Privacy Policy

Who we may share your personal data with and how we keep it secure

Bluwalk is a global company. As such, your personal data may be accessed by our suppliers or service providers located in countries outside the European Economic Area (EEA) for the purposes described in this Privacy Policy, where data protection laws may be less stringent than in the EEA.

We will ensure that your personal data that is exported outside the EEA is handled in accordance with appropriate security measures.

Certain countries located outside the EEA, such as Switzerland and Canada, have already been recognized by the European Commission as offering an adequate level of data protection and, as such, no additional safeguards will be necessary with respect to them.

In the case of countries that have not been subject to this recognition, such as the USA, the export of your personal data will be governed by standard contractual clauses approved by the European Commission, which directly impose data protection obligations equivalent to those existing in the EEA on our suppliers/service providers.

Please contact us if you would like to request a copy of the specific safeguards that have been applied to the export of your data to suppliers/service providers located outside the EEA.

Your personal data is stored on the secure servers of our suppliers/service providers and is accessed and used solely according to our policies and standards (or equivalent policies and standards of our suppliers/service providers).

Entity responsible for processing personal data

Bluwalk, Lda., commercial company with Portuguese Tax Identification Number (NIPC) 509833004, with registered office at Rua Manuel Pinto de Azevedo, 567 E01, 4100-321 Porto, hereinafter referred to as Bluwalk.

To whom this privacy and data protection policy applies

• - TVDE (“rideshare”) driver Service Providers;
• - Purchase collection and delivery Service Providers (“shoppers”);
• - Parcel delivery Service Providers;
• - Other Service Providers;
• - Suppliers;
• - Clients.

How do we collect your personal data?

Your personal data will be collected and processed by Bluwalk in the following situations:

• - You complete your personal information and/or submit the Bluwalk Service Provider Registration Form on this Homepage; and/or
• - You purchase and/or use a product or service from Bluwalk;
• - You fill in your personal data and/or submit the Registration Form for vocational training.

On what basis your personal data may be processed

Under current European Union data protection legislation (GDPR, which can be found here), the use of personal data must be justified by at least one legal ground for processing personal data:

• - When you have consented to the processing of your personal data (for this purpose you will be provided with a document of consent for the use of your data, which you may later withdraw at your own discretion);
• - where processing of the data is necessary for entering into a contract with you or for its execution;
• - When processing is necessary to comply with Bluwalk’s legal obligations;
• - Where processing is necessary to achieve a legitimate interest and our reasons for its use outweigh your data protection rights;
• - Where processing is necessary in order for us to assert, exercise or defend a right in a legal proceeding in which we, you or a third party are an interested party.

Bluwalk will process your data on the following grounds

a. The legal basis for the collection and use of your personal data for the purpose of providing services is the execution of the service contract or pre-contractual steps, e.g., management of the selection process and commercial management of the data subject's relationship with Bluwalk.

b. We also process your data to fulfill legal obligations, for example, communications with the Tax Authority, the location of the vehicle and identification of the driver may be communicated to the entities that manage and supervise TVDE activity, as well as to criminal police agencies.

c. Your data may also be processed based on Bluwalk's legitimate interest, such as defending their interests in legal or similar proceedings to be filed or ongoing, or in locating and recovering stolen and/or misused Bluwalk vehicles.

d. The legal basis applicable to the collection and use of your personal data for marketing purposes is your consent.

Purposes of Data Processing

1. Management of Selection Processes: Your data is used exclusively to provide the information you have requested, to call you for a selection interview, to assess your suitability for the job.

2. Commercial management: Your data is used to manage the commercial relationship that we maintain with you.

3. Compliance with Legal Obligations: when Bluwalk acts as a TVDE operator and a vehicle is used by the driver at the service of a transport operator in an unmarked vehicle via an electronic platform, the identification data provided for in the respective legal regime, as well as the real-time location of the vehicle, must be communicated to the electronic platform, in compliance with legal obligations.

4. Protection of People and Property: monitor the location of the vehicle in real time and also store information about the routes travelled, allowing Bluwalk to locate the vehicle in case of theft, robbery, loss or any other situation where there is suspicion of occupants being in danger or misuse of the vehicle, also allowing the vehicle to be safely blocked after verifying that it is duly and demonstrably stopped. The location of the vehicle can also be used for recovery in case of non-payment or similar situation.

