Russian Federation, Ufa
Revision of 23.07.2024
1. General Provisions
We, Car Blanche OOO ("CAR BLANCHE"), take the protection of your personal data seriously and protect your privacy when processing them in accordance with the applicable data protection regulations.
This privacy policy informs you as a visitor of the Car Blanche websites, as a user or customer of the online platform of Car Blanche, a Car Blanche App or other services of Car Blanche (together also " Car Blanche Services") which of your personal data is processed by Car Blanche and for which purpose. The Car Blanche Services are not aimed at minors.
Information on the processing of personal data of chauffeurs can be found in the
Chauffeur Privacy Policy (e.g. in the CB Chauffeur App).
2. Name and Contact Information of the Controller
The controller for the processing of data within the meaning of the General Data Protection Regulation (GDPR) is:
Car Blanche OOO
106 ul. Dostoevskogo
Ufa
Republic of Bashkortostan
Russian Federation,
45007
E-Mail:
b2b.car.blanche@gmail.comYou can find further information on Car Blanche in the Legal Notice:
https://car-blanche.net/imprint3. Contact Information for the Data Protection Officer
Our data protection officer is: “CAR BLANCHE”, OGRN 1200200052095, INN 0274959783, location address: 450077, Ufa, st. Dostoevsky, 106
You can contact our data protection officer confidentially by mail to the above-mentioned address. Alternatively, you can contact our data protection officer and our data protection crew by e-mail to: b2b.car.blanche@gmail.com
4. Data Security
Car Blanche uses appropriate technical and organizational security measures to ensure a level of protection for personal data appropriate to the risk, taking into account the state of the art, implementation costs and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and the degree of risk. The transfer of personal data between your user device and Car Blanche is generally carried out in an encrypted form (TLS encryption). You can identify an encrypted connection for example by the lock symbol in the address line of your browser.
If you communicate with us by e-mail, access by third parties cannot be ruled out. In the case of confidential information, Car Blanche therefore recommends using ordinary mail or encrypted e-mail communication (PGP). Please let us know if you would like to correspond with us by e-mail in an encrypted form so that we can give you information on the relevant addresses and public keys.
5. Provision of the websites
When visiting Car Blanche websites for information purposes, i.e. even without your registration, data is automatically collected regarding the usage through your browser (hereinafter “surf data”). This includes your IP address, the status code, the Car Blanche websites visited, date and time of the server request, browser type and browser version, referrer (website visited beforehand), files transferred and data volume. The surf data is stored by Car Blanche in so-called log files. If you visit Car Blanche websites without having a Car Blanche account, we will not know who you are.
We inform you about the cookies and analysis services used by Car Blanche in section 6. Otherwise, your surf data will not be provided to third parties. The processing of surf data is mainly carried out to establish and maintain the technical connection when surfing the internet. This data is also used by Car Blanche in a pseudonymized or anonymized form in order to analyze the use of our websites, to design and improve the Car Blanche services to meet demand, to recognize and eliminate technical or process-related disruptions and problems and to prevent illegal use of the Car Blanche services (e.g. fraudulent booking, cyberattacks).
Stored log files are erased or anonymized, provided they are no longer required to ensure the general functionality of Car Blanche services. Car Blanche retains the log files only insofar as you have consented to this or if there are legal retention obligations.
The legal basis for the processing of personal data when providing websites is Art. 6 Paragraph 1 lit f GDPR (Car Blanche legitimate interest). Insofar you are a Car Blanche user or customer, the legal basis is also Art. 6 para. 1 lit. b DSGVO (contract performance, see otherwise below number 9.). If you have consented to an extended usage of your surf data, the legal basis is Art. 6 Paragraph 1 lit. a GDPR (your consent). You can revoke your consent at any time.
6. Special Features for the Car Blanche Apps
Car Blanche apps are another access point to Car Blanche services. Similar processing of personal data is generally carried out via the Car Blanche apps as via the Car Blanche websites (see number 5 above) or in the case of registered use of the Car Blanche Services (see number 9).
When using the Car Blanche apps, Car Blanche may also access additional data in relation to the app or to your end device, such as e.g. the device name, device manufacturer, model, operating system, app or SDK version, mode.
There are also push notifications in the Car Blanche apps, i.e. notifications provided by Car Blanche in the app of your end device. You will only receive push notifications if you have given your consent to this on your end device. The legal basis for the data processing is Art. 6 Paragraph 1 lit a GDPR (your consent).
