Citybug Privacy Policy
Effective Date: 2018/05/24, Last Modified: 2018/05/24
1. Introduction
This Privacy Policy describes how Citybug collects and uses Personal Data about you through the use of our Websites,
our products, and through email, text, and other electronic communications between you and Citybug.
TaxiU bug t/a Citybug ("Citybug" or "we") respect your privacy and are committed to protecting it through our compliance with this policy.
This Privacy Policy (our "Privacy Policy") describes the types of information we may collect from you or that you may provide
when you visit the websites (each, a "Website") or our Online Booking System and our practices for collecting, using,
maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
- on our Websites and our Online Booking System;
- in email, text, and other electronic messages between you and our Websites (including our support services);
It does not apply to information collected by:
- us offline or through any other means, including on any other website operated by Citybug or any third-party;
or
- any third party, including through any application or content that may link to or be accessible from or on the Website
or with our products.
Please read this policy carefully to understand our policies and practices regarding your information and how we will
treat it. If you do not agree with our policies and practices, your choice is not to use our Websites and/or not
to make use of our Online Booking System. By accessing or using these Websites and our Online Booking System, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see
Changes to Our Privacy Policy). Your continued use of these Websites and continued use of our Online Booking System after we make changes is deemed to be acceptance of those changes, so please check this Privacy
Policy periodically for updates.
2. Data Controller, Data Protection Officer
Citybug is the data controller of the Personal Data you provide on the Websites.
Citybug is the data controller of your Personal Data. Citybug, its Data Protection Officer, or its representative
may be contacted in any manner set forth below in the "Contact Information" Section of this Privacy Policy.
3. Children Under the Age of 18
Our Websites are not intended for children under the age of 18 and children under the age of 18 are not permitted to use
our Websites. We will remove any information about a child under the age of 18 if we become aware of it.
Our Websites are not intended for children under 18 years of age. No one under age 18 may provide any information to
or on the Websites or make a booking via our Online Booking System. We do not knowingly collect Personal Data from
children under 18. If you are under 18, do not register on the Websites, make any purchases through the Websites,
use any of the interactive or public comment features of our Websites, or provide
any information about yourself to us, including your name, address, telephone number, email address, or any screen
name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without
verification of parental consent, we will delete that information. If you believe we might have any information from
or about a child under 18, please contact us in any manner set forth below in the "Contact Information" Section of this Privacy Policy.
4. Information We Collect About You and How We Collect It
We collect information different types of information about you, including information that may directly identify you, information
that is about you but individually does not personally identify you, and information that we combine with our other
users. This includes information that we collect directly from you or through automated collection technologies.
Generally
We collect several types of information from and about users of our products and Websites, specifically information:
- by which you may be personally identified, such as name, postal address, e-mail address, telephone number, credit
card information (for payment processing) and any other identifier by which you may be contacted online or offline
("Personal Data");
- that is about you but individually does not identify you, such as Website traffic data, location data (through IP
address), logs, referring/exit pages, date and time of your visit to our Websites, error information, clickstream
data, and other communication data and the resources that you access and use on the Websites;
- if you make a booking via our online booking system; and/or
- about your internet connection, the equipment you use to access our Websites and usage details.
We collect this information:
- directly from you when you provide it to us;
- automatically as you navigate through the site. Information collected automatically may include usage details (including
the number of installations for products you have purchased), IP addresses, and information collected through cookies,
web beacons, and other tracking technologies; and
- From third parties, for example, our resellers.
Information You Provide to Us
The information we collect on or through our Websites are:
- information that you provide by filling in forms on our Websites. This includes information provided at the time
of registering to use our Websites, posting material, or requesting further services (such as technical support).
We may also ask you for information when you enter a contest, sweepstakes, or promotion sponsored by us, and when
you report a problem with our Websites;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to quizzes and surveys that we might ask you to complete for research purposes;
- details of transactions you carry out through our Websites and of the fulfillment of your bookings. You may be required
to provide financial information before placing an order through our Websites; and
- your search queries on the Websites.
The Personal Data we collect from you is required to enter into a contract with Citybug, for Citybug to perform
under the contract, to provide you with our products and services, and to provide you with license keys to our products.
If you refuse to provide such Personal Data or withdraw your consent to our processing of Personal Data, then in
some cases we may not be able to enter into the contract or fulfill our obligations to you under it.
