Noblelane Chauffeur Privacy Policy

We are pleased that you are taking the time to read the Noblelane Chauffeur Privacy Policy (“NCD”). The NCD describes the personal data we collect, how it is used and shared, and what choices you have regarding this data – between you and Noblelane e.U., its parent companies, subsidiaries, agents, affiliates, officers, and managing directors (collectively “Noblelane,” “we,” “us,” or “our”). This applies to theNoblelane Chauffeur application and platform as well as related websites and technologies (collectively the “NL Chauffeur Tools”).

1.   Scope

We offer a mediation platform for high-quality professional transportation services (“Services”) provided by independent local service providers (“Local Service Providers” or “LSP”). We do not provide, own, orcontrol any of the services offered to third parties by the local service providers, but merely facilitate theacquisition of a claim to such services for individuals (“Guests”), which are then provided directly by the local service providers.
To facilitate the services offered by local service providers, we provide them and their professional drivers (“Chauffeurs” or “you”) with access to the NL Chauffeur Tools. Any services you provide are done within theframework of your relationship – contractual or otherwise – with a local service provider. We do not employ chauffeurs, including yourself.
The general Privacy Policy and Cookie Policy of Noblelane apply to the use of the Noblelane website and other Noblelane services.

2.   Name and Contact Details of the Controller

The controller for data processing within the meaning of the General Data Protection Regulation (GDPR) is:

Noblelane e.U.
Dampfgasse 9/2
1100 Vienna
Austria
Email: info@noblelane.at

Further information about Noblelane can be found in the legal notice: https://www.noblelane.at/imprint

3.   Contact Information of the Data Protection Officer

Our data protection officer is:
Noblelane e.U.
Dampfgasse 9/2, 1100 Vienna, Austria
Email: info@noblelane.at

You can contact our data protection officer confidentially by mail at the address above.

4.   Data Security (TLS Encryption)

An encrypted connection can be recognized, for example, by the lock symbol in your browser's address bar. If you communicate with us via email, access by third parties cannot be excluded.For confidential information, Noblelane therefore recommends sending by regular mail or encrypted email communication (PGP). Please let us know if you wish to communicate via encrypted email so that we can provide the appropriate addresses and public keys.

5.   Partner Application

Personal data is processed during the application submitted by the local service provider on your behalf to assess your suitability for chauffeur services for Noblelane end customers. This includes information on whether a partner or chauffeur is appropriately qualified, licensed, experienced, possibly verified through criminal record checks (if legally permitted or required), capable of providing chauffeur services, and whether they comply with all Noblelane policies and requirements.

Your data is necessary for concluding a partnership or transportation contract; otherwise, we cannot process your application or offer you transportation requests. Application data is generally not shared withexternal recipients unless it concerns a Noblelane processor (see Art. 28 GDPR) or is legally permitted. If your application is successful, your application data will be used for the contractual relationship with Noblelane and the provision of professional chauffeur services to Noblelane end customers. Otherwise, application data is generally deleted after 6 months unless there is an additional need or reason for longer storage. The legal basis for processing application data is Article 6(1)(b) GDPR (contract initiation). If you grant us consent to transmit personal data beyond the required scope, the legal basis is Art. 6(1)(a) GDPR (consent).

6.   Chauffeur Data

Noblelane processes partner data, chauffeur application data, and data about partners or chauffeurs arising from the contractual relationship or the provision of Noblelane chauffeur services (hereinafter“Chauffeur Data”). Chauffeur data is used for Noblelane services, i.e., to fulfill the agreement with a local service provider, for transportation requests, transportation contracts, or for billing and payment purposes.This may include the following data: full name, gender, date of birth, age, driver’s licenses, place of birth, residential address, email, phone number, social security number, tax ID, payout preference or bank account, user ID, training and webinars, location data, driving status, ride milestones, license plate, vehicle information, customer orders, customer ratings, photos, audio files, incident information, criminal records, compliance with Noblelane policies, company data.Noblelane provides chauffeur data to third parties when necessary, especially to Noblelane end customers, so that the transportation can be executed, billed, and paid according to their booking. In such cases,chauffeur data may be transferred to a third country outside the European Union or the European Economic Area where the end customer is located or wishes to use Noblelane services. In these cases, Noblelane cannot provide further information on the level of data protection in the third country. An adequacy decision (see Art. 45(3) GDPR) or appropriate safeguards (see Art. 46 GDPR) are not required as the transfer isnecessary for the performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures at the request of the data subject (Art. 49(1)(b) GDPR) or because the transfer is necessary for the performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person (Art. 49(1)(c) GDPR).