There is a special Car Blanche App ("CB Chauffeur") for drivers or driving service providers working with Car Blanche. You can find information on the processing of personal data carried out by means of CB Chauffeur in the
Chauffeur Privacy Policy.
7. Social Media / Social Networks
7.1 Car Blanche Social Media Presence
Car Blanche maintains pages in social networks such as YouTube, GitHub or Instagram. The respective provider of the social network provides detailed information about which personal data is processed and how. In addition, please see our notes on our pages on the respective platforms.
8. Data Processing During Registered Use of Car Blanche Services and Booking Rides
Car Blanche processes the following personal data provided by you when you register and use Car Blanche Services or when you book rides (hereinafter “customer data”).
- Personal master data (form of address, title, first name, last name, company, address, zip code, place, country, password);
- Contact data (e.g. telephone number, cellphone number, e-mail address);
- Contract data (e.g. time and manner of registration, status)
- Ride-related data (e.g. pickup location, destination, times, flight number, special requests).
- Status (e.g. bonus program), customer history (e.g. previous rides);
- Contract invoicing (e.g. invoices, status, invoicing address) and payment data (e.g. last 4 digits of the credit card number).
The customer data will be used for Car Blanche services, i.e. for the personalized fulfillment of the framework agreement after registration (creation, storage, administration and support of your Car Blanche account), for the procurement of booked rides and for the fulfillment of the contract of carriage for the benefit of the customer with the limousine service provider. Car Blanche provides customer data to third parties, if necessary, in particular to the limousine service providers so that the customer can be transported in accordance with their booking and the transport can be processed. If the customer has indicated a bonus program supported by Car Blanche, the data required in this regard is transmitted to the bonus program provider. The payment data collected is stored via a payment service provider and transferred to the intermediary financial service provider or bank (see Point 9).
Personal data can be transmitted to limousine service providers in a third-party country outside of the European Union or the European Economic Area in which the transport is intended to take place. Car Blanche cannot generally provide further information on the data protection level in the third-party country. An adequacy decision (see Art. 45 Paragraph 3 GDPR) or suitable guarantees (see Art. 46 GDPR) are not required for the transmission since the transmission is required for the performance of a contract between the data subject and the controller or to carry out pre-contractual measures upon request from the data subject (Art. 49 Paragraph 1 lit b GDPR) or because the transmission is required to enter into or to perform a contract concluded in the interest of the data subject by the controller with another natural or legal person (Art. 49 Paragraph 1 lit c GDPR).
Customers have the possibility to rate a ride arranged by Car Blanche e.g. in the Car Blanche App. Ratings are stored in the customer's profile and can be communicated to the respective driving service or provider or chauffeur in anonymised form. The customer can view his own reviews, other customers will not see these reviews. The purpose of the data processing within the evaluation system is the handling of the trip or the payment towards the driver or the dispatcher as well as the analysis and improvement of the Car Blanche Services, e.g. to monitor the proper execution of trips, to increase the quality and to prevent or combat illegal use. Ratings are usually not stored for more than 2 years and then deleted or anonymised.
The legal basis for the processing of personal data during the registered use of Car Blanche Services and during the booking of trips is Art. 6 para. 1 lit. b GDPR (contract performance). If the data subject provides additional, voluntary information (e.g. flight number, frequent flyer programme, special requests, rating), the legal basis is their consent according to Art. 6 Paragraph 1 lit a GDPR and our legitimate interest according to Art. 6 Paragraph 1 lit. f GDPR.
In addition, Car Blanche processes customer data in order to analyse the use of the Car Blanche Services, to design and improve them in a demand-oriented and personalised manner, to advertise the Car Blanche Services, to detect, limit and eliminate malfunctions and problems of a technical or process-related nature and to prevent illegal use of the Car Blanche Services (e.g. fraudulent booking, cyberattacks). In this respect, the legal basis for the processing of personal data is Art. 6 para. 1 lit. f GDPR (legitimate interest of Car Blanche). Data will not be passed on to recipients in this respect unless to Car Blanche data processors (see Art. 28 GDPR) or as far as otherwise permitted by law.
