Privacy Policy
Effective Date: 6 Jun 2024
TXY.CO (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and protect your personal information when you use our ride-hailing services, which include franchising to vehicle companies and partnering with rental companies on a daily, weekly, monthly, and yearly basis.
TXY.CO LTD (“TXY.CO”) respects your concerns about privacy. This Privacy Notice governs the privacy practices of TXY.CO in Pakistan. The notice does not apply to the handling of your personal information by any TXY.CO entities located outside the Pakistan or by independent licensees or franchisees.
If you have questions about our privacy practices, please email us at PRIVACY@TXY.CO
This Privacy Notice describes the personal data handling policies of TXY.CO as a data controller, including the following:
- Overview and Scope
- Information we collect and how it’s collected
- How we use the information we collect, including retention of data
- Information we share
- Your privacy choices
- Your privacy and data rights
- Links to other websites
- Data Transfers
- How we protect personal information
- Updates to this Privacy Notice
- How to contact us
BY USING ANY OF OUR WEBSITES OR APPS, YOU UNDERSTAND AND ACKNOWLEDGE WE WILL COLLECT AND USE YOUR PERSONAL INFORMATION AS DESCRIBED IN THIS PRIVACY NOTICE.
1. OVERVIEW AND SCOPE
TXY.CO LTD (“TXY.CO”) respects your concerns about privacy. This Privacy Notice describes the types of personal information we collect when you interact with us in connection with rental car reservations in the Pakistan, and how TXY.CO collects, uses, retains and discloses your personal information. This Privacy Notice does not apply to the handling of your personal information by any TXY.CO entities located outside the Pakistan, or by independent operators of TXY.CO-branded locations or websites.
Our websites and online marketing are not directed to, and TXY.CO does not knowingly collect personal information from minors. If you nevertheless believe that your child has provided us with their personal information, please contact Privacy@TXY.CO so we can assist with deleting their data.
You may connect with TXY.CO via our website, TXY.CO, our mobile site and application, via our Facebook page and other social media pages, or by calling our customer service center.
2. INFORMATION WE COLLECT AND HOW IT’S COLLECTED
We collect information from you, directly and through third parties, in accordance with this Privacy Notice, when you contact us, interact with us in person, or online through our website, social media, or apps, or use our products or services. Other sources of information include travel sites with which we collaborate, information obtained from our parent or affiliate companies or information you provide when you participate in events or certain promotions. We may not be able to provide the services requested if you do not provide some of the information requested, and not providing the requested information may limit our ability to provide you with the level of service that you would otherwise expect from TXY.CO.
When renting a vehicle, joining one of our rental programs, being added as an additional driver to a rental or using TXY.CO for a service, we may collect the following information:
Personal Information and Identity Verification
When ride hailing or renting a vehicle, some of the information we collect can personally identify you (or your device), including, for example, your IP address (to determine your location), your name, address, phone numbers, email addresses, birthdate, driver’s license, insurance information, proof of residence, government identification, passport, payment information, photographs at the counter, insurance information, membership ID or travel partner affiliations and TXY.CO accounts (including login and password) including past rental history with TXY.CO and associated accidents, claims or violations.
Transaction Information
Information related to your transaction with TXY.CO includes vehicle ride hailing or rental information, rental and return locations, dates of the rental, type of rental, vehicle preference, vehicle details (like gas mileage, or damages), billing information, charges, payments, receipts, ancillary products purchased, airline and flight number, photographs of you, claims information, emergency contact information, reservation number, calls recorded for quality assurance, security footage at branches, traffic and tolls violations, customer service communications, dispute resolutions communications, accident or damage claims information and information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers.
Vehicle Data
Vehicle data includes information such as collision information and vehicle operation information like condition, mileage, tire pressure, fuel status and other diagnostic performance information. Depending on the specific technology or programs available in your rental vehicle, vehicle manufacturers and built-in services such as Apple Car Play or OnStar may also collect data or other personal information from the vehicle pursuant to their privacy policies. We may use the assistance of vehicle manufacturers and geolocation data as it relates to recovering stolen or lost vehicles. When you return your vehicle, we may ask you to drive the vehicle through a damage detection machine that will scan the vehicle for damage. While neither our intent nor the design of the machine, it may on rare occasion capture images of individuals located inside the vehicle.
