executive transportation

PRIVACY POLICY


PRIVACY POLICY AND COOKIE POLICY


Privacy Policy


1. Scope of application



We, DotTransfers, take the protection of your personal data seriously and protect your privacy when processing it in accordance with the applicable data protection regulations.


This privacy policy informs you as a visitor of the DotTransfers websites, as a user or customer of the online platform of DotTransfers, a DotTransfers App or other services of DotTransfers (together also "DotTransfers Services") about which personal data of yours is processed by DotTransfers for which purpose. DotTransfers Services are not directed at minors.


2. Name and contact details of the person responsible


Responsible for data processing within the meaning of the General Data Protection Regulation (GDPR):


DotTransfers - Global Ground Transportation


Avda. General Rivera 6329


Montevideo, Uruguay


Phone: 1-800-962-3790


Email: Info@dottransfers.com


Further information about DotTransfers can be found in the imprint.


3. Contact data of the data protection officer


Our data protection officer is:


Avda. General Rivera 6329, Montevideo, Uruguay


You can contact our data protection officer confidentially by post at the above address. Alternatively, you can contact our data protection officer and our data protection team by e-mail at: info@dottransfers.com


4. Data security


DotTransfers uses appropriate technical and organizational 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 type, scope, circumstances and purposes of processing as well as the different probability of occurrence and severity of the risk. The transmission of personal data between your device and DotTransfers is always encrypted (TLS encryption). You can recognize an encrypted connection 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. DotTransfers therefore recommends sending confidential information by post or encrypted e-mail communication (PGP). Please let us know if you wish to correspond with us by e-mail in encrypted form, so that we can provide you with information on the relevant addresses and public keys.


5. Provision of the websites


During the informational use of the websites of DotTransfers, thus also without registration, data are collected automatically about the usage by means of your browser (in the following "surf data"). This includes your IP address, the status code, the DotTransfers websites visited, date and time of the server request, browser type and browser version, referrer (previously visited page), transferred files and data volume. The surf data is stored in so-called log files at DotTransfers. If you visit the DotTransfers websites without having a DotTransfers account, we do not know who you are.


We inform you about the cookies and analysis services used by DotTransfers in section 6.


The processing of surfing data is mainly used to establish and maintain the technical connection when surfing the internet. This data is also used by DotTransfers - if possible pseudonymised or anonymised - to analyse the use of our websites, to design and improve the DotTransfers Services to meet demand, to detect and eliminate technical or process-related faults and problems and to prevent illegal use of the DotTransfers Services (e.g. fraudulent booking, cyberattacks).


Stored log files are deleted or made anonymous if they are no longer required to guarantee the general functionality of the DotTransfers Services. DotTransfers only retains the log files if you have agreed to this or if there are legal storage obligations.


The legal basis for the processing of personal data when the websites are made available is Art. 6 para. 1 lit. f GDPR (legitimate interest of DotTransfers). As far as you as user or customer of DotTransfers have agreed to an extended use of your surf data, the legal basis is Art. 6 para. 1 lit. a GDPR.


6. Cookies, pixels and similar methods


When using DotTransfers Services, cookies, pixels or similar procedures may be used. This is common on most large websites.


Cookies are small text files and pixel small graphic files that can be stored on the user's device. You will find comprehensive information on the cookies, pixels and similar procedures used by DotTransfers in our cookie policy.


During your visit DotTransfers will set the necessary cookies, which are technically necessary, improve the functionality or make the use of DotTransfers Services more user-friendly (e.g. language, login status). DotTransfers also uses its own cookies - if possible pseudonymised or anonymised - to analyse and improve the use of the DotTransfers Services, to recognise and eliminate technical or process-related faults and problems and to prevent illegal use of the DotTransfers Services (e.g. fraudulent booking, cyberattacks).


In addition, DotTransfrers uses its own cookies, pixels or similar methods or those originating from advertising partners (e.g. search engine providers, advertising networks or sales partners) to improve DotTransfers Services or to measure, evaluate, design and improve advertising media. In this respect DotTransfers uses various analysis tools. As far as possible, the evaluation is pseudonymised or anonymised.


By registering as a user of the DotTransfers Services, you agree that we may process the data collected using the cookies, pixels and similar procedures mentioned in the cookie policy for the purposes mentioned above in connection with your account. This consent can be revoked at any time with future effect free of charge.


You can prevent cookies from being saved and delete existing cookies in your browser settings at any time. However, this can lead to the fact that individual functions of the DotTransfers Services are not or only limitedly available. The storage time for each cookie is different and can be viewed in your browser.