You also may provide information to be published or displayed (hereinafter, "posted") on public areas of the Websites or transmitted to other users of the Websites or third parties
(collectively, "User Contributions"). If you consent, your User Contributions may include technical support tickets
that you make publicly available to our user community. Your User Contributions are posted on and transmitted to
others at your own risk. Although we limit access to certain pages, please be aware that no security measures are
perfect or impenetrable. Additionally, we cannot control the actions of other users of the Websites with whom you
may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions
will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Websites, we may use automatic data collection technologies to collect
certain information about your equipment, browsing actions, and patterns, specifically:
- details of your visits to our Websites, specifically traffic data, location data (through IP addresses), logs, referring/exit
pages, date and time of your visit to our Websites, error information, clickstream data, and other communication
data and the resources that you access and use on the Websites;
- the number of installations for the products you have purchased; and
- Information about your computer and internet connection, specifically your IP address, operating system, and browser
type.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data
we collect in other ways. It helps us to improve our Websites and to deliver a better and more personalized service
by enabling us to:
- estimate our audience size and usage patterns;
- store information about your preferences, allowing us to customize our Websites according to your individual interests;
- prevent or deter software piracy and protect our intellectual property;
- speed up your searches; and
- recognize you when you use and return to our Websites.
5. Lawful Basis for Processing Your Personal Data
We have a lawful basis for our processing of your Personal Data, including processing for our legitimate interests (when
balanced against your rights and freedoms), to fulfill our obligations to you under a contract with you, and required
by law, and with your consent.
If you are in the European Union, the processing of your Personal Data is lawful only if it is permitted under the
applicable data protection laws. We have a lawful basis for each of our processing activities (except when an exception
applies as described below):
-
Consent. By using our Websites, you consent to our collection, use, and sharing of your Personal Data
as described in this privacy policy. If you do not consent to this privacy policy, please do not use the Websites.
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Legitimate Interests. We will process your Personal Data as necessary for our legitimate interests. Our
legitimate interests are balanced against your rights and freedoms and we do not process your Personal Data if
your rights and freedoms outweigh our legitimate interests. Specifically, our legitimate interests are to: facilitate
communication between Citybug and you; detect and correct bugs and to improve our Websites, products, and
services; safeguard our IT infrastructure and intellectual property; detect and prevent fraud and other crime (including
misappropriation of intellectual property); promote and market our business; check your credit and perform risk
assessments; and develop our product and services.
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To Fulfill Our Obligations to You under our Contract. We process your Personal Data in order to fulfill
our obligations to you pursuant to our contract with you to deliver our goods and services to you. Specifically,
we use your contact information to provide you with the products, license keys, and support services that you order
from us.
-
As Required by Law. We may also process your Personal Data when we are required or permitted to by law;
to comply with government inspection, audits, and other valid requests from government or other public authorities;
to respond to legal process such as subpoenas; or as necessary for us to protect our interests or otherwise pursue
our legal rights and remedies (for instance, when necessary to prevent or detect fraud, attacks against our network,
or other criminal and tortious activities), defend litigation, and manage complaints or claims.
6. Special Categories of Information
We generally do not request you provide and do not process any special categories of Personal Data.
Citybug does not ask you to provide, and we do not knowingly collect, any special categories of Personal Data
from you, such as Personal Data that reveals your racial or ethnic origin, political opinions, religious, philosophical
beliefs, or trade unions membership, or the processing of data concerning your health or data concerning your sex
life or sexual orientation or history of criminal convictions.
7. Automated Decision Making
We generally do not use your Personal Data with any automated decision making processes.
Citybug does not use your Personal Data with any automated decision making processes.
8. How We Use Your Information
We use your Personal Data for various purposes described below, including to:
- provide our Websites to you;
- provide you with information you request from us;
- enforce our rights arising from contracts;
- notify you about changes; and
- provide you with notices about your account
We use information that we collect about you or that you provide to us, including any Personal Data:
- to present our Websites and their contents to you;
- to provide you with information, products (including license keys), or services that you request from us;
- to provide you with information about security advisories regarding the products or services that you have purchased
from us;
- to fulfill any other purpose for which you provide it;
- to provide you with notices about your account, including expiration and renewal notices, invoices, and receipts;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including
for billing and collection;
- to notify you about changes or updates to our Websites or any products or services you have purchased or that we
offer or provide though our Websites;
- to allow you to participate in interactive features on our Websites;
- when necessary to contact you about processing an order or transaction, to contact you through phone or SMS messages;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
With your consent, we may also use your information to send you newsletters and contact you about our own goods and
services that may be of interest to you, including events and other activities that may be in your area or may be
of interest to you. If you wish to consent to this use, please check the relevant box located on the form on which
we collect your data. Your choices may be found by first navigating to the "My Account" page and then navigating
to the "Notifications" section on the "Manage Profile" page. If you wish to change your choice,
you may do so at any time by checking or unchecking the relevant boxes in this "Notifications" section
or by sending us an email stating your request to
info@citybug. For more information, see
Choices About How We Use and Disclose Your Information.
