Zed, takes privacy seriously.

Zed ("we”. “our”, or “us”) is committed to respecting your personal information and complying with the relevant laws including, without limitation, the UEA FEDERAL Decree Law № (45) of 2021 on Personal Data Protection, DIFC Data Protection Law and EU General Data Protection Regulations (“applicable legislation”). This Data Privacy Notice contains information on what Personal Data we and our related Group companies collect, what we do with that information, and what rights you have. This Data Privacy Notice has been prepared with reference to applicable legislation considerations and will be augmented by jurisdictional specific addendums from time to time.

We are committed to safeguarding the privacy of the personal information that we process in the course of our business, including the personal information we receive from you (“you” or “your”). This Data Privacy Notice describes how and why we collect, store and use personal information, and provides information about the rights of the individuals to whom such personal information relates.

For the purposes of applicable data protection law, Zed is typically the “Data Controller” of any personal information provided to us. Specifically, the data that you have provided and communicated to us will be controlled, collected and processed by Zed. Very occasionally, we will act on specific retainers as a “Processor” (meaning that we process Personal Data only in accordance with the directions of a Data Controller, or as otherwise permitted by law).

Please read the following information carefully to understand our views and practices regarding how we handle personal information. If you have any queries about our approach to data protection that are not already addressed in this Data Privacy Notice, please contact our Data Protection Officer, as per the contact details set out at the end of this Data Privacy Notice.

1. Scope and Application

This Policy applies to persons anywhere in the world who has access to, or who uses, websites, Apps or any other digital platforms owned by Zed.

2. Collection of Personal Data

We may collect personal information from you by electronic and/or physical means in the course of our business, when you contact us or request information from us, when you use our website or mobile app (or other digital platforms), or as a result of your relationship with any of our personnel or clients.

The personal information that we process (“Personal Data”) includes:

• We collect information you provide directly to us through your access or use of the Services, such as when you create or modify your account, request on-demand or scheduled services, contact customer support, or otherwise communicate with us. This information may include: your name, email address, phone number, postal address, profile picture, payment method, financial and credit card information, and other information you choose to provide.
• When you use our Services, we collect personal information (i.e. information that could be used to contact you directly such as full name, postal address, phone number, credit/debit card information, or email address) (“Personal Information”) and demographic information (i.e. information that you submit, or that we collect, that is not personal information; this may include, but is not limited to, post code, hometown, gender, username, device information, including the type of mobile device you use, a unique device identifier (for example, your device's IMEI number, the MAC address of the device's wireless network interface, or the mobile phone number used by the device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, device location, IP address, SMS data, transaction information, age/birth date, browsing history information, searching history information, and registration history information) (“Demographic Information” and, together with Personal Information, “Personal Data”).
• We also use GPS technology to determine your current location. Some of our location enabled Services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose.
• Location data (driver person, ZedDriver app): We collect your device’s precise location when the App is running in the foreground (App open and on-screen) and when the App is running in the background (App open but not on-screen) to get the driver’s current location.
• Location data (rider person, ZedCustomer app): We collect your device’s precise location when the App is running in the foreground (App open and on-screen) and when the App is running in the background (App open but not on-screen) to get the rider’s current location. Riders may use the App without enabling it to collect precise location data from their mobile devices by directly inputting your pick-up and drop-off addresses into the App. This may affect the availability of App features (In this case app won’t be able to pick the rider’s current location).
• We may also receive information from other sources and combine that with Personal Data we receive from you or collect through our Services. For example: If you choose to link, create, or log in to your Zed account with a payment provider or social media service (e.g., Facebook, Google), or if you engage with a separate app or website that uses our API (or whose API we use), we may receive information about you or your connections from that site or app.
• If your employer uses one of our enterprise solutions, we may receive information about you from your employer.
• When you request on demand services, our Drivers may provide us with a User rating after providing services to you.
• If you also interact with our Services in another capacity, for instance as a Driver, we may combine or associate that information with Personal Data we have collected from you in your capacity as a User or rider.

We collect most of this information directly from you, through your use of our website or any other websites operated by Zed business, or any service provided by Zed.

Our company works closely with third parties (including, business partners, vendors, suppliers, sub contractors, advertising networks, analytics providers, search information providers, customer survey providers, etc.) and may receive information about you from them. Where we obtain your information from a third party, we may ask them to provide you with a copy of this Data Privacy Notice to ensure that you know we are processing your information and the purpose for such processing.

The information you provide may be confidential, and we will maintain such confidentiality and protect your information in accordance with our professional obligations and applicable legislation

3. Use of Personal Data

Whether we receive your Personal Data directly from you or from a third party, we will only use your personal information if we have obtained your consent, or if we have another lawful basis upon which to do so.

Depending on the purpose of the processing activity, the legal basis for the processing of your Personal Data will be one of the following:

• necessary to perform our contractual obligations towards you or to take pre-contractual steps at your request;
• necessary to meet our legal or regulatory obligations in accordance with the applicable legislation;
• necessary to public interest;
• necessary to protect the vital interests of the relevant individual or of another natural person, such as providing disability access to places of work where applicable;
• necessary for the legitimate interests of Zed, without unduly affecting your interests or fundamental rights and freedoms and to the extent such Personal Data is strictly necessary for the intended purpose; or
• in some cases, and as may be requested from you from time to time, we have obtained prior consent (for instance where required by law) or processed with your explicit consent in the case of special category of Personal Data (i.e. your medical information).

