Effective Date: July 16, 2018

We at Arro take the protection of your privacy seriously. This policy describes what information we collect, from whom we collect it, when we collect it, how it is used and shared, and the choices users have in how this information is managed.  Given the changes to our previous policy, a short summary is provided with respect to each section of this policy.

A. Purpose

[Summary. This policy describes how Arro and its affiliates collect and use the personal information of its users.]

This policy describes how Arro and its affiliates collect and use personal information to provide our services. This policy applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy policy and to the extent inconsistent with such other policy.

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

B. Scope of Application

[Summary. This policy applies to users of Arro’s services anywhere in the world, including users of Arro’s apps, websites, features or other services.]

This policy applies to the following persons and entities: (a) users of Arro who request or receive transportation services; (b) users of ARRO who provide transportation services to any passenger; and (c) persons and entities who provide information to Arro in connection with an application to use our services, or whose information Arro otherwise receives in connection with its services. All those subject to this policy are referred to as “users” for purposes of this policy.

C. Data Controller

[Summary. Arro provides services to users both in North America and in the European Union (including the United Kingdom).  If a user lives in in the United States, the data controller for such user’s information is Arro, Inc. If a user lives in the European Union, the data controller for such user’s information is Arro Operating (UK) Limited.]

Arro processes data inside and outside of the United States. If you live in the United States, the data controller for the information you provide or that is collected by Arro or its affiliates is:

Arro Inc.
42-32 21st Street
Long Island City, NY
United States, 11101

If you live in the European Union, the data controller for the information you provide or that is collected by Arro or its affiliates is:

Arro Operating (UK) Limited
Unit 11, Vision Industrial Park
Kendal Avenue, London
GB, England W3 0AF

Questions, comments and complaints about Arro’s data practices can be submitted to Arro’s data protection office through here.

D. Information Collected

[Summary. The information collected by or on behalf of Arro is comprised of information you provide, information created when you use our products and services, and information from other sources (in each case, as more carefully detailed below).]

The following information is collected by or on behalf of Arro:

1. Information you provide. This may include:

2. Information created when you use our services. This may include:

3. Information from other sources. These may include:

Arro may combine the information collected from these sources with other information in its possession.

E. How We Use Your Information

[Summary.  Arro collects and uses information to enable reliable and convenient transportation and other products and services, as well as:

Arro does not sell or share your personal information to third parties for third party direct marketing purposes.]

Arro uses the information it collects for purposes including:

1. Providing services and features.  Arro uses the information we collect to provide, personalize, maintain and improve our products and services. This includes using the information to:

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

3. Customer support.  Arro uses the information we collect (which may include recordings of customer support calls after notice to you and with your consent) to assist you when you contact our customer support services, including to direct your questions to the appropriate customer support person, investigate and address your concerns, and monitor or improve our customer support responses

4. Research and development. We may use the information we collect for testing, research, analysis and product development. This allows us to improve and enhance the safety and security of our services, develop new features and products, and facilitate insurance and finance solutions in connection with our services.

5. Communications among users. Arro uses the information we collect to enable communications between our users. This is the case where, for example, a driver or ARRO dispatch center texts or calls a user to confirm a pickup location or help a driver reach a passenger pick-up location.

6. Communications from Arro.  Arro may use the information we collect to communicate with you about products, services, promotions, updates, events, studies, surveys or news. Arro may also use the information to promote and process contests and sweepstakes, fulfill any related actions or verifications required to implement them, fulfill any awards associated with them, and/or serve relevant ads and content about our services and those of our business partners to users. You may receive some of these communications based on your profile as an Arro user. Users in the EU have have the right to object to this type of processing; please consult the GDPR for more information.

7. Legal proceedings and requirements. We may use the information we collect to investigate or address claims or disputes relating to your use of Arro’s services, or as otherwise allowed by applicable law, or as requested by regulators, government entities, and official inquiries. We may also use the information we collect to investigate or address claims or disputes relating to your use of Arro’s services, or to the services provided by our payment and security vendors and partners, including Creative Mobile Technologies, LLC and Creative Mobile Technologies (UK), Ltd.), to manage, prosecute, defend, manage or resolve security, data or payment claims (including, for example, chargeback  claims).

F. Cookies And Third Party Technologies

[Summary. Arro and its partners may deploy cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this policy.]

Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements. Arro, in certain instances, will use cookies and similar technologies for purposes such as:

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 your device when you visit our site and use our services, as well as when you visit other online sites and services.

Please see our Cookie Statement for more information regarding the use of cookies and other technologies described in this section, including regarding your choices relating to such technologies.

G. Information Sharing And Disclosure

[Summary. Some of Arro’s products, services and features require that we share information with other users or at your request. We may also share your information with our affiliates, subsidiaries and business partners, for legal reasons or in connection with claims or disputes.]

