1. Overview and Consent
Solidarity Drive (“Solidarity ”; “We”; “Us”; “Our”; “Drive”) makes the Solidarity Drive powered by Vitality App ( “Solidarity Drive Programme”/ “Solidarity Drive App”) available to you (“the User”).
This Privacy Notice applies to Personal Data (defined below) collected by or received by Solidarity whether online or offline in connection with the Solidarity Drive Programme.
By accessing or using the Solidarity Drive Programme, you agree and accept the terms of this Privacy Notice. Check the terms and conditions for any specific terms relating to you your use of the Solidarity Drive Programme.
Where consent is required to collect location data in terms of your applicable law:
· you consent to Solidarity receiving your physical location when you use the Solidarity Drive Programme. We may use various technologies to determine your location, within the borders of the territory in which you use the Solidarity Drive Programme, such as the location services on your mobile phone.
· you consent to your Personal Data and location being shared with our contracted third party providers in order to i) administer and provide the services and benefits associated with the Solidarity Drive Programme, ii) communicate with you.
You are entitled to discontinue your use of the Solidarity Drive Programme at anytime by uninstalling the Solidarity Drive Programme. You can reach out to Solidarity should you have any privacy concerns or queries. Refer to section 11 for more details.
2. Roles & Relationship with VG
The administration of the Solidarity Drive Programme, further development and the processing of Personal Data in this programme, are undertaken by Vitality Group International, Inc and its affiliates (“VG”) on behalf of Solidarity. Solidarity is the data controller for all Personal Data and VG is the processor (or equivalent under applicable laws). In order to generate your driving score VG provides your de-identified Personal Data to Cambridge Mobile Telematics Inc, who act as a subprocessor (“CMT”).
3. Why do We collect Personal Data and how do We use it?
Personal Data : definition
For the purposes of this Privacy Notice, Solidarity’s definition of Personal Data is any information relating to an identified or identifiable natural person, specifically you as the User.
Personal Data: Source
Other than the driving score provided by CMT, all Personal Data collected directly from you either through your engagement with the Solidarity Drive Programme or you from when you initially engaged with Solidarity.
Personal Data: types collected
· Your basic personal details which may include first name, last name, e-mail, mobile number and/or unique identifier.
· Your device ID.
· Drive information relating to your driving behavior such as Acceleration, Braking, cornering, nighttime driving, distance, phone use while driving and speeding.
· Technical information such as log data, IP address, the type of device, operating system.
· Location data, we may use various technologies to determine your location within the borders of the territory in which you use the Solidarity Drive Programme, such as the location services on your mobile phone.
· Solidarity Drive Programme engagement information which identifies or can be used to identify you.
· Rewards details regarding rewards you have earned and your reward redemptions.
· Additional information provided by you when engaging with the Solidarity Drive Programme and/or by otherwise contacting Solidarity.
Personal Data: purpose of processing
The Personal Data that you submit when using the Solidarity Drive Programme or which is made available as a result of your use of the Solidarity Programme will be used as follows:
· To administer and provide the services and benefits associated with the Solidarity Drive Programme including but not limited to determining your driving score;
· To communicate with you;
· To resolve any complaints or queries that you may have;
· To detect and investigate fraud or security incidents;
· To improve the Solidarity Drive App and improve your in app experience;
· To fulfil any legal obligations; and
· For research and development purposes. (Such information will be de-identified or anonymized prior to such use case occurring and we will not attempt to re-identify this information.)
4. Legal basis for processing
We process your Personal Data based on your contract or the terms and conditions in place with Solidarity (“the Agreement”).
In addition to the above, in instances where Solidarity collects Personal Data from you directly We may rely on the legal basis of consent or the Agreement. You are entitled to revoke your consent at anytime by contacting Us. Refer to section 11 below. Please note that such revocation will make you ineligible to participate in the Solidarity Drive Programme.
5. International transfers
All Personal Data which is processed as a result of your engagement with the Solidarity Drive Programme will be processed in the US, European Union and in South Africa. Such Personal Data may be subject to foreign laws and may be disclosed to foreign authorities under such law.
6. Data security
Solidarity employs great efforts regarding technologies and organizational measures to protect your Personal Data against loss, corruption and unauthorized access pursuant to the applicable data privacy law.
Personal Data that you share through the Solidarity Drive Programme is kept strictly confidential and fully secure. We follow generally accepted industry standards to protect the Personal Data We receive, both during transmission and upon receipt.
No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while We strive to use reasonable and commercially acceptable means to protect your Personal Data, We cannot guarantee absolute security.
7. How long will my Personal Data be retained?
Unless otherwise specified in this Privacy Notice, Personal Data will only be retained for as long as is required for Us to administer the Solidarity Drive Programme, subject to: legislative or regulatory retention periods; or as required for Our legitimate business reasons - after which any Personal Data will be de-identified, archived or destroyed.
8. Categories of recipients to whom the Personal Data may be communicated
· Public authorities that receive data due to legal regulations.
· Solidarity Internal departments involved in the execution of the respective business processes.
· External contractors (service companies) whose services are required to make the Solidarity Drive Programme available.
· VG and CMT refer to section 2 above.
9. Modification of this Privacy Notice
Solidarity reserves the right to modify this Privacy Notice at any time without notification. You should therefore refer to this Privacy Notice each time you make use of the Solidarity Drive Programme.
10. I receive the Solidarity Drive Programme in Bahrain – what are my rights?
Under the Law no. (30) of 2018 with Respect to Personal Data Protection Law and Order No.(48) of 2022 Regarding the Data Subject’s Rights, you have the following rights regarding your Personal Data collected by the Solidarity Drive Programme:
· The right to be informed
· The right to request notification from Us if your Personal Data is being processed
· The right to rectification
· The right to erasure
· The right to restriction of processing of your Personal Data
· The right to object/opt out
· The right to object to automated decision making
In order to exercise rights enumerated above, please contact Us using the details set out in section 11 below.
11. How can I contact Solidarity with my privacy concerns or inquiries?
Individuals with inquiries or complaints regarding the privacy of their Personal Data at Solidarity or this Privacy Notice should contact, Solidarity at the details set out below:
DPO@solidarity.com.bh or through +973 1758 5222