We always process your Personal Data for a specific purpose and only process the Personal Data which is relevant to achieve that purpose. The purposes for which we process your personal information are as follows:

• Provide, maintain, and improve our Services, including, for example, to facilitate payments, send receipts, provide products and services you request (and send related information), develop new features, provide customer support to Users and Drivers, develop safety features, authenticate users, and send product updates and administrative messages;
• Perform internal administration and operations, including, for example, to prevent fraud and abuse of our Services; to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends;
• Send or facilitate communications (i) between you and a Driver, such as estimated times of arrival (ETAs), or (ii) between you and a contact of yours at your direction in connection with your use of certain features, such as referrals or invites;
• Send you communications we think will be of interest to you, including information about products, services, promotions, news, and events of Zed and other companies, where permissible and according to local applicable laws; and to process contest, sweepstake, or other promotion entries and fulfill any related awards;
• Notify you about changes to our Services;
• Allow you to participate in interactive features of our Services;
• Keep our Services safe and secure; and
• Personalize and improve the Services, including to provide or recommend features, content, social connections, referrals, and advertisements.

We may also use your personal information to personalise the marketing messages we send to you and to make them more relevant and interesting, as this is in our legitimate business interests. According to the applicable legislation, we will obtain your consent first. We may use your personal information for this purpose in the following ways:

• using your online browsing behaviour to help us better understand you as a customer and provide you with personalised offers and services;
• providing you with relevant marketing communications (including by email, post, telephone, SMS, or online advertising), relating to products and services we offer, and those of our suppliers and partners;
• to help us to better understand you and provide you with services and marketing communications, that are relevant to your interests, we combine personal information we collect with personal information collected from our websites, mobile apps and other sources.

4. Consent

We process your Personal Data based on your consent or another lawful basis stated in Section 3 of this Data Privacy Notice. Where we do process your Personal Data based on your consent, you have the right to withdraw your consent at any time. To withdraw your consent, please contact us using the contact details stated at the end of this Data Privacy Notice.

5. Sharing of Personal Data

We may share Personal Data with other Zed for the purposes indicated in section 3 to ensure a consistently high service standard across our group, and to provide services and products to you. We may disclose your Personal Data to third parties only:

• where you have given your prior written consent,
• where we are required to do so by applicable legislation (such as to relevant regulators or other authorities),
• when it is necessary for a purpose of legitimate interest, or
• where it is necessary for the purpose of or in connection with legal proceedings or in order to exercise or defend legal rights.

We do not sell, rent, distribute, or otherwise make, personal information commercially available to any third party. Where we transfer your data to third parties, we take steps to ensure they meet our data security standards, so thar your Personal Data remains secure.

6. Storage and Transfer of your Personal Data

• You agree that we have the right to transfer the Personal Data described in this privacy policy to and from, and process and store it in, the Republic of India, the United Arab Emirates and other countries, some of which may have less protective data protection laws than the region in which you reside. Where this is the case, we will take appropriate measures to protect your Personal Data in accordance with this privacy policy. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure your data is treated securely and in accordance with this privacy policy.
• To preserve the integrity of our databases, to carry out on-going Services on your behalf, for research, analytics and statistics purposes and to ensure compliance with applicable laws and regulations, we retain Personal Information and Demographic Information submitted by Users and Drivers for a reasonable length of time. Zed is not responsible for the accuracy of the information you provide, and will modify or update your Personal Information in our databases upon your request. If required by law or at your request, we will erase or archive from active use your Personal Information. By accessing or using the Services, you do hereby represent and warrant that you understand that all information submitted by you through the Services or otherwise to Zed may be used by Zed in accordance with applicable laws, this privacy policy and our customer terms of use.

We will only transfer your data outside of the UAE if:

• we have appropriate safeguards in place to ensure that your data is protected;
  
• we have your explicit consent to the proposed data transfer after being informed of any potential risks; or the transfer is necessary for one of the other reasons under the applicable legislation, including to allow us to perform any contracts we have with you, to protect your interests, and in limited cases, for our legitimate interest.

By providing your personal data to Zed, you agree to this transfer, storing or processing.

The Company will take all steps reasonably necessary to ensure your data is treated securely, to prevent unauthorized access or disclosure and in accordance with this Data Privacy Notice.

If some transfers of your Personal Data may be made to the countries or jurisdictions with data protection or privacy laws that are not adequate (non-adequate jurisdictions) in comparison with the applicable legislation, we will take appropriate measures to protect Personal Data in accordance with the applicable legislation.

