Privacy Policy

Users of the Gozem app consent to the processing of their personal data when installing the Gozem app. Your personal data is collected and processed by Gozem Pte. Ltd. Gozem Pte. Ltd. collects and processes only the personal data submitted by users when installing and using the Gozem app. The user’s disclosure of their geolocation data is a prerequisite for using the Gozem app.

Your personal data is collected and processed by Gozem Pte. Ltd.

Gozem Pte. Ltd. collects and processes only the personal data submitted by users when installing and using the Gozem app.

The user’s sharing of their geolocation data is a prerequisite for using the Gozem app.

1.1. Types of Personal Data

In order to provide and improve our services, Gozem may collect, depending on the features used, various categories of personal data about you, including:

Your last name, first name, gender, date of birth, phone number, email address, user profile picture, ratings, and/or payment information for the app user; the user’s geographic location, time of service provision and destination, and identification data for the device on which the Gozem app has been installed; cookies on the Gozem.co website may record the user’s geolocation data and other available browsing data.

The personal data you provide to us is processed by Gozem for the purposes defined below (“Purposes”).

Furthermore, if you use several of our services or interact in different capacities on our platform—whether as a Merchant, Champion, or user of the services provided by the Gozem Group and its partners—we may combine your data from these various activities in order to optimize your experience and fulfill the Purposes described below:

2.1. Provision of services and features Your data

Your personal data is used to provide, personalize, maintain, and improve our platforms and services. This includes using your personal data to:

provide you with services across our various business sectors, including within and between Gozem entities, where applicable;

• create, manage, and update your account;
• process, manage, or verify your eligibility or your request for products, services, promotions, rewards, and subscriptions;
• conduct due diligence, assess and monitor user risk profiles, and perform ongoing risk analysis to ensure compliance with regulatory and operational requirements;
• verify your identity and eligibility;
• Confirm your order and process payments;
• offer, obtain, provide, facilitate, or maintain insurance or financing solutions;
• track your route, detect unusual deviations from your path, and improve the accuracy and reliability of navigation services using data from your device;
• to allow you to take advantage of loyalty programs or marketing activities organized by our merchant partners and/or in collaboration with Gozem;
• to personalize your experience by identifying your preferences and recommending relevant products and services to you;
• make your experience smoother by automatically filling in your registration information when you switch from one Service to another;
• to protect the security or integrity of the Services and of all facilities or equipment used to make the Services available;
• to facilitate communication among our users;
• to enable you to participate in our events, surveys, and studies;
• enable our partners to manage and allocate their fleet resources; and
• to perform the services provided to you as a data processor, when you have given your consent to the data controller for these services to be provided.

To provide you with these services and features, we may use manual or automated methods, including artificial intelligence services. We strive to ensure the accuracy and reliability of our AI services, and, if necessary, we may manually verify the results.

2.2. Safety and Security

We use your data to ensure the security of our Services and all users. This includes:

• to protect the security or integrity of the Services and of all facilities or equipment used to make the Services available;
• verify the identities of Champions and Merchants before allowing them to join our Services;
• identify dangerous driving behaviors such as speeding, sudden braking, and abrupt acceleration; and provide personalized feedback to the Champions;
• verify your identity when you log in to Gozem;
• use information related to gender to personalize your experience on our platform, for example, by matching rides with people of the same gender;
• use of data related to the device, location, profile, usage, activities during transit, and other personal data to prevent, respond to, detect, and combat fraud or dangerous activities;
• share the location and contact information of Champions and passengers when the emergency button or the “S.O.S.” feature is activated; and
• monitoring compliance with our terms and conditions and our policies.

2.3. User Support

We use personal data to resolve user support issues. Specifically, we may:

• investigate and address concerns;
• monitor and improve our user support responses;
• respond to questions, comments, and feedback; and
• to inform you of the steps taken to resolve user support issues.

2.4. Legal Objectives

We may use the personal data we collect for lawful purposes, including to:

• to prevent, detect, investigate, resolve, or prosecute any attempt at fraud, cybercrime, or illegal activity;
• Comply with court orders, administrative injunctions, and all requirements issued by government or regulatory authorities.
• implement and enforce our Terms of Use, as well as any other agreement binding the user to the platform; and
• to defend our assets, our property rights, and our strategic interests in the context of litigation, complaints, or judicial investigations, regardless of the competent jurisdiction.