9. Payment & Fraud Prevention
9.1 Payment
All Car Blanche bookings can be paid by credit or debit card. The credit card information only has to be stored once upon the first booking and is protected against unauthorized access. For this purpose, a certified payment provider is used whose systems meet the applicable security standards, such as the PCI DSS standard (Payment Card Industry Data Security Standard). For recurring transactions, the card data is stored with our assigned PCI DSS-certified payment provider. In this respect, the legal basis for the processing is Art. 6(1)(b) GDPR (performance of contract).
Car Blanche itself does not store credit card data or only in abbreviated form for analysis purposes or to prevent fraud. The legal basis for this is Art. 6 Paragraph 1 lit f GDPR (Car Blanche legitimate interest).
10.1 Fraud Prevention
To ensure that a payment instrument is used by its rightful owner and to prevent fraud, IP addresses, e-mail addresses, payment data and card information may be transmitted to one or more external fraud prevention service providers. This transmission may also contain additional personal data. The external fraud prevention service providers process these personal data on behalf of Car Blanche. The legal basis for this processing is Art. 6 para. 1 lit. f GDPR (legitimate interest of Car Blanche).
In the course of the authentication of the cardholder, it may also be necessary for individual transactions that Car Blanche requires a copy of an additional identification document (e.g. identity card, passport, drivers’ licence) or a copy of the credit card. Car Blanche will ask you to black out any data that is not required (e.g. the credit card number except the last four digits). In this respect, the legal basis is Art. 6 para. 1 lit. b GDPR (fulfilment of contract), your consent (Art. 6 para. 1 lit. a GDPR) and our legitimate interest (Art. 6 para. 1 lit. f GDPR).
11. Communication with Car Blanche
If you contact Car Blanche (e.g. by phone, contact form, feedback form, chat, messenger, e-mail or social media (YouTube, GitHub или Instagram)), the data you provide will be processed to handle your request and to answer your inquiry. The legal basis is Art. 6 Para. 1 lit. a GDPR (consent) and Art. 6 Para. 1 lit. b GDPR (fulfilment of contract and initiation of contract).
Contact data is also used by Car Blanche - pseudonymised or anonymised if possible - to design and improve Car Blanche services according to your needs, to identify and eliminate malfunctions and problems of a technical or process-related nature and to prevent illegal use of Car Blanche services (e.g. fraudulent booking, cyberattacks). In this respect, the legal basis for the processing of personal data is Art. 6 para. 1 letter f GDPR (legitimate interest of Car Blanche).
Car Blanche also uses external services and tools, e.g. messenger services or chat support tools, to communicate with the customer. The legal basis for the processing of personal data is Art. 6 para. 1 lit. f GDPR (legitimate interest of Car Blanche). Agreements on commissioned data processing exist with the respective providers - where necessary.
Car Blanche also offers customers different feedback channels, also via external platforms. Such customer feedback is also used to process your request and also - if possible pseudonymized or anonymized - to design and improve Car Blanche Services according to your needs, to recognize and eliminate malfunctions and problems of a technical or process-related nature and to prevent illegal use of Car Blanche Services (e.g. fraudulent booking, cyberattacks). The legal basis for the data processing is, if you have separately and explicitly agreed, Art. 6 para. 1 lit. a GDPR (consent) and otherwise Art. 6 para. 1 lit. f GDPR (legitimate interest of Car Blanche). With the respective providers of feedback tools there are again - as far as necessary - agreements on commissioned data processing. The respective feedback tool may contain additional information about which data is collected and in which way data is processed.
12. E-mail Advertising, Newsletter
If you have agreed to receiving advertising or if Car Blanche otherwise has the right, we will use your customer data to send you personalized advertising or general newsletters. The following data is mainly affected: Form of address, name, e-mail address. The purpose of the data processing is for Car Blanche to inform you regarding current offers and to draw attention to features of Car Blanche services.
E-mail advertising and newsletters may contain pixels. In this case, a graphic file is inserted into the e-mail sent in HTML format, based on which a statistical evaluation may be carried out. By using pixels, Car Blanche can detect whether and when e-mails have been opened and links contained therein clicked.
If you do not wish to receive advertising from Car Blanche for similar products or services, you may at any time revoke the corresponding use of your e-mail address without incurring any costs other than the transmission costs in accordance with the base tariffs. To this end, you can use the unsubscribe link contained in any mail or you can write an e-mail to us using the above-mentioned e-mail addresses.
