Privacy Notice

Last update Aug 2023

  1. Introduction

  2. When you use Hwilo , you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data.

  3. Overview

  4. This notice applies to users of Hwilo’s services anywhere in the world, including users of Hwilo’s apps, websites, features, or other services.

    This notice describes how Hwilo and its affiliates collect and use data. This notice applies to all Hwilo users globally, unless they use a service covered by a separate privacy notice, Riders: individuals who request or receive transportation and related services via their Hwilo account.

    Customers; or data of individuals who start but do not complete their applications to be drivers.

    All those subject to this notice are referred to as “users” in this notice.

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

  5. Data controller and transfer

  6. Hwilo Technologies Inc. is the data controller for the data collected in connection with use of Hwilo’s services everywhere else.

    Hwilo Technologies Inc. is the data controller for the data collected in connection with use of Hwilo’s services everywhere else Hwilo operates, and processes personal data, globally; wherever and whenever you travel, your data travels with you so we can offer you a seamless experience. We also respect your data protection rights whether you are in your home country or elsewhere.

    This means that we may transfer personal data to countries other than your home country in order to provide our services in a different country at your request. We may also transfer personal data to another country if that is necessary to respond to a customer support request that you submitted outside your region. And trip/order histories may be accessed by users in another country after they have left the country where services were rendered. Because our services involve multiple users at the same time, limited personal data may be accessible to the other user in another country.

    We do so in order to fulfill our agreements with all of our users, or based on users’ instructions or prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

    We may also transfer data to other countries in order to respond to a request for personal data from a law enforcement agency. To provide additional safeguards to these data transfers, Hwilo applies a robust internal procedure for processing these requests. Hwilo only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the GDPR

    To help provide equivalent data protection wherever you use our services, Hwilo has implemented the following measures across the globe:

    policies and procedures to limit access to, and the processing of personal data for defined purposes; specific training of personnel responsible for managing personal data;

    a government data access policy that refuses government access to data, except when disclosure is mandated by applicable laws including the EU GDPR, there is imminent risk of serious harm to individuals, or consent is obtained;

    robust protection of data while it is in transit between Hwilo apps and our servers, and when the data is processed on our servers. This includes encryption and the use of pseudonymized data to help protect users' full identity against unauthorized disclosure.

    For your convenience, the exercise of your data protection rights can be directed to Hwilo via any of the designated channels mentioned above, and will be handled centrally on behalf of the relevant controller. Questions, comments, and complaints about Hwilo’s data practices can be submitted here. You may also use this form to submit a question to Hwilo’s Data Protection Officer and to ask us for a copy of the Standard Contractual Clauses or other transfer mechanisms in place for the data processing activity of your inquiry.

  7. Data collections and uses

  8. Hwilo collects the following data:

    1. Data provided by users.

    2. This includes:

      User profile information: We collect data when users create or update their Hwilo accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government issued documents (which may include identification numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and evidence of health or fitness to provide services using Hwilo apps.

      Background check information (drivers and delivery persons): This includes information submitted during the driver/delivery person application process, such as driver history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by an authorized vendor on Hwilo’s behalf. Identity verification photos: This includes photos of users (such as, selfies) and/or their government issued identifications (such as, driver’s license or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies. Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification.

      Demographic data: We may collect demographic data about users, such as birth date/age, gender or occupation, when required for certain Hwilo services or programs, such as Hwilo Cash or safety features that allow women users to set a preference to provide or receive services to/from other women (“Women Rider Preference”). We may also collect demographic data, such as age group and household composition, through user surveys, and use this information to offer Hwilo products and services that are likely to be of interest to you.

      We may also infer demographic data from other data collected from users. For example, we may infer a user’s gender based on their first name to enable safety features, such as the Women Rider Preference, or to display personalized ads for third party products or services. See the section titled “How we use personal data” below for more information. User content: We collect the data submitted by users when they contact Hwilo customer support (including at Hwilo Greenlight Hubs or via phone chat or video conferencing tools), provide ratings or feedback for other users, restaurants or merchants, or otherwise contact Hwilo. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also includes metadata relating to the method you use to communicate with Hwilo.

      In certain jurisdictions, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In-app recordings are encrypted and stored on users’ devices, and are only shared with Hwilo if submitted by the users in connection with safety incidents. Please see here for more information.

