I. Introduction

 

When you use Seago, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this carefully.

II. Overview

 

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

This notice describes how Seago and its affiliates collect and use data. This notice applies to all Seago users globally. This notice specifically applies to: Riders: individuals who request or receive transport and related services via their Seago account. Drivers: individuals who provide transport to Riders individually or through partner transport companies. This notice also governs Seago’s other collections of data in connection with its services. All those subject to this notice are referred to as “users” in this notice. Our privacy 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.

B. Data controller and transfer

SEAGO SERVICES P.C. is the data controller for the data collected in connection with use of Seago’s services in Greece.

SEAGO SERVICES P.C. (Pindarou 0, Agios Nikolaos Anavyssou, 19013) is the data controller for the data collected in connection with use of Seago’s services in Greece.

Seago operates, and processes personal data, globally; wherever and whenever you travel, your data travels with you so we can offer you a seamless experience. We also respect your data protection rights whether you are in your home country or elsewhere.

This means that we may transfer personal data to countries other than your home country in order to provide our services in a different country at your request. We may also transfer personal data to another country if that is necessary to respond to a customer support request that you submitted outside your region. And trip/order histories may be accessed by users in another country after they have left the country where services were rendered. Because our services involve multiple users at the same time, limited personal data may be accessible to the other user in another country.

We do so in order to fulfill our agreements with all our users, or based on users’ instructions or prior consent, adequacy decisions for the relevant countries or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

We may also transfer data to other countries in order to respond to a request for personal data from a law enforcement agency. To provide additional safeguards to these data transfers, Seago applies a robust internal procedure for processing these requests. Seago only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the GDPR.

To help provide equivalent data protection wherever you use our services, Seago has implemented the following measures across the globe:

• policies and procedures to limit access to, and the processing of, personal data for defined purposes;
• specific training of personnel responsible for managing personal data;
• a government data access policy that refuses government access to data, except when disclosure is mandated by applicable laws including the EU GDPR, there is imminent risk of serious harm to individuals or consent is obtained;
• robust protection of data while it is in transit between Seago apps and our servers, and when the data is processed on our servers. This includes encryption and the use of pseudonymised data to help protect users’ full identity against unauthorised disclosure.

III. Data collections and uses

 

A. The data we collect Seago collects data: provided by users to Seago, such as during account creation created during use of our services, such as location, app usage and device data from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers and governmental authorities.

Seago collects the following data: 1. Data provided by users. This includes: User profile information: We collect data when users create or update their Seago accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driving licence and other government-issued documents (which may include identification numbers as well as date of birth, gender and photo). This also includes rib boats or insurance information of drivers, emergency contact information, user settings and evidence of health or fitness to provide services using Seago apps. Enhanced background check information (drivers): This includes information submitted during the driver sign up process, such as driver history or criminal record (where permitted by law), licence status, known aliases, prior addresses and right to work. This information may be collected by an authorised vendor on Seago’s behalf. Identity verification photos: This includes photos of users (such as selfies) and/or their government-issued identifications (such as driving licences or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies. Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification. Demographic data: We may collect demographic data about users, such as date of birth/age, gender or occupation, when required for certain Seago services or programmes.We may also infer demographic data from other data collected from users. We may also collect demographic data through user surveys. 2. Data created during use of our services. This includes: Location data (driver): We collect precise or approximate location data from drivers’ mobile devices when the Seago app is running in the foreground (app open and on-screen) or background (app open but not on-screen). Location data (riders). We collect precise or approximate location information from riders’ and order recipients’ mobile devices if they enable us to do so via their device settings.Seago collects such data from the time a trip is requested until it is finished, and any time the app is running in the foreground (app open and on-screen). See “Choice and transparency” below for information on how riders can enable precise location data collection. Riders may use the Seago app without enabling collection of location data from their mobile devices. However, this may affect certain features in the Seago app. For example, a rider who has not enabled precise location data will have to manually enter their pick-up address. In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as 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; trip (such as date and time, requested pick-up and drop-off addresses, distance travelled); and payment transaction information (such as a merchant’s name and location, amount charged and payment method). We also associate a user’s name with that of anyone who uses their promotion code. Usage data: We collect data on how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, app crashes and other system activity. Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data and mobile network data. Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Seago’s apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded. 3. Data from other sources. These include: users participating in our referral programmes. For example, when a user refers another person, we receive the referred person’s data from that user. users or others providing information in connection with claims or disputes. Seago business partners through which users create or access their Seago account, such as payment providers, social media services, or apps or websites that use Seago’s APIs or whose APIs Seago uses. Seago business partners in connection with debit or credit cards issued by a financial institution in partnership with Seago to the extent disclosed in the terms and conditions for the card. vendors who help us verify users’ identity, background information and eligibility to work, or who screen users in connection with sanctions, anti-money laundering or know-your-customer requirements. insurance, rib boats or financial services providers for drivers. partner transport companies (for drivers who use our services through an account associated with such a company). publicly available sources. marketing service providers or data resellers whose data Seago uses for marketing or research. law enforcement officials, public health officials and other government authorities.

