Trafi Privacy Policy

Welcome to Trafi mobile application (hereafter referred to as Trafi), a multi-platform service that uses real-time data and helps you to find the best possible way to commute from door to door.

Trafi is owned by Trafi Ltd., a company incorporated and acting under the laws of United Kingdom, company code 9326640, registered office at WEWORK SOUTH BANK CENTRAL, 30 Stamford Street, London SE1 9LQ, United Kingdom. Trafi is administered by UAB “Intelligent Communications”, legal entity code 300882953, registered office at Labdarių str. 5, Vilnius, Lithuania. Trafi Ltd. and UAB "Intelligent Communications". Both companies together define the purposes and means of data processing and thus are acting as joint controllers (hereinafter collectively referred to as the Controllers).

We have adopted this privacy policy (hereinafter referred to as the Privacy Policy), which determines how we are processing the information collected by Trafi and through Trafi, which also provides the reasons why we have to collect certain personal data of you. Therefore, you must read this Privacy Policy before using Trafi.

Please note that by using Trafi you accept and agree to be bound by this Privacy Policy. Trafi gives you a subdivided form of consent to this Privacy Policy, which marks the necessary and optional permissions. In the event you do not agree to any of the mandatory provisions of our Privacy Policy, you are not allowed to use Trafi, because in this case we will not be able to provide you with our services.

1. Why are we collecting the information about you?

1.1 The Controllers comply with their obligations under the General Data Protection Regulation (more commonly known as the GDPR) when collecting and processing your personal data exclusively for clearly defined purposes and on legitimate grounds, updating your personal data, safeguarding them and destroying them, by not collecting and not keeping too much data, and ensuring the application of the appropriate technical and organizational means for the protection of personal data.

1.2. You shall also be able to see the information displayed in Trafi about public transport, car and bicycle rental, ride sharing services without having to register a Trafi account. In this case, for the operation of Trafi, the Controllers will collect your location data, technical details of the device used (such as the device model, hardware ID), as well as the analytical data, as specified below.

1.3. You shall be able to use certain services (for example, Uber) on the Trafi application if you already are a user of the respective third-party services. In this case, you may link your accounts on Trafi and use these services. Trafi will then be collecting the above data, as in the case of the use without having registered the account (paragraph 1.2), as well as the data related to the ordering of these services, such as the data of the trips completed, service provider session queries.

1.4. In order to use Trafi’s services, such as the purchase of public transport tickets, car rental and ride hailing services, which are provided by third parties, you must create a Trafi account. You can do this through your Facebook or Google accounts, or by creating a separate Trafi profile.

1.4.1. If you want to buy public transport tickets and use ride hailing services, you need to provide your name, surname, e-mail address, bank card details, mobile phone number;

1.4.2. If you want to use car sharing services, you need to provide your name, surname, address of the place of residence, bank card details, mobile phone number. For the purpose of verification of your right to drive a vehicle, you shall be required to provide your driver's license number and the personal identification number.

1.5. In case you order the services and/or goods offered by Trafi, your personal data (your ID, name, surname, e-mail address, order details and account number) will be processed in order for us to invoice you for your ordered services and/or goods.

1.6. By agreeing to this Privacy Policy and submitting your personal information, you confirm that you are granting us permission to process your personal data in order to provide you with the services offered by Trafi.

1.7. We will also process personal data for the analytical purpose. These data relate to your use of Trafi and may include: user ID and hardware ID, country, city, registration data, IP address, data of the operating systems and hardware being used, Trafi usage time and usage actions, statistical data. The source of this data is the analytics system used by us. The said data, which have been pseudonymised, shall be kept separately from the data directly identifying you and are used for the purposes of analytics and Trafi error correction.

1.8. An agreement concluded with you regarding the use of Trafi services and/or your freely given, specific, explicit and unambiguous consent to collection and processing of such data shall be the legal basis for the collection and processing of your personal data in the activities of the Controllers.

2. Marketing and research activities

2.1. We strive to process your data, including your mobile phone number, e-mail, name, surname, user ID, country and city for marketing purposes of Trafi. We will be sending you promotional messages only if you have agreed to receive these messages and exclusively about the services offered by us. You can opt out of these promotional messages at any time by clicking on “unsubscribe” link in any incoming e-mail or in your Trafi account.

2.2. The Controllers are constantly improving Trafi in line with the users’ needs and experience. For this purpose, the Controllers are organising quantitative and qualitative researches. In case you give us your consent, your personal data such as name, surname, e-mail address and phone number will be used to invite you to participate in surveys. You may withdraw your consent at any time in your Trafi account.

2.3 The Company provides full support regarding its services and those of the Transportation Providers. In case you have any issues, problems or concerns, you may contact the Company by e-mail support@trafi.com or via Trafi internal message system.