    3. Data created during use of our services.

    4. This includes:

      Location data (driver and delivery person): We collect precise or approximate location data from drivers’ and delivery persons’ mobile devices when the Hwilo app is running in the foreground (app open and on-screen) or background (app open but not on-screen). Location data (riders and order recipients). We collect precise or approximate location information from riders’ and order recipients’ mobile devices if they enable us to do so via their device settings.

      Hwilo collects such data from the time a ride or order is requested until it is finished, and any time the app is running in the foreground (app open and on-screen). See “Choice and transparency” below for information on how riders and order recipients can enable precise location data collection.

      Riders and order recipients may use the Hwilo apps without enabling collection of location data from their mobile devices. However, this may affect certain features in the Hwilo apps. For example, a rider who has not enabled precise location data will have to manually enter their pickup address.

      In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.

      Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop off addresses, distance traveled and items ordered); and payment transaction information (such as a restaurant’s or merchant's name and location, amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code.

      Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity. Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

      Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Hwilo’s apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.

    5. Data from other sources. These include:

    6. users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s data from that user. Hwilo account owners who request services for or on behalf of other users (such as friends or family members), or who enable other users to request or receive services through their business accounts users or others providing information in connection with claims or disputes. Hwilo business partners through which users create or access their Hwilo account, such as payment providers, social media services, or apps or websites that use Hwilo’s APIs or whose APIs Hwilo uses. Hwilo business partners in connection with debit or credit cards issued by a financial institution in partnership with Hwilo to the extent disclosed in the terms and conditions for the card. vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements. insurance, vehicle, or financial services providers for drivers and/or delivery persons. partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company). publicly available sources. marketing service providers or data resellers whose data Hwilo uses for marketing or research. law enforcement officials, public health officials, and other government authorities.

      • How we use personal data
      • Hwilo uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:

        • to enhance the safety and security of our users and services
        • for customer support
        • for research and development
        • to enable communications between users
        • for marketing and advertising
        • to send non-marketing communications to users
        • in connection with legal proceedings
        • For your convenience, we've provided a visual summary of the data we collect and how we use it here.

      • We use the data we collect:
        • To provide our services.
        • Hwilo uses data to provide, personalize, maintain, and improve our services.

          This includes using data to:

          • create/update accounts.
          • enable transportation, delivery and other services/features, such as:
            • using location data to navigate rider pick-ups and order drop-offs, calculate ETAs, and track the progress of rides or deliveries. features that involve data sharing, such as sharing driver first name and vehicle information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and fare splitting, and user ratings and compliments.
            • match available drivers and delivery persons to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to accept a trip based on their past behavior or preferences.
            • features that facilitate use of our services by those with disabilities.
            • features that involve account linking, such as linking of email to create
          • enable dynamic pricing, in which ride prices, or delivery fees are determined based on factors such as estimated time and distance, predicted route, estimated traffic, and the current number of users requesting or providing services.
            • process payments.
            • personalize users’ accounts. For example, we may present order recipients with personalized restaurant or food recommendations based on their prior orders.
            • facilitate insurance, vehicle, invoicing, or financing solutions.
            • provide users with trip or delivery updates, generate receipts, and inform them of changes to our terms, services, or policies.
            • perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.

          Hwilo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, are compatible with such uses, or on the grounds that they are necessary for purposes of Hwilo’s and its users’ legitimate interests.

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

          • verifying users' identity and eligibility to provide transportation or deliveries, including through reviews of background checks, to help prevent use of our services by unsafe drivers and/or riders.

            In certain regions, this includes Hwilo’s Real-Time ID Check feature, which prompts drivers and delivery persons to share a selfie before going online to help ensure that the driver or delivery person using the app matches the Hwilo account we have on file. We may also use this feature for other verification purposes such as verifying change of bank account information or regaining account access.

            In addition, we may use facial recognition technology to process user profile photographs, identification photographs, or other user-submitted photographs to prevent identity-borrowing or use of our services by unauthorized drivers or delivery people.

            We may also use selfies to verify that users are wearing masks, helmets or other safety gear through the use of object verification technology.

            In some countries, riders may be required to verify their identity to use cash and certain other payment methods. In such cases, Hwilo allows riders to provide their ID number and/or a photo of their identification card to complete such verifications. Please see here for more information about rider identity verification.

