Privacy Notice for Drivers

Last updated: 30 March 2026

1. Who We Are

CaminoCabs Limited is a private company limited by shares, incorporated in Ireland.

• Company Registration Number: 806705
• Registered Address: Finglas, Dublin, Ireland
• Contact Email: info@caminocabs.ie

CaminoCabs is the data controller responsible for your personal data under the General Data Protection Regulation (GDPR) and the Irish Data Protection Act 2018.

1.1 Key Definitions

• "Transportation Services" means all taxi transportation services and other transportation services that may be provided by an SPSV, as made available for procurement by Passengers or otherwise intermediated by CaminoCabs through the Platform.
• "Intermediation Services" means the services provided by CaminoCabs through the Platform to facilitate Transportation Services being procured by Passengers and provided by Drivers.
• "Driver" or "you" means a licensed SPSV driver who provides Transportation Services through the CaminoCabs Platform.
• "Passenger" means any person who uses the CaminoCabs Passenger App to request Transportation Services.

2. What Personal Data We Collect

We collect the following categories of personal data:

2.1 Account and Profile Data

• Full name
• Email address
• Phone number
• Profile photo (required)
• IBAN (bank account details for receiving payments)
• SPSV licence number
• Account creation date
• Last activity timestamp

2.2 Vehicle Data

You may register up to 3 vehicles on your account. For each vehicle we collect:

• Vehicle make and model
• Registration plate number
• Year of manufacture
• Vehicle colour
• Passenger capacity
• Wheelchair accessibility status

2.3 Verification Documents (KYC)

To verify your identity and ensure compliance with regulatory requirements, we collect the following documents:

• Profile photo (mandatory)
• Driving licence (front and back)
• Garda Paper Certificate
• Bank statement
• Vehicle insurance certificate (per vehicle, including expiry date)
• SPSV Certificate (per vehicle, including expiry date)

Vehicle-specific documents (insurance and SPSV Certificate) are linked to each individual vehicle on your account. If you have multiple vehicles registered (up to 3), each vehicle has its own independent set of documents with separate expiry dates.

Documents with expiry dates are monitored by the system. When a document approaches or passes its expiry date, you will be prompted to upload a renewed version. Renewed documents are reviewed and approved by a CaminoCabs administrator before your account is re-activated for ride requests.

2.4 Payment and Earnings Data

• IBAN stored for receiving payments
• Billing model: commission per trip or monthly subscription (processed via Stripe)
• Per-trip earnings breakdown: taximeter fare, tolls, tips, commission charged, VAT on commission
• Weekly earnings summaries
• Launch Offer payments (one-time payment via Stripe, if applicable)
• Payout history

Note: Payment processing is handled securely by Stripe, a PCI-DSS compliant payment processor. CaminoCabs invoices and collects payment of the fare from the Passenger in the name and on behalf of the Driver, and remits the Driver's share to the Driver's registered IBAN.

2.5 Location Data

The Driver app collects location data both in the foreground and in the background to enable ride matching, navigation, and safety features. Specifically:

• During an active trip: GPS position is recorded approximately every 10 seconds when the vehicle has moved at least 30 metres. The trip route is recorded as a polyline for fare verification and fraud detection purposes.
• While online without an active trip (cruising): GPS position is recorded approximately every 60 seconds when the vehicle has moved at least 100 metres, to enable nearby ride matching.
• Heartbeat signal: Every 5 minutes, the app sends a status update including GPS position, device battery level, and app version. This is used for system reliability and driver safety.

Important: Location tracking is only active when you are online and available for rides in the Driver app. When you go offline, background location tracking stops.

2.6 Background Services Data

To ensure reliable operation while driving, the Driver app uses the following background services:

• Android: A Foreground Service with a persistent notification keeps the app running and responsive to ride requests while you are online.
• iOS: Background Location mode is active during trips to ensure continuous GPS tracking.
• Floating bubble (Android): An overlay widget provides quick access to ride controls while using other apps, such as navigation.
• Wakelock (Android): The screen remains on while you are actively driving to prevent interruptions during a trip.

