We, Catalina Software Ltd (“we” “our” or “us”) with our registered office address at Milton Hall, Ely Road, Milton, Cambridge CB24 6WZ are fully committed to respecting your privacy and to protecting any information you provide to us or that we receive about you from our client operator companies ("Catalina Clients"). We treat both privacy and security as a priority and make every effort to ensure that all the information provided by you is safe, secure and protected.

This Data Protection Notice (the "Notice") exists to respect and protect the privacy of all users of the services provided by us (the "Catalina Services") and is intended to inform you about the way that we treat your personal data

1. Scope of Notice

This Notice applies in relation to the processing by Catalina Software Ltd of your personal data as a controller and in particular to your use of, or engagement with our software application (the "Freedom GoX App");

This Notice sets out the basis on which any personal data we receive or collect about you in connection with your use of the Catalina Services ("Personal Data"), will be processed by us or by our third-party service providers.

For the purpose of the EU General Data Protection Regulation (the "GDPR"), we are the controller of your Personal Data in certain circumstances (as outlined below).

Client Services - to the extent that your Personal Data is collected by Catalina Clients in connection exclusively with the provision of their separate operator company services (the "Client Services"), the Catalina Client shall be the controller of your Personal Data. Further information regarding the collection and processing of your Personal Data by the Catalina Client is set out in the Catalina Client Passenger Data Protection Notice which we recommend you read in detail before using the App. This Client Passenger Data Protection Notice is available from the Freedom GoX App.

Catalina Services - to the extent certain categories of your Personal Data are shared with or collected by Catalina for purposes of or in connection with the Catalina Services as more particularly detailed below, Catalina shall be a controller of your Personal Data and your Personal Data shall be processed in accordance with this Notice.

2. Your Personal Data Collected and Processed by Catalina:

IMPORTANT: Please note that the below list of Personal Data, while intended to be as complete and accurate as reasonably possible, is merely indicative and not exhaustive and may be updated from time to time.

Catalina typically receives and processes some or all of the following Personal Data about you:

Data Collected
Information Input	Information provided when you engage with Catalina Clients to use the Client Services and the Catalina Services, create an account through the App, download or install the App, and when you report a problem with the Catalina Services, App or Website or when you correspond with Catalina or Catalina Clients generally in connection with your use of the Services. The information you provide to Catalina Clients may include but is not limited to your name, address, e-mail address, phone number, age, date of birth, username, password and other registration information, financial and credit card information, [photograph] and gender.
Device Info	Technical information including but not limited to the type of device you use, a unique device identifier (for example, network information, your operating system, time zone setting and device locale).
Log Data	Details of your use of the Catalina Services including, but not limited to weblogs and/or other communication data and the resources that you access.
Location Data	Depending on how you choose to use the Catalina Services (that is, whether through use of our App, Website or by contacting Catalina Clients or Catalina Software Ltd through other means), we may collect details of your location data to determine your current location.
Information we receive from other sources	Catalina may receive certain information (both from Catalina Client and from third party service providers) about you that they choose to disclose with us. This information may include your name, email, address and location.
Transaction Data	Catalina may receive transaction details related to your use of the Catalina and/or Client Services, including the type of services you requested, your order details, delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. Catalina and Catalina Clients may also record details as to whether or not a taxi journey is cancelled by you.
Usage Data	Catalina Clients may share information with Catalina about how you interact with the Client Services. This includes information such as access dates and times, App features or pages viewed, App crashes and other system activity, type of browser, and third-party sites or service you were using before interacting with the Client Services. We use Adflex for payment, analytics, and other business services. Adflex collects identifying information about the devices that connect to its services. Adflex uses this information to operate and improve the services it provides to us, including for fraud detection. You can learn more about Adflex and read its privacy policy at Adflex Privacy Policy.