Arro may share the information we collect:

1. With other users. If you are a driver, we may share information with your rider(s) including name and photo; vehicle make, model, color, license plate, and vehicle photo; location; average rating provided by riders; total number of trips; for how long you have been using the Arro app; and contact information (depending upon applicable laws). If you are a rider, we may share your first name, average rider rating given by drivers, pickup and/or drop-off locations, or other identifying information generated by a third party (such as a hospitality partner of Arro) with drivers.  If you are a business using Arro to facilitate trip orders for or in favor of your own patrons or users, we may share certain information about your operations (such as, for example, the fact that there are not enough taxis in the queue to service your business, for example) or information you generate about your patrons (such as times of day where demand is typically highest, or identifiers generated or attached to individual or groups of your business patrons or users) to facilitate access to transportation services. If you choose to complete a driver profile, we may also share any information associated with that profile, including information that you submit and compliments that past riders have submitted about you. The rider will also receive a receipt containing information such as a breakdown of amounts charged, your first name, photo, and a map of the route you took.

2. At your request. This includes sharing your information with other people at your request (for example, we may share your ETA and location with a friend at your request). This also includes sharing your information with Arro business partners (for example, if you requested a service through a partnership or promotional offering made by a third party, Arro may share your information with those third parties). This may include, for example, other apps or websites that integrate with our APIs, vehicle suppliers, or services, or those with an API or service with which we integrate, or business partners with whom Arro may partner with to deliver a promotion, a contest or a specialized service.

3. With the general public when you submit content to a public forum. We love hearing from our users, including through public forums such as Arro blogs, social media, and certain features on our own or our partners’ networks (including, for example, Taxi TV managed by Creative Mobile Media, LLC in certain taxis operating in select markets). When you communicate with us through those channels, your communications may be viewable by the public.

4. With the owner of Arro accounts that you may use. If you use a profile associated with another party we may share your trip information with the owner of that profile. This occurs, for example, if you are:

5. With Arro subsidiaries and affiliates. We share information with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, Arro processes and stores information in the United States on behalf of its international subsidiaries and affiliates.

6. With Arro service providers and business partners. Arro may provide information to its vendors, consultants, marketing partners, research firms, and other service providers or business partners. This may include, for example:

7. For legal reasons or in the event of a dispute. Arro may share your information if we believe it is required by applicable law, regulation, operating agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing your information with law enforcement officials, 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 and Conditions, user agreements, or other policies, to protect Arro’s rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to your use of our services. If you use another person’s credit card, we may be required by law to share information with that credit card holder, including trip information.

This also includes sharing your information 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 your consent. Arro may share your information other than as described in this policy if we notify you and you consent to the sharing.

H. Information Retention And Deletion

[Summary. Arro retains user profile and other information for as long as you maintain your Arro account.

Arro retains transaction, location, usage and other information for 7 years in connection with regulatory, tax, insurance or other requirements in the places in which it operates. Arro thereafter deletes or anonymizes such information in accordance with applicable laws.

If you withdraw consent to the collection or use of personal information for optional features, such as features that use your calendar or address book, Arro deletes such personal information.

Users may request deletion of their accounts at any time. Following such request, Arro deletes the information that it is not required to retain, and restricts access to or use of any information it is required to retain.]

Arro requires user profile information in order to provide its services, and retains such information for as long you maintain your Arro account.

Arro retains certain information, including transaction, location, device and usage information, for a minimum of 7 years in connection with regulatory, tax, insurance and other requirements in the places in which it operates. Once such information is no longer necessary to provide Arro’s services, enable customer support, enhance the user experience or other operational purposes, Arro takes steps to prevent access to or use of such information for any purpose other than compliance with these requirements or for purposes of safety, security and fraud prevention and detection.

You may request deletion of your account at any time through the Privacy Settings in the Arro app, or via Arro’s website.

Following such request, Arro deletes the information that it is not required to retain. In certain circumstances, Arro may be unable to delete your account, such as if there is an outstanding credit on your account or an unresolved claim or dispute. Upon resolution of the issue preventing deletion, Arro will delete your account as described above.

Arro may also retain certain information if necessary for its legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, if Arro shuts down a user’s account because of unsafe behavior or security incidents, Arro may retain certain information about that account to prevent that user from opening a new Arro account in the future.

I. Special Information For EU Users

[Summary. This section summarizes Arro’s grounds for processing personal information under the General Data Protection Regulation (“GDPR”) which will apply as of May 25, 2018 to the personal data and rights of EU users as relates to Arro’s handling of personal information.]

The processing of personal data of users in the European Union is subject to the EU General Data Protection Regulation (“GDPR”) as of May 25, 2018. This section provides information as relates to EU users’ rights, and Arro’s responsibilities, under this regulation.