Location Information
With your consent, we can access location information (geo-location, zip code, postal code, or geographic region) from your mobile device. This location information will only be available if you allow the mobile application to access your device’s location services.
Optional Information
If you choose to, you may provide emergency contact information or any preferences, special requirements or accommodations you may have or need.
Security Cameras
Recordings and/or photographs of you in public areas of our rental locations may be captured if there are security cameras at our branches or facilities.
USING OUR WEBSITES OR APPLICATIONS
When you download our applications or visit or use our website, social media platforms or applications or interact with us using e-mail, texts, or other forms of electronic communications, we may use cookies, scripts or similar technologies to collect information like web logs, IP addresses, unique device identifiers, operating systems, geo-location information (such as, with your consent, the real-time geographic location of the device on which you install our mobile applications), clickstream data and how you interact with our websites. Permission to use your device’s camera enables you to upload your photo identification/driver’s license to your profile (where and when available).
COOKIES
Cookies and web beacons are used on our websites, mobile apps, electronic communications, and similar technology, to collect information by automated means to remember your preferences, improve user experience and tailor advertisements to you. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, is used to transmit information back to a web server. Our emails may also contain web beacons.
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our sites’ features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.
INFORMATION WE COLLECT FROM THIRD-PARTIES
We also may collect information from third parties including information from:
Third party travel booking channels (who generally provide contact information and booking information, such as a confirmation number, and other information needed to facilitate the rental);
Insurance providers;
Your employer;
Airlines, hotels, and membership clubs;
Our group companies which may be within or outside your jurisdiction for administrative and corporate purposes and to facilitate reservations across geographic locations;
Payment card companies;
Credit and financing partners including credit reporting agencies who may assist with providing credit information when and if applicable;
Franchisees;
Service providers such as customer support, roadside assistance, or customer survey or sweepstakes providers;
Third parties who may provide us with, for fraud prevention purposes, information and identity-related verification and document authentication (such as the DMV);
Your social media services consistent with your information sharing settings on your device; and
from other third-party sources that are lawfully entitled to share your information with us.
Please note that some of our franchises and rental locations are equipped with video monitoring for security purposes, which may capture your image while you are on our property.
We operate social media pages on third party networks and have social media icons on our sites. When you visit or link to our social media pages, or if you sign in to your account using your Apple or Google credentials, data is processed both by us and the applicable third party. Social media providers, Apple and Google are unaffiliated with us, and we are not responsible for their content or privacy practices. Social media providers, Apple and Google have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms.
We also may use third-party website analytics tools (such as Omniture and Google Analytics), that collect information about visitor traffic on our sites and mobile applications. The information we may collect by automated means includes:
Information about the devices our visitors use to access the Internet (such as the IP address and the device, browser and operating system type)
URLs that refer visitors to our sites
Dates and times of visits to our sites
Information on actions taken on our sites (such as page views and site navigation patterns)
A general geographic location (such as country and city) from which a visitor accesses our websites
Search terms that visitors use to reach our sites
You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here: https://tools.google.com/dlpage/gaoptout?hl=en.
VEHICLE INFORMATION
Some information collected may be maintained in a form that is not linked to a particular individual, such as vehicle information that is not connected to a passenger, or other aggregated, de-identified, or anonymized information, and this Privacy Notice does not apply to such non-personal information which we may collect and use or disclose for a variety of purposes. Any non-personal information that is linked or combined with personal information will be treated as personal information and is subject to this Privacy Notice.
We collect and use vehicle data in the following manner:
Fuel information is used to monitor fuel levels and properly record and bill for fuel charges.
Odometer information is used to monitor vehicle mileage and bill for any applicable mileage charges.
Vehicle diagnostic and performance information is used to identify any vehicle maintenance issues or needs that may need to be addressed in a specific vehicle.
