GEST PRIVACY POLICY
- Introduction
- Overview
- Data collections and uses
- Choice and transparency
- Updates to this notice
I. Introduction
This notice describes the personal data GEST collects or may collect in the future, how it is used and shared, and your choices regarding this data.
II. Overview
A. Scope
This notice applies to users of GEST’s services anywhere in the world, including users of GEST’s apps, websites, features, or other services.
This notice describes how GEST and its affiliates collect and use riders’ personal data. This notice applies to all users of our app, website, features, or other services anywhere in the world. This notice specifically applies to individuals who request or receive transportation, including those who receive transportation requested by another individual. This notice also governs GEST’s other collections of personal data in connection with its services.
All those subject to this notice are referred to as “users” in this notice.
Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular state or region only if permitted under the laws of those places. Please contact us at GEST Holdings, LLC, 344 Gest Street, Cincinnati, Ohio, 45203, with any questions regarding our practices in a particular state or region.
B. Data controller and transfer
GEST Holdings, LLC, 344 Gest Street, Cincinnati, Ohio, 45203, is the data controller for the personal data collected in connection with use of GEST’s services in the United States.
Questions, comments, and complaints about GEST’s data practices can be submitted to GEST Holdings at the address stated above.
III. Data collections and uses
A. The data we collect
GEST collects or may collect personal data:
provided by users to GEST, such as during account creation
created during 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 GEST:
- Data provided by users. This includes:
User profile: We collect data when users create or update their GEST 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). This may also include gender and/or occupation (when required for certain GEST services or programs).
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.”
Demographic data: We may collect demographic data about users, including through user surveys. We may also receive demographic data about users from third parties.
We may also infer demographic data from other data collected from users.
User content: We collect the data submitted by users when they contact GEST customer support, provide ratings or compliments for other users, restaurants or merchants, or otherwise contact GEST. This may include feedback, photographs or other recordings collected by GEST and/or users, including audio or video recordings (such as from cameras or dashcams). This also includes metadata relating to the method you use to communicate with GEST.
2. Data created during use of our services. This includes:
Location data for drivers. We collect drivers’ precise or approximate location data to enable ride tracking and safety features, to prevent and detect fraud, and to satisfy legal requirements. GEST collects this data when the GEST app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of their mobile device.
Location data for riders. We collect riders’ precise or approximate location data to enable and enhance use of our apps, including to improve pick-ups, facilitate deliveries, enable safety features, and prevent and detect fraud.
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 can enable location data collection). GEST collects such data from the time a ride is requested until it is finished (and may indicate such collection via an icon or notification on your mobile device depending 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 GEST app without enabling GEST to collect precise location data from their mobile devices. However, this may affect features in the GEST apps. For example, a user who has not enabled location data collection will have to manually enter their pick-up address. 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 the use of our services, including the type of services requested or provided, order details, payment transaction information (tipping, fee based cartage, etc.), date and time the service was provided, amount charged, distance traveled, and payment method.
Usage data: We may collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. 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 may 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.
Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.
Communications data: We enable users to communicate with GEST through GEST’s mobile apps and websites. For example, we enable drivers and riders to call or text each other. To provide this service, GEST may receive some data regarding the calls, texts, or other communications, including the date and time of the communications and the content of the communications. GEST may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics.
GEST may record the audio and/or video of user trips through or using a camera or dashcam which may include audio recording.
3. Data from other sources. These include:
Users participating in our referral programs. For example, when a user refers to another person, we receive the referred person’s personal data from that user.
GEST account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts.
Users or others providing information in connection with claims or disputes.
GEST business partners through which users create or access their GEST account, such as payment providers, social media services, or apps or websites that use GEST’s APIs or whose APIs GEST uses.
vendors who help us verify users’ identity, background information or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements
publicly available sources
marketing service providers or data resellers whose data GEST uses for marketing or research
law enforcement officials, public health officials, and other government authorities
GEST may combine the data collected from these sources with other data in its possession.
B. How we use personal data
GEST uses riders’ personal data to enable reliable and convenient transportation and other products and services. We also use such data:
to enhance the availability, safety and security of our users and services, including scheduling the number of vehicles in service
for customer support
for research and development
to enable communications between users
to send marketing and non-marketing communications to users
to sell metadata (data without personal identifiers) to third parties
in connection with legal proceedings
GEST does not sell or share user personal data with third parties for their direct marketing without users’ consent.
GEST uses riders’ personal data under the following conditions: 1) when necessary to fulfill obligations to users under our Terms of Use or other agreements with users, 2) for GEST’s and it’s users’ legitimate interests in informing users about events that may have an impact on how they can use GEST services, 3) for the legitimate safety and security interests of GEST or other parties, including users and members of the general public, 4) for GEST’s legitimate interests in developing new services and features, 5) for informing users about GEST services and features or those offered by GEST partners, 6) for purposes of GEST’s legitimate interests in investigating and responding to claims and disputes relating to use of GEST’s services and features, and/or 7) necessary for compliance with applicable legal requirements, and/or 8) to defray the costs and expenses of operating the service.
