When you use Turvy, you trust us with your data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices.
This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, highlighting key points about our privacy practices.
This notice applies to users of Turvy’s services globally, including users of Turvy’s apps, websites, features, or other services.
This notice describes how Turvy and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features, or other services anywhere in the world unless covered by a separate privacy notice. This notice applies explicitly to:
- Riders: individuals who request or receive transportation, including those who receive vehicle requested by another individual
- Drivers: individuals who provide transportation to Riders individually or through partner transportation companies
This notice also governs Turvy’s other collections of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by Turvy for Business customers.
All those subject to this notice are referred to as “users”.
Our practices are subject to applicable laws in the places 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. Please get in touch with us here.
III. Data collections and uses
The data we collect
Turvy collects personal data:
- provided by users to Turvy, such as during account creation
- created during the use of our services, such as location, app usage, and device data
from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities
The following personal data is collected by or on behalf of Turvy:
1. Data provided by users. This includes:
User profile: We collect data when users create or update their Turvy accounts. 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 identification documents (which may indicate document 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 Turvy apps.
This includes gender and occupation (when required for certain Turvy services or programs, such as Turvy Cash or features that enable women to provide services or receive benefits to/from other women).
We may use the photos submitted by users to verify their identities, such as through facial verification technologies. For more information, please see the section titled “How we use personal data.”
- Background check and identity verification: To verify drivers’ eligibility to provide services through the Turvy apps, we may collect information such as driver history or criminal record (where permitted by law), license status, known aliases and primary addresses and right to work. An authorised vendor may collect this information on Turvy’s behalf.
We may also verify riders’ identities, including collecting photographs of their government-issued identification.
- Demographic data: We may collect demographic data about users, including through user surveys. We may also receive demographic data about users from third parties in some countries.
We may also infer demographic data from other data collected from users. For example, where necessary, to enable features that allow women to provide or receive services from other women, we may infer gender using their first name. In such cases, we allow users to change their gender, if necessary, via in-app settings.
- User content: We collect the data submitted by users when they contact Turvy customer support (including at
Turvy Greenlight Hubs or via videoconferencing tools), provide ratings or compliments for other users or otherwise contact Turvy. This may include feedback, photographs or other recordings collected by users, including audio or video recordings (such as from dashcams) submitted by users in connection with customer support. This also includes metadata relating to your communication method with Turvy.
- Travel information: We collect travel itinerary information, including the times and dates of upcoming flights, lodging or car rental reservations, from users of our Turvy Travel feature. We collect such information: (i) when users manually input their tip into a Turvy Travel itinerary; or (2) if authorised by users to access their Gmail accounts from travelled-related email confirmations. If so approved, Turvy will only access users’ Gmail accounts to collect travel itinerary information to enable the Turvy Travel feature and will adhere to Google’s API Services User Data Policy, including the limitations on the use of data collected from users’ Gmail accounts
- Data created during the use of our services. This includes:
- Location data (drivers): We collect drivers’ precise or approximate location data, including enabling ride tracking and safety features, to prevent and detect fraud and to satisfy legal requirements. Turvy collects this data when the Turvy app is running in their mobile device's foreground (app open and on-screen) or background (app available but not on-screen)
- Location data (riders). We collect riders’ and delivery recipients’ precise or approximate location data to enable and enhance the use of our apps, including improving pick-ups, and drop-offs, enabling safety features and preventing and detecting fraud. Please see our Rider Location Help page for detailed information on using this data.
We collect such data from users’ mobile devices if they enable us to do so. (See “Choice and transparency” below for information on how riders and delivery recipients can allow location data collection). Turvy collects such data from the time a ride is requested until it is finished (and may indicate such group via an icon or notification on your mobile device depending on a ding on your device’s operating system) and any time the app is running in the foreground (app open and on-screen) of their mobile device.
