Pumba Privacy Notice (en)
Last Updated: April 22, 2021
Pumba Parking Ltd. (“Pumba”, “we”, “our” or “us”) provides its customers and users (“User(s)” or “you”) with a mobile application platform and web services enabling
Our Services include our websites at www.pumbaparking.com and any additional websites owned and operated by Pumba (the “Site”) and to our downloadable mobile application (the “App”) and related public transportation information services.
- WHAT INFORMATION DO WE COLLECT ABOUT YOU?
- First – what is personal information?
- Personal information is individually identifiable information about a person, namely information that identifies an individual or may with reasonable efforts or together with additional information we have access to, enable the identification of an individual, or information relating to an identified or identifiable natural person which may be of private or sensitive nature. Under certain applicable laws identification of an individual also includes any information which associates an individual with a persistent identifier such as a name, an identification number, persistent cookie identifier etc.
- Personal information does not include information that has been anonymized or aggregated so that it can no longer be used or to identify a specific natural person.
- Next – what and when do we collect personal information?
- We collect personal information from you and from any devices (including mobile devices) you use when you install or have the App installed (or pre-installed) on your device, or when you use or access our Services, register for an account with us, provide us with information such as your favourites and travel habits provide, us information on a web form, run searches on our Services, update or add information to your account, or through correspondence you conduct with us.
More specifically we collect and use the following categories and types of information:
Personal information we collect automatically when you use our Services–
- Information collected when installing the App
- Usage Information
- We receive information from you when you access and use our Services, as follows: your IP address, tokens of social networks you choose to connect to your account (as described below), information regarding your clicks, views and engagement with the Services and with advertisements we may display on the Service, information concerning your traffic to and from the Services, your referral URL, our communications with you, your public transit historical searches on the Services, information about your use and your interaction with our Services, including the duration of such use; your in-app settings; and your in-app scores (“points”).
- Geo-Location Information and other Sensors data
- Pumba automatically collects location information such as your geo-location and your route and travel information (for example, routes and times of travel from one destination to another) in order to provide you with our Services. When using the App, we collect detailed location including GPS signals and other device sensors data such as gyro/oscilloscope sent by your mobile device for which the Service is installed and activated.
- PLEASE NOTE THAT PUMBA COLLECTS YOUR LOCATION DATA EVEN WHEN YOU ARE NOT USING THE APP TO PERSONLIZE THE SERVICES AND MAXIMIZE YOUR USER EXPIRIENCE AND TO DEVELOP AND ENHANCE OUR ON-STREET PARKING INFORMATION SERVICES. YOU MAY CHOOSE TO DISABLE AND OPT-OUT FROM THIS BACKGROUND COLLECTION OF DATA UNDER THE APP’S PRIVACY SETTINGS SCREEN.
- Pumba uses this location and sensor information to provide you with the Service and to create a detailed location history of your public transit trips.
- Cookies & Similar Technologies
- Please take into consideration that certain portions of such above mentioned information may also be collected from your device or software, when the Services are running in the background, i.e. when they have been launched but are not actively used.
- Please keep in mind that most mobile devices and operating systems allow you to control or disable the use of certain collectable information including location services by applications, in the device’s settings menu.
Personal information you give us when you use our Services–
Generally, this category refers to any information, data or content you actively and voluntarily create, upload, or provide to use through our Services.
- Account Information.
- You may choose to set up a registered Pumba User account in connection with your use of the Services. When setting your Pumba registered User account, you may actively share with us certain personal information with us, such as email address, Car model and residence address. Another way to create an account is through connecting and using your existing social media profiles to the App, as further detailed below.
- Note – while our Services are available to all Users, whether or not they set up a registered Pumba User account, we note that setting up such an account may allow you to enjoy certain features in the App that are only available to registered Pumba Users.
- Actively Provided Points of Interests (POI) Data
- In addition, you may choose to upload specific destinations and POIs such as your home address, work address or other favourite destinations and POIs in order to personalize the Service.
- Pumba also collects information regarding public transportation lines, stations and/or routes you may have saved or searched for via the Services, User’s most-used travel and public transit routes and stations for purposes of providing the Service, enhancing the User’s experience and personalizing the Service.
Personal information collected from other sources–
- Third Parties
- We may also collect personal information concerning you, from third parties who have assured us that they have obtained your consent for such provision of information or that you have freely and publicly provided. For example, we may collect and use demographic and other information that is publicly available in an applicable jurisdiction, additional contact information, credit check information, and information from credit bureaus, as allowed by applicable national laws.
