This notice applies to users of Emto’s services anywhere in the world, including users of Emto’s apps, websites, features, or other services.

This notice describes how Emto and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world, unless covered by a separate privacy notice. This notice specifically applies to:

• Drivers: individuals who provide, or submit applications to Emto to provide, transportation individually or through partner transportation companies

• Consignees: individuals who request or receive products and services

• Consigners: individuals who provide, or submit applications to Emto to provide, delivery or other services

This notice also governs Emto’s other collections of personal data in connection with Emto’s services. For example, we may collect the contact information of individuals who use accounts owned by Emto for Business customers or of owners, or we may collect other personal data in connection with our mapping technology and features.

All those subject to this notice are referred to as “users” in this notice.

Our data practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

 

Emto Logistics and Technologies Private Limited. is the data controller for the personal data collected in connection with use of Emto’s services anywhere else.

Emto Logistics and Technologies Private Limited. is the data controller for the personal data collected in connection with use of Emto’s services anywhere else. We process personal data inside and outside of India. The personal data of users outside the India is transferred on the basis of mechanisms approved under applicable laws.

Questions, comments, and complaints about Emto’s data practices can be submitted on our website.

Emto collects:

• Data provided by users to Emto, such as during account creation

• Data created during use of our services, such as location, app usage, and device data

• Data from other sources, such as Emto partners and third parties that use Emto APIs

The following data is collected by or on behalf of Emto:

1. Data provided by users. This includes:

• User profile: We collect data when users create or update their Emto accounts. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), government identification documents, including driver’s license numbers and images, birthdate, signature, and photo. This also includes vehicle or insurance information of drivers and delivery partners, and user settings. We may use the photos submitted by drivers and/or delivery partners to verify their identities, such as through facial recognition technologies. For more information, please see the section titled “How we use personal data.”

• Background check and identity verification: We collect background check and identity verification information for drivers and delivery partners. This may include information such as driver history or criminal record (where permitted by law), and right to work. This information may be collected by an authorized vendor on Emto’s behalf.

• Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties.

• User content: We collect the information users submit when they contact Emto customer support, provide ratings or compliments for other users, or otherwise contact Emto. This may include feedback, photographs or other recordings collected by users.

2. Data created during use of our services. This includes:

• Location data: We collect precise or approximate location data from a user’s mobile device if enabled by the user to do so. For drivers and delivery partners, Emto collects this data when the Emto app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device. For consigners, Consignees, and drivers, Emto collects this data when the Emto app is running in the foreground. In certain regions (which do not include the European Union), Emto may also collect this data when the Emto app is running in the background of the user’s mobile device. consigners, Consignees, and drivers may use the Emto apps without enabling Emto to collect location data from their mobile devices. However, this may affect some functionality available in the Emto apps. For example, a user who has not enabled location data collection will have to manually enter their address. In addition, the location data collected from a driver or rental device during a trip will be linked to the consigner’s or driver’s account, even if they have not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.

• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, delivery information, date and time the service was provided, amount charged, distance traveled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.

• Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, type of browser, and third-party sites or services used before interacting with our services. In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers.

• Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address, operating systems and versions, software, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion data, and mobile network data.

• Communications data: We enable users to communicate with each other and Emto through Emto’s mobile apps and websites. For example, we enable drivers and consigners, and restaurants or delivery partners and Consignees, to call, text, or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, Emto receives some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. Emto may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our products and services, and for analytics.

• Rental devices data: We collect data generated by rental devices, such as bicycles, scooters, or other light electric vehicles or devices, when they’re in use. This includes the date and time of use, and the location, route, and distance traveled. To the extent permitted by law, the location data collected from the rental device during the trip will be linked to the driver’s account, even if they have not enabled Emto to collect location data from their mobile device.

3. Data from other sources. This includes:

• User feedback, such as ratings, feedback, or compliments.

• Users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s personal data from that user.

• Emto account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of Emto for Business accounts.

• Users or others providing information in connection with claims or disputes.

• Emto business partners through which users create or access their Emto account, such as payment providers, social media services, or apps or websites that use Emto’s APIs or whose APIs Emto uses.

• Vendors who help us verify users’ identity, background information, and eligibility to work, for regulatory, safety, and security purposes.

• Insurance, vehicle, or financial services providers for drivers and/or delivery partners.

• Partner transportation companies (for drivers or delivery partners who use our services through an account associated with such a company).

• Publicly available sources.

• Marketing service providers.

Emto may combine the data collected from these sources with other data in its possession.

Emto collects and uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use the data we collect:

• To enhance the safety and security of our users and services
• For customer support
• For research and development
• To enable communications between users
• To send marketing and non-marketing communications to users
• In connection with legal proceedings

Emto does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.

