as tax authorities), including responding to requests when the information is required by law or furthers a public interest task. In any scenario, we’ll always satisfy ourselves that we have a lawful basis on which to share the information, and we’ll make sure that we document our decision.
We will share your data with insurers, where you, or a family member in your absence, request for a claim to be processed, for the purposes of facilitating the processing of insurance claims and for reporting purposes due to contractual requirements from the insurers.
Certain municipal by-laws and other laws and regulations legally require Hopp to share your personal data with licensing authorities. Depending on which cities you operate in, we may disclose certain personal data to comply with these licensing requirements.

5. Security and access

Any personal data collected in the course of providing services is transferred to and stored in the data centres of Zone Media LTD and/or Amazon Web Services, Inc., which are located in the territories of Member States of the European Union. Only authorised employees of Hopp group companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).
Please see Section 8 ‘Jurisdictional Disclosures’ for details of the lawful basis that we rely upon in your country to transfer your personal data.
Hopp group companies and partners can access personal data to the extent necessary to provide customer support in the respective country.

6. Processing passengers’ personal data

You may not process the personal data of passengers without our permission. You may not contact any passenger or collect, record, store, grant access, use or cross-use the personal data provided by the passenger or accessible to you via the Hopp app for any reason other than for the purposes of fulfilling Hopp-related transportation services.
You must comply with the rules and conditions for processing of personal data of passengers as set forth in the Privacy Notice for Passengers (https://gethopp.com/en-ca/privacy/privacy-for-passengers/?category=rides). If you violate the requirements for the processing of personal data of passengers, we may terminate your drivers account and claim damages from you.

7. Access, correction, retention, deletion and data portability

Personal data can be viewed and corrected in Hopp Driver Portal.
As a data subject you may have the following rights:
- the right to access and to request copies of your personal data.
- the right to request that we correct any information that is inaccurate. You can change certain data yourself within the Hopp Driver Portal.
- the right to request that we erase your personal data, under certain conditions (e.g., we are processing your personal data under your consent). Data that is processed pursuant to a legal obligation or where we have an overriding legitimate interest may not be deleted upon request.
- the right to request that we restrict the processing of your personal data, under certain conditions (e.g., we are processing your personal data under consent).
the right to object to our processing of your personal data, under certain conditions (e.g., we are processing your personal data under legitimate interest). You may submit an objection to any automated decision we have made, and ask that a person reviews it.
the right to request that we transfer the data that you have given us to another organization, or directly to you, under certain conditions. This only applies to information you have given us.
If we process your personal data using consent as legal basis, then you have the right to withdraw your consent at any time (e.g., by unsubscribing or using privacy controls in Driver portal). Withdrawing your consent won’t change the legality of processing done before withdrawal.
In cases where we use automated processing or profiling that has a significant effect on your rights, you may, under certain circumstances, have the right on grounds relating to your particular situation to object to the processing of personal data concerning you based on automated decisions/profiling and to require human intervention. You may also be entitled to an explanation regarding the logic of making an automated decision.
You have the right to file a complaint to the supervisory authority if you believe that we have processed your personal data unlawfully or have not complied with our legal obligations. You may also have a right to seek a judicial remedy - see Section 9 of this privacy notice.
Your personal data will be stored as long as you have an active driver's account. If your account will be closed the personal data will be stored for additional 3 year period.
Data necessary for accounting purposes shall be stored for 7 years.
In the event that there are formal investigations of a criminal offence, fraud or false information having been provided, the data will be stored as long as necessary according to the internal, legal, and regulatory requirements.
In the event of disputes, the data shall be retained until the claim is satisfied or the expiry date of such claims.
We respond to the request for deleting and transferring personal data submitted by an e-mail within a month and specify the period of data deletion and transfer.
The retention period for the data about instant messages directly in the Hopp app messages is 90 days, except cases where messages are related to a reported incident - in which case we will store them for 6 month.
The retention period for audio recording data generated through our Audio Trip Recording Feature is:
- 24 hours, while stored locally on the device of the person who generates the recording. The - recordings are automatically deleted after 24 hours if a report to Hopp’s customer support team is not created and the recording is not explicitly shared with Hopp’s customer support team as part of the report.
- Recordings shared and investigated by Hopp will be automatically deleted after 7 days unless the retention period is manually extended for investigation/legal reasons.