          • using data from drivers’ or delivery persons’ devices to detect unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.
          • using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pickup in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee.
          • using device, location, user profile, usage, and other data to prevent, detect, and combat other types of fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized drivers or delivery persons, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts. In some cases, such as when a user is determined to be abusing Hwilo’s referral program or has submitted fraudulent documents, such behavior may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review.
          • using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries. (This data use is not performed in Switzerland and Belgium). In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal. For more information about how ratings are determined and used, please see here for rider ratings, here for driver ratings, and here for delivery person ratings.
          • using driver data (such as past trip information and reported incident rates) and rider data (such as past trip information, cancellation and reported incident rates, account information, ratings information, and current pick-up and drop-off location) to predict and help avoid pairings of users that may result in increased risk of conflict (for instance, because one user previously gave the other a one-star rating).
          • sharing user name, location, phone number, vehicle details and other relevant information with third-party companies that support the management and de-escalation of interpersonal conflicts that may occur between users while on a trip or in the process of making a delivery.

          Hwilo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Hwilo, our users and members of the general public.

        • Customer support.
        • Hwilo uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.

          Hwilo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users or for purposes of Hwilo’s legitimate interest in monitoring and improving its customer support services.

        • Research and development.
        • We use data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our services, and develop new services and features.

          Hwilo performs the above activities on the grounds that they are necessary for purposes of Hwilo’s legitimate interests in improving and developing new services and features.

        • Enabling communications between users.
        • For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item, or a restaurant or delivery person may contact an order recipient with information about their order.

          Hwilo performs the above activities on the grounds that they are necessary to fulfill the terms of our agreements with users.

      • Marketing and Advertising.
      • Hwilo uses data (other than Guest Users’ data) to market its services, and those of Hwilo partners.

        This may include:

        • Sending emails, text messages, push notification, and in-app messages or other communications marketing or advertising Hwilo products, services, features, offers, promotions, sweepstakes, news and events.

          This may include using location, trip and order history, device data and usage data to send marketing communications that are personalized based on users’ observed or inferred interests and characteristics. For example, we may send push notifications suggesting a user’s favorite destinations or merchants, or in-app messages offering discounts or promo for products or merchants similar to those a user has previously ordered. Displaying Hwilo advertising on third party apps or websites. This includes using location, trip and order history, device data and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners (such as Facebook and TikTok), to personalize such ads to users’ interests.

        • Displaying third party advertising in Hwilo’s apps or in connection with our services.
          • This includes ads for restaurants or merchants that are available on Hwilo’s apps. These ads (which are identified as “Sponsored Listings'' in Hwilo’s apps) include recommendations that are personalized based on users’ location and order histories.
          • This also includes ads for other third party products or services that are personalized based on users’ observed or inferred interests and characteristics, which we determine using data such as approximate location, trip information and history, usage data, demographic data (which may include inferred gender), and device or user identifiers.
          • This also includes ads that are personalized based on data about the current trip or delivery request, including time of request and services requested. For example, if a user requests a trip to a supermarket, we may display in-app ads for third party products that may be available at that supermarket.
        • Measuring the effectiveness of Hwilo’s ads, and of third party ads displayed in Hwilor’s apps or in connection with our services.

        Hwilo performs the above activities on the grounds that they are necessary for purposes of Hwilo’s legitimate interests in informing users about Hwilo services and features or those offered by Hwilo partners. See the sections titled “Choice and transparency” and “Marketing and advertising choices'' for information on your choices regarding how Hwilo may use your data for marketing and advertising.

      • Non-marketing communications.
      • Hwilo may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Hwilo or its partners.

        We may also send users communications regarding elections, ballots, referenda, and other political processes that relate to our services.

        For example, Hwilo has notified some users by email of ballot measures or pending legislation relating to Hwilo’s services in those users’ areas.

  9. Cookies and third-party technologies

  10. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements.