2.7 Trip Data

• Complete trip history
• Origin and destination addresses
• Date, time, and duration of trips
• Distance travelled
• Fare charged and payment method used by the Passenger
• Tips received
• Vehicle used for each trip
• Number of passengers
• Cancellations (reason, timestamp, who cancelled)
• Matching phase data (request received, accepted, arrived, trip started, trip completed)
• Passenger details visible during a trip: first name, phone number, passenger rating, and payment method

2.8 Rating and Performance Data

• Driver rating: a dual system consisting of an internal (real-time) rating and a display rating (updated in batches to protect Passenger privacy)
• Total ratings received
• Ratings given by Passengers
• Written reviews (when submitted by Passengers for low ratings)
• Acceptance rate (calculated on a rolling window of the last 20 trip requests)
• Cancellation rate (calculated on a rolling window of the last 20 trips, with weighted penalties based on the timing of cancellation)

2.9 CaminoPoints Data

• Current points balance
• Lifetime points earned and spent
• Points earned per completed trip
• Points transaction history
• Shop redemption history (benefits claimed using points)

2.10 Communications Data

• In-app chat messages with Passengers during trips
• Support chat conversations (including AI-assisted support)
• Support tickets and their history, including specific incident types: payment issues, Passenger behaviour, route/GPS disputes, fare disputes, lost property, and technical problems
• VoIP call logs (duration and status only; calls are not recorded)

2.11 Device and Technical Data

• Device type and model
• Operating system version
• App version
• Push notification tokens (up to 3 devices per Driver, stored as an array of FCM tokens)
• Device identifiers
• Theme preferences
• Notification settings
• Battery level (collected via heartbeat signal)

2.12 Security and Anti-Fraud Data

• Device hash
• IP address hash
• Trip route polylines (used to detect route manipulation or fare fraud)
• Fraud flags and review status
• Account suspension records

3. How We Use Your Personal Data

Purpose	Legal Basis (GDPR)
Creating and managing your Driver account	Contract performance
Verifying your identity, SPSV licence, and vehicle documentation	Contract performance / Legal obligation
Monitoring document expiry and prompting renewal	Contract performance / Legal obligation
Matching you with Passenger ride requests	Contract performance
Tracking your location to enable ride matching and navigation	Contract performance
Recording trip routes for fare verification and fraud detection	Contract performance / Legitimate interest
Calculating your earnings, commissions, and processing payouts	Contract performance
Generating weekly earnings summaries	Contract performance
Managing the CaminoPoints rewards programme and Shop	Contract performance
Providing customer support (including AI-assisted)	Contract performance / Legitimate interest
Maintaining the Driver rating and performance system	Legitimate interest
Preventing fraud and abuse	Legitimate interest
Improving our Intermediation Services and App functionality	Legitimate interest
Complying with legal, tax, and regulatory obligations	Legal obligation
Sending marketing communications (if opted in)	Consent

4. Who We Share Your Data With

4.1 Passengers

When a Passenger books a ride through our Intermediation Services, the Passenger can see:

• Your first name
• Your profile photo
• Your Driver rating
• Your vehicle details (make, model, colour, registration plate)
• Your real-time location during the trip

4.2 Third-Party Service Providers

Provider	Purpose	Data Shared	Location
Firebase (Google)	Authentication, database, storage, push notifications, crashlytics	Account data, trip data, device data, location data, crash reports	EU (Belgium)
Stripe	Payment processing (commission/subscription collection, Driver payouts)	IBAN, earnings data, transaction data, billing information	EU (Ireland)
Google Maps	Maps, navigation, address search	Location data, addresses searched	EU
Anthropic (Claude AI)	AI-powered customer support	Support chat messages, trip context for support queries	United States
Agora	In-app voice calls between Drivers and Passengers	Voice call audio (real-time only, not recorded)	Global (edge servers)
Brevo	Transactional emails	Email address, name, earnings summaries	EU (France)

