1. General

STAXY LTD (whose registered office is at East Barn, Kings Ash, Great Missenden HP16 9NP) ("we", "our" or "us"), acting as data controller, is committed to protecting and respecting your privacy. This notice (the "Privacy Notice") is designed to tell you about our practices regarding the collection, use and disclosure of information that you may provide via this website or our mobile applications (the "Platforms").

This Privacy Notice (together with our Terms and Conditions, any other documents referred to in it and our Cookie Notice) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

2. What information do we collect from you and for how long?

We may collect and process the following data about you:

2.1. Information you give us

You may give us information, including information that can identify you ("Personal Data"), when you use our Platforms, by filling in forms on the Platforms (such as the sign-up form), when you enter into any of our competitions, promotions or surveys, when you correspond with us by phone, e-mail or otherwise, and when you report a problem with our Platforms.

The information you give us may include:

• 2.1.1. Mandatory information required to register for the service we provide on our Platforms or to access other services provided by us, including your name, email address, mobile phone number and a password. All these fields are mandatory. STAXY will not be able to provide you with the services offered on our Platforms if the required information is not provided, consequently you will not be able to register for a user account on our Platforms;

• 2.1.2. Date of birth

• 2.1.3. Gender

• 2.1.4. Address

• 2.1.5. Photograph;

• 2.1.6. Details on your cars;

• 2.1.7. Your mini-biography;

• 2.1.8. A record of any correspondence between you and us;

• 2.1.9. A record of any correspondence between you and other users;

• 2.1.10. A record of any bookings you have made or trip related advertisements you have placed with or through our Platforms;

• 2.1.11. Details of accounting or financial transactions including transactions carried out through our Platforms or otherwise. This may include information such as your payment card or bank account details, details of trips or legs you have booked or offered through our Platforms;

• 2.1.12. Details of your visits to our Platforms and the resources that you access;

• 2.1.13. Your replies to any surveys or questionnaires, such as your reviews on the trips you have shared with other members of our community. Such information may be used for analytic user understanding purposes;

• 2.1.14. Information we may require from you when you report a problem with our Platforms or our service, such as the subject of your request for support;

• 2.1.15. Location information:

  • When you use specific features that require your location (e.g., setting start/end points for a journey).
  • Optionally, your precise background location, collected over time using GPS and other sensors in your phone, even when the app is closed. This feature requires your explicit opt-in consent and is used to understand your travel patterns (e.g., commuting, travel to specific types of locations relevant to the organisation providing the platform access like a university or sports stadium) and to provide improved travel recommendations and carbon emission monitoring. You can enable or disable this feature at any time through the app settings.

• 2.1.16. Passport, Driving Licence, ID Card and such other documents that you have agreed to provide to us.

2.2. Information we collect automatically

2.2.1. If you sign up via social media authentication methods, STAXY will access certain Personal Data (e.g. first name, surname, picture, email, number of Facebook friends, etc.) in your social media account pursuant to the applicable terms and conditions of these social media platforms. We may also collect some of your Personal Data when you interact with third party social media features, such as "Like" functions.

2.2.2. With regard to each of your visits to our Platforms we may collect, in accordance with applicable laws and where required with your consent, information relating to the devices you use and the networks you are connected to when using our services. This may include the following information: your IP address, log-in information, browser type and version, browser plug-in types and versions, operating system and platform, advertising identifier, information about your visit including the URL clickstream to, through and from our Platforms, products you viewed or searched for, download errors, length of visits to certain pages, page interaction and any phone number used to call our customer service number. We collect this information through the use of various technologies including cookies (for further information please refer to our Cookie Notice).

2.2.3. We also collect aggregated information regarding your activity on our Platform (such as the amount of rides offered, your message response rate, etc.). Such information may be published on your public profile on our Platform.

2.3. Data retention

2.3.1. Except regarding the categories of Personal Data mentioned in clauses 2.3.2, 2.3.3 and 2.3.4 below, your Personal Data will be stored for the duration of your relationship with us and then put beyond use:

• 5 years after your last use of our Platform, if you did not close your account;
• 1 year after the closing of your account, except if you received a negative rating or report, in which case your Personal Data is stored for either (i) a 2-year period following the latest negative rating or report, or (ii) 1 year after the closing of your account, whichever is longer.

