Privacy Policy

I. Introduction

When you use City Bodyguard, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our Privacy Overview, which highlights key points about our privacy practices.

II. Overview

A. Scope This notice applies to users of City Bodyguard services anywhere in the world, including users of City Bodyguard apps, websites, features or other services.
This notice describes how City Bodyguard, and its affiliates collect and use personal data. This notice applies to all users of our apps, websites, features or other services anywhere in the world, unless covered by a separate privacy notice, such as the City Bodyguard privacy policy. This notice also governs City Bodyguards’ other collection of personal data in connection with its services. For example, we may collect the contact information of individuals who use accounts owned by City Bodyguard for Business customers, or of owners, employees or other merchants; personal data of those who start but do not complete applications; or other personal data in connection with our mapping technology and features. All those subject to this notice are referred to as “users” in this notice. In addition, please note the following: · Our practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places. Please contact us here or via the addresses below with any questions regarding our practices in a particular country or region.
B. Data controller and transfer City Bodyguard and City Bodyguard Technologies Inc. are the data controllers for the personal data collected in connection with the use of City Bodyguard services in the European Economic Area, the United Kingdom and Switzerland. City Bodyguard Technologies Inc. is the data controller for the personal data collected in connection with the use of City Bodyguard services everywhere else. City Bodyguard Limited
Brulimar House Jubilee Road, Middleton, Manchester, M24 2LX are the data controllers for the personal data collected in connection with the use of City Bodyguard services in the European Economic Area, the United Kingdom and Switzerland. If you’re a bodyguard in the UK, the City Bodyguard entity holding the relevant SIA operator licence is a controller for complying with licensing requirements. City Bodyguard Technologies Inc. is the data controller for the personal data collected in connection with the use of City Bodyguard services everywhere else. City Bodyguard operates and processes personal data globally. We may also transfer such data to countries other than the one where our users live or use City Bodyguard services. We do so in order to fulfil our agreements with users, such as our Terms of Use, or based on users’ prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses. Questions, comments and complaints about City Bodyguard data practices can be submitted here. You can also use this form to submit a question to City Bodyguard’s Data Protection Officer.