VIN or license plate information or a combination of several types of vehicle data may be legally compelled by governmental or regulatory authorities and we will disclose such legally compelled information.
Automated damage detection services to determine any damage to the vehicle.
INFOTAINMENT SYSTEMS AND OTHER APPS
If you pair your (or a) mobile device with our vehicle’s navigation or infotainment system (such as Apple Car Play or OnStar, etc. or any other similar third party software or service) your personal information and other data may be transferred and stored on those systems, and we cannot guarantee the privacy or confidentiality of such information on third-party systems. You are responsible for deleting all such personal information from vehicles (including vehicle systems and devices) before your vehicle is returned.
ONLINE ADVERTISING
On our websites, we may collect information about your online activities. You may see certain ads on this and other sites because we participate in advertising networks. Ad networks may include third-party ad servers, ad agencies, ad technology vendors, social networks, and research firms. We are not responsible for the privacy practices of these third parties, and we encourage you to read their privacy policies, which may apply to these third-party programs.
Ad networks allow us to target our advertising to users through demographic, behavioral and contextual means. These networks track your online activities over time across third-party websites or online services by collecting information through automated means, including through the use of cookies, web server logs, web beacons and other methods. The networks use this information to show you advertisements for TXY.CO and our business partners that are tailored to your individual interests. The information our ad network vendors collect includes information about your visits to websites that participate in the vendors’ advertising networks, such as the pages or advertisements you have viewed, and the actions you take on the sites. This data collection and ad targeting may take place both on our websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.
“DO NOT TRACK” DISCLOSURE
We do not track our customers over time and across third party websites to provide targeted advertising on our websites. Some third-party websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such websites, you should be able to set the do not track signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked. We utilize an automated tool designed to recognize Do Not Track settings and Global Privacy Controls in end-user browsers.
3. HOW WE USE THE INFORMATION WE COLLECT
We may use the information we obtain about you to:
Facilitate your rental vehicle reservation (including, for example, by helping you identify the closest TXY.CO location using the geo-location, if enabled, of your mobile device);
Register you for a TXY.CO profile, including the TXY.CO card, and manage and maintain your account or enroll you in our loyalty program;
Process, validate, confirm, verify and monitor your rental reservations (including by processing payment card transactions and contacting you about reservations);
Assist with any transactions including communication of important information regarding a specific transaction or providing customer service;
Determine whether you qualify for a specific vehicle category, pricing or rental program or product;
Provide third-parties (service providers) with information as it relates to your rental and your specific needs, requests or accommodations;
Maintain a record of your reservations and rentals;
Respond to your questions and comments and provide customer support;
Communicate with you about our products, services, offers, events and promotions, and offer you related products and services we believe may be of interest to you;
Enable you to share information with your social network;
Facilitate your communications with us, through social networks and other interactive media;
Manage your participation in our events, surveys, sweepstakes and other promotions;
Tailor our products, services and website content according to your location and to suit your personal interests;
Operate, evaluate and improve our business and the products and services we offer;
Analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read);
Analyze trends and statistics regarding visitors’ use of our sites, mobile applications and social media assets, and the purchases visitors make on our sites and tailor our products, services and website content accordingly;
Protect against and prevent fraud, unauthorized transactions, claims and other liabilities, and manage risk exposure, including by identifying potential hackers and other unauthorized users;
De-identify or aggregate personal information collected about you and use it for any lawful purpose;
Comply with applicable legal requirements, obligations and industry standards and our policies.
We also may use the information we obtain about you in other ways for which we provide specific notice.
NOTICE OF LOYALTY PROGRAM AND FINANCIAL INCENTIVES
TXY.CO has implemented a loyalty program to reward its repeat customers. Users are given “Gold”, “Platinum” or “Diamond” status based on the number of rentals or amounts spent in a given year; we use only our rental records and do not request any additional personal information from you for participation. We may adjust the terms of participation from time to time. From time to time discounts are offered to members, which may be tiered according to status level, which are applied automatically when the member logs in to their account and completes a transaction at check-out.