We use personal data we collect:
1. To provide our services. GEST uses data to provide, personalize, maintain, and improve our services.
This includes using data to:
create/update accounts
enable transportation services (such as using location data to facilitate a pick up or drop off), features that involve data sharing (such as fare splitting, ETA sharing, and ratings and compliments), and accessibility features to facilitate use of our services by those with disabilities
scheduling the number of vehicles in service based on usage
process payments and/or gratuities to drivers
track and share the progress of rides
personalize users’ accounts. Please see the section of this notice titled “Choice and transparency” to learn how to object to this use of personal data.
facilitate insurance, vehicle, invoicing, or financing solutions
perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems; to conduct data analysis, testing, and research; and to monitor and analyze usage and activity trends.
2. Safety and security. We may use personal data to help maintain the safety, security, and integrity of our services and users. This includes:
verifying users’ identity and eligibility to receive transportation, including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders.
using data from drivers’ devices to detect unsafe driving behavior such as speeding or harsh braking and acceleration, and to inform them of safer driving practices.
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, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.
using user ratings, reported incidents, and other feedback to encourage compliance with our guidelines and as grounds for deactivating users who violated such guidelines.
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 GEST’s or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation.
using ratings, usage and other data to prevent matching of riders and drivers for whom there is higher risk of conflict (for instance, because one user previously gave the other a one-star rating).
3. Customer support. GEST uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes.
4. Research and development. We may use personal data or metadata for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easier to use, enhance the safety and security of our services, and develop new services and features.
5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pickup location, or a rider may contact a driver to retrieve a lost item, etc.
6. Marketing. GEST may use personal data to market our services to our users. This includes sending users communications about GEST 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 GEST partners. For example, we may provide recommendations, promotions, or ads for GEST partners. Although we inform users about products and services offered by GEST partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent.
We may use the data we collect, including in combination with advertising partners’ data, to personalize and improve the marketing communications (including ads) that we send on and off GEST’s apps and websites, including based on user location, use of GEST’s services, and user preferences and settings. For information about how to opt out of certain marketing communications (including ads) from GEST and its advertising partners, please see the section titled “Marketing choices.”
We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, GEST has notified some users by email of ballot measures or pending legislation relating to GEST’s services in those users’ areas.
See the sections titled “Choice and transparency” and “Marketing choices” for information on your choices regarding GEST’s use of your data for marketing.
7. Non-marketing communications. GEST 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 are not for the purpose of marketing the services or products of GEST or its partners.
8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to use of GEST’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement.
9. Automated decision-making. We may use personal data to make automated decisions relating to use of our services. This includes:
matching available drivers to users requesting services. Users can be matched based on availability, proximity, and other factors such as likelihood to accept a trip based on their past behavior or preferences.
determining user ratings.
flagging users who are identified as having engaged in fraud, unsafe activity, or other activities that may harm GEST, its users, and others.
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 increased risk of conflict.
C. Cookies and third-party technologies
GEST and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and GEST’s Cookie Notice
Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. GEST uses cookies and similar technologies for purposes such as:
authenticating users
remembering user preferences and settings
determining the popularity of content
delivering and measuring the effectiveness of advertising campaigns
analyzing site traffic and trends, and understanding the online behaviors and interests of people who interact with our services
We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services.
Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.
D. Data sharing and disclosure
Some of GEST’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 or in connection with claims or disputes.
E. Data retention and deletion
GEST retains user data for as long as necessary for the purposes described above.
Users may request deletion of their accounts at any time. GEST may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
GEST retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.
Users may request deletion of their account at any time through the Settings > Privacy menus in the GEST app, or through GEST’s website. Following an account deletion request, GEST 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.
IV. Choice and transparency
GEST enables users to access and/or control data that GEST collects, including through:
privacy settings
device permissions
in-app ratings pages
marketing choices
GEST also enables users to request changes or updates to their accounts, or deletion of their accounts, or that GEST restricts its processing of user personal data.
1. Privacy settings
The Settings > Privacy menu in the GEST 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 GEST 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 may enable/disable GEST 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.
Emergency Data Sharing
Riders may enable GEST to share real-time location data from their mobile devices with emergency police, fire, and ambulance services. Such data may include approximate location at the time the emergency call was placed; the rider’s name and phone number; pickup and drop off locations; and the driver’s name.
Notifications: discounts and news
Users may enable GEST to send push notifications about discounts and news from GEST. Push notifications may be enabled or disabled through the Settings > Privacy menus in the GEST app.
2. 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, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider.
3. In-app ratings pages
After every trip, drivers and riders are able to 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 behavior. Accountability helps create a respectful, safe environment for drivers and riders.
4. Marketing choices
Users may opt out of certain marketing communications (including ads) and use of their data for marketing in the following ways:
Ad settings: These settings enable users to choose whether their data is shared with GEST’s advertising partners to deliver personalized ads, and/or to measure the effectiveness of such ads.
