PRIVACY NOTICE

This Privacy Notice (“Notice”) sets out how Osa Travel Management B.V., a company located in the Netherlands, (collectively referred to in this document as “Company”, “Dispo” “we” “our” or “us”) protects the privacy of your personal information. If you’re interested in what we do with cookies and similar technologies, please check out our Cookie Statement.

We may change this Notice from time to time; so please check back here for any updates.

We offer a range of services related to online ground transportation, including products and services through our own websites, mobile apps, emails and text messages (‘platforms’). We also do this through our business partners’ websites, social media and other platforms. This Notice applies to all the personal information we collect while we provide these services, or when you contact us by email, live chat, phone or post.

Our business partners should also visit our Privacy and Cookie Statement for Business Partners to understand how personal information is processed as part of our business relationship.

PERSONAL INFORMATION

“Personal information” means information that identifies you or could reasonably be used to identify you and which is submitted to and/or collected and maintained by Us when you make a booking. Examples of personal information include your name, your postal address and your telephone number.

When you make a Booking through our website, you will be required to provide us with certain information to help us deliver an express service to you. This information we collect may include your name, age, date and place of birth and contact details (email, address and phone number).

In addition, we collect information from your computer when you use one of our platforms, even if you don’t make a booking. This may include your IP address, the browser, and your language settings. There are also situations where we receive information about you from third parties, or automatically collect other information. This is a basic overview of the information we collect. Would you like to know more?

PERSONAL INFORMATION YOU GIVE US

We store and use the information that you give us. When you make a booking, we need at least your name, email address, phone number, pick up and drop off address and payment information. We might also ask for your home address, flight number and date of birth, and the names of any additional passengers.

We will also collect information from you if you contact us (by phone, by email or through social media, for example).

After a Booking, we may request you to provide a review, comments regarding your experience to help us improve our services, and to help ensure future customers get exactly what they’re looking for.

There are also other ways you might give us information. For example, if you’re browsing with your mobile device, you can share your current location with us, so we can provide you with the best possible service. To make things easier, you can also open a user account, which lets you review and manage your bookings, as well as saving your personal settings. It also makes it easier to make future bookings.

Personal information You Give Us About Others

You might add someone as an additional passenger, or you might make a booking on behalf of someone else, for example, a friend, family member or colleague. If you do, please make sure that the person knows you’re giving us their details, and has accepted the way we handle their personal information (as described in this Notice). This is your responsibility.

PERSONAL INFORMATION WE COLLECT AUTOMATICALLY

When you make a booking, we record what platform you made it on, and how you got to our platform (if you came through from another site, for example).

Even if you don’t end up making a booking, we may automatically collect some information when you visit our platforms. This may include your IP address, which pages you’ve visited, which browser you’re using, and information about clicks. It might also include information about your computer’s operating system, its application version, language settings, device-specific setting and characteristics, and data that identifies your device.

If you’re using a mobile device, we might also collect location details. And we might analyze and process basic data related to the apps installed on it (e.g. name, description and category).

PERSONAL INFORMATION WE GET FROM THIRD PARTIES

We may also collect certain information about you from social media platforms, our business partners, subsidiaries of the Dispo corporate family, affiliates of the Osa Travel Management B.V. and other third parties. For example:

We work with affiliate business partners to offer our services on other platforms. When you make a booking on any of our platforms, we may share your personal information with them, and they may share your personal information with us.
The Transport Service Provider that provide the services you have booked through our platforms may need to send us information regarding your booking – for example, if your booking leads to a customer service dispute.
Our business partners may also send us information about you that may help us provide you with promotional information and advertisements.
We may combine any of this information with the information you give us directly.

WHY DO WE COLLECT AND USE YOUR PERSONAL INFORMATION?

a. We ask for your personal information to enable us book your ground transportation (and anything else you need for your booking),
b. We also use the personal information sure you get the best experience when you use our service.
c. We also use it to contact you, and to tell you about our latest deals and special offers.
d. To tailor our service to your needs.
e. To provide answers to your questions and help you with any needed support
These are the main reasons we collect your personal information, but there are other reasons too. Would you like to know more?