3. Profiling

3.1. Data of the searches you made, with your prior express consent, will be used for Trafi user profiling purposes. Trafi profiling is carried out in order to offer you the most convenient and optimal way of traveling, depending on your habits of usage of Trafi.

3.2. In case you do not agree to profiling actions in relation to you, upon logging in to Trafi, we will abstain from them and this will not prevent you from using any of Trafi’s services.

3.3. In case you do not agree to profiling actions in relation to you, upon logging in to Trafi, but you would like to have these services at any time in the future, you will be able to do that by selecting the appropriate option in your Trafi account.

3.4. You have the right to withdraw your consent to the analysis of your use of Trafi and with the presentation to you of travel offers depending on your habits at any time. You will be able to do this by writing an e-mail to Trafi Data Protection Officer at privacy@trafi.com or by selecting the appropriate option in your Trafi account. Having exercised this right, you will continue to be able to use Trafi services without limitation.

4. Age limit

4.1. The information available on Trafi can be used by people of all age groups. Regardless of the age of a person, he/she may download Trafi and access all the information contained therein, purchase public transport tickets and use ride hailing services.

4.2. If you want to use car sharing services, you must be at least 18 years of age and meet other requirements specified in the contracts and regulations for each service offered.

4.3. In case you associate your existing third-party accounts with Trafi (for example, Uber), you must meet the age requirements applicable by those third parties as well as other requirements set by the said persons.

4.4. In case you are under 16 years of age, the above profiling actions will not apply to you.

5. Use of cookies and similar technologies

5.1. By using cookies on the trafi.com website, the country where you are located is stored in order for you to be shown the Trafi information relevant to your country.

5.2. You shall also have an option to save your work and residence addresses. We use a different type of cookies (known as LocalStorage) for you to be able to access the said addresses on your device.

5.3 You have no right to scan, copy or use, for any other purposes than using Trafi as established by these Conditions, any information or the integral part hereof provided to you while using Trafi or in the Company’s Web page www.trafi.com.

6. For how long will your information be stored?

6.1. Personal data that we are processing for any purpose or purposes cannot be stored for longer than necessary for that particular purpose or purposes.

6.2. In order for us to be able to provide the services of Trafi, the data you have provided will be stored for 3 (three) years from the time when you provided us with the necessary information or the last time you used our services.

6.3. The data you have provided for the purpose of the analysis will be stored for 3 (three) years from the date you provided us with the required information or the last time you used our services.

6.4. The data you have provided for the marketing purposes will be stored for 3 (three) years from the time when you provided us with the information required, or the last time you used our services, or until you have opted out of processing your data for marketing purposes.

6.5. The data you have provided for the purposes of research will be stored for 3 (three) years from the date you provided us with the information required, or the last time you used our services, or until you have opted out of processing of your data for the purpose of research.

6.6. Taking into account the relevant provisions of the Republic of Lithuania Law on the Prevention of Money Laundering and Terrorist Financing, the data relating to financial transactions will be stored for 10 (ten) years from the last time you used our services.

6.7. The above cookies that save your country will be stored for 1 (one) year from your first visit to the website trafi.com.

6.8. Your saved residence and work addresses noted on the website are stored in your browser, so they are only controlled by you and can be removed using your browser settings.

6.9. We make reasonable efforts to ensure protection of your personal information.

6.10. After the expiry of the relevant period for storage of data, we undertake to destroy the information you have provided.

7. Your rights

7.1. Except where the GDPR or the relevant laws provide for exceptions, you have the following rights in relation to your personal data:

7.1.1. The right to access your personal data. You have the right to apply to the Controllers with a free-form request for access to your personal data. Upon receipt of this request, the Controllers will provide you with a copy of the information relating to you, as well as explain to you why and how they are processing the said information. During your use of Trafi, the data related to your browsing of Trafi are collected, as well as the internal technical data of the service. Taking into account the fact that such data are more of a technical nature and large-volume, we will provide you with these if you would request for a more detailed information;

7.1.2. The right to request that the Controllers corrected, supplemented or erased any of your personal data should they be inaccurate or incomplete;

7.1.3. The right to demand that your personal data be erased when the Controllers no longer need to store such data ("the right to be forgotten");

7.1.4. The right to restrict data processing, after you challenge the accuracy of the data, the processing is unlawful and you oppose the erasure of the personal data, we no longer need the data for the purposes of processing them, but they are necessary for the exercise or defence of legal claims, or, after you have objected to processing of the data, some time is needed to verify whether the grounds stated by you are not overridden by legitimate grounds for the processing?

