Privacy Policy
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Data Controller: Linyr360 Limited (operating Linyr360). Registered Office: Kingston, Jamaica. Contact Email: info@linyr360.com.
Linyr360 ("the Platform", "we", "us") is a technology platform that connects independent, licensed transport operators ("Drivers") with people who need a ride ("Riders"). This policy explains what personal data we collect, why we use it, who we share it with, how long we keep it, and the rights you have under the Data Protection Act, 2020 of Jamaica ("the Act"). It applies to our apps and our website.
1. The Data We Collect
A. Data You Give Us
- Riders: your name, email address, mobile number and profile photo if your account has them, your saved places, and the pickup and drop-off locations and notes you enter. If you pay by card, you enter your card details on the secure page of our payment processor. We keep only a secure token, the card brand and the last four digits.
- Emergency contacts: if you add them, the name and phone number of the people you want us to alert when you press SOS. Please add only people who have agreed to this.
- Drivers: your name and email address, a mobile number if your account has one, a photo of you, which you take in the App when we ask for one and our staff check, and the documents needed to operate legally on the Platform:
- Driver's licence
- Transport Authority (PPV) badge
- Road licence
- Certificate of Fitness
- Motor vehicle registration certificate
- Commercial vehicle insurance
- Taxpayer Registration Number (TRN) document
- Proof of address
- Police record certificate. We treat this as sensitive personal data, and we use it only to check that you can drive on the Platform.
- Vehicle owners: from a motor vehicle registration certificate we collect and keep the name, address and owner number of the vehicle's owner, who may not be the Driver. The owner number may be a Taxpayer Registration Number. We use these details only to check the vehicle. Our verification provider, Didit, reads them from the certificate, and our staff see them when they review it. A Driver sending us a certificate in someone else's name must tell the owner first.
- Drivers also give us vehicle details (make, model, colour, year and plate), bank details for payouts (bank, branch, account name, number and type), any taxi association code they enter, and whether a Rider paid for a cash trip, with any note they add.
- Roadside help (Drivers): photos of your tools and fuel receipts, if you take these jobs when they are available.
- Chat and support: the messages Riders and Drivers send each other in the App, ratings and comments, and your messages to our support team. A chat message may appear in a push notification on the other person's phone.
B. Data Collected Automatically
- Location (Drivers): while you are online and the App is open, we collect your device's location every few seconds so we can match you with nearby Riders, show your position to your Rider and work out arrival times. When you go offline, collection stops.
- Location (Riders): while the App is open, we use your location to set or suggest your pickup point and to show nearby cars. You can also choose to share your live location with your Driver until pickup. This is optional, needs your separate permission, and is passed to your Driver without being stored. If you press SOS, we record your location at that moment. We do not collect your location when the App is closed.
- Trip records: times, the route the Driver took (recorded as points along the way), distance, the fare and its breakdown, and how the trip ended.
- Device and technical data: device type and operating system, app version, push notification token, and error and performance reports. We record your IP address and device details when you accept our terms or this policy, or give or withdraw a consent in the App.
- Card check data: when you add or use a card, our payment processor's fraud check may look at your device on its secure page.
C. Data from Third Parties
- Sign-in providers: if you sign in with Google or Apple, we receive your name and email address from them.
- Document checks (Drivers): you upload documents issued by the Transport Authority, the police and other authorities. Our verification provider, Didit, reads them and returns the details it extracts (such as names, document numbers, addresses and dates) and whether the document passed its checks. Didit also receives your email address when a check starts. Our staff review the results. Didit keeps its own copy of what you upload and of its results for 1 year, unless it is deleted sooner. Didit may also keep and use limited data for its own security, fraud-prevention, legal and audit purposes, and it is responsible for that use. You can write to it at privacy@didit.me. We have opted out of Didit using this data to train or improve its models. Didit may use some biometric checks on the photo on your licence to confirm the document is genuine and to help prevent fraud. We don't ask you for a face scan through Didit. Where you give us a photo, our own staff compare it with your licence photo by eye.
- Payment processor: confirmation from your bank and our payment processor of whether a card was verified and whether a payment was approved, including the result of a fraud check.
