Last updated: September 5, 2021
This policy describes how GoTo Global Mobility Ltd. and/or its subsidiaries, controlling companies as well as other companies controlled by them and/or companies related to any of the aforementioned (collectively shall hereinafter be referred to as “GoTo”, “the Company” and/or “we”) uses the personal data collected as part of its various services (hereinafter “the services”), in respect of the following data subjects:
1. Users registering to the Company’s services, whether they registered themselves or registered for an organization on behalf of which they use the services, including additional persons about which the data is provided during the registration and/or order process and/or who use the Company’s services.
2. Persons visiting the website and the digital assets, customers and potential users, business partners, suppliers, participants in marketing campaigns or in our physical events, and any person who uses and/or interacts with the websites, applications and other GoTo electronic interfaces, including advertisements and online content, email, social networks, registration interfaces (application/webs), our digital assets or other communication under our control (hereinafter: “GoTo websites”).
You are not legally obligated to provide us personal information, and its provision is entirely your decision. If you do not want to provide us personal information, or you object to GoTo (including service providers on its behalf) processing personal information pertaining to you, please refrain from using the services (including by way of registration, browsing GoTo websites or any other use). If you would like to retract your consent to the stated policy, please contact us at: firstname.lastname@example.org.
This policy refers to all genders, and is worded in the masculine solely for the sake of convenience.
Types of Data we Collect
1. Data about users: The services enable users to order rides, private or business. To this end, GoTo collects and processes personal data about private and business users (including representatives on their behalf, for example in the case of a business customer), inter alia as detailed below:
A. User profile: name, email address, mobile and/or other telephone number, home and/or business address, and if needed also personal password.
B. Business information (if relevant): company name, industry, account classification, commercial terms.
C. Details of orders, rides and accompanying transactions: orders, pick-up and return details of all vehicles, ride route, GPS-based location, information about a search that did not materialize, contact details, payment method, invoices, documentation of prior transactions, definitions of a ride using toll roads, use of a parking application (Pango, Cellopark, etc.), traffic tickets, fines, etc., as well as any other information that the user and/or any person on their behalf chose to provide.
D. Ratings and feedback provided by the user and/or the driver and/or any person on their behalf regarding the service experience and/or any part thereof, including registration, placing an order, the ride, the service, etc., and any other feedback that may be provided in their regard.
E. Information about the service mode of use: technical usage data and activity logs, including trends and subscriber preferences, connecting and disconnecting times from the service, IP address and connectivity data, device data and application data (e.g., type, operating system, application detector, advertisement detector, application version, browser version, location, time zone and language definitions), logs of connection and activity as part of the services, as well as cookie files and pixels installed or used in respect of said device.
F. Inquiries and communication with us: conversation details and content (written or recorded) and correspondence provided us verbally, through online forms, email, mail and/or chats with various GoTo departments (e.g., Customer Service, Finance, etc.).
2. Information about visitors to GoTo websites, customers and potential users, business partners, suppliers, participants in marketing campaigns and in our physical events and any person who interacts with GoTo websites and applications:
A. Information about the mode of use of GoTo websites: technical usage data and activity logs, connecting and disconnecting times from the service, IP address and connectivity data, device data and application data ( e.g., type, operating system, application detector, advertisement detector, application version, browser version, location, time zone and language definitions), logs of connection and activity as part of the services, as well as cookie files and pixels installed or used in respect of said device;
B. Business data: contact information (e.g., name, contact details, organization and positon), and information relating to agreements and payments with our customers/ potential users, suppliers and business partners, which may also include details of main contact persons who contract with us directly or indirectly using their name, such as the account managers and authorized signatories on behalf of the customer or the partner; as well as the needs and preferences of the customer or the relevant business partners, as provided us or as identified as part of our engagement with them;
C. Inquiries and communication with us: conversation details and content (written or recorded) and correspondence provided us verbally, through online forms, email, mail and/or chats with various GoTo departments (e.g., Customer Service, Finance, etc.).