9. Disclosure of Your Information
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy.
We disclose your Personal Data to a few third parties, including:
- our third-party service providers that we use to support our business, such as our payment processors and hosting
providers;
- to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
- to comply with our legal obligations;
- to enforce our rights; and
- with your consent.
We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy
Policy. However, we may disclose aggregated information about our users, and information that does not identify any
individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this privacy policy:
- to contractors, service providers, and other third parties we use to support our business and who are bound by contractual
obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them.
Specifically, these entities provide IT and infrastructure support services and payment processing services.
- to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution,
or other sale or transfer of some or all of TaxiU bug t/a Citybug´s assets, whether as a going concern or as part
of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by TaxiU bug t/a Citybug about
our Websites’ users is among the assets transferred;
- to fulfill the purpose for which you provide it. For example, if you give us a name and/or email address and post
in public comments to a page, we will transmit your name and/or email address to anybody who views that comment
page;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your Personal Data:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
-
to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of TaxiU bug t/a Citybug, our customers, or others. This includes exchanging information with other companies and organizations for
the purposes of fraud protection and credit risk reduction.
10. Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties
to advertise to you, our advertising to you, and other targeted advertising.
We do not control the collection and use of your information collected by third parties described above in
Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this
data only for providing the services to us and to maintain this information strictly confidential. These third parties
may, however, aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms
to provide you with control over your Personal Data:
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Promotional Offers from Citybug. We will only use your email address to promote our own or third
parties’ products and services with your express consent. If you wish to consent to such use, you can check the
relevant box located on the form on which we collect your Personal Data or otherwise seek such consent. Your choices
may be found by first navigating to the "My Account" page and then navigating to the "Notifications"section on the "Manage Profile" page. If you wish to change your choice, you may do so at any time by
checking or unchecking the relevant boxes in this "Notifications" section or by sending us an email stating
your request to
info@citybug. If we have sent you a promotional email, you may unsubscribe by clicking the unsubscribe
link at the bottom of the email. This opt out does not apply to information provided to Citybug as a result
of a product purchase, support emails, product service experience, security advisory messages (security fixes and
updates) for the products you have purchased from us, or other transactions.
11. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may have certain rights under applicable data protection laws, including the right to access and update your Personal
Data, restrict how it is used, transfer certain Personal Data to another controller, withdraw your consent at any
time, and the right to have us erase certain Personal Data about you. You also have the right to complain to a supervisory
authority about our processing of your Personal Data.
Applicable data protection laws may provide you with certain rights with regards to our processing of your Personal
Data.
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Access and Update. You can review and change your Personal Data by logging into the Websites and visiting
the "Manage Profile" section of your "My Account" page. You may also notify us through the
contact information below or through our Websites’ live chat features of any changes or errors in any Personal
Data we have about you to ensure that it is complete, accurate, and as current as possible. We may also not be
able to accommodate your request if we believe it would violate any law or legal requirement or cause the information
to be incorrect.
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Restrictions. You have the right to restrict our processing of your Personal Data under certain circumstances.
In particular, you can request we restrict our use of it if you contest its accuracy, if the processing of your
Personal Data is determined to be unlawful, or if we no longer need your Personal Data for processing, but we have
retained it as permitted by law.
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Portability. To the extent the Personal Data you provide Citybug is processed based on your consent,
you have the right to request that we provide you a copy of, or access to, all or part of such Personal Data in
structured, commonly used and machine-readable format. You also have the right to request that we transmit this
Personal Data to another controller, when technically feasible.
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Withdrawal of Consent. To the extent that our processing of your Personal Data is based on your consent,
you may withdraw your consent at any time by closing your account. Withdrawing your consent will not, however,
affect the lawfulness of the processing based on your consent before its withdrawal, and will not affect the lawfulness
of our continued processing that is based on any other lawful basis for processing your Personal Data.
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Right to be Forgotten. You have the right to request that we delete all of your Personal Data. We cannot
delete your Personal Data except by also deleting your user account and revoking your licenses, and we will only
delete your account when we no longer have a lawful basis for processing your Personal Data or after a final determination
that your Personal Data was unlawfully processed. We may not accommodate a request to erase information if we believe
the deletion would violate any law or legal requirement or cause the information to be incorrect. In all other
cases, we will retain your Personal Data as set forth in this policy. In addition, we cannot completely delete
your Personal Data as some data may rest in previous backups. These will be retained for the periods set forth
in our disaster recovery policies. We also cannot delete your User Contributions, however proper access and use
of information provided on the Websites, including User Contributions, is governed by our
Terms of Use.