Riders may use the Turvy apps without enabling Turvy to collect precise location data from their mobile devices. However, this may affect features in the Turvy apps. For example, a user who has not enabled location data collection will have to enter their pick-up address manually. In addition, the location data collected from a driver during a trip will be linked to the rider’s account, even if the rider has not enabled location data to be collected from their device, including for purposes of receipt generation, customer support, fraud detection, insurance, and litigation.
- Transaction information: We collect transaction information related to our services, including the type of services requested or provided, order details, payment transaction information, date and time the service was provided, amount charged, distance travelled, and payment method. Additionally, if someone uses your promotion code, we may associate your name with that person.
- Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, app crashes and other system activity, and browser type. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see "How We Use Data" below for more information on how we market our services to users).
In some cases, we collect this data through cookies, pixels, tags, and similar tracking technologies that create and maintain unique identifiers. To learn more about these technologies, please see our Cookie Notice.
- Communications data: We enable users to communicate with each other and Turvy through Turvy’s mobile apps and websites. For example, we encourage drivers and riders to call, text, or send other files (generally without disclosing their telephone numbers to each other). To provide this service, Turvy receives some data regarding the calls, texts, or other communications, including the date and time of the contacts and the content of the communications. Turvy may also use this data for customer support services (including resolving disputes between users), for safety and security purposes, to improve our services and features, and for analytics
- Safety recordings: In certain jurisdictions, and where permitted by law, users can record the audio and video of their trips through an in-app feature or a dashcam. In-app recordings are encrypted and stored on users’ devices and are only shared with Turvy if submitted to customer support by the users in connection with safety incidents. Please see here for more information.
- Data from other sources. These include:
- Users are participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s data from that user.
- Turvy account owners who request services for or on behalf of other users or who enable such users to order or receive benefits through their accounts. This includes owners of Turvy for Business accounts.
- Users or others are providing information in connection with claims or disputes.
- Through Turvy business partners, users create or access their Turvy accounts, such as payment providers, social media services, or apps or websites that use Turvy’s APIs or whose APIs Turvy uses.
- Turvy business partners in connection with debit or credit cards issued by a financial institution in partnership with Turvy 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 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
- law enforcement officials, public health officials, and other government authorities Turvy may combine the data collected from these sources with other data.
B.How we use personal data.
Turvy uses personal 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
- to send marketing and non-marketing communications to users
- in connection with legal proceedings
Turvy does not sell or share personal data with third parties for direct marketing, except for users’ consent.
We use personal data we collect:
- To provide our services. Turvy uses data to provide, personalise, maintain, and improve our services.
This includes using data to:
- create/update accounts
- enable transportation and delivery services (such as using location data to facilitate a pickup or delivery), features that involve data sharing (such as fare splitting, ETA sharing, and ratings and compliments), and accessibility features to facilitate the use of our services by those with disabilities
- process payments
- track and share the progress of rides or deliveries
- create Turvy travel itineraries and offer related services, such as rides to the airport, rental car reservations
- facilitate insurance, vehicle, invoicing, or financing solutions
- perform necessary operations to maintain our services, including troubleshooting software bugs and operational problems; conducting data analysis, testing, and research; and monitoring and analysing usage and activity trends.
- Safety and security. We use personal data to help maintain our services and users' safety, security, and integrity. This includes:
- verifying users' identity and eligibility to provide transportation or deliveries, including thorough reviews of background checks, where permitted by law, to help prevent unsafe drivers and riders using our services.
This includes Turvy’s Real-Time ID Check feature in certain regions, which prompts drivers to share a selfie before going online to help ensure that the driver using the app matches the Turvy account we have on file. Where permitted by law, this also includes performing facial verification of photographs submitted by users or collected from public databases to prevent identity-borrowing or verifying users’ identities.
- using data from drivers’ devices to detect unsafe driving behaviour 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 device, location, user profile, usage, and other data to prevent, detect, and combat fraud. This includes identifying fraudulent accounts or uses of our services, avoiding our services by unauthorised drivers or delivery persons, verifying user identities in connection with specific payment methods, and preventing and combating unauthorised access to users’ accounts.