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information in the following ways:

a. Bookings: We use your personal information to make and administer your booking, and to forward the necessary details to the company that provides your ground transportation (or other product or service), and the driver providing the Ride. This includes sending you communications in relation to your booking, such as confirmations, modifications and reminders.

b. Customer service: We provide you with Customer support. Our customer service teams need your details so they can help you make a booking, for example, or to reply to any queries you may have before, during or after your booking.

c. Customer reviews: We may use your contact details to send you a short questionnaire about your booking. This helps us understand and improve our service and the service our business partners provide.

d. Account facilities: To make things easier, you can create a user account on our platforms. This involves giving us your personal information, and it lets you do a number of useful things. You can manage your bookings or other purchases, take advantage of special offers, and manage your personal settings and preferences. It also makes it easier to make future bookings.

e. Promotional activities: We also use your personal information for marketing activities, which may include:

i. Contacting you by phone, email or SMS (depending on the contact details you give us) with our latest news, special offers, discounts and updates, including details of our products and services (and/or those of our group companies or affiliate business partners). You can unsubscribe from these marketing communications quickly, easily and at any time – just click the “unsubscribe” link in any email or other communication, or visit our Data Subject Request Portal.
ii. Contacting you by phone, email or SMS with information about products that you didn’t include in your booking.
iii. Showing you relevant offers on our platforms or on third-party websites, including social media sites.
iv. Inviting you to participate in promotional activities (such as referral programs or competitions).

f. Communicating with you: There may be other times when we contact you by phone, email or SMS. There could be a number of reasons for this, including:
i. Responding to, and handling any requests you have made.
ii. Emailing you a reminder about a booking you didn’t finalize, to see if you need any help to do so. We see this as a useful additional service because it lets you carry on with a booking without having to find the ground transportation again or fill in all the booking details from scratch.
iii. Sending you a questionnaire or inviting you to review your experience.
iv. Sending you other material related to your booking, such as how to contact us (or another company) if you need help during your booking.
v. Sending you a summary of your previous bookings.
vi. Sending you other administrative messages, which may include tips, security alerts, even if you don’t have upcoming bookings.
g. Market research: We may ask you to take part in market research. Any additional personal information that you give us as part of this research will be used only with your consent.

h. Fraud detection and prevention: To provide a safe, trustworthy service, we use your personal information to detect and prevent fraud and other illegal or unwanted activities. Similarly, we may use personal information for risk assessment and security purposes, which can include verifying users and bookings. This can sometimes mean we may have to put certain bookings on hold.

i. Improving our services: We analyze personal information to help us improve the functionality and quality of our online services, and enhance the whole user experience. We’re always working to make our platforms easier and more enjoyable for you to use.

j. Customer reviews: After your booking, we may invite you to review the services that we or our business partner provided. Your review will help future customers make the right choice, and help our business partners improve the services they offer. By submitting a review, you are agreeing that it can be displayed, as explained in our Terms and Conditions. You can make a review anonymously or simply put your first name and country location.

k. Call monitoring: We may record phone calls and/or allow other staff to listen in to them, to help us train our colleagues and make sure we’re consistently providing a top-quality service. We automatically delete recordings after a specified time, unless we have a legitimate reason not to (if we think there’s evidence of fraud, for example).

l. Legal purposes: Finally, in certain cases, we may need to use your personal information to handle and resolve legal disputes, for regulatory investigations, for compliance reasons, or to make sure we apply our terms and conditions accurately

To process your personal information like this, we rely on the following legal grounds:

Performance of a contract: We need to use your personal information to fulfill any contract you’ve made with us. For example, when you book ground transportation, we need to transfer your booking details to the ground transportation company and the driver providing the Ride, to make sure your ground transportation is waiting for you.

Legitimate interests: We may use your information for our ‘legitimate interests’ (a term which applies to anything we believe is an essential part of carrying out our business effectively – at the same time as respecting your rights and upholding the law). For example, to provide you with the most suitable content on our platforms, including our emails and newsletters; to improve and promote our products and services; and for administrative purposes.