The legal basis for processing chauffeur data is Art. 6(1)(b) GDPR (performance of a contract). If thechauffeur provides additional voluntary information, the legal basis is the chauffeur’s consent under Art. 6(1)(a) GDPR as well as our legitimate interest under Art. 6(1)(f) GDPR.

In addition, Noblelane processes chauffeur data for the analysis, personalization, and improvement of Noblelane services (e.g., ride ratings), for advertising Noblelane services, for detecting, limiting, and resolving technical or procedural issues and problems, as well as to prevent illegal use of Noblelane services (e.g., fraudulent bookings, cyberattacks). For such purposes, chauffeur data is generally notshared with recipients unless it concerns the chauffeur’s employer or contractor, a Noblelane processor (see Art. 28 GDPR), or it is otherwise legally permissible (e.g., to assert or defend legal claims). The legal basis for processing chauffeur data in this context is Art. 6(1)(f) GDPR (legitimate interest of Noblelane).

7.   Data Processing and Automated Decision-Making

Data generated or used when using the NL Chauffeur Tools, i.e., all chauffeur tool data or ride-related data (e.g., date, time, pickup location, destination, stopovers, number of passengers, vehicle category/class,information and logos for the pickup sign, name and mobile number of the end customer, flight or train connections, reference number, booking comments, special needs, cancellations, changes, no- shows, and delays), is processed as described in Section 6.

Noblelane may base its decision about an offer from a partner or chauffeur solely on automated processing. Such an automatic decision is necessary for the conclusion of a contract (Art. 22(2)(a) GDPR). The data subject has the option to contact us via the contact details provided (see Section 2) to request an explanation,human intervention, or to express their point of view.

8.   GPS Tracking, Location Data

Noblelane processes and utilizes GPS tracking or location data (including longitude, latitude, speed, and accuracy). Chauffeurs must first consent to such processing via the relevant confirmation field or system settings on their mobile device (i.e., by selecting “Allow” within Android or iOS). Once consent is granted, the chauffeur’s location is determined via the GPS data of the Noblelane Chauffeur App (hereinafter referred to as “Location Data”) from the moment the chauffeur activates the “On the way to Pick-up Location” function until the “Finish Ride” button is pressed in the Noblelane Chauffeur App.

In the event that the chauffeur does not press “On the way to Pick-up Location,” Location Data will be automatically collected starting 90 minutes prior to the scheduled pick-up time. If the “Finish Ride” function is not activated, the system will automatically terminate the collection of Location Data 120 minutes after the estimated time of arrival at the drop-off point.

The purposes for processing Location Data include: performance of the contractual relationship (including planning, dispatch, coordination, execution, billing, and payment of transportation services); monitoring of ride execution; quality assurance; support for Noblelane, the chauffeur, and the customer in the event of questions or issues; design and enhancement of Noblelane’s services; detection, limitation, and correction of technical or operational errors or disruptions; and the prevention or detection of unlawful activity (cf. Section 6 above).

Location Data may be shared with the respective end customer for the purposes of improving the coordination and execution of the ride, including for billing and payment. Location Data is not disclosed to third parties except where necessary for the performance of services by authorized Noblelane contractors (pursuant to Art. 28 GDPR) or where otherwise legally permitted.

Location data is processed securely and stored on encrypted storage media. It is not permanently linked to the chauffeur profile but stored separately. Access is granted based on a separate authorization concept, which permits access only to a limited group of people for a limited time. Evaluations are otherwise carried out in a pseudonymized or anonymized form.

Profiling (Art. 4(4) GDPR) with location data does not take place. Location data is not stored longer than 2 years and is then deleted or anonymized. The legal bases for processing location data by Noblelane are Art. 6(1)(a) GDPR (consent) and Art. 6(1)(b) GDPR (contract performance and initiation). The described location tracking is necessary so the chauffeur can simultaneously use a navigation app while GPS tracking is active in the Noblelane Chauffeur App. Rides can only be carried out if GPS tracking is active. The chauffeur can revoke their consent to GPS monitoring at any time by changing the device settings for the Noblelane Chauffeur App. Such a revocation does not affect the processing carried out previously. The chauffeur can also revoke further use of their location data by sending us a corresponding message (see Sections 2 and 3). Such a revocation does not affect the previously collected location data.