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Complaints. You have the right to lodge a complaint with the applicable supervisory authority in the country
you live in, the country you work in, or the country where you believe your rights under applicable data protection
laws have been violated. However, before doing so, we request that you contact us directly in order to give us
an opportunity to work directly with you to resolve any concerns about your privacy.
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How You May Exercise Your Rights. You may exercise any of the above rights by contacting us through any
of the methods below and through the live chat feature of our Websites. If you contact us to exercise any of the
foregoing rights, we may ask you for additional information to verify your identity. We reserve the right to limit
or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy
our legal and business requirements.
12. Do Not Track Signals
We do not track you over time and across other third-party websites or services and therefore We currently do not honor do-not-track
signals that may be sent by some browsers.
We do not track you over time and across third-party websites or other online services for any purpose. Some web browsers
permit you to broadcast a signal to websites and online services indicating a preference that they "do not track "your
online activities. At this time, we do not honor such signals and we do not modify what information we collect or
how we use that information based upon whether such signal is broadcast or received.
13. Data Security
Information transmitted over the Internet is not completely secure, but We do our best to protect your Personal Data. You
can help protect your Personal Data and other information by keeping your password to our Websites confidential.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access,
use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen)
a password for access to certain parts of our Websites, you are responsible for keeping this password confidential.
We ask you not to share your password with anyone. We urge you to be careful about giving out information in public
areas of the Websites like message boards. The information you share in public areas may be viewed by any user of
the Websites.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to
protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Websites. Any
transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings
or security measures contained on the Websites.
14. Consent to Processing of Personal Data in South Africa
We may process your Personal Data outside of your home country, including to South Africa. We only do this when we are
legally permitted to do so and when we have appropriate safeguards in place to protect your Personal Data.
If you are a resident of the European Economic Area ("EEA"), in order to provide our Websites, products, and services to you, we may send and store your
Personal Data outside of the EEA, including to South Africa. Accordingly, your Personal Data may be transferred
outside the country where you reside or are located, including to countries that may not or do not provide an adequate
level of protection for your Personal Data.
Your Personal Data is transferred by Citybug to another country only if it is required or permitted under applicable
data protection law and provided that there are appropriate safeguards in place to protect your Personal Data. By
using our Websites or making a booking via our Online Booking System, you represent that you have read and understood the
above and hereby consent to the storage and processing of Personal Data that you provide directly to us on our Websites
or through our Online Booking System. To ensure your Personal Data processed by other recipients is treated
in accordance with this Privacy Policy, Citybug uses Data Processing Agreements between Citybug and all
other recipients of your data that include, where applicable, the Standard Contractual Clauses adopted by the European
Commission (the "Standard Contractual Clauses"). The European Commission has determined that the transfer of Personal
Data pursuant to the Standard Contractual Clauses provides for an adequate level of protection of your Personal Data.
Under these Standard Contractual Clauses, you have the same rights as if your data was not transferred to such third
party. You may request a copy of the Data Processing Agreement by contacting us through the contact methods below.
15. Data Retention Periods
We retain your Personal Data for as long as you keep your account open. In some instances, we may keep it after you
close your account, for example we may keep it:
- on our backup and disaster recovery systems;
- for as long as necessary to protect our legal interests; and
- and to comply with other legal requirements.
Citybug will retain your personal data for the entire time that you keep your account open. After you close your
account and request your information to be deleted, we may retain your Personal Data:
- for as long as necessary to comply with any legal requirement;
- on our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;
- for as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies; and
- for data that has been aggregated or otherwise rendered anonymous in such a manner that you are no longer identifiable,
indefinitely.
16. Changes to Our Privacy Policy
We will post any changes to our Privacy Policy on our Websites. If we make material changes to our Privacy Policy, we may
notify you of such changes through your contact information and invite you to review (and accept, if necessary) the
changes.
We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on
this page with a notice that the Privacy Policy has been updated on the Websites’ home page. If we make material
changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your
account and through a notice on the Websites’ home page. The date this Privacy Policy was last revised is identified
at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address
for you, and for periodically visiting our Websites and this Privacy Policy to check for any changes.
17. Contact Information
You may contact our Data Protection Officer through the contact information below. If you wish to contact us, you must contact
both us and our representative through the contact information below or through the "Contact Us" page on
our Websites.
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related
to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you must contact both us and
our representative in the European Union at the contact information below or through the "Contact" page
on our Websites.
To Contact Citybug (Controller)
Citybug
61 Graniet Street
Nelspruit, 1200
info@citybug.co.za
0861 33 44 33