We utilize a third party service provider to make available “digital cards” that you can opt to load into an Apple or Google wallet. The passes contain your name, email and status level. You may elect to receive push notifications on your device to inform you of offers and other promotions associated with your TXY.CO status and/or use of the wallet.
You may also receive discounts if you subscribe to our newsletter with your email address. Our collection of certain personal information about you allows us to operate the loyalty programs and newsletter subscription and provide member benefits.
You may withdraw from our loyalty program by requesting to delete your account and/or may withdraw from our newsletter subscription at any time, and you may delete the “digital card” from your applicable wallet application on your device at any time. However, we may continue to process information about you in connection with your rental transactions.
The price and service differences (including in connection with discounts and rewards) that are available to you through our loyalty program and newsletter subscription are based upon our reasonable determination of the value that we receive from collecting and retaining personal information about you in connection with operating our business. The estimated value considers a variety of factors, including, without limitation, our expenses incurred in collecting and processing the information, our expenses incurred in providing rewards to you, and the estimated marginal increase in revenue that we may derive from information related to a specific loyalty program participant.
RETENTION OF DATA
We retain your personal for as long as you have an account with TXY.CO, as needed to fulfill our services or obligations to you, or as otherwise necessary for the processing purposes for which the information was originally collected. Additionally, we will retain your personal information for any legitimate business purposes, including any legal, accounting, archival or audit purposes. Depending on the state of the rental transaction, we are required by law to retain some of your personal information indefinitely. Once retention of the personal information is no longer necessary for the purposes outlined throughout this Privacy Notice, we will either delete, deidentify or anonymize the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will not further process the personal information until deletion, deidentification or anonymization is possible.
4. INFORMATION WE SHARE
We may share the information we collect with:
Businesses that provide services on our behalf (such as identity verification services, payment processors or debt collection agencies);
Any intermediary you use, such as a travel agent, broker or booking engine, in relation to any aspect of your rental;
Independent operators of TXY.CO-branded locations and websites (i.e., licensees or franchisees) for use in providing the products or services you have requested, and to communicate with you regarding such products and services;
Your company or organization if you use our services under a corporate membership or other commercial account;
Our loyalty program partners, and other business or marketing partners;
Financial institutions that issue and process credit and debit cards, in connection with payment card transactions;
Credit reporting and fraud prevention agencies;
The government or private organizations responsible of the processing or handling of traffic or parking related violations; and
Driver licensing authorities directly or through intermediary organizations, when needed to verify compliance with TXY.CO’s safe driver criteria for qualified drivers and/or to verify license information
We may also disclose information about you (i) if we are required to do so by law or legal process, (ii) when we believe disclosure is necessary to prevent harm or financial loss, (iii) to bring and defend claims, or (iv) in connection with an investigation of suspected or actual fraudulent or illegal activity.
We may share your data with a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock with such third party, and we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that information.
We also may share the information about you in other ways for which we provide specific notice at the time of collection.
SERVICE PROVIDERS AND BUSINESS PARTNERS
As stated above, we may share information with service providers and business partners that provide services on our behalf including, but not limited to:
Payment support providers;
Insurance companies;
Vehicle recovery providers;
Debt collection providers;
Credit reporting agencies;
Claims processing companies;
Roadside assistance providers;
Tolls and citations processors;
Adaptive driving installers;
Security providers;
Any other business or service provider relating to accident recovery or vehicle repair, assessment or maintenance; and
Any governmental authority as needed or requested by such.
FRANCHISEES
We may share your contact information and, where applicable, driver qualification and other information with a Franchisee in order to facilitate your rental with a Pakistani franchisee.
5. YOUR PRIVACY CHOICES
We offer you certain choices about what information we collect from you, how we use and disclose the information, and how we communicate with you.
Here are the choices we offer:
Marketing Emails
You may choose not to receive marketing email communications from us by clicking on the unsubscribe link in the marketing emails. If you opt out, you will continue receiving emails related to your reservations as well as important information about your relationship with TXY.CO.
Targeted Advertising & Tracking
We may engage with advertising networks that are members of organizations or programs that manage the privacy choices that these ad networks offer to consumers. Please note that we also may work with ad networks that offer their own opt-out mechanisms and may not participate in the opt-out mechanisms that we linked above.