2. Why We Use Your Data, and Our Legal Basis
- To provide the service (performance of a contract): creating your account, matching Riders and Drivers, showing live trip progress, working out and charging fares, paying Drivers and emailing their statements, chat between Rider and Driver, ratings, receipts and support.
- Safety (vital interests and legitimate interests): Share My Ride links, the trip PIN, the SOS button, alerting your emergency contacts and our on-call team, and looking into safety reports.
- Legal obligations: checking that Drivers are licensed and their documents are valid, keeping financial and tax records, and responding to lawful requests from authorities.
- Legitimate interests: preventing fraud and misuse (including card fraud screening), keeping the Platform secure, fixing errors, and improving routes and arrival times.
- Consent: optional live location sharing by Riders, and joining our pre-launch waitlist. You can withdraw consent at any time.
We do not use your data for advertising. We do not send marketing messages unless you have asked for them. Our website sets no tracking cookies and runs no analytics, and our apps contain no advertising or analytics tools.
3. Who We Share Data With
We do not sell personal data. We share it only as follows:
- Between Riders and Drivers: Drivers see the Rider's first name and rating, the pickup and destination, any pickup note, the number of passengers, the fare and how it is being paid, and chat messages. Riders see the Driver's name and rating and, while matched, the Driver's photo if we have an approved one, the vehicle's make, model, colour and plate, the Driver's live location, and chat messages. Neither sees the other's phone number. To start a trip, the Rider gives the Driver their trip PIN in person. After a trip, a Driver can see in their trip history the Rider's first name and rating, the number of passengers, the fare and a map of the trip. The map and addresses are exact for 24 hours. After that they show only the general area.
- Share My Ride: if a Rider shares a trip, anyone with the link can see the trip status, the pickup and drop-off, the Driver's name, the vehicle and plate, and the Driver's live position while the trip is in progress or an SOS is open. The link stops working after 24 hours, or later if an SOS is open. It does not show the Rider's name.
- Emergency contacts: if a Rider presses SOS, we text their emergency contacts with the Rider's name, a link to follow the trip live, and the advice to call 119.
- SOS response: our on-call team receives the Rider's first name and location, and may call the Rider or Driver. Our on-call staff's phone numbers are used to connect those calls.
- Nearby cars: the Rider's map shows the approximate positions of nearby available cars. These positions are blurred and shifted so individual Drivers cannot be identified or followed, and no Driver details are shown.
- Taxi associations: if a Driver enters an association's referral code, the association sees only totals. It never sees the Driver's name, trips or earnings.
- Service providers: companies that run parts of the Platform for us:
- Hosting and databases: Google Cloud, Supabase, Upstash and Fly.io
- Sign-in: Clerk
- Maps and routing: Google Maps Platform
- Driver document checks: Didit, which also uses limited data for its own purposes (section 1C)
- Card payments and fraud screening: Powertranz, National Commercial Bank (NCB) and Kount
- Driver payouts: NCB
- Text messages and calls: Telnyx
- Push notifications and app updates: Expo, Google and Apple
- Error monitoring: Sentry and Expo
- Email: Resend
- Website spam protection, where it is switched on: Cloudflare
- Driver training videos, which play through YouTube's player: YouTube
- Payments: card details are entered on the secure hosted page of Powertranz and sent directly to it over an encrypted connection. Linyr360 never receives or stores your card number or CVV. Visa and Mastercard payments are verified by your bank using 3-D Secure.
- Authorities: the Transport Authority, the police or other authorities, when the law requires it, when they show a valid court order or legal demand, or when there is an emergency risk to someone's life or safety.
- Business changes: a buyer or successor if Linyr360 Limited is reorganised or sold, under this policy.
4. International Data Transfers
Our servers and most of our service providers are in the United States. Our document check provider is Didit Identity, Inc., a United States company. Didit processes this data mainly in the European Economic Area, and its own service providers may handle it elsewhere. Card payments pass through our payment processor's gateway in Bermuda and our bank in Jamaica. When your data leaves Jamaica, it is handled under our agreements with these providers, and we share only what each one needs to do its job.
5. How Long We Keep Data
We keep your account data while your account is open. After the periods below, we delete or anonymise data, unless the law requires us to keep it longer.
