CTG Driver App Privacy Policy

This privacy policy applies to drivers participating in the Corporate Transportation Group Ltd “CTG” drivers’ program by use of downloadable software known as the “CTG Driver Application.” By participating as a CTG driver and using the CTG Driver Application, you consent to the data collection and usage practices described in this privacy policy.

Collection of your Personal Information and Data

In order better to provide you with services and products, CTG may collect personally identifiable information (“PII”), such, without limitation, the following:

We only collect PII that you voluntarily provide. However, by our standards and under applicable law, you may be required to provide certain PII to us in order to serve as a CTG driver or use the CTG Driver Application. We will use your information for communicating with you. We also may gather additional PII or non-personal information from you in the future.

Processing and Use of Your PII

CTG collects and process PII for the purpose of connecting passengers with drivers and to help them communicate, as well as to provide its other services and products to drivers and passengers.

CTG may use your PII to inform you of other products or services available from CTG and its affiliates.

Personal data may be processed on the ground of legitimate interest in investigating and detecting fraudulent payments. Data regarding criminal convictions and offences, in similar information, are processed and used in compliance with law and with CTG standards and practices. Those data may be shared with law enforcement and other governmental authorities as and when requested.

Processing and Use of Your PII

CTG collects your device’s precise location when you open and use the CTG Driver Application, including whenever the application is running in the background when in driver mode or otherwise.

Geolocation and driving routes are processed to analyze the geographical area, to give suggestions to the drivers and for usage analysis and legal compliance purposes. In the course of connecting you with passengers and others, as well as for follow-up services, your location at any given moment, vehicle license plate number, other information you post or upload, and limited information about you and your vehicle will be shared with passengers and potential passengers. If you do not want to disclose your location for to potential passengers, you must close the CTG Driver Application or indicate in the CTG Driver Application that you are offline and currently are not providing transportation services.

Location data provided by the CTG Driver Application is for solely basic location purposes and is not intended to be relied upon in situations where precise location information is needed or where erroneous, inaccurate or incomplete location data may lead to death, personal injury, property or environmental damage. Neither CTG, nor any of its content providers, guarantees the availability, accuracy, completeness, reliability, security or timeliness of location data tracked or displayed by the CTG Application.

As a CTG driver, you may use Google Maps while using the CTG Driver Application. You understand and agree that Google may collect and share your location data when the CTG Driver Application is running in order to provide and improve Google's services in accordance with its own terms of service and privacy policy. Those data may be shared with CTG in order to help it analyze and improve its operations. Google’s terms and conditions may be found at:Google Terms and its privacy policy may be found at:Google Privacy Policy.

Processing and Use of Passengers’ PII

You may not use or process the PII of passengers without our prior written permission. You may not contact any passenger or collect, record, store, grant access to, use or cross-use PII provided by the passenger or accessible to you via the CTG Driver Application for any reason other than for the purposes of fulfilling the transportation request of the passenger that had been accepted by you.

You understand and agree that PII of passengers may be protected by federal or state privacy and confidentiality laws, such as, without limitation, the Health Information Portability and Accountability Act of 1996 with respect to transportation to or from facilities for the delivery of medical goods or services or otherwise. Civil or criminal penalties may apply for the unauthorized disclosure of data protected applicable laws and regulations. Violation of this provision may also cause us to terminate your driver account and take legal action against you.

Confidentiality

Other than as expressly allowed under the CTG terms of service, other contract between us or this privacy policy, you understand and agree not to use or disclose to any third party at any time any technical, financial, strategic and other proprietary and information that can be reasonably interpreted as confidential to CTG or its vendors, drivers or others that relates to CTG’s business, operations and properties, information about the passengers, routes, pickup locations and destinations made available to you are confidential information of CTG (“Confidential Information”). You understand and agree never to store any passenger PII or Confidential Information in any manner, form or format other than the CTG Driver Application.

Sharing Information with Third Parties

CTG does not sell, rent or lease its driver, customer or passenger lists to third parties. CTG may share data, including, without limitation, PII in an aggregated form that does not identify individuals, with trusted third parties to help perform statistical analysis, send you electronic or postal communications, provide customer support, or arrange for deliveries. All such third-party participants are required to maintain the confidentiality of information so provided to them.

CTG may disclose your PII, without notice, if required to do so by law or governmental authority in the good faith belief that doing so is necessary to: (a) comply with applicable law or regulation; (b) comply with any subpoena, legal process, order, decision, edict or other mandate of law; (c) protect and defend the rights or property of CTG, such as, without limitation, in responding to a security breach or ransomware attack; or (d) act under exigent circumstances to protect the personal safety of employees, drivers, passengers and the general public.

Access, Correction, Retention and Data Portability

Your PII will be stored as long as you have an active driver's account. If your account is closed for any reason, your PII will be stored for an additional three (3) year period; PII and other data necessary for accounting and tax compliance purposes, however, will be stored for seven (7) years. CTG reserves the right to store PII for a longer period in any instance if it reasonably believes doing so will be necessary to comply with applicable law or regulation or with current or future actions by any governmental authority.

Right to Deletion

We will respond to any request to delete PII within one (1) month if received by email. Subject to certain exceptions set out below, on receipt of such a request from you in verifiable form, and if shown good reason or to comply with applicable law or regulation, we will:

Please note the following:

Without the benefit of your PII, we may no longer be able to allow you to have access to, and use of, the CTG Driver Application or serve as a CTG driver. We may not be able to comply with a request to delete your PII within the one (1) month period or possibly longer if it should be reasonably necessary to:

External Data Storage Sites

We may store your PII on servers provided by third-party hosting vendors with whom we have contracted or will later contract.

Changes to this Statement

CTG reserves the right to change this privacy policy from time to time. We will notify you about any significant changes in the way that we treat PII by sending a notice to the primary email address specified in your account, by placing a prominent notice through the CTG Driver Application or by updating this policy. Your continued use of the CTG Driver Application will constitute your: (a) acknowledgment of the modified privacy policy; and (b) agreement to abide and be bound by that policy. Please check this privacy policy from time to time for any updates or modifications.

Contact Information

CTG welcomes your questions or comments regarding this privacy policy. Please contact us at:

Corporate Transportation Group Ltd.

241 37th St.

STE 1-4-B460

Brooklyn, New York 11232