Emto uses the data it collects for purposes including:

1. Providing services and features. Emto uses the data we collect to provide, personalize, maintain, and improve our products and services.

This includes using the data to:

• Create and update users’ accounts.

• Verify drivers’ and delivery partners’ identity, background history, and eligibility to work.

• Enable transportation, deliveries, and other services.

• Offer, process, or facilitate payments for our services.

• Offer, obtain, provide, or facilitate insurance, vehicle, invoicing, or financing solutions in connection with our services.

• Track and share the progress of rides or deliveries.

• Enable features that allow users to share information with other people, such as when consigners submit a compliment about a driver, when Consignees provide feedback for a delivery partner, refer a friend to Emto, split fares, or share ETA and location with their contacts.

• Enable Accessibility features that make it easier for users with disabilities to use our services, such as those that enable deaf or hard-of-hearing drivers to alert their consigners of their disabilities, allow only text messages from consigners, and enable receipt of flashing trip request notifications instead of sound notifications on their mobile device.

• Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.

2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes:

• Screening consigners, drivers, and delivery partners before enabling their use of our services and at subsequent intervals, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or consigners.

• Using data from drivers’ or delivery partners’ devices to help identify unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery partners’ devices to verify the type of vehicles they used to provide deliveries.

• In certain regions, using information derived from driver’s license photos, and other photos submitted to Emto, for safety and security purposes. This includes Emto’s Real-Time ID Check feature, which prompts drivers and delivery partners to share a selfie before going online to help ensure that the driver or delivery partner using the app matches the Emto account we have on file. This also includes comparing photographs that we have on file against photographs (i) of other users to prevent identity-borrowing, and (ii) from public databases to verify user identity.

• Using device, location, profile, usage, and other data to prevent, detect, and combat fraud or unsafe activities.

• Using user ratings and feedback to encourage compliance with our Community Guidelines and as grounds for deactivating drivers and delivery partners with low ratings or who otherwise violated such guidelines in certain countries.

3. Customer support. Emto uses the information we collect (including recordings of customer support calls with notice to and the consent of the user) to provide customer support, including to:

• Direct questions to the appropriate customer support person

• Investigate and address user concerns

• Monitor and improve our customer support responses and processes

4. Research and development. We may use the data we collect for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us to improve and enhance the safety and security of our services, improve our ability to prevent the use of our services for illegal or improper purposes, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Enabling communications between users. For example, a driver may message or call a consigner to confirm a pickup location, a consigner may contact a driver to retrieve a lost item, or delivery partner may call a Consignee with information about their order.

6. Marketing. Emto may use the data we collect to market our services to our users. This includes sending users communications about Emto services, features, promotions, sweepstakes, studies, surveys, news, updates, and events.

We may also send communications to our users about products and services offered by Emto partners. For example, if a user has placed an delivery order, we may provide recommendations, promotions, or ads offered by other Emto partners. Although we may send users communications about Emto partners’ products and services, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.

We may use the data we collect to personalize the marketing communications (including advertisements) that we send, including based on user location, past use of Emto’s services, and user preferences and settings.

We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, Emto has notified some users by email of ballot measures or pending legislation relating to the availability of Emto’s services in those users’ areas.

7. Non-marketing communications. Emto may use the data we collect to generate and provide users with receipts; inform them of changes to our terms, services, or policies; or send other communications that aren’t for the purpose of marketing the services or products of Emto or its partners.

8. Legal proceedings and requirements. We may use the personal data we collect to investigate or address claims or disputes relating to use of Emto’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries.

9. Automated decision-making

We use personal data to make automated decisions relating to use of our services. This includes:

• Enabling dynamic pricing, in which the price of a ride, or the delivery fee, is determined based on constantly varying factors such as the estimated time and distance, the predicted route, estimated traffic, and the number of consignments and drivers using Emto at a given moment.

• Matching available drivers and delivery partners to users requesting services. Users can be matched based on availability, proximity, and other factors.

• Determining driver and delivery partner ratings, and deactivating drivers, consigners, and delivery partners with low ratings. For more information about how ratings are determined and used.

• Deactivating users who are identified as having engaged in fraud or activities that may otherwise harm Emto, its users, and others. In some cases, such as when a user is determined to be abusing Emto’s referral program, such behavior may result in automatic deactivation.

• Using driver location information, and communications between consigners and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine by using such information that a driver is delaying a consignment pickup in order to induce a cancellation, we will not charge the consigner a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such adjustment, please contact Emto customer support.

Click the links in this section for more information about these processes. To object to a deactivation resulting from these processes, please contact Emto customer support.

Emto and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice.

Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Emto uses cookies and similar technologies for purposes such as:

• Authenticating users

• Remembering user preferences and settings

• Determining the popularity of content

• Delivering and measuring the effectiveness of advertising campaigns

• Analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services

We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.