The legal basis for the processing of personal data using cookies, pixels and similar procedures are Art. 6 para. 1 lit. a (your consent) and lit. f GDPR (legitimate interest of DotTransfers).


7. Features for the DotTransfers apps


DotTransfers apps are another way to access DotTransfers Services. As a rule, the DotTransfers Apps process personal data in the same way as the DotTransfers websites.


When using the DotTransfers Apps, DotTransfers can also access additional data related to the app or your device, such as the device name, device manufacturer, model, operating system, app or SDK version, mode.


In addition, there are push notifications in the DotTransfers apps, i.e. messages triggered by DotTransfers in your device's app. You only receive push notifications if you have agreed to this on your mobile device. The legal basis for data processing is Art. 6 para. 1 lit. a GDPR (your consent).


8. Social media / social networks


8.1 DotTransfers´s social media appearances


DotTransfers, maintains pages on social networks such as Twitter, Google (Google+) or Facebook. The respective provider of the social network provides detailed information on which personal data are processed and how they are used.


8.2 Facebook, Facebook Messenger and Facebook Connect


DotTransfers uses services of the social network Facebook, which is operated by Facebook Inc, 1601 Willow Road, Menlo Park, CA 94025, USA ("Facebook"). Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is responsible for data processing in Europe. Facebook is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU. Facebook's privacy information can be viewed here: https://www.facebook.com/about/privacy/


Via Facebook Messenger you can contact us and exchange messages with DotTransfers.


DotTransfers also offers the possibility to log in for DotTransfers Services with Facebook-Connect. You will be redirected to a Facebook page where you can log in with your Facebook usage data. When you log in to DotTransfers with Facebook Connect, certain personal information is transferred from Facebook to DotTransfers. Facebook tells you which of your information is being transferred, what you can opt-in to or opt-out of. No personal information will be transferred from Facebook to DotTransfers without your consent. Conversely, Facebook can use your Facebook Connect login to determine that and when you log in to us. DotTransfers uses the information provided by Facebook to identify you.


If you actively select the log in with Facebook, you agree that DotTransfers processes the data transmitted by Facebook for your identification also in connection with your account on a personal basis. This consent can be revoked at any time with future effect free of charge.


You can also stop using Facebook Connect and log in to DotTransfers by different means.


The legal basis for the processing of personal data when using Facebook Connect is Art. 6 Para. 1 lit. a GDPR (your consent).


We inform you in our cookie policy about Facebook cookies, pixels and similar methods used by DotTransfers.


9. Data processing during the registered use of DotTransfers Services and booking of rides


DotTransfers processes the following personal data provided by you when you register and use the DotTransfers Services or when booking rides (hereinafter "Customer Data"):


Personal data may be transferred to limousine service providers in a third country outside the European Union or the European Economic Area where the ride is scheduled. As a rule, DotTransfers cannot provide any further information on the level of data protection in the third country. An adequacy decision (see Art. 45 para. 3 GDPR) or appropriate guarantees (see Art. 46 GDPR) are not required for the transfer, since the transfer is necessary for the performance of the contract between the data subject and the data controller or for the implementation of pre-contractual measures at the request of the data subject (Art. 49 para. 1 letter b GDPR) or because the transfer is necessary for the conclusion or performance of a contract concluded by the data controller with another natural or legal person in the data subject's interest (Art. 49 para. 1 letter c GDPR).


The legal basis for the processing of personal data during the registered use of the DotTransfers Services and during the booking of rides is Art. 6 Para. 1 lit. b GDPR (fulfilment of contract). If the person concerned provides additional information voluntarily (e.g. flight number, frequent flyer programme, special requests), the legal basis is their consent pursuant to Art. 6 para. 1 lit. a GDPR and our legitimate interest pursuant to Art. 6 para. 1 lit. f GDPR.


In addition, DotTransfers processes Customer Data in order to analyse, personalise and improve the use of DotTransfers Services, to advertise DotTransfers Services, to identify, limit and eliminate technical or process-related faults and problems and to prevent illegal use of DotTransfers Services (e.g. fraudulent booking, cyberattacks). The legal basis for the processing of personal data is Art. 6 para. 1 lit. f DSVO (legitimate interest of DotTransfers). The data will not be passed on to recipients, except to DotTransfers contractors (see Art. 28 GDPR) or to the extent otherwise permitted by law.