- Social Media you elected to connect to your account
- We allow you to share information with social platforms or use social platforms to create your Pumba account. These social platforms give us automatic access to certain personal information retained by these social networks about you. This includes your Facebook Access Token, Google Sign-In Token, advertiser ID and information from your public profile, which may include your name, gender, profile picture, age group and residency. You control the personal information you allow us to have access to through the privacy settings on the applicable social platforms and the permissions you give us when you grant us access to the personal information retained by the respective social platforms about you.
- WHO IS THE DATA CONTROLLER OF YOUR PERSONAL INFORMATION?
Pumba Parking LTD are the data controllers of the Personal Information collected in connection with the use of Pumba’s services.
- HOW WE USE YOUR INFORMATION
- When Performing this Agreement: We collect and process your personal information in order to provide you with the Service, following your acceptance of these Terms; to maintain and deliver our Services to the User; for example, we collect your location information in order to provide you with recommended available on-street parking spots.
- Purpose of Use
We may use information that we collect about you for the following purposes:
- to provide you with and to operate the Service, including for aggregation, statistical and research purposes and creation and use of aggregated anonymous data which is all necessary to maintain, develop and improve Pumba’s services, including to determine navigation, routes, and statistical information.
- in order to determine and ascertain User accounts; verify User identity; and enable users, if relevant, to transfer or receive payments, which may include calculation of the costs for the services,
- to track your trips and aid you with navigation;
- to personalize the Service and content provided to you, to customize your experience with the Services, to communicate with users about their trips, including transport recommendations based on your preferences and to enable you to retrieve your information;
- to develop, improve and customize the Service, the experience of other users and the offering available through the Service;
- to be able to contact Users for the purpose of providing them with technical assistance, support, handle requests and complaints, and collect feedback in connection with our performance of the Services and in connection with public transportation needs;
- to send you updates, notices, announcements, and additional information related to the Service, such as changes in public transportation services or closures;
- to be able to reply to User online queries in connection with performance of the Services;
- for customization and improvement of the Service’s accuracy and interface;
- Marketing: we may use the data we collect to market our services to our users. This includes sending users communications about Pumba services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may also send communications to our users to provide promotional information and participation in the promotions, as well as information regarding offers, discounts and promotions related to our services and services of our collaboration partners. Although we may send users communications about Pumba 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.
- to comply with any governmental agencies’ legal requests or court orders, and/or with any applicable law, rule or regulation, such as reporting an abusive user or fulfilling tax regulation obligations with regard to promotions and which require the use of user data; and to use the information to create statistical, aggregated or anonymous data which may be used at our discretion for any purpose.
- TO WHOM WE SHARE PERSONAL INFORMATION
We may share your personal information with third parties (or otherwise allow them access to it) only in the following manners and instances:
- Third Party Services
- Pumba has partnered with a number of selected service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting, database and server co-location services (such as AWS, data analytics services (such as Facebook Analytics, Google Analytics), App analytics tools including session replay records for usability and functionality monitoring and analysis (such as: Mixpanel), e-mail distribution and monitoring services (such as Mailchimp), and our business, legal and financial advisors (collectively, “Third Party Services“). Such Third Party Services may receive or otherwise have access to our Users’ personal information, depending on each of their particular roles and purposes in facilitating and enhancing our Services and business, and may only use it for such purposes. Pumba, as the controller of the information collected from its Users in connection with the use of the Services, remains responsible for any personal information processing done by Third Party Services on its behalf, except for events outside of its reasonable control.
- Pumba may offer you the option to link Pumba to third party services that may be useful to you, such as private parking lots services. Where Pumba detects an integration may be available (either because a third party service attempts to link to Pumba, or Pumba detects an installed service on the device which has an integration option, or you request a particular integration), Pumba will ask for confirmation to connect the accounts. If you choose to connect the accounts, Pumba will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and Pumba is not responsible for the third party service’s use of data. You can disconnect Pumba and the third party service at any time and Pumba will cease sharing data with that service from the point of disconnection onwards.
- Governmental/Law Enforcement Agencies and Legal Requests or Duties
- We may disclose or otherwise allow access to your personal information pursuant to a legal request, such as a subpoena, search warrant or court order, or in compliance with applicable laws, with or without notice to you, if we have a good faith belief that we are legally required to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, counter terrorist financing verification requirements, fraud, or other wrongdoing.
- Protecting Rights and Safety
- We may share your personal information with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of Pumba, any of our Users, or any member of the general public.