2.5. Marketing and Promotions

We may use your personal data to send you marketing communications about personalized products or services that may interest you or be relevant to you based on your profile, or about products, services, events, or promotions from Gozem’s partners, sponsors, and advertisers.

We may provide you with this marketing information through various channels, including, where applicable, push notifications, WhatsApp, Telegram, phone calls, and email.

If you wish to unsubscribe from these marketing communications, please click the unsubscribe link in the relevant email or message. You can also change your preferences in our app’s settings. Please note that even if you choose to stop receiving marketing or promotional communications, Gozem may still send you messages related to your account and/or the service (such as two-factor authentication, information about your transactions, your rewards, etc.).

Any content you post on the Gozem platform (reviews, comments, etc.) will be visible to all users, along with your profile information (username, photos) and any other details you choose to include.

2.6. Retention Period for Your Personal Data

Gozem retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, unless a legal obligation requires a longer retention period. This retention period varies depending on the nature of the data, the context in which it was collected, and the applicable legal or operational requirements. For example, identity verification photos are deleted no later than ten years after they are collected, unless otherwise required by law or court order.

When your data is no longer needed, Gozem takes the appropriate steps to delete it, destroy it, or make it permanently inaccessible, in compliance with applicable legal obligations regarding security and fraud prevention.

We collect your personal data when you provide it to us. Specifically, when you:

• Fill out a user registration form or customize your profile (such as your name, contact information, and other identifying details, if necessary);
• Provide information that will allow us to assess your eligibility to provide services as a Champion or delivery driver (such as information regarding your driver’s license, your vehicle, and the results of your background check);
• Please provide supporting documents, such as proof of disability or eligibility for a discount, so that we can better support you as a Champion, delivery partner, or user of our platform;
• Provide information that will allow us to assess your eligibility to become a Gozem Merchant, Fleet Manager, supplier, or other partner (such as the name and contact information of the authorized representative);
• Interact with our social media pages (such as your social media account username, profile picture, and any content—for example, photos, videos, and stories—that you create for posting on our social media channels);
• Participate in contests or events organized by us (such as photos, audio recordings, or videos that you may submit through our various channels, which may include images of yourself);
• Fill out the demographic information in the surveys (such as your age, gender, and other information you may voluntarily provide, such as your marital status, occupation, and income);
• Allow us to access the events in your calendar (such as dates, times, and the names or addresses of reservation locations);
• Submit loan applications, insurance claims, or other financing-related documents to enable us to assess your eligibility (such as income statements, bank statements, accident reports, medical certificates, proof of family relationship, and any relevant information you may voluntarily provide);
• Contact us through our various customer support channels (such as in-app help, messages, emails, call recordings, and photos you submit to support your claim);
• Submit reviews, comments, ratings, media, or other content about a location and/or any service, which we may associate with your public profile page and display alongside it;
• Interact with other users using our in-app communication features;
• Agree to take a ride that includes onboard audio and/or video recording features;
• When you use map-related features, such as live location sharing, we may collect and use precise location information from your device with your permission;
• You provide information through the use of our artificial intelligence (“AI”) services, such as when you ask questions of AI-powered chatbots or when you enter data into our AI solutions.

We verify your identity through various methods (logging in via social media, submitting selfies, verifying your presence, or independently verifying your credit card information). For example, if you are a user, we may verify your identity using a selfie as an additional security measure.

3.1. Data Collection from Other Sources

We may collect personal data, including, but not limited to, information about you such as customer information, your contact information, other identifying information, and financial data, if applicable, from other sources. These sources include:

Referral programs; our business partners, such as fleet managers, payment service providers, car rental partners, and transportation partners; insurance and financial services providers; risk intelligence and fraud assessment providers; credit bureaus, payment network providers, alternative credit reporting agencies, and any other third-party credit reporting organizations; public or government data sources; and marketing service providers or partners.

Some of our partners may install personal apps or devices in their vehicles for their own purposes. This practice is neither approved nor prohibited by Gozem;

The collection, use, and disclosure of personal data obtained through personal in-vehicle applications or devices are the responsibility of the relevant partner. Please contact that partner with any questions regarding the use of personal in-vehicle cameras.

3.2. Collection of Personal Data Concerning Third Parties

In certain situations, you may need to provide us with personal data about other people, particularly when you designate them as emergency contacts, make a reservation on their behalf, or identify them as recipients or beneficiaries of our services.

By providing us with this information, you represent and warrant that you have obtained their prior consent to the collection, use, and disclosure of their personal data, in accordance with this Privacy Policy.