3. We collect said information directly from the data subjects and/or following their interaction with and use of our services or GoTo websites; By means of third parties (e.g., suppliers and business partners); by means of linking the user’s account of GoTo services to the same user’s accounts on social networks; and in respect of events and activities we organize or take part in as well as various business initiatives.
Should the information mentioned in this clause not pertain to a certain individual (e.g., telephone number or bank account of company or business), we will not treat it as personal data and the stated in this policy shall not apply to them.
A. Provide the services, including accompanying services, inclusive of, inter alia, contacting the user or a potential customer in order to provide the aforesaid.
B. Endorse traffic fines, parking, handle payments to toll roads and fast lanes, pay parking using an application (e.g., Pango, Cellopark, etc.), endorse payment to parking garages and any monetary obligation to any third party created in the course of using GoTo services. As well as to provide a response, support and service to customers in general. It is hereby clarified that the aforesaid does not impose on GoTo the obligation to execute any payment instead of the user and it shall act at its sole discretion and subject to the provisions of the agreement with the user.
C. Verify the identity of our customers, the users and the drivers to enable them access to and use of the services;
D. Gain insights related to use of GoTo services and websites, so that we can enhance and improve our services and other activities;
E. Analyze areas of interest, browsing habits, conduct research, examine and improve service, as well as for advertising and marketing needs (including the provision of information to third parties).
F. Engage by means of general and/or personalized messages regarding our services and/or by means of marketing messages;
G. Organize and/or support various events and activities;
H. Data security and to protect our business activity, including in order to prevent or mitigate the risk of fraud or deceit, or any other prohibited or illegal activity;
I. Create aggregate statistical data, derived non-personal data or data processed such that it is unidentifiable or cannot be connected to an identified person, which we or our business partners may use in order to provide and improve our services or for any other similar purpose;
J. Personalize the advertisement of services and/or products and offer then to every user and their areas of interest;
K. Facilitate placing orders in the future on GoTo websites, including contacting users if needed;
L. Provide updates regarding special offerings and promotions, pursuant to your right not to receive advertising information as described below and in compliance with applicable laws and regulations, or any other legal matter, such as enforcing local policy rules, handling damage suits with third parties including insurance companies, responding to suits and/or protecting the rights, property and/or safety of others.
M. Offer the user information about activities of the Company and/or other entities that appear on GoTo websites.
It is hereby clarified that collection of the data and it uses for the aforementioned purposes, all or in part, shall be at the Company’s sole discretion, as may be determined from time to time.
5. A user or potential user who provided information to the Company when using GoTo websites consents to have offers and/or information regarding the activities of the Company and other entities related to the Company and/ or business partners sent from time to time via email and/or other means of communication, whether by the Company or by a third party, such that this constitutes consent to send advertising materials according to Section 30A of the Communications Law (Telecommunications and Broadcasting), 5742-1982. It goes without saying that any user at any time may request to remove their data and accordingly the user shall no longer receive said material, among other things by clicking on the link for removal from the distribution list displayed at the bottom of the messages sent to them.
Data Sharing with Third Parties
6. The user’s data shall not be transferred to third parties except in the following cases:
A. If the user provided their details in order to receive additional information from one of the entities that appear on GoTo websites, in which case the user’s information shall only be transferred to this entity.
B. If the user uses links and referrals to other websites (if any) that appear on any of the GoTo websites. In this regard it is hereby clarified that:
B.2. It is hereby clarified that the Company is not responsible and does not assume any type of responsibility with respect to the provision of information by the user and/or any person on their behalf to any third parties. Provision of said information is the sole responsibility of the user.
D. We may disclose or permit access to personal data, or grant enforcement or regulatory authorities said access. These measures shall be taken if we believe in good faith that this is what we are compelled to do pursuant to a court order (e.g. a search warrant or any other legal order issued by an authorized authority), by virtue of the law, and/or for the prevention or cessation of illegal actions or other wrongdoing (whether these actually occurred or there is concern that they may occur) and/or due to concern that damage may be caused to us and/or to someone on our behalf.