- Trip route records: 180 days
- Driver location history: 90 days
- Chat messages: 1 year, then anonymised
- Ratings and comments: 2 years, then anonymised
- SOS records: 5 years, then anonymised
- Driver document images: 7 years in our own storage. Our document check provider keeps its copy for 1 year, unless it is deleted sooner.
- Details read from Driver documents, including a vehicle owner's name, address and number from a registration certificate: 7 years
- Financial and tax records (payments, refunds, earnings, deposits and payouts): as required by Jamaican law, currently up to 7 years
- Consent records and logs of staff actions: as long as we need them to show we met our legal duties
- Waitlist sign-ups: 12 months after we launch in your area
- Details of permanently deactivated Drivers (TRN, licence and vehicle details): as long as we need them to stop the Driver rejoining
6. Deleting Your Account
You can ask us to delete your account in the App (under Account) or at https://linyr360.com/delete-account. Our team closes it within 30 days and emails you when it is done. We remove or anonymise your name, contact details and saved places, and remove your saved cards. We keep a removed card's secure token only for open disputes, and never charge it again. We keep the trip, payment, payout and safety records that the law requires or that we need for safety, fraud prevention or an open dispute, in a form no longer linked to your name where possible.
7. How We Protect Your Data
We use encrypted connections for all data in transit, encryption at rest provided by our hosting providers, access controls that limit each user and staff member to the data they need, two-step sign-in for staff, and a log of staff actions. No system is completely secure, so please keep your sign-in details private and tell us straight away if you think your account has been misused.
8. Automated Decisions
Some decisions are made automatically by the Platform:
- Matching: ride requests are offered to nearby available Drivers who are approved and eligible for that trip.
- Pricing: fares are worked out from set rates by distance, with a surcharge at set busy times of day and an adjustment for traffic, which can be affected by things like poor weather or road works. Prices do not change based on who you are.
- Fraud and card checks: a card or payment can be declined automatically if your bank's verification fails or the fraud check flags it as high risk.
- Drivers: a Driver who owes more than the cash balance limit stops receiving cash trips until it is paid, a Driver whose required document has expired stops receiving trips until a valid one is approved, and a driver's licence may be approved automatically when it passes the document check.
- Riders: a Rider who owes a balance cannot choose cash until it is paid.
You can ask for any automated decision that affects your account to be reviewed by a person by emailing info@linyr360.com.
9. Your Rights Under the Act
You have the right to:
- Access: ask for a copy of the personal data we hold about you.
- Correction: ask us to correct data that is inaccurate or incomplete.
- Erasure: ask us to delete your data where we no longer need it, subject to records we must keep by law.
- Restriction and objection: ask us to limit how we use your data, or object to processing based on our legitimate interests.
- Withdraw consent: for anything we do on the basis of your consent.
- Complain: to the Office of the Information Commissioner of Jamaica.
Email info@linyr360.com to make a request. We will respond within 30 days.
10. Children
The Platform is for people aged 18 or over. We do not knowingly create accounts for anyone younger. If you believe a child has created an account, email info@linyr360.com and we will close it.
11. Pre-launch Waitlist
Before Linyr360 launches in your area you can ask us to notify you, or register your interest in driving. We collect only what you type into the form: your first name (optional), a phone number or email address, the area you are in and, for drivers, whether you already hold a PPV badge. We record the version of this policy shown to you and a one-way hash of your connection's IP address to prevent abuse. Where our spam protection is switched on, it also checks your IP address.
We use this information for one purpose: to tell you when Linyr360 launches or when driver onboarding opens in your area. The lawful basis is your consent, given when you submit the form. We do not add you to marketing lists, share your details with anyone else, or contact you for any other reason.
We keep waitlist entries for 12 months after launch in your area, then delete them. To be removed earlier, email info@linyr360.com with the address or phone number you registered.
12. Changes to This Policy
We may update this policy when our service or the law changes. The version date at the top shows when it last changed. We will tell you about important changes in the App or by email before they take effect.
13. Contact Our Data Protection Officer
Our Chief Technology Officer acts as our Data Protection Officer. For privacy questions or to exercise your rights, email info@linyr360.com or write to Linyr360 Limited, Kingston, Jamaica.
Questions about this document?
Email info@linyr360.com.