2.3.2. The following categories of Personal Data may be stored for different durations:

• Financial data (e.g. payments, reimbursements, etc.) is stored for the duration required by applicable tax and accounting laws;
• All user-generated content (e.g. comments and ratings) is anonymised but remains available on our Platforms.

2.3.3. In the event that your account is suspended or blocked, we will keep your data for a period of between 2 and 10 years in order to prevent you from circumventing the rules applying to our Platforms.

2.3.4. Background location data collected with your explicit consent (as described in 2.1.15) is processed to identify travel relevant to the specific service context (e.g., commuting for an employer-provided platform). Non-relevant location data identified during this process is deleted as soon as possible and held for no longer than 72 hours. Relevant travel history derived from this data is retained according to the general retention periods outlined in 2.3.1 unless specified otherwise for a particular service or feature.

3. How do we use the information we collect from you?

We will use the information we collect:

4. Who are the recipients of the Information we collect from you and for which purposes?

4.1. When you use our services, some information about you is shared with the members of our communities, either on your public profile or during the booking process (e.g. we give your telephone number to the members with whom you will share a ride).

4.2. We may receive and send information about you, including your Personal Data, if you use any of the platforms we operate or from other STAXY entities and affiliates, for the purposes outlined in this Privacy Notice.

4.3. We are also working closely with third parties which may be the recipients of your Personal Data such as:

• our business partners who are social media platforms and which may provide you with connecting services, such as the connection of the information of your profile, from their social media platforms to our Platforms;
• our business partners who may advertise their services on our Platforms and to which you may decide to sign up for: these services may be any service related to our services such as insurance services, banking services, rental services, etc. For instance, we may provide insurance companies such as AXA with some of your information in order to confirm that you are eligible for insurance cover;
• our business partners who may advertise our services on their websites;
• our sub-contractors in technical, payment, identity verification and delivery services, or analytics providers.

4.4. We only share your Personal Data with any of these third parties in the following cases:

• 4.4.1. Where it is necessary to involve a third party service provider, for the performance of any contract we enter into with you in order to facilitate or extend our services (e.g. if we charge you any fees or collect any money from you in relation to any services on the Platforms);
• 4.4.2. As part of the booking process and in order to provide the requested services, information such as your name, photography, mobile phone number and/or email address, may be displayed on the Platforms and/or passed on to a passenger (if you are a driver) or a driver (if you are a passenger);
• 4.4.3. As part of our rating system, the reviews you write will be published on the Platforms. The reviews including your abbreviated name and photography are visible to all visitors of the Platforms;
• 4.4.4. We use analytics and search engine providers to assist us in the improvement and optimisation of our Platforms;
• 4.4.5. It is explicitly requested by you (e.g. with when using social media authentication methods, or enabling features that require data sharing like background location tracking for specific organisational insights);
• 4.4.6. We may distribute parts of our Platforms (including the trips you have posted) for display on our business partners' websites through API or widgets. In these cases, some information from your public profile may be displayed on these websites;
• 4.4.7. STAXY may also disclose your information if required to do so by law or in a good faith belief that such access, preservation or disclosure is reasonably necessary to (i) respond to claims asserted against STAXY, (ii) to comply with legal proceedings, (iii) to enforce any agreement with our users such as our Terms and Conditions and our Privacy Notice, (iv) in the event of an emergency involving the danger of public health, death or physical injury to a person (v) in the framework of investigation or (vi) to protect the rights, property or personal safety of STAXY, its members or others ;
• 4.4.8. In the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets; and
• 4.4.9. If STAXY or all or part of its assets are acquired by a third party, in which case Personal Data held by it about its members will be one of the transferred assets.

4.5. In accordance with applicable laws and where required with your consent (such as for background location data), we may combine information about you, including your Personal Data and cookie information, we send to and receive from our business partners. We may use this information and the combined information for the purposes set out above. Aggregated and anonymised insights derived from user data, including location data, may be shared with external organisations on a commercial basis for understanding CO2 emissions and travel patterns, but this shared data will not be personal data.

4.6. We draw your attention on the fact that if you decide to share your information, including Personal Data, with us through our business partners' connecting services, any of our business partners' privacy policies and/or notices may also be applicable to you, in addition to this Privacy Notice. We do not control the collection and/or the processing of your information eventually made by our business partners on their own platforms.

