TOGOTRANSFER PRIVACY POLICY

Effective date: December 1, 2025

This Privacy Policy (“Policy”) describes how To Go Transfer FZ LLC (“Company”, “we”, “our”) collects, processes, stores, and shares personal data when you use the ToGoTransfer.com service (the “Service”), including our website, mobile apps, and related features. By using the Service, you confirm your agreement with this Policy.

1. GENERAL

1. The data controller is To Go Transfer FZ LLC, License No. 19520/2025, P.O.Box 4422, Twin Towers, Fujairah Creative City – Media Free Zone, UAE.
2. We may update this Policy at any time. The current version is always published on our website. Continued use of the Service means you accept the updated Policy.
3. Terms not defined in this Policy have the meaning given in the ToGoTransfer Terms of Use.

2. DATA WE COLLECT

2.1. Passengers / Users

• Name or nickname
• Contact details (phone, email)
• Photos, avatar, chat messages, reviews
• Booking and order history
• Geolocation (with your consent)
• IP address, device info, cookies
• Support requests

Important: We do not collect or store your card details. Payments are processed securely via licensed third-party providers.

2.2. Drivers / Carriers

• Company or sole trader details, licenses
• Representative name, contact info
• Vehicle and driver documents/photos
• Bank/payment details for payouts
• Booking history, ratings, chat messages

2.3. Special categories of data

Information about health, mobility, or special needs (e.g. child seats, wheelchair access) is processed only with your explicit consent and solely for providing transport services.

3. HOW WE USE DATA

We use your data to:

• process bookings and payments;
• communicate with you;
• verify and maintain account accuracy;
• provide support and resolve disputes;
• ensure safety, compliance, and KYC/AML checks;
• send service updates;
• send marketing messages (with your consent).

4. WHO WE SHARE DATA WITH

We share data only where necessary:

• With drivers – passenger’s name/nickname, phone, pickup details.
• With passengers – driver/carrier details, contact info, vehicle info.
• With payment providers – for transaction processing.
• With IT and cloud service providers – for hosting and technical support.
• With affiliates/contractors – to operate the Service.
• With auditors, consultants, legal advisors – when required.
• With government authorities – where required by law.
• In case of merger/sale – with the new owner.

Data may be transferred internationally, including outside the UAE, EU, UK, and US.

5. ROLES AND RESPONSIBILITIES

• The Company is the controller of user data.
• Carriers are independent controllers of the data they receive to perform rides.
• Payment providers and cloud services act as controllers or processors, depending on context.

6. DATA RETENTION & DELETION

1. Data is stored until the account is deleted.
2. For compliance (accounting, AML, legal claims), we may retain data for up to 7 years after account deletion.
3. After that, data will be deleted or anonymized.

7. YOUR RIGHTS

You have the right to:

• access your data;
• correct inaccurate information;
• delete your data (“right to be forgotten”);
• restrict processing;
• data portability (machine-readable format);
• object to processing (including marketing);
• withdraw consent at any time;
• file a complaint with your local Data Protection Authority (DPA).

Requests: info@togotransfer.com

8. COOKIES & TRACKERS

We use cookies to:

• personalize and save preferences;
• analyze usage (aggregated statistics);
• display relevant ads.

Users in the EU/UK will see a cookie consent banner and can choose categories. You may disable cookies in your browser, but some features may not work properly.

9. LEGAL BASES & JURISDICTIONS

We comply with:

• GDPR (EU/EEA, Switzerland)
• UK Data Protection Act 2018
• CCPA/CPRA (California, USA)
• LGPD (Brazil)
• PIPEDA (Canada)
• PDPL (UAE)

Processing is based on:

• contract performance (Terms of Use);
• our legitimate interests (without overriding your rights);
• your consent (marketing, special data);
• legal obligations.

10. SECURITY

We use technical and organizational measures: SSL/TLS encryption, ISO 27001-certified hosting, access controls, and fraud-monitoring systems.

11. CONTACT

If you are located in the EU/UK, you may also contact your local data protection authority.

12. LANGUAGE & PRIORITY

This Policy may be translated into other languages. In case of discrepancies, the English version published on the website prevails.