1. EU User Rights. If you are an Arro user in the EU, you have the following rights with respect to Arro’s handling of your personal information. To exercise these rights, please see below or submit your request at [email protected]. Users outside the EU may also request explanation, correction, deletion or copies of their personal data at the same email address.

a. Explanation and copies of your data

b. Correction

c. Deletion

d. Objections and complaints

2. Grounds for Processing

The GDPR requires that we process the personal data of EU users on the basis of specific legal grounds. Arro processes the information of EU users based on one or more of the grounds specified under the GDPR, as described below:

a. The processing is necessary to provide the services and features you request

b. The processing is necessary to protect the vital interests of our users or of others

c. The processing is necessary for Arro’s legitimate interests. Arro collects and uses personal information to the extent necessary for its legitimate interests. This includes collecting and using information to:

(i) prevent, detect and combat fraud in connection with the use of our services (for example, Arro uses user profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud Arro or other users);

(ii) maintain and enhance our users’ safety and security (for example, by monitoring chargeback events) and prevent use of our services by users who have engaged in inappropriate or dangerous behavior (for example, by retaining information of banned users to prevent their use of Arro’s apps);

(iii) provide customer support

(iv) inform law enforcement officials regarding criminal acts or threats to public safety,

(v) optimize or enhance existing products and/or services, or develop new products and/or services. This includes, for example, improved driver navigation and efficiency (including through the communication of information, such as anticipated duration of airport taxi queue lines, for example), and enhancing riders and driver matches based on past feedback or conduct in connection with either or both.

(vi) enforce Arro’s Terms and Conditions.

Arro’s collection and use of personal information to the extent necessary for its legitimate interests also includes collecting and using information for:

(vii) research and analytical purposes (for example, to analyze usage trends to improve the user experience and enhance the safety and security of our services), and

(viii) direct marketing purposes. This includes, for example, analysing data to identify trends and tailor marketing messages to user needs.

d. The processing is necessary for the legitimate interests of other persons or parties. Arro collects and uses personal information to the extent necessary for the interests of other persons or the general public. This includes sharing information in connection with legal or insurance claims, to protect the rights and safety of others. Arro may also process personal information when necessary in regards to a substantial public interest, on the basis of applicable laws.

e. The processing is necessary to fulfill Arro’s legal obligations. Arro is subject to legal requirements in the jurisdictions in which it operates that require us to collect, process, disclose and retain your personal data. For example, Arro is subject to laws and regulations in many cities and countries that require it to collect and retain information about your trips, to retain such information for extended periods of time, and to provide copies of such information to governmental or other authorities. Arro uses your information to comply with such laws to the extent they apply to your use of the Arro apps.  Arro may also share information with law enforcement, or requests by third parties pursuant to legal processes. For more information about such sharing, please see Arro’s Guidelines for Law Enforcement Authorities in the United States, Guidelines for Law Enforcement Authorities Outside the United States, and Guidelines for Third Party Data Requests.

f. Consent. Arro may collect and use your information on the basis of your consent. You may revoke your consent at any time.  If you revoke your consent, you will not be able to use any service or feature that requires collection or use of the information we collected or used on the basis of consent.  Arro relies on consent in connection with data collections or uses that are necessary to enhance the user experience, to enable optional services or features, or to communicate with you. If you are an EU user, the following types of data collections or uses are done on the basis of your consent.

• Please see the Choice & Transparency section below for further information about these data collections and uses, how to opt in or out of them, and the effect of opting out of these on your use of Arro’s apps.

• Arro may also collect personal information about you through voluntary surveys. Your responses to such surveys are collected on the basis of consent, and will be deleted once no longer necessary for the purposes collected.

J. Privacy Settings, Permissions and Other

[Summary. Arro provides you with the ability to see and control the information that Arro collects, including through:

You may also request that Arro provide you with explanation, copies or correction of your data.]

J1. PRIVACY SETTINGS. The Privacy Settings menu in the Arro rider app gives users the the ability to set or update their location and contacts sharing preferences, and their preferences for receiving mobile notifications from Arro. Information on these settings, how to set or change these settings, and the effect of turning off these settings are described below.

1. Location Information

2. Share Live Location (Riders)

3. Notifications: Account and Trip Updates

4. Notifications: Discounts and News

5. Address Book / Contacts

6. Calendar Syncing

J2. DEVICE PERMISSIONS

Most mobile platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. And these platforms have different permission systems for obtaining your consent. The iOS platform will alert you the first time the Arro app wants permission to access certain types of data and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Arro app seeks before you first use the app, and your use of the app constitutes your consent.

J3. RATINGS LOOK-UP

After every trip, drivers and riders are able to rate each other, as well as give feedback on how the trip went. This two-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for both drivers and riders.

Your rider rating is available in the main menu of the Arro rider app.

Your driver rating is available in the Ratings tab of the Arro Partner app.

J4. EXPLANATIONS, COPIES AND CORRECTION

You may request that Arro:

You can make these requests by contacting Arro here.

You can also edit the name, phone number and email address associated with your account through the Settings menu in Arro’s apps. You can also look up your trips, orders and deliveries history in the Arro apps.

J5. MARKETING OPT-OUTS

You may opt out of receiving promotional emails from Arro here. You may also opt out of receiving emails and other messages from Arro by following the instructions in those messages. Please note that if you opt out, we may still send you non-promotional messages, such as receipts for your rides or information about your account.

K. Updates To This Policy

We may occasionally update this policy. If we make significant changes, we will notify you of the changes through the Arro apps or through others means, such as email. To the extent permitted under applicable law, by using our services after such notice, you consent to our updates to this policy. We encourage you to periodically review this policy for the latest information on our privacy practices. We will also make prior versions of our privacy policies available for review.