3. Legal Bases and Purposes

Where your Personal Data is used for the purposes of the Catalina Services (e.g. for taxi tracking, fraud prevention and credit risk reduction purposes) Catalina shall be a controller and process your Personal Data for the purposes and on the bases set out below:

Legal Basis

Legitimate Interests

Purposes

It is in Catalina’s legitimate interests to collect and process the personal data for the following purposes: To facilitate the Catalina Services being provided to you through utilisation of Catalina software. To protect the rights, property or safety of you, or others (this includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction). To monitor metrics such as total number of visitors, traffic and demographic patterns. To prevent, detect and combat fraud in connection with the use of the Catalina Services. For example, Catalina uses user profile, location, device and usage information, to identify and prevent circumstances when users attempt to defraud other users. To carry out analysis and research on usage trends & traffic. This includes, for example, predicting demand and trends, to improve the user experience, and to enhance the safety and security of the Catalina Services. You have the right to object at any time to the processing of your personal data carried out on the above basis. When Catalina processes your personal data based on legitimate interests, it makes sure to consider and balance any potential impact on you and your data protection rights. Catalina will not process your personal data for activities where its interests are overridden by the impact on you.

Legal Basis	To Comply with a Legal Obligation
Purposes	Catalina may process your Personal Data as necessary in order for it: To comply with applicable UK law. To comply with requests from regulators, government entities and official inquiries.

4. Disclosure of Your Information to Third Parties

Where Catalina acts as a controller of your Personal Data, Catalina may disclose some or all of the Personal Data it holds about you to the following third parties:

Recipient

Law Enforcement Agencies: Catalina may disclose your information if it is under a duty to disclose or share your Personal Data in order to comply with any legal or regulatory obligation or request.

Buyers and Sellers of Business Assets: If Catalina or substantially all of its assets are acquired by a third party, personal data held by it about its customers will be one of the transferred assets.

Catalina Group: Catalina may disclose your personal information to other members of its group, which means its subsidiaries, its ultimate holding company and its subsidiaries.

5. Links to Third Party Websites

The App or Website may contain links to and from the websites of Catalina Software Ltd and/or Catalina Software Ltd Client partner networks, advertisers and service providers. If you follow a link to any of these websites, please note that these websites and any services that may be accessible through them have their own data protection notices and that Catalina Software Ltd and Catalina Software Ltd Clients do not accept any responsibility or liability for these notices or for any Personal Data that may be collected through these websites or services, such as contact and location data. Please check these notices before you submit any personal data to these websites or use any such third party services.

6. Catalina Software Ltd Use of Statistical Information

Catalina Software Ltd may log certain information concerning your use of the App or Website in relation to activities connected with the use the Catalina Software Ltd Services. This information is logged for the purpose of providing the Catalina Software Ltd Services. The information gathered is then aggregated and anonymised.

From the anonymised information collected, statistics may be compiled in the form of percentages and/or figures relating to users’ interaction with the Catalina Software Ltd Services. As a service, certain anonymised statistical information may be supplied to third parties in order to help them understand the likes, dislikes, trends, habits and behaviour of Catalina Software Ltd Service users.

7. Storing and Transfers of Your Personal Data

The Personal Data collected from you may be transferred to, and stored at, a destination outside the European Economic Area ("EEA"). It may also be processed by staff or contractors operating outside the EEA who work for us or for one of our suppliers.

Your Personal Data is only transferred outside the EEA where the EU Commission has decided that the third country in question ensures an adequate level of protection in line with EU data protection standards OR there are appropriate safeguards in place to protect your personal data.

All information that is shared with and controlled by Catalina Software Ltd is stored on our secure servers or the servers of our service providers, contractors or suppliers. Where we have given you (or where you have chosen) a password that enables you to access the App or Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8. How Long We Keep Your Personal Data For

Catalina Software Ltd will keep your Personal Data for as long as you use the App or Website and after you delete your account for a reasonable period not exceeding 7 years.