Consent: We may rely on your consent to use your personal information in certain circumstances, for example direct marketing purposes. You may withdraw your consent at any time via our Data Subject Request Portal or by emailing support@dispo.travel, stating “Privacy” in the subject line.

HOW WE DISCLOSE YOUR INFORMATION.

There are a number of different business partners integrated in the services we provide, and in certain situations we may share your personal information with them. In most cases, we’re simply passing on your booking details to the business partners that are helping us deliver the service you’re requesting. We will also share your data with other third parties, which may include payment processors, advertising partners, subsidiaries of the Dispo corporate family and affiliates of the Osa Travel Management B.V., and – in some cases – the authorities. These are the main reasons we would share your personal information. Would you like to know more?

WHAT THIRD PARTIES DO WE SHARE YOUR PERSONAL INFORMATION WITH – AND WHY?

Transport Service Providers: The Transport Service Providers responsible for providing you with ground transportation and/or related products and services: To fulfill your booking, we need to send the relevant details to the Transport Service Providers supplying the ground transportation and/or other related products that you have requested. These details may include your name, age range, contact details (email, address and phone number), date and place of birth, flight number, pick up and drop off address and any preferences you told us about while booking. If there is a dispute about your booking, or any other kind of customer service issue, we may need to provide the Transport Service Providers with some information about the booking process as well as the dispute that may arise in connection with the booking. This may include a copy of your booking confirmation, to prove that a booking was actually made, as well as any information related to your complaint. Please note that any information you provide directly to the Transport Service Providers supplying your ground transportation and/or related products will be stored and used in accordance with their own privacy notice(s) and terms and conditions.

Our business partners: We work with business partners around the world. Some of our partners offer or advertise our services, as well as helping our other business partners offer and advertise their own travel-related services. These business partners may also include the Osa Travel Management B.V. other projects, which includes OriginalTransfers.com and OsaBus.com, and our sister companies (AroundLatvia.com, RigaTransfers24.com). This may mean that their services are integrated into our platforms. When you make a booking on one of our business partners’ platforms, they’ll send us some of the personal information you have provided to them. Similarly, we may send our business partners some of the personal information related to your booking. This could be to help them analyze their business, for example, or to help them run their loyalty programs. It could also be so that they can send you things like special offers, but only if you’ve given your consent for this. If the business partner provides customer service support, we will send them the details of your booking that they need to give you the support you need. In any of these cases, the handling of your personal information is governed by the privacy notices of these business partners. When you make a booking on a business partner’s website, please take the time to read their privacy notice to see how they handle your personal information. When you buy a product or service provided by one of our business partners, we will send them the personal information they need to provide it. Finally, we may also exchange information about our users with business partners for fraud detection/prevention purposes, but only as strictly necessary.

The Osa Travel Management B.V.: Please read here how we may share your personal information with the Osa Travel Management B.V. sister companies.

Competent authorities: We may share your personal information with government or investigative authorities if we’re required to do so by law (or any regulation having the force of law). This includes court orders, subpoenas and orders arising from legal processes and criminal investigations. We may also disclose your personal information if strictly necessary for the prevention, detection or prosecution of fraud and other criminal acts. And we may need to disclose personal information to competent authorities to protect and defend our rights or properties, or the rights or properties of our business partners.

Third-party service providers: We may use third-party service providers to process your personal information on our behalf and support us in providing our services. For example, we may use them to contact you, or to send booking information on our behalf to the company providing the service, or to manage aspects of our site, call centers or marketing activities. We may also use third-party service providers for market research and fraud detection and prevention services, including anti-fraud screening services. These third parties are bound by confidentiality clauses and are not allowed to use your personal information for other purposes.

Advertising partners: We may share your email address and other personal information with third-party advertising partners, so we can make sure you see relevant advertisements when we market our services via third-party business partners. We also work with third-party advertisement networks to market services on other platforms, and with third-party suppliers who help us analyze our own data. All these third parties will be bound by confidentiality agreements and will not be allowed to use your personal information for any other purposes. For more information on personalized advertisements and your choices: in our Cookie Statement.