 

Some of Emto’s products, services, and features require that we share data with other users or at a user’s request. We may also share data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Emto may share the data we collect:

1. With other users

This includes sharing:

• Consigners’ first name, rating, and pickup and/or dropoff locations with drivers.

• Consignees’ first name, delivery address, and order information with their delivery partner and restaurant. We may also share ratings and feedback, or other information to the extent required by law, with the delivery partner.

• For drivers and delivery partners, we may share data with the consigner(s), Consignee(s), and other partner(s), including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; length of use of the Emto app; contact information (depending upon applicable laws); and driver or delivery partner profile, including compliments and other feedback submitted by past users. We also provide consigners and Consignees with receipts containing information such as a breakdown of amounts charged, driver or delivery partner first name, photo, route map, and such other information required on invoices in the country or region where the driver or delivery partner operates.

• For those who participate in Emto’s referral program, we share certain personal data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

2. At the user’s request

This includes sharing data with:

• Other people at the user’s request. For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.

• Emto business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Emto may share certain data with those third parties. This may include, for example, other services, platforms, apps or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or other Emto business partners and their users in connection with promotions, contests, or specialized services.

3. With the general public

Questions or comments from users submitted through public forums such as Emto blogs and Emto social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.

4. With the Emto account owner

If a user requests transportation or places an order using an account owned by another party, we may share their order or trip information, including real-time location data, with the owner of that account. This occurs, for example, when:

• A driver or delivery partner uses an account owned by or associated with an Emto partner transportation company or restaurant

• A consigner takes a trip arranged by a friend or under a Family Profile

• A delivery partner acts as a substitute (UK only)

5. With Emto subsidiaries and affiliates

We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Emto processes and stores data in the India on behalf of its international subsidiaries and affiliates.

6. With Emto service providers and business partners

Emto provides data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:

• Payment processors and facilitators

• Background check and identity verification providers (drivers and delivery partners only)

• Cloud storage providers

• Marketing partners and marketing platform providers, including social media advertising services

• Data analytics providers

• Research partners, including those performing surveys or research projects in partnership with Emto or on Emto’s behalf

• Vendors that assist Emto to enhance the safety and security of its apps

• Consultants, lawyers, accountants, and other professional service providers

• Fleet partners

• Insurance and financing partners

• Airports

• Lime and other local providers

• Vehicle solution vendors or third-party vehicle suppliers

7. For legal reasons or in the event of a dispute

Emto may share users’ personal data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Emto’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. If you use another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card.

This also includes sharing personal data with others in connection with, or during negotiations 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.

8. With consent

Emto may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.

 

Emto retains user profile, transaction, and other personal data for as long as a user maintains their Emto account.

Emto may retain certain user data after receiving an account deletion request if necessary, such as to comply with legal requirements.

Emto retains user profile, transaction, and other information for as long as a user maintains their Emto account. For drivers and delivery partners, Emto also retains vehicle and background check information (to the extent permitted by law) for as long as they maintain their Emto account.

consigners and Consignees may request deletion of their account at any time through the Settings > Privacy menus in the Emto app. Following such requests, Emto deletes the data that it is not required to retain for purposes of regulatory, tax, insurance, litigation, or other legal requirements. For example, Emto retains location, device, and usage data for these purposes for a minimum of 7 years; while it retains such data, it may also use it for purposes of safety, security, fraud prevention and detection, and research and development. In certain circumstances, Emto may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Emto will delete the account as described above.

Emto may also retain certain information if necessary for purposes of safety, security, and fraud prevention. For example, if Emto deactivates a user’s account because of unsafe behavior or security incidents, Emto may retain certain information about that account to prevent that user from opening a new Emto account in the future.

We only collect and use personal data where we have lawful grounds to do so. These include processing user personal data to provide requested services and features, for purposes of Emto’s legitimate interests or those of other parties, to fulfill our legal obligations, or based on consent.

We collect and use personal data only where we have one or more lawful grounds for doing so. Such grounds may vary depending on where our users are located, but generally include processing personal data:

a. To provide requested services and features

In order to provide our services, we must collect and use certain personal data. This includes:

• User profile data, which we use to establish and maintain user accounts; verify user identity; communicate with users about their trips, orders, and accounts; and enable users to make payments or receive earnings

• Background trip information, which is used to verify an applicant’s eligibility to be a driver or delivery partner

• Driver and delivery partner location data, which we use to track trips and assist with navigation

• Usage data, which is necessary to maintain, optimize, and enhance Emto’s services, including to determine incentives, connect consigners and drivers, and calculate costs of trips and driver earnings

• Transaction information
• Information relating to customer support

b. For purposes of the legitimate interests of Emto or other parties

This includes using personal data to maintain and enhance our users’ safety and security. For example, we use personal data to prevent use of our services by users who have engaged in inappropriate or dangerous behavior, such as by retaining data of banned users to prevent their use of Emto’s apps. We also use usage data to prevent matching of consigners and drivers for whom there is higher risk of conflict (for instance, because they have been the subject of prior complaints from other users).