5. How do we use and moderate your messages?

5.1. We may review, scan, or analyse the messages you exchange with other members of our community through our Platforms for fraud prevention, service improvement, customer support purposes, enforcement of the contracts entered into with our members (such as our Terms and Conditions). For example, in order to prevent the circumventing of our online booking system, we may scan and analyse messages sent through our Platforms to check that they do not include any contact details or references to other websites.

5.2. We will never scan or analyse your messages with other members of our community for commercial and advertising purposes. We may use automated methods to carry out the moderation of these messages, but no automated individual decision-making is performed in this regard.

6. Targeted ads on social media platforms and our communications sent by e-mail and/or text messages

In accordance with applicable laws and where required with your consent, we may use the information you give us on our Platforms for electronic direct marketing purposes (e.g. (i) receiving our newsletters, invitations to our events or other communications that we think may interest you or (ii) serving you with targeted advertising on social media platforms or third parties websites). Your background location data, if you consent to its collection, may be used to help tailor suggestions and recommendations as described in section 3, but will not be directly used for serving third-party targeted advertising unrelated to our services.

For electronic marketing communications: You can withdraw your consent at any time by (i) unticking the relevant box in your member account, (ii) clicking on the unsubscribe link we provide in each STAXY communication sent to your attention or (iii) contacting us using the contact details provided in section 13 below.

For targeted ads and content:

• on social media (e.g. Facebook and Twitter): you can object at any time by configuring your settings regarding advertisement via your social media account;
• on third party websites: please refer to our Cookie Policy to see how to object.

7. What are your rights in respect of your personal data?

7.1. You are entitled to receive a copy of your personal data that is in our possession ( your right of data access ).

7.2 You may request the deletion of personal data or the correction of inaccurate personal data ( your right to erasure and rectification ). Please note that we may keep certain information concerning you, as required by law, or when we have a legal basis to do so (e.g., our legitimate interest to keep the platform safe and secure for other users, or legal requirements for financial data retention). You can review and request corrections to your travel history derived from location data via the platform features.

7.3 You have the right to object at any time (i) to the processing of your personal data for the purpose of direct marketing, or (ii) to the processing of your personal data for other purposes on grounds relating to your particular situation ( your right to object to processing ). Please note that in the latter case, this right only applies if the processing of your personal data is based on our legitimate interest. Processing based on your explicit consent (such as background location tracking) can be stopped by withdrawing your consent (e.g., disabling the feature in the app settings).

7.4 You have the right to restrict the processing of your personal data ( your right to restriction of processing ). Please note that this only applies if (i) you contested the accuracy of your personal data and we are verifying the accuracy of the personal data, (ii) you exercised your right to object and we are still considering, as foreseen by the applicable law, whether our legitimate grounds to process your personal data in that case override your interests, rights and freedoms; or (iii) your personal data has been processed by us in an unlawful way but you either oppose the erasure of the personal data or want us to keep your personal data in order to establish, exercise or defend a legal claim.

7.5 You have the right to receive and/or have us transfer to another data controller a subset of personal data, that concern you and that you provided us with, and which we process for the performance of our contract or because you previously consented to it, in a structured, commonly used and machine-readable format ( your right to data portability ).

7.6 To exercise your rights, or withdraw consent for processing like background location tracking, you can use the settings within our Platforms where available, or contact the Group Data Protection Officer (see under Article 13).

7.7. You also have the right to make a complaint to the relevant data protection supervisory authority (in the UK, this is the Information Commissioner's Office - ICO) or to seek a remedy through the courts if you believe that your rights have been breached.

8. Cookies & similar technologies

To find out more, please see our Cookie Notice.

9. Confidentiality of your password

Where you have chosen a password which enables you to access certain parts of our Platforms, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

10. Links to other websites and social media

Our Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy practices and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.

11. Changes to our Privacy Notice

Any changes we may make to our Privacy Notice in the future will be posted on this page. Where appropriate, we will notify you or seek your consent, especially for significant changes impacting how your data is processed. Please check back frequently to see any updates or changes to our Privacy Notice.

12. Contact & Data Protection Officer

If at any time you would like to contact us with your views about our privacy practices, or with any enquiry relating to your Personal Data, including exercising your rights or withdrawing consent, please use one of the following means:

• via email to our Data Protection Officer under communications@staxy.live

Version dated 13 January 2025