III. Data collection and uses

A. The data we collect City Bodyguard collects personal data:  · provided by users to City Bodyguard, such as during account creation · created during use of our services, such as location, app usage and device data · from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities
The following personal data is collected by or on behalf of City Bodyguard 1. Data provided by users. This includes: · User profile: We collect data when users create or update their City Bodyguard accounts. This may include their name, email address, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driving licence and other government identification documents (which may provide document numbers as well as date of birth, gender and photo). This also includes users, emergency contact information, user settings, and evidence of health or fitness to provide services using City Bodyguard apps. · We may use the photos submitted by users to verify their identities, such as through facial verification technologies. For more information, please see the section called “How we use personal data”. · Background check and identity verification. This may include information such as history or criminal record (where permitted by law), licence status, known aliases and prior addresses, and right to work. This information may be collected by an authorised vendor on City Bodyguard behalf. · Demographic data: We may collect demographic data about users, including through user surveys. In some countries, we may also receive demographic data about users from third parties. · We may also infer demographic data from other data collected from users. For example, where necessary to enable features that allow women to provide or receive services to/from other women, we may infer gender using their first name. In such cases, we enable users to change their gender, if necessary, via in-app settings. · User content: We collect the data submitted by users when they contact City Bodyguard customer support (including at City Bodyguard Greenlight Hubs, or via video conferencing tools), provide ratings or compliments for other users or merchants, or otherwise contact City Bodyguard. This may include feedback, photographs or other recordings collected by users submitted by users in connection with customer support. This also includes metadata relating to the method you use to communicate with City Bodyguard 2. Data created during the use of our services. This includes: · Location data (security personnel) City Bodyguard collects this data when the City Bodyguard app is running in the foreground (app open and onscreen) or background (app open but not onscreen) of their mobile device. · Location data (security personnel). We collect security personnel precise or approximate location data to enable and enhance use of our apps. We collect such data from users’ mobile devices if they enable us to do so. City Bodyguard collects such data from or service if is requested until it finishes (and may indicate such collection via an icon or notification on your mobile device depending on your device’s operating system), and whenever the app is running in the foreground (app open and onscreen) of their mobile device. Security personnel and recipients may use the City Bodyguard apps without enabling City Bodyguard to collect precise location data from their mobile devices. However, this may affect features in the City Bodyguard apps. For example, a user who has not enabled location data where they need help will have to enter their address manually. In addition, the location data collected from a security personnel during its call out will be linked to the account. · Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided, order details, payment transaction information (delivery information, date and time the service was provided, amount charged, distance travelled, and payment method. Also, if someone uses your promotion code, we may associate your name with that person. · Usage data: We collect data about how users interact with our services. This includes data such as access dates and times, app features or pages viewed, app crashes and other system activity, and type of browser. We may also collect data regarding the third-party sites or services used before interacting with our services, which we use for marketing. (Please see “How we use data” below for more information on how we market our services to users). In some cases, we collect this data through cookies, pixels, tags and similar tracking technologies that create and maintain unique identifiers. To find out more about these technologies, please see our Cookie Notice. · Device data: We may collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data. · Communications data: We enable users to communicate with each other and City Bodyguard through City Bodyguard mobile apps and websites. For example, we enable security personnel to call, text or send other files to each other (generally without disclosing their telephone numbers to each other). To provide this service, City Bodyguard receives some data regarding the calls, texts or other communications, including the date and time of the communications and the content of the communications. City Bodyguard may also use this data for customer support services (including to resolve disputes between users), for safety and security purposes, to improve our services and features, and for analytics. · Safety recordings: In certain jurisdictions, and where permitted by law, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In app recordings are encrypted and stored on users’ devices and are only shared with City Bodyguard if submitted to customer support by the users in connection with safety incidents. 3. Data from other sources. These include: · Users participating in our referral programmes. For example, when a user refers another person, we receive the referred person’s personal data from that user. · City Bodyguard account owners who request services for or on behalf of other users, or who enable such users to request or receive services through their accounts. This includes owners of City Bodyguard for Business accounts. · Users or others providing information in connection with claims or disputes. · City Bodyguard business partners through which users create or access their City Bodyguard account, such as payment providers, social media services, or apps or websites that use City Bodyguard APIs or whose APIs City Bodyguard uses. · City Bodyguard business partners in connection with debit or credit cards issued by a financial institution in partnership with City Bodyguard to the extent disclosed in the terms and conditions for the card. · Vendors who help us verify users’ identity, background information and eligibility to work, or who screen users in connection with sanctions, anti-money laundering or know-your-customer requirements. · insurance, vehicle or financial services providers for drivers and/or couriers. · Publicly available sources. · Marketing service providers or data resellers whose data City Bodyguard uses for marketing or research. · Law enforcement officials, public health officials and other government authorities. City Bodyguard may combine the data collected from these sources with other data in its possession.