13. Involvement of Data Processors by Car Blanche
As far as Car Blanche involves third parties in its data processing, e.g. technical service providers or other Car Blanche subsidiaries, this is always done on behalf of Car Blanche and only if these processors offer sufficient guarantees that suitable technical and organisational measures are carried out in such a way that the processing is in accordance with the data protection requirements, in particular Art. 28 GDPR, and guarantees the protection of the rights of the data subject. If processors are located in third countries, the data protection requirements for the transfer pursuant to Art. 44 et seq. GDPR are complied with in each case. As a rule, the appropriate guarantees in third countries are established by means of an adequacy decision (Art. 45 para. 3 GDPR) or the agreement of standard contractual clauses (see Art. 46 para. 2 c) GDPR in conjunction with Art. 93 para. 2 GDPR).
14 Rights of Data Subjects
If your personal data is processed by Car Blanche, you are the data subject (Art. 4 No. 1 GDPR). As the data subject, you have the following rights in relation to the personal data affecting you:
14.1 Right to information (Art. 15 GDPR)
The data subject has the right to obtain a confirmation from the controller as to whether personal data is processed; if this is the case, they have a right of information about this personal data and further information on the data processing.
14.2 Right to rectification (Art. 16 GDPR)
The data subject has the right to obtain from the controller without undue delay the rectification or completion of inaccurate personal data.
14.3 Right to erasure (Art. 17 GDPR)
The data subject has the right to demand from the controller the erasure of personal data without undue delay and the controller is obliged to erase personal data without undue delay, provided the data is no longer required, the data subject revokes their consent or lodges an objection to the processing, the personal data was processed unlawfully or there is otherwise a ground for erasure within the meaning of Art. 17 GDPR and the controller does not have the right to object to erasure.
14.4 Right to the restriction of data processing (Art. 18 GDPR)
The data subject has the right to demand from the controller the restriction of processing when one of the conditions mentioned in Art. 18 GDPR applies, namely the accuracy of the personal data is contested by the data subject or the processing is unlawful and the data subject opposes the erasure of the personal data.
14.5 Right to objection (Art. 21 GDPR)
Insofar as the data processing is based on a legitimate interest from our side (Art. 6 Paragraph 1 lit. f GDPR) or is direct advertising, the data subject has at any time the right to lodge an objection to the processing of personal data affecting them for the reasons mentioned in Art. 21 GDPR. The controller will then no longer process the personal data, unless they can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or the processing serves for the establishment, exercise or defense of legal claims.
14.6 Right to data portability (Art. 20 GDPR)
The data subject has the right within the meaning of Art. 20 GDPR to receive the personal data, which they have provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit this data to another controller without hindrance from the controller to which the personal data has been provided.
14.7 Right to lodge a complaint (Art. 77 GDPR)
Without prejudice to any other administrative or judicial remedy, every data subject has the right to lodge a complaint with a supervisory authority according to Art. 77 GDPR.
14.8 Revocation of consent (Art. 7 para. 4 GDPR)
If the data processing is based on the consent of a data subject, the data subject has the right to revoke his or her consent at any time. You can do this by sending an e-mail to:
b2b.car.blanche@gmail.com. The revocation of consent shall not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
15. Automated decisions
In the case of Car Blanche, you are only subject to an automated decision process (see Art. 22 GDPR) in exceptional cases if you re-enter a payment method via which a payment has already previously failed or when current indications justify the suspicion that it is a fraudulent booking. In these cases, your request to book a ride with Car Blanche will be refused. Such an automatic decision is required to conclude the contract (Art. 22 Paragraph 2 lit a GDPR). The data subject has the option of contacting us using the mentioned contact data (see section 2) in order to have an explanation or an intervention by a person or to express their point of view.
16. Data Erasure and Storage Duration
We will erase your personal data as soon as the legal basis for its processing lapses. However, legal bases may also exist in parallel or a new one may intervene with the lapsing of a legal basis, such as for example the duty to store determined data to fulfill a legal retention obligation (e.g. according to commercial or tax law).
17. Amendment or Update of this Privacy Policy
Car Blanche reserves the right to update or amend this privacy policy at any time without giving reasons, as far as this should become necessary, e. g. due to developments in legislation, jurisdiction or regulatory actions or due to further technical developments.
Issued: July 23, 2024.