4.3 Administrators

CaminoCabs administrators may access your data for:

• Reviewing and approving verification documents (KYC)
• Reviewing renewed documents upon expiry
• Customer support and dispute resolution
• Reviewing low ratings (2 stars or below require admin approval)
• Fraud and route manipulation investigation
• Legal compliance

4.4 Legal and Regulatory Authorities

We may share your data with law enforcement, regulatory bodies (including the National Transport Authority), or courts when required by law or to protect our legal rights.

5. International Data Transfers

Most of your data is processed within the European Union. However, some data is transferred to the United States:

• Anthropic (Claude AI): Support chat messages are processed by AI servers in the United States.
• Agora: Voice call audio may be routed through global servers, including outside the EU.

Where data is transferred outside the EU/EEA, we ensure appropriate safeguards are in place, including:

• Standard Contractual Clauses (SCCs) approved by the European Commission
• Adequacy decisions where applicable

6. How Long We Keep Your Data

Data Type	Retention Period
Active account data	As long as your account is active
Trip history (active Drivers)	As long as your account is active
Earnings and payout records	6 years (Irish tax law requirement)
Verification documents (KYC)	As long as your account is active. After account deletion, retained for up to 6 years where required for regulatory compliance, otherwise deleted with the account.
Trip route polylines	6 months after the trip (fraud detection purposes)
Support tickets	Deleted when account is deleted
Data after account deletion	See "Account Deletion" section below

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

• Right of Access: Request a copy of your personal data.
• Right to Rectification: Request correction of inaccurate data.
• Right to Erasure: Request deletion of your data (see Account Deletion below).
• Right to Restrict Processing: Request limitation of how we use your data.
• Right to Data Portability: Receive your data in a portable format.
• Right to Object: Object to processing based on legitimate interests.
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent.

To exercise any of these rights, contact us at info@caminocabs.ie.

8. Account Deletion

You can request deletion of your account directly from the app:

Menu → Delete Account

How it works:

• You must re-enter your password to confirm
• There is a 30-day grace period during which you can cancel the deletion
• You cannot delete your account if you have outstanding payments or unresolved disputes
• After 30 days, deletion is processed automatically

What is deleted:

• Your profile and personal data
• Profile photo
• Payment methods and IBAN
• Support tickets
• CaminoPoints balance and history
• Push notification tokens

What is retained or anonymised:

For legal, tax, and accounting purposes, certain records are anonymised or retained:

• Your name is replaced with "Deleted Driver"
• Your email, phone, photo, and IBAN are removed
• Trip records (date, fare, route) are retained in anonymised form for Passenger records and tax compliance
• Earnings and payout records are retained for 6 years as required by Irish tax law
• Verification documents (KYC) may be retained for up to 6 years after deletion where required for regulatory compliance

9. Children's Privacy

CaminoCabs is not intended for use by anyone under the age of 18. We do not knowingly collect personal data from children under 18. If you believe a child has provided us with personal data, please contact us immediately at info@caminocabs.ie.

10. Security

We implement appropriate technical and organisational measures to protect your personal data, including:

• Encryption of data in transit (HTTPS/TLS)
• Encryption of data at rest
• Secure authentication via Firebase Authentication
• Access controls limiting who can view your data
• Secure storage of verification documents with restricted admin access
• Regular security reviews
• Anti-fraud monitoring, including trip route analysis

11. Changes to This Privacy Notice

We may update this Privacy Notice from time to time. We will notify you of significant changes by:

• Posting a notice in the app
• Sending you an email
• Updating the "Last updated" date at the top of this notice

12. Contact Us

13. Complaints

If you are not satisfied with how we handle your personal data, you have the right to lodge a complaint with the Irish Data Protection Commission: