- Your use of the HYPR website www.hypr.life;
- Your application to become a member of HYPR;
- Your membership of HYPR (if your application is approved)
- Your use of HYPR Drive;
- The HYPR mobile application software (HYPR App) made available on iTunes (and later on Google Play) (App Site), once you have downloaded copy of the App onto your handheld device (Device).
This policy sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
HYPR membership is not intended for children and we do not knowingly collect data relating to children. Please read the following carefully to understand our practices regarding your personal data and how we will treat it.
This policy is provided in a layered format so you can click through to the specific areas set out below.
- Important information and who we are
HYPR Drive Limited is the data controller and is responsible for your personal data (collectively referred to as “Company”, “we”, “us” or “our” in this policy).
Our full details are:
- Full name of legal entity: HYPR Drive Limited, a limited company registered in England with company number 10774888
- Our registered office is at 48 Charlotte Street, Fitzrovia, London, England, W1T 2NS
- Name or title of data privacy manager: Charlie Clamp, Head of Technology
- Email address: email@example.com
- Postal address: 48 Charlotte Street, Fitzrovia, London, England, W1T 2NS
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues or other competent supervisory authority of an EU member state if the App is downloaded outside the UK.
If you do have any questions or concerns relating to our use of your personal data, we would appreciate the opportunity to look into and resolve your question or concern before you make a complaint to the supervisory authority.
This version was last updated on 13 November 2019.
It may change and if it does, these changes will be posted on this page and, where appropriate, notified to you by email or when you next start the App or log onto one of the Services Sites. The new policy may be displayed on-screen and you may be required to read and accept the changes to continue your use of the App or the Services.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you by updating your details on your HYPR account profile page.
- Third party links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
- Understanding the data we collect about you
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data – this is your first name, last name, username or similar identifier, title, date of birth, gender, and social media account names provided by you.
- Contact Data – this is your billing address, your pick up address and drop off address when you use HYPR Drive, your email address and telephone number.
- Payment Data – this is your debit/credit card details as requested by our third-party payment service provider.
- Transaction Data – these are details about payments to and from you and details of in-App purchases, journey data made by you on the HYPR APP
- Device Data – includes the mobile phone number used by the Device
- Content Data – this includes information you supply us such as your profile photo.
- Profile Data – this includes your username and password, in-App purchase history, feedback and survey responses.
- Usage Data – this includes details of your use of the HYPR App or your visits to any of Our Sites including, but not limited to, traffic data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data – includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data – includes your location disclosed by GPS technology in your handheld device which has downloaded the HYPR App.
We explain when we use these categories of data below.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) other than the photo verification you provide as part of your application. We do not collect any information about criminal convictions and offences.
- What personal data is collected?
We will collect and process the following data about you:
- When you apply for membership of HYPR: when you apply to become a member of HYPR, you give us personal information as part of submitting your online application and so that we can review your application and decide whether it is accepted or rejected.
This includes your Identity Data, Contact Data, Marketing and Communications Data.
You will also supply a form of photo verification for us to verify your identity. We delete the form of verification provided after we have processed your application.
As part of your application we are also provided with your Payment Data via our third-party payment service provider.
If your application is rejected then we delete the data provided as part of your application. If your application is successful, your personal data forms your membership account where you can update and change the information you have provided.
- To process this personal data, the Lawful Basis we rely upon is: the processing is necessary for the Performance of a Contract with you to consider your application to become a member of HYPR, necessary to Performance of a Contract we are about to enter into with you, or it is necessary for our Legitimate Interests to manage the membership applications of our private membership group.
- We rely on your consent to process your photo verification for the purpose of verifying your identity as part of your application.
- Information you give us as a HYPR Member: If your application to become a HYPR Member is successful, we will continue to store and use the personal information supplied to us as part of your application so that we can provide our services to you. However we do not store the photo identification you provided us to verify your ID, and this is deleted after we have processed your application.
We will collect and process information you provide when you use Our Sites, subscribe to any of the HYPR Services, and when you report a problem with the HYPR App, the HYPR Services, or any of Our Sites.
We will also use the personal information to manage our relationship with you including notifying you of changes to HYPR, to administer and protect our business including troubleshooting, data analysis and system testing, and to comply with our legal obligations with TFL. We may also use the personal information as part of any investigations into your use of the HYPR Service.
If you contact us, we will keep a record of that correspondence.
To process this personal data, the Lawful Basis we rely upon is: the processing is necessary for the Performance of a Contract with you to provide your membership and services of HYPR, or it is necessary for our Legitimate Interests to manage the membership applications of our private membership group and to manage the HYPR Services generally.
To process this personal data, the Lawful Basis we rely upon is your Consent.
