GDPR Privacy Notice

This GDPR Privacy Notice describes the rights and choices that residents of the EU, the European Economic Area (EEA), the United Kingdom, or Brazil have with respect to their Personal Data, and ways to contact Bringg to learn more about our privacy practices. For the avoidance of doubt, reference to “GDPR” is for convenience purposes only, and this GDPR Privacy Notice equally relates to UK GDPR and LGPD (as these terms defined below).

1. Your Rights

   We hereby inform you of the following rights you may have with respect to the processing of your Personal Data under the GDPR and/or the UK GDPR and/or the LGPD:

   • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
   • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
   • Erasure:You can request that we erase or “block” some or all of your Personal Data from our systems (e.g.: where the continued processing of a specific data is not justified), unless such Personal Data is necessary for compliance with a legal obligation or the establishment, exercise or defence of legal claims.
   • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time, although we may have other legal grounds for processing your data for other purposes. However, if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
   • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
   • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes (in particular, where we don’t have to process the data to meet a contractual or other legal requirement)./li>
   • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
   • Right to File Complaint: You have the right to lodge a complaint about Bringg’s practices with respect to your Personal Data before the relevant data protection authority or supervisory authority of your jurisdiction.

   To exercise these rights, where applicable, please contact your organization or, if applicable, use the appropriate functionality available on the Platform and/or Apps. For the purpose of this GDPR Privacy Notice:

   • “UK GDPR” means the Data Protection Act 2018, as well as the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018 and as amended by the Data Protection, Privacy and Electronic Communications (Amendments etc.) (EU Exit) Regulations 2019 (SI 2019/419); and
   • “LGPD” means the Brazilian Law No. 13.709 of 14 August 2018 which provides for the Protection of Personal Data and amends the Federal Law No. 12.965 of 23 April 2014

2. Specific Rights of Mobile Personnel

   If you are a California consumer, you may have the right to:

   • Where we display each Mobile Personnel’s shifts, breaks, and working hours to Authorized Users on behalf of the Customer (the dispatcher), this may result in some deliveries not being assigned by the Authorized Users to certain members of the Mobile Personnel. You may contact a representative of your organization or of the Customer (as the case may be) to receive more information on the grounds that have led to make the decision on assignment of deliveries.
   • Where the End-Customers rate the applicable Mobile Personnel and the entire delivery experience, this may result in certain members of the Mobile Personnel becoming preferable over others and as a result, being assigned with more deliveries. You may contact a representative of your organization or of the Customer (as the case may be) to receive more information on the grounds that have led to make the decision on assignment of deliveries and to appeal on such decision.

3. Transfers of Personal Data

   Your Personal Data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different from the laws of your country. Our group companies and third-party service providers and partners operate around the world. This means that when we collect your Personal Data, we may process it in any of these countries. Specifically, our Services are hosted both in the EU and the USA, and our support services are provided from Israel, USA, and Ukraine.
   Bringg is committed to protect your Personal Data and takes appropriate steps to ensure that your Personal Data is processed and stored securely and in accordance with applicable privacy laws, as detailed in this Privacy Policy. Specifically, we apply the following safeguards when transferring your Personal Data outside of the European Economic Area (“EEA”) or the UK (as the case may be):

   • We transfer your Personal Data to countries approved by the European Commission as providing adequate protection for Personal Data, or subject to a UK “adequacy regulations” (such as Israel) (collectively, “Approved Countries”);
   • We use the EU Standard Contractual Clauses set out in the Commission Implementing Decision (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries (“EU SCC”), or the international data transfer agreement and/or the international data transfer addendum to the EU SCC adopted pursuant to or permitted under Article 46 of the UK GDPR (“UK SCC”) (as the case may be), when Personal Data is transferred outside the EEA or UK, into countries which are not Approved Countries (such as the USA);
   • All Bringg entities have signed an Intragroup Agreement containing the EU SCC and/or UK SCC for the transfer of data outside the EEA and UK; and
   • Finally, all Bringg entities have the same technical, physical, and administrative security controls and are required to comply with our data protection policies and procedures, applicable laws, and the terms of our client and member contracts governing the collection and use of information.

4. UK Representative

   Bringg UK Limited has been appointed as Bringg’s representative in the United Kingdom for data protection matters, pursuant to Article 27 of the UK GDPR. If you are in the United Kingdom, Bringg UK Limited can be contacted on matters related to the processing of Personal Data. To make such an inquiry, please send an email to privacy@bringg.com.