B. How we use personal data City Bodyguard uses personal data to enable reliable security services and other products and services. We also use such data: · To enhance the safety and security of our users and services · For customer support  · For research and development  · To enable communication between users  · To send marketing and non-marketing communications to users · In connection with legal proceedings City Bodyguard does not sell or share user personal data with third parties for their direct marketing, except with users’ consent.
We use personal data we collect: 1. To provide our services. City Bodyguard uses data to provide, personalise, maintain and improve our services. This includes using data to: · Create/update accounts · Enable transport and delivery services (such as using location data to facilitate a pick-up or delivery), features that involve data sharing (such as fare splitting, ETA sharing, and ratings and compliments), and accessibility features to facilitate use of our services by those with disabilities · Process payments · Track and share the progress of services · Facilitate insurance, vehicle, invoicing or financing solutions · Perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems, to conduct data analysis, testing and research, and to monitor and analyse usage and activity trends. City Bodyguard performs the above activities, including the collection and use of location data for purposes of these activities, on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users. 2. Safety and security. We use personal data to help maintain the safety, security, and integrity of our services and users. This includes: · Verifying users’ identity and eligibility to provide security services including through reviews of background checks, where permitted by law, to help prevent use of our services by unsafe drivers and/or riders. In certain regions, this includes City Bodyguard Real-time ID check feature, which prompts drivers and couriers to share a selfie before going online to help ensure that the security personnel using the app matches the City Bodyguard account we have on file. Where permitted by law, this also includes performing facial verification of photographs submitted by users, or collected from public databases, to prevent identity borrowing or to verify users’ identities. · Using device, location, user profile, usage and other data to prevent, detect and combat fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorised security personnel verifying user identities in connection with certain payment methods, and preventing and combating unauthorised access to users’ accounts. · Using user ratings, reported incidents and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who have otherwise violated such guidelines in certain countries. · Sharing information regarding serious security personnel safety incidents or compliance with local regulations with third parties, including other companies who enable users to request or provide trips or delivery services, or intermediaries who collect and report such information for multiple companies, to prevent drivers or couriers who may pose a safety risk to the platform or its users from using City Bodyguard or those other companies’ services. We may also share with third parties, including those affected by such incidents, whether the incidents result in account deactivation. · Using ratings, usage and other data to prevent matching of security personnel for whom there is higher risk of conflict (for instance, because a user previously gave the other user a one-star rating). City Bodyguard performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users, and/or for purposes of the legitimate safety and security interests of City Bodyguard or other parties, including users and members of the general public. 3. Customer support. City Bodyguard uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes. City Bodyguard performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users. 4. Research and development. We may use personal data for testing, research, analysis, product development and machine learning to improve the user experience. This helps us make our services more convenient and easier to use, enhance the safety and security of our services, and develop new services and features. City Bodyguard performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users in order to improve our existing services and features, or for purposes of City Bodyguard legitimate interests in developing new services and features. City Bodyguard performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users. 6. Marketing. City Bodyguard may use personal data to market our services to our users. This includes sending users communications about City Bodyguard services, features, promotions, sweepstakes, studies, surveys, news, updates and events. We may do so via various methods, including email, text messages, push notifications, in-app communications and ads, and ads on third-party platforms. We may also inform users about products and services offered by City Bodyguard partners. For example, we may provide recommendations, promotions or ads for City Bodyguard partners based on users’ past delivery orders. Although we inform users about products and services offered by City Bodyguard partners, we do not sell users’ personal data to, or share it with, such partners or others for purposes of their own direct marketing or advertising, except with users’ consent. We may use the data we collect, including in combination with advertising partners’ data, to personalise and improve the marketing communications (including ads) that we send on and off City Bodyguard apps and websites, including based on user location, use of City Bodyguard services, and user preferences and settings. For example, we share user data (such as hashed email address, usage information, and device or user identifiers) with Facebook and TikTok to personalise and improve our ads for City Bodyguard services. For information about how to opt out of certain marketing communications (including ads) from City Bodyguard and its advertising partners, please see the section titled “Marketing choices”. We may also send users communications regarding elections, ballots, referenda, and other political and notice processes that relate to our services. For example, City Bodyguard has notified some users by email of ballot measures or pending legislation relating to City Bodyguard services in those users’ areas. City Bodyguard performs the above activities on the grounds that they are necessary for purposes of City Bodyguard legitimate interests in informing users about City Bodyguard services and features or those offered by City Bodyguard partners, or on the basis of user consent. See the sections entitled “Choice and transparency” and “Marketing choices” for information on your choices regarding City Bodyguard use of your data for marketing. 