Marketing emails and messages: You may opt out of receiving marketing emails from GEST. Users may also opt out of receiving emails and other messages from GEST by following the unsubscribe instructions in those messages. We may still send users who have opted out 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 personalized ads using cookies and related technologies, please see our Cookie Notice.
5. User personal data requests
GEST provides users with a variety of ways to learn about, control, and submit questions and comments about GEST’s handling of their personal data.
Accessing data: Users can access data including their profile data and trip history through the GEST apps or via GEST’s website.
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 GEST’s app.
Deleting data: Users may request deletion of their account at any time through the Settings > Privacy menus in the GEST app, or through GEST’s website.
Objections, restrictions, and complaints: Users may request that we stop using all or some of their personal data, or that we limit our use of their data. This includes objecting to our use of personal data that is based on GEST’s legitimate interests. GEST 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 GEST’s handling of their personal data.
Users may submit the above requests to GEST Holdings, LLC, 344 Gest Street, Cincinnati, Ohio, 45203.
V. Updates to this notice
We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the GEST apps or through 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.
GEST COOKIE POLICY
COOKIE POLICY
We and our affiliates, 3rd-parties, and other partners may use cookies and other identification technologies on our websites, mobile applications, email communications, advertisements, and other online services (collectively, the ‘Services’) for a number of purposes, including: authenticating users, remembering user preferences and settings, determining the popularity of content, delivering and measuring the effectiveness of advertising campaigns, analyzing site traffic and trends, and generally understanding the online behaviors and interests of people who interact with our Services. You can read more here about the types of cookies we use, why we use them, and how you can exercise your choices.
Cookies and Related Technologies Overview
Cookies are small text files that are stored on your browser or device by websites, apps, online media, and advertisements that are used to remember your browser or device during and across website visits. We also utilize other technologies that may identify you or the devices you use. For example, ‘pixel tags’ (also called beacons) are small blocks of code installed on (or called by) a webpage, app, or advertisement which can retrieve certain information about your device and browser, including, for example: device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, advertising identifiers, and other similar information, including the small text file (the cookie) that uniquely identifies the device. Pixels provide the means by which third-parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner. ‘Local storage’ refers generally to other places on a browser or device where information can be stored by websites, ads, or third-parties (such as HTML5 local storage and browser cache). ‘Software Development Kits’ (also called SDKs) function like pixels and cookies, but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the SDK) from partners in the app, and thereby allow the partner to collect certain information about user interaction with the app and information about the user device and network information.
Advertising Synchronization & Relevancy
In order to facilitate the most relevant ads possible, GEST works with various service providers who assist us in delivering similar ads to end users across devices and platforms. For example, we work with social media advertising services to provide you with relevant ads based on your GEST activity through their media channels. We may also use service providers to provide you with a similar ad on a mobile website or mobile application as with a traditional website ad. See below for more information on your choices to limit these types of advertising.
Your Choices
You have the right to choose whether or not to accept cookies. However, they are an important part of how our Services work, so you should be aware that if you choose to refuse or remove cookies, this could affect the availability and functionality of the Services.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. To do so, please follow the instructions provided by your browser which are usually located within the ‘Help’ or ‘Preferences’ menu. Some third-parties also provide the ability to refuse their cookies directly by clicking on an opt-out link, and we have indicated where this is possible in the table below.
For mobile users, you have controls in your device Operating System that enables you to choose whether to allow cookies, or share your advertising ID with companies like GEST or our advertising service providers.
Types and Purposes of Cookies
The following table sets out the different categories of cookies that our Services may use and why we use them. The lists of third-party cookie providers are intended merely as illustrative and should not be viewed as a comprehensive list.
| Types of Cookie | Purpose | |
| Strictly Necessary | These cookies (including local storage and similar technologies) are essential to enable your use of the site or services, such as assisting with your account login, so we can show you the appropriate experience and features, such as your account information, trip history, and to edit your account settings. They may also provide authentication, site security and help localize the language based on the geography of your visit. | |
| Site features and Services | These provide functionality that help us deliver products and Services. For example, cookies help you log in by pre-filling fields. We may also use cookies and similar technologies to help us provide you and others with social plug-ins and other customized content and experiences, such as making suggestions to you and others. |
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| Analytics, Performance and Research | These are used to understand, improve and research products and Services, including when you access the GEST website and related websites and apps from a computer or mobile device. For example, we may use cookies to understand how you are using site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use websites, apps, products, services and ads. |
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| Advertising | These cookies and pixels are used to deliver relevant ads, track email marketing or ad campaign performance and efficiency. For example, we and our ad partners may rely on information gleaned through these cookies to serve you ads that may be interesting to you on other websites. Similarly, our partners may use a cookie, attribution service or another similar technology to determine whether we have served an ad and how it performed or provide us with information about how you interact with them. | |
| Mobile-Specific | These service providers use various technologies to deliver relevant mobile ads, track mobile marketing or mobile ad campaign performance and efficiency. |
Contact Us
If you have any questions about our use of cookies, please contact GEST Holdings, LLC, 344 Gest Street, Cincinnati, Ohio, 45203.