This also includes purposes such as combating fraud; improving our services, direct marketing, research, and development; and enforcing Emto’s Terms of Service.

In addition, it includes using personal data to the extent necessary for the interests of other people or the general public, such as in connection with legal or insurance claims, and to protect the rights and safety of others.

c. To fulfill Emto’s legal obligations

For example, Emto is subject to laws and regulations in many cities and countries that require it to collect and retain data about our users’ trips, and to provide copies of such data to the government or other authorities. We collect and use personal data to comply with such laws.

Emto may also share data with law enforcement regarding criminal acts or threats to public safety, or requests by third parties pursuant to legal processes.

d. With consent

Emto may collect and use personal data based on the user’s consent. For example, we may collect personal data through voluntary surveys. Responses to such surveys are collected on the basis of consent and will be deleted once no longer necessary for the purposes collected.

A user who has provided consent to a collection or use of their personal data can revoke it at any time. However, the user will not be able to use any service or feature that requires collection or use of that personal data.

Emto enables users to access and control the data that Emto collects, including through:

• In-app settings
• Device permissions
• In-app ratings pages
• Marketing opt-outs

Emto also enables users to request access to or copies of their data, changes or updates to their accounts, deletion of their accounts, or that Emto restrict its processing of user personal data.

A. Privacy settings

Settings menus in the Emto app for consigners give them the ability to set or update their location-sharing preferences and their preferences for receiving mobile notifications from Emto. Information about these settings, how to set or change these settings, and the effect of turning off these settings is described below.

• Location data

Emto uses consigners’ device location services to make it easier to get a ride whenever they need one. Location data helps improve our services, including pickups, navigation, and customer support.

consigners may enable or disallow Emto to collect location data from their mobile devices through the Settings > Privacy menus in the Emto app. consigners and Consignees can enable or disallow such collections through the settings on their mobile device.

• Share Live Location (consigners)

consigners who have enabled Emto to collect location data from their mobile device may also enable Emto to share their location with their driver from the time the ride is requested to the start of the trip. This can help improve pickups for both drivers and consigners, particularly in crowded areas.

consigners may enable or disable this feature through the Settings > Privacy menus in the Emto app.

• Emergency Data Sharing (consigners)

consigners who have enabled Emto to collect location data from their mobile device may also enable the Emergency Data Sharing feature that shares data with emergency police, fire, and ambulance services. Such data includes approximate location at the time the emergency call was placed; the car’s make, model, color, and license plate information; the consigner’s name and phone number; pickup and dropoff locations; and the driver’s name.

consigners may enable or disable this feature through the Settings > Privacy menus or the Safety Center in the Emto app.

• Notifications: account and trip updates

Emto provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the Emto app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menus in the Emto app.

• Notifications: discounts and news

Users may enable Emto to send push notifications about discounts and news from Emto. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Emto app.

B. Device permissions

Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. iOS devices notify users the first time the Emto app requests permission to access certain types of data and gives users the option to grant or refuse permission. Android devices notify users of the permissions that the Emto app seeks before their first use of the app, and use of the app constitutes a grant of such permission.

C. Ratings look-up

After every trip, drivers and consigners are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, consigner ratings are available to drivers from whom they request transportation, and driver ratings are available to their consigners.

This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and consigners. consigners can see their average rating in the main menu of the Emto app. Drivers can see their average rating after tapping their profile photo in the Emto Driver app.

Delivery partners are also rated by Consignees.

D. Marketing opt-outs

Users may opt out of receiving promotional emails from Emto. Users may also opt out of receiving emails and other messages from Emto by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for rides or information about their account.

E. User data requests

Emto provides users with a variety of ways to learn about, control, and submit questions and comments about Emto’s handling of their data.

• Accessing data: Users can ask for an explanation of the data we collect from them and how we use it.

• Receiving data: Users can ask for a copy of data that Emto collects from them with their consent or as necessary to provide our services.

• Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Emto’s apps or driver portal. They may also ask that Emto change or update their data, including if they believe such data is inaccurate or incomplete.

• Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the Emto app, or through Emto’s website.

• Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. Emto may continue to process data after such objection or request to the extent required or permitted by law.

In addition, depending on their location, users may have the right to file a complaint relating to Emto’s handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America may submit such requests to the data protection authorities in the country in which they live.

We may occasionally update this notice. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Emto apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. After such notice, use of our services by users in countries outside the European Union will be understood as consent to the updates to the extent permitted by law.