7. non-marketing communications. City may use personal data to generate and provide users with receipts, inform them of changes to our terms, services, or policies, or send other communications that aren’t for the purpose of marketing the services or products of City Bodyguard or its partners. City Bodyguard performs the above activities on the grounds that they are necessary to fulfil our obligations to users under our Terms of Use or other agreements with users, or for purposes of City Bodyguard and its users’ legitimate interests in informing users about events that may have an impact on how they can use City Bodyguard services. 8. Legal proceedings and requirements. We may use personal data to investigate or address claims or disputes relating to the use of City Bodyguard services, to satisfy requirements under applicable laws, regulations, or operating licences or agreements, or pursuant to legal process or governmental request, including from law enforcement. City Bodyguard performs the above activities on the grounds that they are necessary for the purposes of City Bodyguard legitimate interests in investigating and responding to claims and disputes relating to the use of City Bodyguard services and features, and/or necessary for compliance with applicable legal requirements.
C. Cookies and third-party technologies City Bodyguard and its partners use cookies and other identification technologies on our apps, websites, emails and online ads for purposes described in this notice and City Bodyguard Cookie Notice.
Cookies are small text files that are stored on browsers or devices by websites, apps, online media and advertisements. City Bodyguard uses cookies and similar technologies for purposes such as: · Authenticating users · Remembering user preferences and settings · Determining the popularity of content · Delivering and measuring the effectiveness of advertising campaigns · Analysing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services. Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.
D. Data sharing and disclosure Some of City Bodyguard services and features require that we share personal data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries and partners for legal reasons or in connection with claims or disputes.
City Bodyguard may share personal data: 1. With other users This includes sharing: · Clients’ first name, rating of services 2. At the user’s request This includes sharing data with: · City Bodyguard business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Uber may share certain data with that third party. This may include, for example, other services, platforms, apps or websites that integrate with our APIs, vehicle suppliers or services, those with an API or service with which we integrate, or restaurants, merchants or other Uber business partners and their users in connection with promotions, competitions or specialised services. 3. With the general public Questions or comments from users submitted through public forums such as City Bodyguard blogs and City Bodyguard social media pages may be viewable by the public, including any personal data included in the questions or comments submitted by a user. 4. With City Bodyguard subsidiaries and affiliates We share personal data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf. For example, City Bodyguard processes and stores such data in the United States on behalf of its international subsidiaries and affiliates. 5. With City Bodyguard service providers and business partners City Bodyguard provides personal data to vendors, consultants, marketing partners, research firms and other service providers or business partners. These include: · Payment processors and facilitators · Background check and identity verification providers · Cloud storage providers · Google, in connection with the use of Google Maps in Uber’s apps (see Google’s Privacy Policy for information about their collection and use of data) · Social media companies, including Facebook and TikTok, in connection with City Bodyguard use of their tools in City Bodyguard apps and websites (see Facebook’s and TikTok’s privacy policies for information on their collection and use of data) · Marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers and other service providers to reach or better understand our users and measure advertising effectiveness · Research partners, including those performing surveys or research projects in partnership with City Bodyguard or on City Bodyguards behalf · Vendors that assist City Bodyguard to enhance the safety and security of its apps · Consultants, lawyers, accountants and other professional service providers · Insurance and financing partners 7. For legal reasons or in the event of a dispute City Bodyguard may share users’ personal data if we believe that it’s required by applicable law, regulation, operating licence or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or similar concerns. This includes sharing personal data with law enforcement officials, public health officials, other government authorities, airports (if required by the airport authorities as a condition of operating on airport property) or other third parties as necessary to enforce our Terms of Service, user agreements or other policies, to protect City Bodyguard rights or property or the rights, safety or property of others, or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to the use of another person’s credit card, we may be required by law to share your personal data, including trip or order information, with the owner of that credit card. 8. With consent City Bodyguard may share a user’s personal data other than as described in this notice if we notify the user and they consent to the sharing.
E. Data retention and deletion City Bodyguard retains user data for as long as necessary for the purposes described above. Users can request deletion of their accounts at any time. City Bodyguard may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy.
City Bodyguard retains user data for as long as necessary for the purposes described above. This means that we retain different categories of data for different periods of time depending on the type of data, the category of user to whom the data relates and the purposes for which we collected the data. Users may request deletion of their account at any time through the Settings > Privacy menus in the City Bodyguard app, or through City Bodyguard website (riders and delivery recipients here; drivers and couriers here). Following an account deletion request, City Bodyguard deletes the user’s account and data, unless they must be retained for legal or regulatory requirements, for purposes of safety, security and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and couriers, this generally means that we retain their account and data for a minimum of 7 years after a deletion request.