B. How we use personal data

Seago uses data to enable reliable and convenient transport and other products and services. We also use such data:

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

 

We use the data we collect:

1. To provide our services. Seago uses data to provide, personalise, maintain and improve our services.

This includes using data to:

• create/update accounts.
• enable transport and other services/features, such as:

• using location data to navigate rider pick-ups, calculate ETAs and track the progress of rides.
• features that involve data sharing, such as sharing a driver’s first name and rib information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and user ratings and compliments.
• match available drivers to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to confirm a trip based on their past behaviour or preferences.

• enable dynamic pricing, in which the price of a trip is determined based on factors such as estimated time and distance, predicted route and the current number of users requesting or providing services.
• process payments.
• provide users with trip update, generate receipts and inform them of changes to our terms, services or policies.
• perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.Seago performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, are compatible with such uses, or on the grounds that they are necessary for purposes of Seago’s and its users’ legitimate interests.

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

• verifying users’ identity and eligibility to provide transport, including through reviews of enhanced background checks, to help prevent use of our services by unsafe drivers and/or riders.In addition, we may use facial recognition technology to process user profile photographs, identification photographs or other user-submitted photographs to prevent identity borrowing or use of our services by unauthorised drivers or riders.
• using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pick-up in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee.
• using device, location, user profile, usage and other data to prevent, detect and combat other types of fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorised drivers, verifying user identities in connection with certain payment methods, and preventing and combating unauthorised access to users’ accounts. In some cases, such as when a user is determined to be abusing Seago’s referral programme or has submitted fraudulent documents, such behaviour may result in automatic deactivation, or in the European Union or where otherwise required by law.

Seago performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Seago, our users and members of the general public.

3. Customer support. Seago uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

Seago performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users or for purposes of Seago’s legitimate interest in monitoring and improving its customer support services.

4. Research and development. We use data for testing, research, analysis, product development and machine learning to improve the user experience. This helps us make our services more convenient and easier to use, enhance the safety and security of our services and develop new services and features.

Seago performs the above activities on the grounds that they are necessary for purposes of Seago’s legitimate interests in improving and developing new services and features.

5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item.

Seago performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users.

6. Marketing and Advertising.Seago uses data (other than Guest Users’ data) to market its services and those of Seago partners. This may include:

• Sending emails, text messages, push notifications and in-app messages or other communications marketing or advertising, services, features, offers, promotions, sweepstakes, news and events.This may include using location, trip, and usage data to send marketing communications that are personalised based on users’ observed or inferred interests and characteristics. For example, we may send push notifications suggesting a user’s favourite destinations, or in-app messages offering discounts or promos for products or destinations similar to those a user has previously visited.
• Displaying Seago advertising on third-party apps or websites. This includes using location, trip, and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners (such as Facebook, Instagram and TikTok), to personalise such ads to users’ interests.
• Measuring the effectiveness of Seago’s ads, and of third-party ads displayed in Seago’s apps or in connection with our services.Seago performs the above activities on the grounds that they are necessary for purposes of Seago’s legitimate interests in informing users of Seago services and features or those offered by Seago partners. See the sections titled “Choice and transparency” and “Marketing and advertising choices” for information on your choices regarding how Seago may use your data for marketing and advertising.