F. The Company engages the services of various service providers, including, inter alia, services for data storage, providing content, clearing and online payments, customer management, surveys, data monitoring and analysis, data security, detecting and preventing fraud, email, sending text messages and alerts, social media and advertising, recording and analysis of conversations, activities and correspondence, external sales call center, as well as the service of our legal counsels, financial and business consultants, and our compliance consultants (collectively: “service providers”). The service providers may receive access to your personal data, according to their function, the service they provide and the specific purpose for which the Company contracted with them, and they will be permitted to use this personal data exclusively for these purposes. In these cases, the Company shall enter into agreements with them as required by law. For the avoidance of doubt, the abovementioned list of service providers is not an exhaustive and final list, and there may be additional service providers as may be decided from time to time, at the Company’s sole discretion.
G. The data may be transferred to additional entities for the purpose of research, analyzing browsing habits, statistics, as well as for advertising, marketing, service improvement and additional business uses in accordance with the aforementioned purposes, and this at the Company’s sole discretion.
H. The Company may share your personal data with others if we believe in good faith that we must do so in order to protect the rights, property and security of GoTo, our employees, service providers, customers, users, drivers or any other individual or entity.
For the avoidance of doubt, GoTo may share your personal data in additional ways, subject to your agreement, or if we will be legally obligated to do so, or if we rendered said data anonymous/statistical that no longer pertains to you. We may transfer, share or use non-personal data for any other purpose at our sole discretion and without the need to obtain additional approval.
7. A “Cookie” file is a small text file that is used, for example, to collect and retrieve data about activity conducted on GoTo websites. Certain “Cookie” files are removed when you close the browser (these are known as “session files”) while other files remain for longer periods of time (these are known as “persistent files”). We use both types.
Providing Data to Additional Entities
10. It is hereby clarified that the Company is not responsible and does not assume any type of responsibility with respect to the provision of information by the user to any third parties. Provision of said information is the sole responsibility of the user.
Advertisements and Links to Third Parties
11. The Company reserves the right to permit third parties to add advertisements and/or notifications and/or banners and/or any other link, at its sole discretion. The Company and GoTo websites are not responsible for the content of the notifications, banners or any other advertising material on GoTo websites.
Right to Review the Data
13. In accordance with and subject to the provisions of the law in the matter, every user shall be entitled to review the information held by the Company. A user who reviewed the data about them and found that it is incomplete, unclear or not updated, may request that the Company correct or update the data and the Company may accept said request in full or in part at its sole discretion, in accordance with the law. The Company shall not be responsible for the data held by third parties and the user shall not have any claim and/or demand and/or suit against the Company in this matter.
14. Should the data be used to personally contact the user by direct mail, the user shall be entitled, subject to the provisions of any law, to demand in writing that the data pertaining to them shall be deleted from the Company’s records. In this case the data that will be deleted will only be the data which the Company needs in order to contact the user to send commercial offers. Information which the Company needs in order to manage its business, including for current or potential litigation, inclusive of documenting actions the user performed on the website, shall be saved by the Company at its sole discretion.
15. The Company takes measures to secure the data collected on the website, including the data processing system, infrastructures and means of communication, from environmental risks and damage, by means of suitable technological and organizational security measures, in accordance with the sensitivity level of the data collected. These systems are operated in order to mitigate the possibility of unauthorized infiltration, however they do not provide absolute security. Accordingly, the Company does not guarantee that use of the website will be absolutely immune to unauthorized access, and the user waives any claim and/or demand and/or suit in respect of any data security breach.
16. Any information provided by the user through the website, whether when registering to receive a price offer, or when requesting to receive information, by means of products and/or any other service of the website, shall be provided voluntarily and with the full agreement of the website user and shall constitute clear and explicit agreement according to Sections 11 and 17 of the Protection of Privacy Law, 5741 – 1981, and to Section 30A of the Communications Law (Telecommunications and Broadcasting), 5742-1982.