For the avoidance of doubt, Pumba may share your personal information in additional manners, pursuant to your explicit approval. Additionally, we may transfer, share or otherwise use anonymized, aggregated or non-personal information in our sole discretion and without the need for further approval.
- WHERE DO WE STORE USER’S PERSONAL INFORMATION
- Information regarding the Users will be maintained, processed and stored by us and our authorized affiliates and service providers in Israel, a country offering an adequate level of protection in accordance with European Commission Decision 2011/61/EU of 31 January 2011 for the management of the Mobile Application platform and Ireland, and as necessary, in secured cloud storage, provided by our third party service provider.
- You hereby accept the place of storage and the transfer of information as described above.
- We take great care in implementing and maintaining the security of Pumba’s Service and its User’s personal information. Pumba employs industry standard procedures and policies to ensure the safety of its Users’ personal information and prevent unauthorised access, disclosure and alteration of any such information. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorization controls. We cannot, however, guarantee that unauthorized access will never occur.
- COMMUNICATIONS FROM PUMBA
- Service Messages
- Pumba may contact you with information regarding our Services, or your use thereof. For example, we may notify you (through any of the means available to us) of changes or updates to our Services, including changes to these Terms, transactions performed, payment issues, service maintenance, etc. You will not be able to opt-out of receiving such service messages.
- Promotional and Surveys Messages
- In addition to communications that are an inherent part of our Services, occasionally we may also use your contact information to contact and notify you about new services and special opportunities or promotions we think you will find valuable and may also contact you in connection with surveys we conduct with respect to our services or in connection with on-street parking spots issues either on our own behalf or on behalf of our partners. We may contact you through e-mail, push notifications, through the Services, or any other contact methods available to us, including with the help of our Third Party Services.
- Accordingly, we shall be entitled to call you or send you promotional content or messages by e-mail, SMS, direct text messages, web chat, marketing calls, and similar forms of communication, with your prior written consent.
- if you wish not to receive such promotional messages or calls, you may notify Pumba at any time by e-mailing us at firstname.lastname@example.org, or by following the “unsubscribe” or “stop” instructions contained in the promotional communications you receive. As for messages we send through push notifications you may opt-out of receiving such notification by changing your device or App settings.
- YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
- If you are an EU, EEA or Switzerland person and to the extent entitled under applicable law of your jurisdiction, you may contact us to exercise your right to access personal information, to request us to make corrections to your personal information that you have stored with us, to object to any form of processing, or to have such personal information deleted or exported in a portable copy. For this, please send us an e-mail to email@example.com, or mail your request to the EU representative with a copy to Pumba Parking Ltd., 28 HaDganim St., Yehud, Israel, and we will respond within a reasonable timeframe and in accordance with applicable laws and regulations.
- In certain circumstances, you may request that the processing of your data be restricted, in which case Pumba will only keep it for the exercise or defense of claims.
- We also remind you that, as a User, you may oppose the processing of your data for promotional or advertising purposes, at any time.
- Likewise, you have the right to withdraw your consent at any time, in those cases in which it is necessary for the processing, without this affecting the legality of the processing based on the consent prior to its withdrawal.
- To exercise the rights regarding data protection, or revoke the consents given, the User may write to Pumba Parking Ltd., 28 HaDganim St., Yehud, Israel, or to the email address firstname.lastname@example.org.
- The User may file a complaint with their national data protection authority if the User has a concern about our privacy practices, including the way we handle personal information.
HOW LONG MAY WE KEEP YOUR PERSONAL INFORMATION
- We will retain your personal information for as long as you maintain an account or as otherwise necessary to provide you the Services. We will also retain your personal information as necessary to comply with our legal obligations, to resolve disputes, to prevent fraud and abuse, to enforce our agreements and/or protect our legitimate interests.
- To use our Services, you must be over the age of sixteen (16). Therefore, we do not knowingly collect personal information from minors under the age of sixteen (16) and do not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors under the age of sixteen (16) are not using the Services.
- CONTACT US; DATA PROTECTION OFFICER; EU REPRESENTATIVE
- By contacting us, you represent that you are free to do so and that you will not knowingly provide Pumba Parking Ltd. with information that infringes upon third parties’ rights, including any intellectual property rights. You further acknowledge that notwithstanding anything herein to the contrary, any and all rights, including intellectual property rights in such information provided, shall belong exclusively to Pumba, and we may use or refrain from using any such information at our sole discretion.1