10. Credit card data


All DotTransfers bookings can be paid by credit card. Only during the first booking the credit card information must be entered once. After that the credit card data is stored and protected against unauthorized access. For this purpose, a certified payment provider is used whose systems comply with the applicable security standards, such as the PCI-DSS standard (Payment Card Industry Data Security Standard). For recurring transactions, credit card data is stored by the PCI-DSS-certified payment provider.


In this respect, the legal basis for processing is Art. 6 para. 1 lit. b DSVO (fulfilment of contract).


DotTransfers itself does not store credit card data or only stores it in an abbreviated form for analysis purposes or to prevent fraud. The legal basis for this is Art. 6 para. 1 lit. f DSVO (legitimate interest of DotTransfers).


11. Communication with DotTransfers


If you contact DotTransfers (e.g. by phone, contact form, Facebook Messenger or e-mail) the data provided by you will be processed to handle your request and to answer your question. The legal basis is Art. 6 para. 1 lit. a GDPR (consent) and Art. 6 para. 1 lit. b GDPR (performance and initiation of contracts).


DotTransfers also uses contact data - if possible pseudonymized or anonymized - to design and improve DotTransfers Services to meet demand, to identify and eliminate technical or process-related disruptions and problems and to prevent illegal use of DotTransfers Services (e.g. fraudulent booking, cyberattacks). The legal basis for the processing of personal data is Art. 6 para. 1 lit. f GDPR (legitimate interest of DotTransfers).


12. E-mail advertising, newsletter


If you have agreed to receive advertising or if DotTransfers is otherwise entitled to do so, we will use your Customer Data to send you personalized advertising or general newsletters. The following data are particularly affected: Title, name, e-mail address. The purpose of data processing is that DotTransfers can inform you about current offers and draw your attention to features of DotTransfers Services.


E-mail advertising and newsletters can contain pixels. A graphic file is inserted into the e-mail in HTML format, which can be used for statistical evaluation. By using the pixels DotTransfers can recognize if and when e-mails have been opened and links contained have been clicked.


The legal basis for data processing is, if you have agreed separately and expressly, Art. 6 para. 1 lit. a GDPR (consent) and otherwise Art. 6 para. 1 lit. f GDPR (legitimate interest of DotTransfers) in conjunction with § 7 para. 3 German Act Against Unfair Competition (UWG). DotTransfers is entitled within the scope of the legal permission according to § 7 Abs. 3 UWG to use the e-mail address, which you provided in connection with a chargeable booking, for direct advertising of own and similar products or services. If you do not wish DotTransfers to advertise similar products or services, you can object to such use of your e-mail address at any time without incurring any costs other than the transmission costs according to the basic rates. You can use the unsubscribe link contained in each mailing or send us an e-mail to the above e-mail addresses (see 2.).


13. Rights of the data subject


If your personal data are processed by DotTransfers, then you are the data subject (Art. 4 No. 1 GDPR). As the data subject, you have the following rights with regard to your personal data:


13.1. Right of access (Art. 15 GDPR)


The data subject has the right to request confirmation from the data controller as to whether personal data concerning him or her are being processed; if this is the case, he or she has a right of access to such personal data and to further information on data processing.


13.2. Right to rectification (Art. 16 GDPR)


The data subject has the right to request the data controller to correct or, if necessary, complete inaccurate personal data concerning him/her without delay.


13.3. Right to erasure (Art. 17 GDPR)


The data subject has the right to request the data controller to delete personal data concerning him/her immediately and the data controller is obliged to delete personal data immediately if the data are no longer necessary, if the data subject withdraws his/her consent or objects to the processing, if the personal data have been processed unlawfully or if there is any other reason for deletion within the meaning of Art. 17 GDPR and the data controller is not entitled to object to the deletion.


13.4. Right to restriction of processing (Art. 18 GDPR)


The data subject has the right to request the controller to restrict processing if one of the conditions specified in Art. 18 GDPR is met, for example if 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.


13.5. Right to object (Art. 21 GDPR)


If the data processing is based on a legitimate interest on our part (Art. 6 para. 1 lit. f GDPR) or if it is a matter of direct advertising, the data subject has the right to object to the processing of personal data concerning him/her at any time for the reasons stated in Art. 21 GDPR. The data controller will then no longer process the personal data, unless he can prove compelling legitimate grounds for processing, which outweigh the interests, rights and freedoms of the data subject, or the processing serves to assert, exercise or defend legal claims.