Geo-Location Information
When you use a TXY.CO application on your mobile device, we may use the geo-location of the device to enhance your booking experience, and to provide you with notifications related to our locations, reservation information, local offers or other information that we think will be helpful in providing you with better services. You may choose not to share your geo-location details with us by adjusting the device’s location services settings. For instructions on changing the relevant settings, please contact your service provider or device manufacturer. Please note that if you disable geo-location services for the TXY.CO application, you will not be able to take advantage of location-based features of the application.
Camera Information
With your consent, our application may utilize your device’s camera. If you have allowed us to utilize your device’s camera in the past and wish to revoke the permissions, please change the settings on your device.
Cookies
Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Please note, however, that without cookies you may not be able to take full advantage of all of our sites’ features. In addition, disabling cookies may cancel opt-outs that rely on cookies, such as web analytics or targeted advertising opt-outs.
6. YOUR PRIVACY AND DATA RIGHTS
(a) General.
This section is subject to specific disclosures on privacy rights set forth below. We are committed to facilitating the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale or sharing of your personal information (as applicable), including in the context of targeting advertising. We will do our best to honor your requests subject to any legal and contractual obligations. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal information, such as the right to appeal our decision regarding a data access request.
You may obtain a copy of certain personal information we maintain about you or update or correct inaccuracies in that information using the TXY.CO account you may establish on our website. In addition, if you believe other personal information we maintain about you is inaccurate, you may request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section of this Privacy Notice.
HOW TO EXERCISE YOUR RIGHTS
You may submit a request to exercise your rights described above. If you submit a data subject request, we will ask for your name, email address, phone number and your last rental agreement or reservation number, We may also require that you submit your request via the our site’s standard authentication procedures (i.e., log on with user name and password to submit a request) and/or provide information about any historical transactions with us to ensure you are the person you say you are. If this information or these processes are insufficient to verify your identity and assess your privacy request, we may need to ask for additional information. You may also designate an authorized agent to make a CCPA privacy request.
7. LINKS TO OTHER WEBSITES
Our websites may contain links to other sites for your convenience and information. These sites may be operated by companies not affiliated with TXY.CO. Linked sites may have their own privacy notices, which you should review if you visit those websites. We are not responsible for the content of any websites not affiliated with TXY.CO, any use of those sites, or those sites’ privacy practices.
8. DATA TRANSFERS
This is a Pakistani website and application subject to Pakistani laws, including those governing the privacy and security of your information. When we obtain personal information about you, we may process the information outside of the country in which you are located, including in the European Union and the United States. The countries in which we process the information may not have the same data protection laws as the country in which you are located. We will protect your information as described in this Privacy Notice.
9. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards designed to assist us in protecting the personal information we collect against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
Please note that no electronic transmission of information can be entirely secure. We cannot guarantee that the security measures we have in place to safeguard personal information will never be defeated or fail, or that those measures will always be sufficient or effective.
To help protect yourself, you should safeguard your TXY.CO account user name and password and not share that information with anyone. You should not use the same user name and password for your TXY.CO account as you do for your other online accounts. Using the same log-in credentials across your online accounts may significantly increase the risk of identity theft and fraud. You should also sign off your account and close your browser window when you have finished your visit to our site. Please note that we will never ask for your TXY.CO account user name or password via email.
10. UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice may be updated periodically. We will post a notice on TXY.CO to notify you of any material changes to our Privacy Notice and indicate at the bottom of the notice when it was most recently updated. We will also communicate changes as required by applicable law.
11. HOW TO CONTACT US
If you have any questions or comments about this Privacy Notice, or if you would like us to update information about you or your preferences that we have with us, please contact us by email at PRIVACY@TXY.CO. You also may write to us at:
TXY.CO LTD
Attention: Privacy / Legal
Sardar Plaza, Blue Area, Near China chowk,
Islamabad, 44000, Pakistan
CONTACT US
For questions or inquiries related to privacy and data protection, please email us at PRIVACY@TXY.CO