7. Non-marketing communications. Seago may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Seago or its partners.

Seago performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, or for purposes of Seago’s and its users’ legitimate interests in informing users of events that may have an impact on their use of Seago services.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Seago’s services, to satisfy requirements under applicable laws, regulations, or operating licences or agreements, or pursuant to legal process or governmental request, including from law enforcement.

Seago performs the above activities on the grounds that they are necessary for purposes of Seago’s legitimate interests in investigating and responding to claims and disputes relating to use of Seago’s services and features, and/or necessary for compliance with applicable legal requirements.

D. Data sharing and disclosure

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

Seago may share data:

1. With other users

This includes sharing:

• riders’ first name, rating, and pick-up and/or drop-off locations with drivers..
• for drivers, we may share data with the rider(s), including name and photo; rib boat make, model, colour, identification number and rib boat photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver; contact information; and driver profile, including compliments and other feedback submitted by past users.We also provide riders with analysis containing information such as a breakdown of amounts charged, driver’s first name, photo and route map.
• for those who participate in Seago’s referral programme, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral reward.

2. At the user’s request

This includes sharing data with:

• Emergency services: We offer features that enable users to share their data with police, coast guard, fire and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.

3. With the general public

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

4. With Seago service providers and business partners

These include:

• payment processors and facilitators
• enhanced background check and identity verification providers
• cloud storage providers
• Apple and Google, in connection with the use of Google Maps and Apple Maps in Seago’s apps.
• social media companies, including Facebook and TikTok, in connection with Seago’s use of their tools in Seago’s apps and websites (see Facebook’s privacy policy and TikTok’s privacy policy for information on their collection and use of data)
• research partners, including those performing surveys or research projects in partnership with Seago or on Seago’s behalf
• vendors that assist Seago to enhance the safety and security of Seago apps and services
• consultants, lawyers, accountants and other professional service providers
• insurance and financing partners
• airports
• third-party rib suppliers, including fleet and rental partners

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

Seago may share users’ data if we believe it’s required by applicable law, regulation, operating licence or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.

This includes sharing 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 Seago’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. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your data, including trip or order information, with the owner of that credit card.

This also includes sharing 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.

6. With consent

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

C. Cookies and third-party technologies

Seago 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. Seago 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
• analysing site traffic and trends, and generally understanding the online behaviours 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.

E. Data retention and deletion

Seago retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations.

Seago retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates and the purposes for which we collected the data.

The length for which Seago retains user data may further be determined by legal and regulatory requirements, purposes of safety, security and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

For example, we retain data:

• for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
• after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).

Users may request deletion of their accounts at any time. Seago may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

Users may request deletion of their account at any time through Seago’s website contact form.

Following an account deletion request, Seago deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements; for purposes of safety, security and fraud prevention; or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

IV. Choice and transparency

 

Seago enables users to access and/or control data that Seago collects, including through: device permissions in-app ratings pages Seago also enables users to make changes or updates to their accounts, request deletion of their accounts or request that Seago restrict its processing of user data.

Α. 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. Please check the available settings on your device or check with your provider. Β. In-app ratings pages After every trip, drivers and riders 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, rider ratings are available to drivers from whom they request transport, and driver ratings are available to their riders. This 2-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for drivers and riders. Riders can see their average rating in the main menu of the Seago app. Drivers can see their average rating after accessing their profile in the Seago Driver app.

V. Updates to this notice

 

We may occasionally update this notice.

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Seago apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.