Payment processors and other financial institutions: We also work with third-party payment processors to arrange payment or payment guarantees. If you (or the holder of the bank card used to make your booking) request a charge-back, we may need to share certain booking details with the payment processor and the relevant financial institution. This may include a copy of your booking confirmation or the IP address used to make your booking. We may also share information with relevant financial institutions, if we consider it necessary for fraud detection and prevention purposes.

HOW DO WE MAKE USE OF MOBILE DEVICES?

We offer free apps for a range of mobile devices, as well as versions of our regular website that have been optimized for mobile and tablet browsing. They collect and process your personal information in much the same way as our other platforms do, and they also allow you to find local ground transportation based on your current location. Would you like to know more?

HOW DO WE MAKE USE OF MOBILE DEVICES?
If you agree to it, we can send ‘push’ notifications straight to your mobile device, so you don’t miss important information about your booking. And, if you let us access your device’s location or contact details, we can provide extra services if you request them. Your mobile device will have instructions on allowing push notifications and giving us access to this kind of data.

To give you a better service and more relevant marketing, we may use something known as ‘cross-device tracking’. This just means we look at the way you use our platforms on more than one device: we could, for example, combine data from your mobile phone and your home computer. This is something we may or may not use cookies for (for more on cookies and similar technologies, please see our Cookie Statement).

To make sure you find deals that are more likely to interest you in our newsletter, we look at the searches you make and the services you book on multiple devices once you’ve signed in to your user account. If you don’t want us to do this, just sign out before you browse, or unsubscribe from our newsletter.

Cross-device tracking can also mean that when you’re using one device, you may see personalized advertisements from lots of different companies, based on your activities on linked devices. The NAI (Network Advertising Initiative) should stop this happening if you opt out of the NAI behavioral advertising program (our Cookie Statement gives you the link you need, under “It’s your choice: Opting in and opting out”). Please note: simply signing out of your user account won’t stop this happening.

WHAT SECURITY PROCEDURES DO WE PUT IN PLACE TO SAFEGUARD YOUR PERSONAL INFORMATION?

Our business systems and procedures ensure we take all reasonable steps to protect your personal information and safeguard it against any misuse or unauthorized access, in accordance with Estonian and European data protection laws. We also have specific security procedures and restrictions (both technical and physical) that limit access to, and use of, any personal information that we hold. Only authorized personnel can access personal information – and they’re only allowed to do it for specific, authorized reasons.

HOW DO WE TREAT THE PERSONAL INFORMATION OF CHILDREN?

We don’t direct our services to children under the age of 16. For children younger than 16 years old, the use of any of our services is only allowed if accompanied by a parent or a guardian. We may receive information about children in certain situations, for example as part of a booking or in relation to a customer service dispute. If that happens, we will only collect and use that information with the consent of the child’s parent or guardian. We reserve the right to delete any information we may receive from a child under this age or without the valid consent of a parent or guardian.

HOW CAN YOU CONTROL THE PERSONAL INFORMATION YOU HAVE GIVEN US?

You have the right, subject to some legal exceptions, to access, correct or delete any personal information we keep about you, and to object to your personal information being processed. You can use our Data Subject Access Portal to enforce any of these rights. If you do, we will ask for further information to confirm your identity, to keep your information safe and we will handle your request in accordance with applicable Estonian data protection law. You can update or delete your user account at any time by signing in on our site.

When you make a booking or request a quote, we ask whether you’d like to opt in to receive marketing emails. You can opt out at any time by clicking “unsubscribe” in any of these marketing emails, or by updating your email preferences in your user account.

WHO IS RESPONSIBLE FOR THE PROCESSING OF PERSONAL INFORMATION ON OUR PLATFORMS?

Osa Travel Management B.V. (trading as Dispo) controls the processing of personal information on its platforms. Osa Travel Management B.V. is a private limited liability company, incorporated under the laws of Netherlands. If you have any questions, concerns or comments about our practices, or this Privacy Notice, please email support@dispo.travel, stating “Privacy” in the subject line, and we’ll get right back to you.