13.6. Right to data portability (Art. 20 GDPR)


Under Article 20 GDPR, the data subject has the right to receive the personal data concerning him/her which he/she has provided to a controller in a structured, current and machine-readable format and he/she has the right to transmit this data to another controller without interference by the controller to whom the personal data has been provided.


13.7. Right to lodge a complaint (Art. 77 GDPR)


Without prejudice to any other remedies, any person concerned has the right to lodge a complaint with a supervisory authority pursuant to Article 77 GDPR.


14. Automated decision-making


In the case of DotTransfers, you are only subject to automated decision-making in exceptional cases (see Art. 22 GDPR) if you want to use a payment method that has already failed to make a payment, or if there are otherwise actual grounds for suspecting that the booking is fraudulent. In these cases your request for a DotTransfers ride will be rejected. Such automatic decision is necessary for the conclusion of the contract (Art. 22 para. 2 lit. a GDPR). The person concerned has the option of contacting us via the contact data provided (see section 2.) in order to request an explanation or the intervention of a person or to state his or her point of view.


15. Data erasure and storage time


We will delete your personal data as soon as the legal basis for their processing ceases to exist. In some cases, however, legal bases can also exist in parallel or, if a legal basis ceases to exist, a new one can come up, such as the obligation to store certain data in order to fulfil a legal obligation to retain data (e.g. in accordance with commercial or tax law).


16. Modification or update of this Privacy Policy


DotTransfers may update and modify this Privacy Policy at any time. Users of the DotTransfers Services will be informed and may be asked for renewed consent.


Last updated: May 25, 2018


DotTransfers Cookie Policy (as of 18.05.2018)


DotTransfers may use cookies, pixels or similar methods (e.g. using tags, web beacons or gifs). These are small files that are stored on your device so that we can recognize you or better collect information when you use the DotTransfers websites or DotTransfers apps.


Cookies can be distinguished according to their lifetime between session cookies, which are automatically deleted at the end of the browser session, or permanent cookies, which are stored beyond the individual browser session and enable later recognition of the end device. You can also distinguish between DotTransfers cookies and those of third parties.


You can prevent the storage of cookies or delete existing cookies in your browser settings at any time. However, this can lead to the fact that individual functions of the DotTransfers Services are not or only limitedly available. The storage time for each cookie is different and can be checked in your browser.


The legal basis for the processing of personal data by using cookies, pixels and similar procedures are Art. 6 para. 1 lit. a (consent) and lit. f GDPR (legitimate interest of DotTransfers).


During your visit DotTransfers will set the necessary cookies, which are technically necessary, improve the functionality or make the use of DotTransfers Services more user-friendly. Such as


DotTransfers also uses own cookies to analyze and improve the use of DotTransfers Services, to detect and eliminate technical or process-related faults and problems, and to prevent illegal use of DotTransfers Services (e.g. fraudulent booking, cyberattacks). Evaluations by DotTransfers are pseudonymized or anonymized if possible.


In addition, DotTransfers uses own or from advertising partners (e.g. search engine providers, advertising networks or sales partners) originating cookies, pixels or similar methods to improve DotTransfers Services or to measure, evaluate, design and improve advertising media. In this respect DotTransfers uses various analysis tools. Also in this respect an evaluation by DotTransfers takes place as pseudonymized or anonymized as possible.


The following cookies, pixels and similar procedures may be used within the DotTransfers Services:


AdRoll Roundtrip


DotTransfers uses AdRoll Roundtrip, an online marketing service from AdRoll Inc., 972 Mission Street, San Francisco, CA 94103, USA ("AdRoll"). AdRoll is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


When you visit our website, AdRoll Roundtrip cookies and related technologies may be used to help us recognize you and measure your activity on our website. If you now visit the website of another company, which also cooperates with AdRoll, our advertising can be displayed there in a targeted manner.


For more information on AdRoll's privacy policy, please visit the following website:


https://www.adrollgroup.com/privacy


If you do not want AdRoll to address you with targeted advertising, you can adjust your browser's cookie settings accordingly or disable the feature at https://app.adroll.com/optout/safari


Facebook (Custom Audiences and Impressions)


DotTransfers uses the Facebook Custom Audiences and Facebook Impressions services operated by Facebook Inc, 1601 Willow Road, Menlo Park, CA 94025, USA ("Facebook"). Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland is responsible for data processing in Europe. Facebook is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


When you visit our website, you are made recognizable by the use of cookies. This allows to measure when and how often you return and use DotTransfers. On the basis of this information, we can display targeted advertising on Facebook. The data collected is stored and processed in the USA. Facebook Impressions measures how often ads appear on your screen. This enables us to draw conclusions about the effectiveness of our advertising measures.