- 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.
- sharing information regarding serious driver safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide rides or intermediaries who collect and report such information for multiple companies, to prevent drivers who may pose a safety risk to the platform or
its users from using Turvy’s or those other companies’ services. We may also share whether the incidents result in account deactivation with third parties, including those affected by such incidents.
- using ratings, usage and other data to prevent matching of riders and drivers for whom there is a higher risk of conflict (for instance, because one user previously gave the other a one-star rating).
- Customer support. Turvy uses the information we collect (including call recordings) to provide customer support, investigate and address user concerns, and monitor and improve customer support responses and processes.
- Research and development. We may use personal 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.
- Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location; a rider may contact a driver to retrieve a lost item.
- Marketing. Turvy may use personal data for marketing our services to our users. This includes sending users communications about Turvy services, features, promotions, sweepstakes, studies, surveys, news, updates, and events. We may do so through various methods, including email, text messages, push notifications, in-app communications and ads, and ads on third-party platforms.
We may also inform users about products and services offered by Turvy partners. For example, we may provide recommendations, promotions, or ads for Turvy partners based on users’ past delivery orders. Although we inform users about products and services offered by Turvy partners, we do not sell users’ data to or share it with such partners or others for direct marketing or advertising purposes, except with users’ consent.
We may use the data we collect, including in combination with advertising partners’ data, to personalise and improve the marketing communications (including ads) that we send on and off Turvy’s apps and websites, including based on user location, use of Turvy’s services, and user preferences and settings. For example, we share user data (such as hashed email addresses, usage information, and device or user identifiers) with Facebook and TikTok to personalise and improve our ads for Turvy’s services.
For information about opting out of certain marketing communications (including ads) from Turvy and its advertising partners, please see “Marketing choices.”
We may also send users communications regarding elections, ballots, referenda, and other political and notice processes related to our services. For example, Turvy has notified some users by email of ballot measures or pending legislation about Turvy’s services in those users’ areas.
Turvy performs the above activities because they are necessary for Turvy’s legitimate interests in informing users about Turvy services and features or those offered by Turvy partners or based on user consent. See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding Turvy’s use of your data for marketing.
- Non-marketing communications. Turvy may use personal data to generate and provide users with receipts, inform them of changes to our terms, services, or policies, or send other communications that aren’t to market the services or products of Turvy or its partners.
- Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to Turvy’s services, satisfy requirements under applicable laws, regulations, operating licenses or agreements, or under legal processes or governmental requests, including from law enforcement.
Turvy performs the above activities because they are necessary for Turvy’s legitimate interests in investigating and responding to claims and disputes relating to Turvy’s services and features and must comply with applicable legal requirements.
- Automated decision-making
We use personal data to make automated decisions relating to our services. This includes:
- matching available drivers and delivery persons to users who are requesting services. Users can be matched based on availability, proximity, and other factors such as the likelihood to accept a trip based on their past behaviour or preferences. Please see here for further information about our matching process.
- determining user ratings and deactivating users with low ratings. In the European Union or where otherwise required by law, such deactivation occurs only after human review and the possibility to appeal. For more information about how ratings are determined and used, please see here for rider ratings.
- flagging users identified as having engaged in fraud, dangerous activity, or other activities that may harm Turvy, its users, and others. In some cases, such as when a user is determined to be abusing Turvy’s referral program or has submitted fraudulent documents, such behaviour may result in automatic deactivation. In the European Union or where otherwise required by law, deactivation after human review.
- using driver location information and communications between riders and drivers to identify cancellation fees earned or induced through fraud. For example, suppose we determine by using such notification that a driver is delaying a rider pickup to cause a cancellation. We will not charge the rider a cancellation fee and adjust the amounts paid to the driver to omit such a fee. To object to such an adjustment, please contact Turvy customer support.