Please note that in certain circumstances, Catalina Software Ltd may hold your Personal Data for a longer period, for example, if we are processing an ongoing claim or believe in good faith that the law or a relevant regulator may reasonably in our view expect or require us to preserve your data.

9. Your Rights & How to Exercise Them

You have a number of rights in relation to your Personal Data which are set out in this Section

In particular these rights include the right to object to processing of your personal data where that processing is carried out for our legitimate interests. Note that in certain circumstances, these rights might not be absolute.

Right	Further Information
Right to be Notified	You have the right to know whether your Personal Data is being processed by us, how we use your personal data and your rights in relation to your personal data.
Right of Access	You have the right to request a copy of the personal data held by us about you. We will only charge you for making such an access request where we feel your request is unjustified or excessive. You may also access your personal data by logging into your account on the App or Website and viewing your profile.
Right to Rectification	You have the right to request that we amend any inaccurate personal data that we have about you.
Right to Erasure	You have the right to ask us to erase your Personal Data where: It is no longer necessary to perform the contract you withdraw your consent and there is no other legal basis permitting us to process your personal data you object to the processing and we have no overriding legitimate grounds your personal data have been unlawfully processed; or it must be erased to comply with a legal obligation. Please note that some of your personal data may be required in order for the App to function correctly.
Right to Restriction of Processing	You have the right to ask us to restrict processing your personal data in the following situations: where you contest the accuracy of your personal data where the processing is unlawful and you do not want us to delete your personal data where we no longer need your personal data for the purposes of processing but you require the data in relation to a legal claim where you have objected to us processing your personal data pending the verification as to whether or not our legitimate interests override your interests or in connection with legal proceedings. When you exercise this right we may only store your personal data. We may not further process the data unless you consent or the processing is necessary in relation to a legal claim or to protect the rights of another person or legal person or for reasons of important public interest. Please note that it be may necessary for us to process some of your personal data in order to provide the App or Website and in certain instances where you ask us not to process your personal data you may not be able to use the App or Website. We will inform you before the processing restriction is lifted.
Right to Data Portability	You may request us to provide you with your Personal Data which you have given us in a structured, commonly used and machine-readable format and you may request us to transmit your Personal Data directly to another controller where this is technically feasible. This only arises where: we process your personal data on the legal bases of your consent or where it is necessary to perform our contract with you; and the processing is carried out by automated means.
Right to Object	You have a right to object at any time to the processing of your Personal Data where we process your Personal Data on the legal basis of pursuing our legitimate interests.
Right to Object to Automated Decision- Making, including Profiling	You have a right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you. We may not be able to comply with this request where the processing is necessary to enter or perform our contract with you or where you explicitly consent to this. However, you are entitled to have a person from our team to review the decision so that you can query it and set out your point of view to us.

If you wish to submit a request to Catalina Software Ltd to exercise any of the above rights, please submit a request in writing to support@catalina-software.co.uk

10. Age Restriction

Individuals under the age of 18 are not eligible to use the Services and must not attempt to register and/or submit any personal information to us. We do not knowingly collect personal information from any person who is under the age of 18 or allow them to register. If it comes to our attention that we have collected personal data from a person under the age of 18, we will delete this information as soon as reasonably possible. If you have reason to believe that this has occurred, please contact us at support@catalina-software.co.uk

11. Changes to the Data Protection Notice

Any material changes we may make to the Notice in the future will be notified to you by pop- up notification when you next start the App or visit the Website. The new Notice may be displayed on-screen and you may be required to read and accept them to continue your use of the App or the Website.

12. Questions Regarding This Notice

If you have a comment, request or question regarding Catalina Software Ltd's processing of your Personal Data, please contact support@catalina-software.co.uk Any questions regarding the processing by Catalina Software Ltd Clients of your Personal Data should be directed to the contact details set out in the relevant Catalina Software Ltd Client's data protection notice available from the Catalina Software Ltd Client (Operator)