    Hwilo uses cookies and similar technologies for purposes such as:

    • authenticating users
    • remembering user preferences and settings
    • determining the popularity of content
    • delivering and measuring the effectiveness of advertising campaigns
    • analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our services
    • 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 the devices used by visitors to our websites, as well as when they visit other online sites and services.
    We use the following Tracking Technologies for the purposes described in this Notice:
    • “Cookies” are small text files that are placed and stored on your browser when you visit a website, or on your device when you use an app. They may be created and placed by either the website or app you are visiting (in which case they are referred to as “first party” cookies), or by websites or apps other than the one you are visiting (in which case they are referred to as “third party cookies”). We use both “session cookies,” which expire when you close your browser, and “persistent cookies,” which expire after a set period of time (even if you close your browser).
    • “Pixel tags” (also called beacons) are small blocks of code placed on webpages, apps, emails or ads that enable us to identify users when providing our Services and track interactions with our Online Properties.
    • “Software Development Kits” (also called SDKs) are blocks of code that are functionally similar to cookies and pixel tags, except for mobile apps. SDKs allow their developers to collect information about the device and network you use to access our apps, and about your interaction with ours apps.
    • “Local storage” refers to files that are created by apps or websites, and stored on your device or browser. Such files function similarly to cookies.

  11. Data sharing and disclosure

  12. Some of Hwilo’s services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

    Hwilo may share data:

    1. With other users

      This includes sharing:

      • riders’ first name, rating, and pickup and/or dropoff locations with drivers.
      • riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the dropoff location of the other riders.
      • order recipients’ first name, delivery address, and order information with the restaurant or merchant and, for order deliveries, with the delivery person. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant or merchant and, for order deliveries, the delivery person.
      • for drivers and delivery persons, we may share data with the rider(s), order recipient(s) and restaurants or merchants, including name and photo; vehicle make, model, color, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver or delivery person; contact information; and driver or delivery person profile, including compliments and other feedback submitted by past users.

      We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person first name, photo, and route map. We also include other information on those receipts if required by law.

      for those who participate in Hwilo’s referral program, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

    2. At the user’s request

      This includes sharing data with:

      • Other people at the user’s request.

        For example, we share a user’s ETA and location with a friend when requested by that user, or a user’s trip information when they split a fare with a friend.

      • Hwilo business partners.

        For example, if a user requests a service through a partnership or promotional offering made by a third party, Hwilo may share certain data with those third parties.

        This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or restaurants, merchants or other Hwilo business partners and their users in connection with promotions, contests, or specialized services.

      • Emergency services.

        We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.

    3. With the general public

      Questions or comments from users submitted through public forums such as Hwilo blogs and Hwilo social media pages may be viewable by the public, including any data included in the questions or comments submitted by a user.

    4. With the Hwilo account owner

      If a user receives services through an account owned by another party, we may share their trip or order information, including location data, with the owner of that account.

      This occurs, for example, when:

      • a rider uses their employer’s Hwilo for Business profile, such as when they take trips arranged through Hwilo Central.
      • a driver or delivery person uses an account owned by or associated with an Hwilo partner transportation company or restaurant.
      • a rider takes a trip or a delivery recipient receives an order arranged by a friend or under a family profile.
      • a delivery person acts as a substitute (UK only).

      In addition, if a user creates an account using an email address affiliated with an Hwilo for Business account owner (i.e., their employer), we may use, and share their profile data (such as name and email address) with such account owner, to help that user expense trips or orders to that Hwilo for Business account. This is applicable in all regions except the European Economic Area, the United Kingdom and Switzerland.

    5. With Hwilo subsidiaries and affiliates

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

  13. Data retention and deletion

  14. Hwilo retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations.

    Hwilo retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

    The length for which Hwilo retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

    For example, we retain data:

    • for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
    • for 7 years if necessary to comply with tax requirements. E.g., drivers’ and delivery persons’ trip or delivery location information.
    • for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete driver applications for 1 year, and rejected driver applications for 7 years.
    • after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved claim or dispute).
    • Users may request deletion of their accounts at any time. Hwilo may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.

    Users may request deletion of their account at any time through the Hwilo app, or through email request ([email protected])

    Following an account deletion request, Hwilo deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

  15. Choice and transparency

  16. Hwilo enables users to access and/or control data that Hwilo collects, including through:

    • device permissions
    • in-app ratings pages
    • marketing choices

    Hwilo also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Hwilo restrict its processing of user data.

    1. Device permissions

      Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.

    2. In-app ratings pages

      After every trip, drivers and riders are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transportation, and driver ratings are available to their riders.

      This 2-way system holds everyone accountable for their behavior. Accountability helps create a respectful, safe environment for drivers and riders.

      Riders can see their average rating in the Hwilo Riders app.

      Drivers can see their average rating in the Hwilo Driver app.

Updates to this notice
We may occasionally update this notice.
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the Hwilo apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices.
Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.