- Using driver data (such as location, rating and gender) and rider data (such as rating, origin and destination) to help avoid pairings of users that may result in an increased risk of conflict.
Click the links in this section for more information about these processes. To object to a deactivation resulting from this platform, please contact Turvy customer supporter support.
C.Cookies and third-party technologies
- authenticating users
- remembering user preferences and settings
- determining the popularity of content
- delivering and measuring the effectiveness of advertising campaigns
- analysing site traffic and trends and generally understanding the online behaviours and interests of people who interact with our services
Please see our Cookie Notice for more information regarding cookies and other technologies described in this section.
D.Data sharing and disclosure
Some of Turvy’s services and features require that we share personal 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, claims, or disputes.
Turvy may share personal data:
- With other users This includes sharing:
- riders’ first name, rating, and pick-up and drop-off locations with drivers' first names
- riders’ first names with other riders in a carpool trip. Riders in carpool trips may also see the drop-off location of the other riders.
- For drivers, we may share data with the rider(s), including name and photo; vehicle make, model, colour, license plate, and vehicle photo; location (before and during the trip); average rating provided by users; the total number of trips; period since they signed up to be a driver or delivery person; contact information (if permitted by applicable laws); and driver profile, including compliments and other feedback submitted by past users.
We also provide riders with receipts containing information such as a breakdown of amounts charged, driver’s first name, photo, and route map. We also include other information on those receipts if required by law.
- for those who participate in Turvy’s referral program, we share personal data of referred users, such as trip count, with the user who referred them to the extent relevant to determining the referral bonus.
- 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.
- Turvy business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Turvy may share specific data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs;
- 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 specific incidents. Please see “Choice and Transparency” and “Emergency Data Sharing” for more information.
- With the general public
Questions or comments from users submitted through public forums such as Turvy blogs and Turvy social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user.
- With the Turvy account owner
Suppose a user requests transportation or places an order using an account owned by another party. In that case, we may share their order or trip information, including location data, with the owner of that account. This occurs, for example, when:
- a rider uses their employer’s Turvy for Business profile, such as when they take trips arranged through Turvy Central
- a driver uses an account owned by or associated with a Turvy partner transportation company
- a rider takes a trip arranged by a friend or under a Family Profile
- With Turvy service providers and business partners
Turvy provides personal data to vendors, consultants, marketing partners, research firms, and other service providers or business partners. These include:
- payment processors and facilitators
- background check and identity verification providers
- cloud storage providers
- social media companies, including Facebook and TikTok, in connection with Turvy’s use of their tools in Turvy’s apps and websites (see Facebook’s and TikTok’s privacy policies for information on their collection and use of data)
- Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers, to reach or better understand our users and measure advertising effectiveness
- research partners, including those performing surveys or research projects in partnership with Turvy or on Turvy’s behalf
- vendors that assist Turvy in enhancing the safety and security of its apps
- consultants, lawyers, accountants, and other professional service providers
- insurance and financing partners
- third-party vehicle suppliers, including fleet and rental partners
- For legal reasons or in the event of a dispute
Turvy may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns.
This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property), or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Turvy’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute about using another person’s credit card, we may be required by law to share your data, including trip or order information, with the owner of that credit card.
Please see Guidelines for Law Enforcement Authorities - Outside the US and Guidelines for Third-Party Data Requests and Service of Legal Documents.
This also includes sharing personal data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.
- With the consent
Turvy may share a user’s data other than as described in this notice if we notify the user and consent to the sharing.
E. Data retention and deletion
Turvy retains user data for as long as necessary for the purposes described above.
Users may request deletion of their accounts at any time. Turvy may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
Turvy retains user data for as long as necessary for the purposes described above. This means that we have different categories of data for different periods depending on the type of data, the variety of users to whom the data relates, and the purposes for which we collected the data.
Users may request deletion of their account through the Settings > Privacy menus in the Turvy app or through Turvy’s website (riders here; drivers here).