9.   End Customer Rating

Noblelane offers guests the opportunity to comment on and rate a ride – e.g., in the Noblelane App. Endcustomers can rate each ride with one to five stars, optionally also separately for certain aspects of the ride (e.g., chauffeur, vehicle), and leave a comment. Comments and ratings are stored in the chauffeur profile and may be shared with the chauffeur and the relevant transport partner in anonymized form. End customers can only view their own comments and ratings.

Purposes of data processing in the context of the rating system are: calculation of compensation and invoicing with transport partners, display and selection of chauffeurs, analysis and improvement of Noblelane services – particularly for monitoring ride performance, improving ride quality, and preventing or detecting illegal use (seealso Section 6). No profiling (Art. 4(4) GDPR) or automated decision-making based on rating data takes place.

The legal basis for processing end customer ratings is Art. 6(1)(b) GDPR (contract performance), particularly for bonus calculation. The processing of rating data also takes place based on Art. 6(1)(f) GDPR (legitimate interest of Noblelane). Noblelane has a legitimate interest in allowing end customers to give feedback and in using this feedback to improve services. Such rating systems are standard in the chauffeur industry andtherefore to be expected. Chauffeurs have the right to object to a rating at any time (see Sections 12.3 and 12.5).

10.   Communication with Noblelane

If you contact Noblelane (e.g., by phone, video conference, contact form, chat, messenger, SMS, email, or via the Noblelane Chauffeur App), the data you provide will be processed to handle your request and answer your questions. Legal bases for this are Art. 6(1)(a) GDPR (consent) and Art. 6(1)(b) GDPR (contract performanceand initiation). Noblelane also uses external services and tools to communicate with chauffeurs.

Noblelane processes personal data from communication, where possible, in pseudonymized or anonymized form to analyze usage, improve the design of Noblelane services, detect and fix technical or procedural issues,and to prevent illegal use of Noblelane services (e.g., fraudulent bookings, cyberattacks). The legal basis for this processing is Art. 6(1)(f) GDPR (legitimate interest of Noblelane).

11.   Rights of Data SubjectsIf your personal data is processed by Noblelane, you are a data subject within the meaning of Art. 4 No. 1 GDPR. As a data subject, you have the following rights concerning your personal data:

11.1  Right of Access (Art. 15 GDPR)

You have the right to request confirmation from the controller as to whether personal data concerning you is being processed; if this is the case, you have the right to access this personal data and further information about the processing.

11.2  Right to Rectification (Art. 16 GDPR)

You have the right to request the immediate correction of inaccurate personal data concerning you or the completion of incomplete personal data.

11.3  Right to Erasure (“Right to Be Forgotten”, Art. 17 GDPR)

You have the right to request the immediate deletion of your personal data where the conditions of Art. 17 GDPR are met, especially if the data is no longer necessary, you withdraw your consent, object to theprocessing, the data was unlawfully processed, or there is another ground for deletion.

11.4  Right to Restriction of Processing (Art. 18 GDPR)

You have the right to request the restriction of processing where the conditions of Art. 18 GDPR are met.

11.5  Right to Object (Art. 21 GDPR)

Where data processing is based on our legitimate interests under Art. 6(1)(f) GDPR or for direct marketing purposes, you have the right to object at any time to the processing of your personal data for reasons arisingfrom your particular situation. The controller will then no longer process your data unless it can demonstrate compelling legitimate grounds or the processing serves to assert, exercise, or defend legal claims.

11.6  Right to Data Portability (Art. 20 GDPR)

You have the right to receive the personal data concerning you that you have provided to a controller in a structured, commonly used, and machine-readable format and to transmit this data to another controller.

11.7  Right to Lodge a Complaint (Art. 77 GDPR)

Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with a supervisory authority.

12.   Data Deletion and Retention Period

We delete your personal data as soon as the legal basis for its processing ceases to exist. In certain cases,however, other legal bases may apply, e.g., when processing is necessary to fulfill Noblelane's legal obligations (e.g., commercial or tax-related retention requirements).

13.   Amendment or Update of this Chauffeur Privacy Policy

We may update this policy from time to time. If we make significant changes, we will inform users in advance via the NL Tools or by other means, e.g., by email. We recommend reviewing this notice regularly to stay informed about our current data protection practices. Continued use of our services after an update is considered consent to the updated policy, to the extent permitted by law. Noblelane may update and amend this Chauffeur Privacy Policy at any time. Chauffeurswill be informed and may be asked for renewed consent if necessary.