IV. Choice and transparency

City Bodyguard enables users to access and/or control data that City Bodyguard collects, including through:  · Privacy settings · Device permissions · In-app ratings pages · Marketing choices  City Bodyguard also enables users to request access to or copies of their data, changes or updates to their accounts, or deletion of their accounts, or to request that City Bodyguard restricts its processing of user personal data.
1. Privacy settings The Settings > Privacy menu in the City Bodyguard app allows recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications. · Location data collection recipients can enable/disable City Bodyguard to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu. · Share live location Riders can enable/disable City Bodyguard to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > Privacy > Location menu. · Emergency data sharing Riders can enable City Bodyguard to share real-time location data from their mobile devices with emergency police, fire and ambulance services. Users may enable/disable this feature via the Settings > Privacy > Location menu, or the Safety Centre. Users can also enable/disable emergency data sharing via the App settings > Emergency data sharing menu, or the Safety Toolkit. · Notifications: account and trip updates City Bodyguard provides users with status notifications and updates relating to activity on their account. These notifications are a necessary part of using the City Bodyguard app and cannot be disabled. However, users can choose the method by which they receive these notifications in the Settings > Privacy menu. · Notifications: discounts and news Users can enable City Bodyguard to send push notifications about discounts and news from City Bodyguard. Push notifications can be enabled or disabled through the Settings > Privacy menus in the City Bodyguard app. 2. Device permissions Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please check the available settings on your device or check with your provider. 3. In-app ratings pages After every emergency call security personnel are able to rate each other on a scale of 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users to whom they provide services or from whom they receive services. This two-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for security personnel Security personnel can see their average rating in the main menu of the City Bodyguard app Security personnel can see their average rating after tapping their profile photo in the City Bodyguard app 4. Marketing choices Users can opt out of certain marketing communications (including ads) and use of their data for marketing in the following ways: · Ad settings: These settings enable users to choose whether their data is shared with City Bodyguard advertising partners to deliver personalised ads, and/or to measure the effectiveness of such ads. · Marketing emails and messages: To opt out of receiving marketing emails from City Bodyguard, or for instructions on how to set your preferences regarding whether to receive marketing SMS or push notifications from City Bodyguard, click here. Users can also opt out of receiving emails and other messages from City Bodyguard by following the unsubscribe instructions in those messages. We may still send users who have opted out non-promotional communications, such as receipts for trips or information about their account. · Cookies and related technologies: For information on how to opt out of personalised ads using cookies and related technologies, please see our Cookie Notice. 5. User personal data requests City Bodyguard provides users with a variety of ways to find out about, control, and submit questions and comments about City Bodyguard handling of their personal data. · Accessing data: Users can access data including their profile data and trip or order history through the City Bodyguard apps or via City Bodyguard website. Users can also use our Explore your data feature to view an online summary of information about their account, such as number of trips or orders, rating, rewards status, and number of days they’ve been a City Bodyguard user. Users can also request access to their data here. · Receiving data: Users can request a copy of their personal data using our Download your data tool. For an overview of the data available through that tool, please click here. Users can also request a copy of their data here. · Changing or updating data: Users can edit the name, phone number, email address, payment method and photo associated with their account through the Settings menu in City Bodyguard apps or driver portal. Users can also ask to update or correct their data here. · Deleting data: Users can request deletion of their account at any time through the Settings > Privacy menus in the City Bodyguard app, or through Uber’s website (security personnel · Objections, restrictions and complaints: Users can request that we stop using all or some of their personal data, or that we limit our use of their data. This includes objecting to our use of personal data that is based on City Bodyguard legitimate interests. City Bodyguard may continue to process data after such objection or request to the extent required or permitted by law. In addition, depending on their location, users may have the right to file a complaint relating to City Bodyguard handling of their personal data with the data protection authority in their country. For example, users in the European Union and South America can submit such requests to the data protection authorities in the country in which they live. Users can submit the above requests here.

V. Updates to this notice

We may occasionally update this notice. If we make significant changes, we will notify users in advance of the changes through the City Bodyguard apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.