Following an account deletion request, Turvy 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, this generally means that we retain their account and data for a minimum of 7 years after a deletion request. For riders, their data is usually deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.
IV. Choice and transparency
Turvy enables users to access and control data that Turvy collects, including through:
- privacy settings
- device permissions
- in-app rating pages
- marketing choices
Turvy also enables users to request access to or copies of their data, changes or updates to their accounts, or delete their accounts. Turvy restricts its processing of personal user data.
- Privacy settings
The Settings > Privacy menu in the Turvy app allows riders to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications.
- Location data collection (riders)
Riders can enable/disable Turvy to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu.
- Share Live Location (Riders)
Riders can enable/disable Turvy to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > Privacy > Location menu.
Riders may enable Turvy to share real-time location data with emergency police, fire, and ambulance services from their mobile devices. Such data may include an approximate location when the emergency call was placed; the car’s make, model, colour, and license plate information; the rider’s name and phone number; pickup and drop-off locations; and the driver’s name.
Riders may enable/disable this feature via the Settings > Privacy > Location menu or the Safety Centre.
Drivers can also enable/disable Emergency Data Sharing via the App settings > Emergency Data Sharing menu or the Safety Toolkit.
- Notifications: account and trip updates
Turvy provides users with trip status notifications and updates related to activity on their accounts. These notifications are necessary for using the Turvy app and cannot be disabled. However, users may choose the method they receive these notifications through the Settings > Privacy menu.
- Notifications: discounts and news
Users may enable Turvy to send push notifications about discounts and news from Turvy. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Turvy app.
- 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. These platforms have different methods for obtaining that permission. Please check the available settings on your device or check with your provider.
- In-app rating pages
After every trip, drivers and riders can 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 behaviour. Accountability helps create a respectful, safe environment for drivers and riders.
Riders can see their average rating on the main menu of the Turvy app.
Drivers can see their average rating after tapping their profile photo in the Turvy Driver app.
- Marketing choices
Users may opt out of specific marketing communications (including ads) and use their data for marketing in the following ways:
- Ad settings enable users to choose whether their data is shared with Turvy’s advertising partners to deliver personalised ads and measure such ads’ effectiveness.
- Marketing emails and messages: To opt-out of receiving marketing emails from Turvy, or for instructions on setting your preferences regarding whether to receive marketing SMS or push notifications from Turvy, click here. Users may also opt-out of receiving emails and other messages from Turvy by following the
unsubscribe instructions in those messages. We may still send users who have opted out of non-promotional communications, such as receipts for rides or information about their account.
- Cookies and related technologies: For information on how to opt-out of personalised ads using cookies and related technologies, please see our Cookie Notice.
- User personal data requests
Turvy provides users with various ways to learn about, control, and submit questions and comments about Turvy’s handling of their data.
- Accessing data: Users can access data, including their profile data and trip or order history, through the Turvy apps or via Turvy’s website. Users can also use our Explore Your Data feature to view an online summary of information about their accounts, such as several trips or orders, ratings, rewards status, and several days since they’ve been a Turvy user. Users can also request access to their data here.
- Receiving data: Users can request a copy of their data using our Download Your Data tool. For an overview of the data available through that tool, please click here. Users may also request a copy of their data here.
- Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Turvy’s apps or driver portal. Users may also request to update or correct their data here.
- Deleting data: Users may request deletion of their account through the Settings > Privacy menus in the Turvy app or through Turvy’s website (riders here; drivers here).
- Objections, restrictions, and complaints: Users may request that we stop using all or some of their data or limit our use of their data. This includes objecting to our use of personal data based on Turvy’s legitimate interests. Turvy may continue to process data after such objection or request to the extent required or permitted by law.
- In addition, depending on their location, users may have the right to file a complaint relating to Turvy’s handling of their data with the data protection authority in their country.
- Users may submit the above requests here.
V. 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 Turvy apps or 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.