To exercise any of the above rights, you can contact our Customer Support Team via the Hopp App or via our website. You can also contact our Data Protection Officer Team by emailing our Privacy Mailbox at privacy@bolt.eu - please mark the subject line of the email “For the attention of Hopp’s Data Protection Officer”. For information about the specific rights that apply in your jurisdiction, please see Section 11 (Jurisdictional Disclosures) below.

8. Jurisdictional Disclosures

Hopp may choose or be required by law to: (i) provide different or additional disclosures about our data privacy practices; and/or (ii) process your personal data using a different legal basis other than Legitimate Interests, depending on your state or country of residence.

Country Canada (CA)

Disclosures

Legal basis for processing of personal information: In Canada, Hopp relies on consent (or, where legally required or permitted, an exception to consent) to collect, use and disclose your personal data for the purposes set out in this Privacy Notice above.

Consent for marketing: With your consent, Hopp may send you marketing communications. You can unsubscribe from these communications at any time within the Hopp App or by clicking the “unsubscribe” link in the communication itself.

Payments Processing in Canada: In Canada, Hopp has partnered with Airwallex, a third-party financial technology company providing embedded financial services. As cash transactions are not accepted in Canada, drivers are required to use Airwallex's services to receive payments. By agreeing to this Privacy Notice, you acknowledge that:

Hopp may request certain personal data from you and share it with Airwallex for processing as part of providing their embedded financial services. Any such processing is subject to Airwallex's privacy notices and terms.
You will establish a separate relationship with Airwallex, which includes accepting their privacy notice and providing necessary consents for the use of their embedded financial services. The content and terms of Airwallex's privacy notice are solely their responsibility.
Hopp is not responsible for Airwallex's data processing activities, financial service operations, or the content of their privacy notices.
Upon termination of your agreement with Hopp, we will cease sharing your data with Airwallex and its partners, except as required by applicable law.

Transfers of your personal data:

By agreeing to Hopp’s Privacy Notice, you are consenting to Hopp transferring (exporting) your personal data from Canada to other Hopp Group Companies.
We may also transfer any information we have about you as an asset in connection with a proposed or completed merger, acquisition or sale (including transfers made as part of insolvency or bankruptcy proceedings) involving all or part of Hopp or its parent company, or as part of a corporate reorganization or other change in corporate control.

Legal disclosure of your personal data: We may disclose your personal data if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we operate.

Data subject rights:

In Canada you have the right to access, update, rectify and correct inaccuracies in your personal data in our custody or control. You may also withdraw your consent to our use and disclosure of your personal information.
Depending on your province, you may also have additional rights such as the right to request that we cease disseminating or de-index (or re-index) your personal information, if applicable.
You may request access, updating, rectification and corrections of inaccuracies in your personal information in our custody or control or withdraw your consent by contacting our Customer Support Team at the contact information set out in the “How do you contact us?” section below.

9. Dispute resolution

Disputes relating to the processing of personal data are resolved through customer support or by contacting Hopp's Data Protection Officer (privacy@bolt.eu).

Our supervisory authority is the Estonian Data Protection Inspectorate www.aki.ee ↗) which can be contacted by email info@aki.ee.

10. How do you contact us?

We have appointed a Global Data Protection Officer and an Office of the Data Protection Officer Team who can be contacted by emailing our Privacy Mailbox at privacy@bolt.eu - please mark the subject line of the email ‘For the attention of Hopp’s Data Protection Officer’. You can also raise any privacy-related questions by contacting our Customer Support Team in the Hopp App when you go to the main menu and tap ‘Support’, the Customer Support Team will then escalate the issue internally to Hopp’s Privacy Legal Team.

11. Making this notice great

We hope you have found this privacy notice easy to understand. Data protection laws are important. They strengthen rules and enhance your information rights. Many of these rules may appear complicated, but most are grounded in common sense. We take our responsibilities with your data seriously. Hopp will continue to make changes to this privacy notice as part of our commitment to protecting your privacy and affording you even more transparency.