- When you use HYPR Drive: As a HYPR Member you can use the HYPR Drive service made available on the HYPR App.
We use your Identity Data, Device Data and Contact Data when you use the HYPR App so that the use of the app and booking a car is associated with your account.
To process this personal data, the Lawful Basis we rely upon is: it is necessary for our Legitimate Interests to ensure that our HYPR App is used by registered members only.
We use your Device Data and Location Data to determine your location when you use the HYPR App. This is an essential part of enabling us to provide you with the HYPR Drive service, and so that we can send a car to you and record your route. 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. You can withdraw your consent at any time by disabling Location Data in your settings.
To process this personal data, the Lawful Basis we rely upon is: your Consent, and also that the processing is necessary for the Performance of a Contract with you so that we can send a vehicle to the registered member’s location and provide the trip.
We use your Identity Data and Content Data to verify that you are using HYPR Drive when our drivers pick you up, and if necessary, for our drivers to call you from their mobile phones so as to locate you.
To process this personal data, the Lawful Basis we rely upon is: it is necessary for our Legitimate Interests to ensure that our HYPR App is used by registered members only. We are also required by Transport for London to verify the identity of users of the HYPR Drive service, and therefore this is to enable us to Comply with a Legal Obligation.
We use the Payment Data to take payment for your journey, and any tips you provide the driver.
To process this personal data, the Lawful Basis we rely upon is: the processing is necessary for the Performance of a Contract with you to provide you the HYPR Drive service.
We retain the Transaction Data, including the data of your journey, after each your use of HYPR Drive.
To process this personal data, the Lawful Basis we rely upon is: it is necessary for our Legitimate Interests to keep records of the usage of HYPR Drive. In addition, we keep records in accordance with our Retention Period to Comply with a Legal Obligation.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
- Device Data from the following parties:
analytics providers such as Google based outside the EU;
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as Stripe based inside the EU;
- Identity and Contact Data from publicly available sources such as the social network account profile you share with us during the membership application; and
- Direct Marketing: We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Advertising and Recommendations: We may use your Identity Data, Contact Data, Device Data, Content Data, Profile Data, Usage Data, Location Data and Marketing Data to deliver content and advertisements to you on Our Sites, to make recommendations to you about goods or services which may interest you, to measure and analyse the effectiveness of the advertising we serve you, and to monitor trends so we can improve the HYPR Service.
To process this personal data, the Lawful Basis we rely upon is: it is necessary for our Legitimate Interests to develop our produces and services and grow our business.
This helps us to provide you with a good experience when you use the HYPR App or browse any of Our Sites and also allows us to improve the HYPR App and Our Sites.
- Disclosures of your personal data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
- International transfers
We do not transfer your personal data outside the European Economic Area (EEA) and have selected partners who are located in the EEA for hosting the HYPR service.
- Data security
All information you provide to us is stored on our secure servers. Any payment transactions carried out by our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
Unfortunately, the transmission of information over the internet or public communications networks can never be completely secure.
We will take appropriate technical and organisational security measures to protect the personal data that you submit to us against unauthorised/unlawful access or loss, destruction or damage, although we cannot 100% guarantee the security of personal data that you provide to us online.
- Payment Information
We do not store or directly process your credit/debit card details. Any payments you make through the HYPR website are processed by our third-party payment provider – currently Stripe – and the data you send them will be stored and encrypted by them.
As HYPR is a subscription service, we arrange for your payment data to be stored with our third-party payment provider so that we can take your first payment and monthly regular payments, as well as for future payments you make via Our Sites.
When you permanently delete your account, we will delete your credit/debit card details.
For details on Stripe and their security and data policy, please visit https://stripe.com/gb/privacy.
- Data retention
As part of our regulatory requirements to Transport for London, we keep all your personal data for 12 months after you use the HYPR Drive service.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see Your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
In the event that you do not use the App for a period of 12 months then we will treat the account as expired and your personal data may be deleted once we no longer need to keep it.
- Your legal rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data.
- Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
- Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
- Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
- if you want us to establish the data’s accuracy;
- where our use of the data is unlawful but you do not want us to erase it;
- where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
- you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
- Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
You also have the right to ask us not to continue to process your personal data for marketing purposes.
You can exercise any of these rights at any time by contacting us at firstname.lastname@example.org.
- Consent means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
- Internal third parties
Our HYPR Drive car drivers.
- External third parties
Service providers acting as processors based in the EU who provide financial payment services – such as Stripe.
Professional advisers including insurers based in the EU who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
Transport for London who require reporting of processing activities in certain circumstances
Your friends and contacts where you choose to share the details of your journey with them from within HYPR Drive.