3.3. Personal Data of Individuals Under Legal Protection

Information for Legal Representatives

The security and privacy of users under legal guardianship are a priority for Gozem. When using our services on behalf of your minor children under guardianship and adults under conservatorship, it may be necessary to process certain personal data about them, including their last name, first name, phone number, date of birth, and location.

This information is used to verify their access to specific features, such as trip tracking, as well as to facilitate communication through notifications or calls integrated into the app.

Additional data may also be collected when necessary, provided there is an appropriate legal basis for doing so. By authorizing the registration of a person subject to a legal protection measure on the platform, you, as a parent, guardian, or conservator, consent to the processing of that person’s personal data.

Information for Individuals Under Legal Protection

The services offered may require the use of certain personal information provided by your legal representatives through the app. This information may include your last name, first name, phone number, date of birth, and location.

This information is used to ensure your safety and keep you informed about available services. In some cases, this information may be shared with trusted partners, such as Champions or delivery providers, to enable the requested services to be provided.

As part of the provision of our services, Gozem may need to share some of your personal data with third parties, strictly limited to what is necessary. Specifically:

4.1. Sharing Among Platform Users

Users' personal data may be shared among them to the extent necessary for the provision and proper functioning of the services offered by Gozem.

Certain information, such as name, phone number, geographic location, or any other relevant data related to the service, may be shared with the relevant users, partners, drivers, merchants, delivery personnel, or service providers, depending on the operational needs of the service being used.

After the ride, the user’s name may remain visible to the driver. This is necessary to allow drivers to resolve any issues related to the ride, such as contacting the user if an item was left in the car;

Feedback on service quality is anonymous, and drivers do not receive any information about the names or phone numbers of users who provided feedback;

4.2. Sharing with Third Parties in Connection with Your Services

We may disclose your personal data to service providers for the purposes set forth in this privacy policy:

In the event of an incident, the information necessary to process an insurance claim may be shared with the insurance company and the relevant authorities.

If authorization is granted to connect a third-party payment method, the data required for the transaction will be provided to the relevant service provider.

4.3. Sharing with Business Account Managers

If you use a Gozem Business account, your employer or the administrator of the group to which your account is linked will be able to access data related to your business transactions.

4.4. Sharing within the Gozem Group

Entities within the Gozem Group may share personal data with one another to ensure the consistency, reliability, and security of the services offered, as well as for the purposes of analysis, risk management, and regulatory compliance.

We may transfer your personal data to business partners or affiliates for commercial and direct marketing purposes;

Depending on the user’s location, their personal data may be shared with the relevant local entities that provide the Gozem app’s services. Any collection and processing of personal data by Gozem’s local service providers will be carried out under the same conditions as those set forth in this Privacy Policy.

4.5. Sharing Information with the Competent Authorities

We will be entitled to disclose your personal data if a regulatory body, government authority, public official, or law enforcement agency requests it from us for the purpose of investigating a suspected crime.

4.6. Restructuring or Divestiture Transactions

In the event of a merger, acquisition, divestiture, or any other transaction involving all or part of Gozem’s business, your personal data may be disclosed to the parties involved, in accordance with the confidentiality obligations previously agreed upon.

As part of its business operations, Gozem may need to transfer your personal data to other countries, particularly for processing, storage, administrative, or technical support purposes.

All personal data collected in connection with the provision of the Gozem service is transferred to and stored in a central data center located in England.

Unfortunately, transmitting information over the Internet is not completely secure. Although we do everything we can to protect your personal data, we cannot guarantee the security of the data you transmit to our websites. Once we receive your information, we will implement strict security procedures and measures to prevent unauthorized access.

Please note that uninstalling the Gozem app from your device does not close your account or, consequently, delete your personal data.

If you wish to have your personal data collected by Gozem deleted, please send a written request to close your account and delete your personal data via email.

Please note that you can only request the deletion of your personal data if we delete your account. As a result, you will no longer be able to use Gozem services with your current account. After deletion, your personal data will be anonymized and used solely for analytical purposes.

If you believe that we (or any other Gozem entity processing your personal data) are processing your personal data in a manner that violates your personal rights or the law—particularly if the personal data is inaccurate—you may:

• a) ask us (and/or any other Gozem entity that processes your personal data) for an explanation;
• b) request that we (and/or any other Gozem entity processing your personal data) remedy the situation that has arisen (including by blocking, correcting, or supplementing the personal data);
• c) file a complaint directly with the data protection authority responsible for personal data.