For more information about Facebook's privacy policy, please visit the following websites:


https://www.facebook.com/about/privacy/


https://www.facebook.com/policy.php


https://www.facebook.com/policies/cookies/


If you do not want Facebook to address you with targeted advertising, you can adjust your browser's cookie settings accordingly.


Google AdWords Conversion Tracker


DotTransfers uses the online advertising program "Google AdWords" and in the context of Google AdWords the conversion tracking of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


We use the offer of Google Adwords to draw attention to our offers with the help of advertising materials (so-called Google Adwords) on external websites. The conversion tracking cookie is set when a user clicks on an AdWords ad served by Google. Cookies are small text files that are stored on your computer system. These cookies usually expire after 30 days and are not used for personal identification. If you visited a particular page and the cookie has not expired, Google and DotTransfers can see that you clicked on the ad and were redirected to that page. Each Google AdWords customer receives a different cookie. Cookies cannot therefore be traced through the websites of AdWords customers. The information collected using the conversion cookie is used to generate conversion statistics for AdWords customers who have opted for conversion tracking. Adwords customers see the total number of users who clicked on their ad and were redirected to a page with a conversion tracking tag. However, they will not receive any information that personally identifies users. The data collected is stored and processed in the USA.


If you do not wish to participate in tracking, you can block this use by deactivating the Google Conversion Tracking cookie via your internet browser under User Settings. After that you are not included in the conversion tracking statistics.


For more information about Google's privacy policy, please visit the following web addresses:


http://www.google.de/policies/privacy


https://www.cookiechoices.org/


Google Analytics


DotTransfers uses Google Analytics, a web analysis service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google")


Google is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


Google Analytics uses "cookies", which are text files placed on your computer and which enable an analysis of your use of the website. The information generated by the cookie about your use of this website (including the shortened IP address) is generally transmitted to a Google server in the USA and stored there. DotTransfers uses Google Analytics exclusively with the extension "_anonymizeIp()", which ensures an anonymization of the IP address by shortening and excludes a direct personal relationship. As a result of the extension, your IP address will previously be reduced by Google within member states of the European Union or in other signatory states to the Agreement on the European Economic Area. On our behalf, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide us with other services relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.


If you do not agree to the use of Google Analytics, you can adjust your browser's cookie settings accordingly or deactivate the functions at https://tools.google.com/dlpage/gaoptout


For more information about Google's privacy policy, please visit the following web addresses:


http://www.google.com/policies/privacy


https://www.cookiechoices.org/


Google Dynamic Remarketing


DotTransfers uses the Google Dynamic Remarketing service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


When you visit our website, an ID in the form of a cookie is stored on your device, which makes it possible to recognize you when you visit a website that belongs to Google's advertising network. You can now see banners on these websites that refer to previously viewed content. Google does not collect any personal information during this process. The data collected is stored and processed in the USA.


If you do not agree to the remarketing, you can adjust the settings for cookies in your browser or deactivate the function at https://adssettings.google.com/


For more information about Google's privacy policy, please visit the following web addresses:


http://www.google.com/policies/privacy


https://www.cookiechoices.org/


Google Tag Manager


DotTransfers uses Google Tag Manager, a tool of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google") to manage website tags via one interface. Google is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


The Google Tag Manager implements tags. This means that no cookies are used and no personal data is collected. The Google Tag Manager triggers other tags that may collect data. However, the Google Tag Manager does not access this data.


For more information about Google's privacy policy, please visit the following web addresses:


http://www.google.com/policies/privacy


https://policies.google.com/technologies/product-privacy?hl=en


LinkedIn Marketing Solutions


DotTransfers uses the LinkedIn Marketing Solutions service operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA ("LinkedIn"). LinkedIn is certified for the "Privacy Shield" (https://www.privacyshield.gov/), which guarantees compliance with the data protection level applicable in the EU.


When visiting our website, an ID in the form of a cookie is stored on the user's device. This ID makes it possible to recognize you when using the website and to record certain usage data. If you visit LinkedIn below, advertisements based on the data collected will be displayed. The data stored and processed in the USA does not make it possible to make you identifiable as a person.


If you do not wish to participate in tracking, you can deactivate the storage of LinkedIn cookies in your browser settings or at https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out


For more information about LinkedIn's privacy policy, please visit the following web address:


https://www.linkedin.com/legal/privacy-policy?_l=en_EN