7.1.5. The right to request to be provided with your personal data and, if possible, to transfer the said data directly to another data controller;

7.1.6. The right to withdraw your consent to the processing of personal data at any time when the processing of the data is based on your consent or the existence of a legitimate interest;

7.1.7. The right to object the processing of your personal data;

7.1.8. The right to lodge a complaint to the relevant data protection authority according to the address of one's place of residence or work, as well as the place of the Controller’s data processing, which is the Republic of Lithuania, or the place of the infringement. In Lithuania, this service is the State Data Protection Inspectorate.

7.1.9. You have the right to order us at any time to discontinue the use of your personal information for marketing purposes.

7.1.10. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

7.2. Relevant actions will be taken no later than within 30 (thirty) calendar days from the date of referral. The provision of information can be done free of charge no more often than once a calendar year.

7.3. To exercise your rights, you may contact us at privacy@trafi.com.

8. Third party services

8.1. The Controllers have entered into agreements with data processors who take care of security of your personal data. The data processors Google inc. and Amazon Web Services, engaged by us, ensure security of your personal data, the appropriateness of their systems and operations is confirmed by relevant ISO standards and recognized in the European Union.

8.2. Your personal data will be kept strictly confidential and will only be provided to the service providers who have concluded contracts with the Controllers. The information we disclose to third parties listed below is not excessive, given the services provided by the said third parties:

8.2.1. Your ID, your hardware and application IDs, the actions taken, their time, hardware model, operating system name, your continent, state, region, and city of residence are used in the applications Fabric, Localytics, Adjust, and Branch for pursuing Trafi’s analytics goals and monitoring of performance;

8.2.2. Trafi-related financial transactions are handled by our payment service provider Adyen. We share the details of your payments with the respective service providers participating in Trafi only to the extent necessary for processing your payments and handling complaints and managing issues related to such payments;

8.2.3. Adyen’s services are used as payment gateways; therefore, we do not collect any of your personal data related thereto. When making payments for Trafi or third-party services, you are using Adyen’s services and providing your information directly to it.

8.3. Our Privacy Policy applies only during your operation and use of Trafi. If you will leave Trafi or will be redirected to third-party services, such as a payment section, our Privacy Policy will no longer be in force and you will not be subject to it.

8.4. In no way shall we be responsible for the content of other websites or applications.

9. Disclosure of information

9.1. We endeavour to ensure that the information provided to us is confidential, and therefore we shall not have the right to disclose your personal data to other data recipients, during normal use of Trafi, unless it is necessary for proper implementation of Trafi services or protection of legitimate interests.

9.2. When you order public transport, ride hailing, car sharing or other mobility services, you shall be using the services of transport service providers (for more, see "Terms of Use"). We will provide to service providers your mobile phone number, e-mail address, name, surname, date of birth, address of the place of residence, details of payments and the use of the respective services in case of any dispute concerning the user of their services or where it is necessary when providing to you the services you have ordered. A more detailed description of the use and provision of the data is provided in the relevant terms for the provision of the service and/or contracts.

9.3. If you violate the terms of use of Trafi or if required by law, we shall have the right to disclose information about you to the competent authorities. We may disclose your personal data to professional advisers who are reasonably required for us to obtain professional advice, to investigate or defend legal disputes in court proceedings and administrative proceedings as well as extra-judicial procedures.

10. Changes to the privacy policy

10.1. We reserve the right to change this Privacy Policy at any time and without prior notice. As any new changes to it shall take effect from the time they are published on Trafi, you should revisit it regularly.

10.2. In the event of updates to this Privacy Policy, we will send you an internal message through Trafi.

10.3. If we intend to use your personal data for a new purpose that is not covered by this Privacy Policy, we will present a notice explaining this new use before we begin the new processing actions, by specifying the relevant purposes and terms of processing. In case we need to, we will seek to obtain your prior consent to the new use of personal data.

11. Settlement of disputes

11.1. Any dispute relating to at least one of the Controllers, their services and Trafi’s activities shall be resolved by negotiations between you and the Controllers, upon applying by e-mail to privacy@trafi.com.

11.2. Given the fact that data processing is carried out in Lithuania, the State Data Protection Inspectorate of the Republic of Lithuania shall be considered to be the responsible supervisory authority.

11.3. If a dispute would reach the court, the laws of the Republic of Lithuania would apply and the dispute would be heard by a competent court of the Republic of Lithuania.

12. Contact information

Trafi Ltd.
Legal entity code 9326640
Address of the registered office WEWORK SOUTH BANK CENTRAL, 30 Stamford Street, London SE1 9LQ, United Kingdom.

UAB “Intelligent Communications”
Legal entity code 300882953
Office address Labdarių g. 5, Vilnius, Lithuania.
Shared e-mail address of the Controllers for the matters of data protection privacy@trafi.com