5. Provide Driving Advice: An in-vehicle tracker collects information on vehicle miles traveled, routes and driving style, records alerts for sudden braking or other inappropriate driving maneuvers, and Bluwalk can use this information to provide you with information to improve your driving safety and fuel economy.

6. Or they may be used for anonymous statistical evaluations in order to optimize/improve our website and our services.

What personal data Bluwalk handles

1. Contact information: Name; contact details (address, phone, mobile, e-mail).

2. Personal information: Date of birth; marital status; profession; preferred method of payment; IBAN; preferred contact channel; company name.

3. Identification data: Taxpayer number; citizen card number and expiry date; driver's license number, customer number; TVDE driver's certificate number, contract number.

4. Customer/user history: Customer satisfaction ratio; offers received; assistance history; campaign/response history; event participation (local, company); complaint history.

5. Bluwalk application data (data from the www.bluwalk.com portal): If you have registered on the Customer Portal, the following data can be used: details of how you have used the Portal, the date and time and nature of your requests, your IP address, data about the device you use to interact with the Customer Portal.

6. Website and social media: If the customer has registered or signed in, use of the following data is possible: average app usage (behavior within the apps); location information; online entertainment usage; usage of Bluwalk's website; usage of Bluwalk's social media, e.g., forum visits and posts ).

How we keep your personal data secure

We use a variety of security measures, including encryption and authentication tools, to help protect and maintain the security, integrity and availability of your personal data.

Although the transmission of data via the internet or website cannot guarantee full security against intrusion, Bluwalk, our service providers and business partners use their best efforts to implement and maintain physical, electronic and procedural security measures to protect your personal data in compliance with applicable data protection requirements. Among other measures, we have implemented the following:

• - Restricted personnel access to your personal data on a "need-to-know" basis and only within the scope of the communicated purposes;
• - Transfer of collected data only in encrypted form;
• - Storage of highly confidential data (such as credit card information) only in encrypted form;
• - Protection of information technology systems through firewalls, in order to prevent unauthorized access to your personal data; and
• - Permanent monitoring of access to information technology systems in order to prevent, detect and block the misuse of your personal data.

How long we keep your personal data

We only retain your data for as long as is necessary for the purpose for which it was collected.
Once the maximum retention period has been reached, your personal data will either be irreversibly anonymized (anonymized data may be retained) or securely destroyed.

For the purposes described in this Privacy Policy, your personal data will be retained:

• a. In the case of the provision of services and marketing, your personal data will be kept in compliance with the legal time limits arising from legal obligations, namely those related to tax, accounting and commercial obligations;
• b. in the case of marketing, until no later than 12 to 18 months from the collection of your consent or the last contact made (whichever is the latest) and if, within this period, you have not withdrawn your consent.

How to change or withdraw your consent

In accordance with the provisions of data protection legislation, you may change or withdraw your consent with future effect at any time.
If you withdraw your consent, you will no longer be contacted and will no longer receive communications for the purposes described in this Privacy Policy.

Withdrawing your submitted consent statements to Bluwalk is simple; simply access the Homepage again, fill in your personal details and re-submit the Consent Form, selecting, or not, the check boxes according to your preferences.

The most recent Consent Form submitted to Bluwalk will supersede all previous Consent Forms.
Contact us about exercising your data protection rights and your right to lodge a complaint with your supervisory authority

If you have any questions regarding the use of your personal data, you should first contact our customer service here.
Additionally, you may contact the Data Protection Officer here.

Subject to certain conditions, you may have the right to request that we:

• - provide you with additional information about our use of your personal data;
• - provide you with a copy, in editable format, of the personal data you have provided to us;
• - provide the personal data you have indicated to us to another controller and always at your request;
• - update any inaccuracies in the personal data we hold;
• - that we delete personal data whose use is no longer legitimate;
• - limit how we use your personal data until the complaint you have made has been investigated.

The exercise of these rights is subject to certain exceptions intended to safeguard public interest (prevention or detection of crimes) or our own interest (maintenance of professional secrecy).

If you exercise any of these rights, we will review it and usually respond within one (1) month.

If you are unhappy with our use of your personal data or with our response after exercising any of these rights, you have the right to lodge a complaint with your supervisory authority (Comissão Nacional de Proteção de Dados - CNPD | Rua de São Bento, n.º 148, 3º, 1200-821 Lisboa | Tel: +351 213 928 400 | Fax: +351 213 976 832 | e-mail: geral@cnpd.pt).