Rodeo Privacy Policy

GENERAL

This is a privacy policy for users of the Rodeo Mobile Application (‘Rodeo’) which is an app built and operated by Lightning Riders Ltd (‘Lightning Riders/We/Us/Our’).

This policy provides users (‘User/You/Your’) of Rodeo with information about who we are, how we process your personal data and for what purposes. It also explains your rights in relation to your personal data.

Rodeo enables Users to consolidate their information and data from multiple delivery apps such as Deliveroo and UberEats and allows Users to share and view comments and other content with other users.

Lightning Riders is the controller of the personal data processed by Rodeo and we are responsible for overseeing this policy and any queries which arise from it.  We respect your privacy and take the protection of your personal data very seriously. If you have any questions about this policy, or wish to exercise your data protection rights, please contact hello@gorodeo.app.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), which is the supervisory entity in the UK for data protection issues. We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

It is important that the data we hold about you is accurate and current. Please keep us informed if your personal data changes during your use of Rodeo.

By downloading and using Rodeo, the personal data listed below will be processed by us.

The Personal Data We Collect

Personal data, or personal information, means any information relating to an identified or identifiable living individual. We collect, use, and store data about you which we have grouped together as follows:

Identity data - including your name.

Contact data
- including your email address and telephone number.

Technical data
- including your IP address, your login data, device details, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the device you use to access Rodeo.

Profile data
- including your username, and profile details.

Content data - including any content you share on the Rodeo app, such as photos, posts, comments, and reviews on the Rodeo Feed.We collect the data above directly from you when you create a profile and use the Rodeo app.

Usage data
- should you choose to connect your delivery rider accounts to Rodeo, we collect usage data such as details about the orders you have delivered. This includes the order start timestamp, pickup location, order payment, delivery duration and distance.

We collect usage data from third party apps only where you have explicitly requested and authorised such requests. Rodeo uses a combination of third-party services, including Argyle, to enable you to request and access your data. Please review their Privacy Policy to understand how they process personal data.

We also collect and use Aggregated Data to monitor and analyse overall market conditions. Aggregated data is derived from your personal data but is not considered personal data from a legal point of view if it does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to understand the average rider fees for an order in a city.

We reserve the right to share Aggregated Data with third parties. For example, we may wish to share statistics regarding the changes in average rider earnings over time with researchers or other third parties, with the aim of benefiting users.

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). Nor do we collect any information about criminal convictions and offences.

HOW WE USE YOUR DATA

We only process your personal data where necessary, and only in accordance with our objective of providing Users with individual and market-level insights from the data we receive.
We may process your personal data for the following purposes:

- to open and manage your account;
- to manage our relationship with you, including: notifying you about changes to our terms or privacy policy and asking you to provide feedback;
- if you authorise us, to retrieve data about your trips and deliveries from various platforms;
- to administer and protect our application (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data);
- to deliver relevant content to you, and to operate our services;
- to facilitate communication between users, such as through the Rodeo Feed;
- to measure or understand the effectiveness of the service we provide;
- to help provide Users with additional access to work opportunities;
- to improve our products/services, marketing, user relationships and experiences.

If you authorise us, we process your Usage data to provide you information and insights that may be useful to you in carrying out your work. For instance, this may allow you to compare earnings across orders, time periods, and platforms. We may also provide you aggregated insights about earnings and market conditions from other drivers in your area.

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If we need to use your personal data for an unrelated purpose, we will notify you in accordance with our legal obligations and we will explain the legal basis which allows us to do so.

Legal Bases for Processing Data

We rely on a number of legal bases to process the data that relates to you. We process personal data:
- In order to fulfil our obligations and provide you the services laid out in our Terms of Use. For example, this includes processing data necessary for you to create an account with Rodeo; to retrieve your earnings data from different platforms; and to provide individual and aggregate-level insights from the market.
- Pursuant to our legitimate interests, (or that of third parties), where your interests and fundamental rights do not override those interests. For example, we may process Content data, in a fair and proportionate manner, to create content for our marketing and communications activities.
- In some cases, solely based on your specific and informed consent. In such instances, you would have the right to withdraw your consent at any time by contacting us at the address provided at the end of this Policy.
- In cases where it may be necessary to comply with a legal or regulatory obligation.

Disclosures of Your Personal Data

We will not share your personal data with any external third parties, without your explicit consent.

You share information with other users when sharing messages, posts, comments, reviews, or other content on the Rodeo app. While the content you share may be beneficial to other users when collecting and delivering orders, we advise you to exercise caution regarding sharing any sensitive personal information with other users on the app.

data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

Rodeo provides users the ability to post, see and comment on updates from other users in their area. Please note that clicking on user-provided links may allow third parties to collect or share data about you. When you leave Rodeo, we encourage you to carefully review the privacy policies on other websites that you visit or applications that you use to see how third parties use your data. We are not responsible for the privacy practices on any applications, websites or channels which are not controlled by us.

data retention

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Your Legal Rights

Under certain circumstances, you have 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: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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 (d) 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.

If you wish to exercise any of the rights set out above, please email hello@gorodeo.app.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you have any questions relating to this Privacy Policy, do not hesitate to contact us at hello@gorodeo.app.