7. Your data protection rights

Various rights may be available to you, depending on the circumstances and the applicable legislation. We summarise key rights likely to be available to most data subjects:

• to access your personal information – you can request access to your personal information and, further details about how it is handled;
• to rectify your personal information – if the personal information we hold about you is inaccurate or incomplete, you are entitled to request to have it rectified;
• to request your personal information is erased – you can ask us to delete or remove your personal information where the processing is not necessary for the legitimate interests of Zed;
• to restrict processing or object to the processing of your personal data – you have the right to restrict or to object to the processing of your personal information unless the processing of your personal information is necessary for the legitimate interests of Zed;
• data portability - you have the right, in certain circumstances, to obtain personal information you have provided to the Zed in a structured, commonly used and machine-readable format and to reuse it elsewhere or to ask us to transfer this to a third party of your choice
• to withdraw your consent - at any time you have the right to withdraw your consent for Zed to process your personal information.
• to lodge a complaint - if you have a complaint or concern about our privacy practices or how we have used or processed your personal information, you can report it to the relevant authority.

If you:

• would like to discuss or exercise above-mentioned rights;
• would like to see or access the personal information we hold about you;
• concerned that any of the information we hold about you is incorrect, or out of date,

please write to the address stated at the end of this Data Privacy Notice to report your concerns and we will take appropriate steps to fulfil your request.

Please note that some of the rights listed above may be limited where we have an overriding interest or legal obligation to continue to process your personal data or not disclose the same.

8. Children’s Privacy

Zed does not knowingly collect the information of, or make contact with, children, including to participate in customer research activities. If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to Zed. Users aged 18 or under without such consent are not allowed to provide us with personal information.

9. Data retention

We will retain your personal information for the length of time needed to fulfil the purposes for which it was collected, unless we specifically agree a longer retention period with you, or a longer retention period is required or permitted by applicable legislation.

At any time, you can ask for your stored information to be deleted from the company’s database using the contact details below. However, some of your information may be retained in some circumstances, such as to resolve disputes, troubleshoot problems, enforce terms and conditions or as required by regulators. Further, in some circumstances such information is never entirely removed from databases due to technical constraints and systems back-ups.

10. How we protect your Personal Data

We have implemented reasonable administrative, technical, and physical measures to protect your personal information against loss, misuse and alteration. However, no internet-based site can be 100% secure and we cannot be held responsible for unauthorised or unintended access that is beyond our control.

11. Cookies

Cookies are text files containing small amounts of information which are downloaded to your computer’s hard drive when you visit a website and are used to distinguish your device but cannot identify you personally. We use cookies to distinguish you from other users, personalise content and provide you with an improved user experience.

By clicking the “I agree” button on the pop-up when you first use the Zed website you are agreeing to the use of cookies by Zed website. You can control and manage cookies using your browser. Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

We only set a few cookies ourselves, but when we include content from other websites, they also get the opportunity to set cookies, to help them serve their content better. We cannot guarantee that we will have listed every cookie you might get from a third party, as they can change them at any time as their needs change.

The main categories of cookies used by our website are set out below.

Categories of cookies:

• Strictly Necessary Cookies: These cookies are fundamental to website functionality and cannot be switched off without blocking features on the website. They are usually set in response to your actions on the website, such as filling in forms, setting preferences, or recognize the user as valid and authenticated while accessing protected areas of the website.
• Analytics cookies: we collect information about how you use our website including details such as the website that referred you (e.g. search engines, marketing campaigns, referring domains), the content you viewed, the website path you navigated and the links that you clicked on. This is in order to understand your interests on our website and the number of times you visit our website. We use this information to improve our website and enhance visitor experience. We share this information with analytics and search engine providers that assist us in improving and optimising our website.
• Preference cookies: we use preference cookies also known as “functionality cookies,” to allow our website to remember the choices you have made in the past (such as your username, language or the region you are in) and provide you with an enhanced more personalised experience.
• Advertising cookies: we may present ads to you on websites that are not owned or operated by Zed to promote our services. The cookies are used to make advertising messages more relevant to you and your interests. They also perform functions like preventing the same ad from continuously re-appearing. These advertisements are solely intended to make you aware of relevant Zed promotions. We do not sell your data to any third parties.

Once you have given us your consent to the use any categories of cookies, we shall store cookies on your computer or device. If you do not wish to have non-permanent cookies (analytics, preference and advertising) placed on your computer you should not agree to proceed when you see the cookie ribbon on the homepage.

Most web browsers allow some control of most cookies through the browser settings. If you change your mind about permitting the use of cookies on your computer, you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. If you use your browser settings to block all cookies (including strictly necessary cookies) you may not be able to access and/or use all or parts of the Zed website.

12. Changes to the Data Privacy Notice

We update this Data Privacy Notice when needed and place updates on our platforms. If we are going to use your personal information in a manner different from that stated at the time of collection, we will notify you. All changes will become effective when posted unless indicated otherwise. Please review this Data Privacy Notice periodically for changes.

13. Contact Details

If you have any concerns about our compliance with applicable legislation or this Data Privacy Notice, please use the contact details below:

Data Protection Officer (Group Risk Assurance Services Department)

Al Ghurair Investment – Corporate Office

United Arab Emirates, Dubai

Post Box No. 5326

e-mail: DataProtection.Officer@al-ghurair.com

We will endeavour to respond to your concerns as soon as possible.