Privacy Policy

1. Introduction

Kyytiin ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform, in compliance with the General Data Protection Regulation (GDPR) (EU) 2016/679 and other applicable European data protection laws.

By using our Platform, you consent to the data practices described in this Privacy Policy. If you do not agree with this policy, please do not use our services.

2. Data Controller

Kyytiin is the data controller responsible for processing your personal data. Our contact information is:

Company: Kyytiin
Email: privacy@yourway.com
Address: [Your Company Address]
Phone: [Your Phone Number]

3. Information We Collect

3.1 Personal Information

We collect the following personal information when you register and use our Platform:

• Identity Data: First name, last name, username
• Contact Data: Email address, phone number, postal address
• Account Data: Password (hashed), account preferences, role
• Profile Data: Profile information, travel history, service preferences
• Transaction Data: Payment information, service requests, transaction history
• Technical Data: IP address, browser type, device information, login data
• Usage Data: How you interact with our Platform, pages visited, features used
• Communication Data: Messages sent through the Platform, customer support communications

3.2 Automatically Collected Information

We automatically collect certain information when you visit our Platform, including:

• Log files and analytics data
• Cookies and similar tracking technologies (see Cookie Policy below)
• Device and browser information

4. Legal Basis for Processing (GDPR Article 6)

We process your personal data based on the following legal grounds:

• Consent: When you have given clear consent for specific processing activities (e.g., marketing communications)
• Contract Performance: To fulfill our contractual obligations to you and enable you to use our services
• Legal Obligation: To comply with legal requirements (e.g., tax obligations, fraud prevention)
• Legitimate Interests: For our legitimate business interests, such as improving our services, security, and fraud prevention (balanced against your rights and interests)

5. How We Use Your Information

We use your personal data for the following purposes:

• To create and manage your account
• To facilitate connections between Travelers and Requesters
• To process payments and transactions
• To communicate with you about your account and services
• To send you important updates and notifications
• To provide customer support
• To improve and personalize your experience
• To detect and prevent fraud, abuse, and illegal activities
• To comply with legal obligations
• To send marketing communications (with your consent)
• To analyze usage patterns and improve our Platform

6. Data Sharing and Disclosure

We may share your personal data with:

• Service Providers: Third-party companies that help us operate our Platform (payment processors, hosting providers, analytics services) - all bound by data processing agreements
• Other Users: Limited profile information necessary for service facilitation (e.g., name, travel dates, service type)
• Legal Authorities: When required by law or to protect our rights and safety
• Business Transfers: In connection with a merger, acquisition, or sale of assets (with notice to users)

We do not sell your personal data to third parties.

7. International Data Transfers

If we transfer your personal data outside the European Economic Area (EEA), we ensure appropriate safeguards are in place, such as:

• Standard Contractual Clauses approved by the European Commission
• Adequacy decisions by the European Commission
• Other legally recognized transfer mechanisms

8. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Specifically:

• Account Data: Retained while your account is active and for 3 years after account closure (for legal and fraud prevention purposes)
• Transaction Data: Retained for 7 years (for tax and accounting purposes)
• Marketing Data: Retained until you withdraw consent or unsubscribe
• Legal Claims: Retained as long as necessary to resolve disputes and enforce agreements

9. Your Rights Under GDPR

As a data subject under GDPR, you have the following rights:

• Right of Access (Article 15): Request a copy of your personal data we hold
• Right to Rectification (Article 16): Request correction of inaccurate or incomplete data
• Right to Erasure (Article 17): Request deletion of your personal data ("right to be forgotten")
• Right to Restrict Processing (Article 18): Request limitation of how we process your data
• Right to Data Portability (Article 20): Receive your data in a structured, commonly used format
• Right to Object (Article 21): Object to processing based on legitimate interests or for direct marketing
• Right to Withdraw Consent: Withdraw consent at any time where processing is based on consent
• Right to Lodge a Complaint: File a complaint with your local data protection authority

To exercise these rights, please contact us at privacy@yourway.com. We will respond to your request within one month (may be extended by two months for complex requests).

10. Cookies and Tracking Technologies

We use cookies and similar technologies to enhance your experience. Cookies are small text files stored on your device. We use:

• Essential Cookies: Required for the Platform to function (no consent needed)
• Analytics Cookies: Help us understand how users interact with our Platform (consent required)
• Marketing Cookies: Used to deliver relevant advertisements (consent required)

You can manage cookie preferences through your browser settings or our cookie consent banner. Note that disabling certain cookies may affect Platform functionality.

11. Data Security

We implement appropriate technical and organizational measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction, including:

• Encryption of data in transit (SSL/TLS) and at rest
• Secure authentication and access controls
• Regular security assessments and updates
• Staff training on data protection
• Incident response procedures

However, no method of transmission over the Internet is 100% secure. While we strive to protect your data, we cannot guarantee absolute security.

12. Children's Privacy

Our Platform is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children. If we become aware that we have collected data from a child, we will take steps to delete such information promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Material changes will be notified to you via email or through a prominent notice on the Platform. The "Last Updated" date at the top indicates when this policy was last revised.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

14. Data Protection Officer (DPO)

If you have questions or concerns about our data processing activities, you can contact our Data Protection Officer at:

Email: dpo@yourway.com
Address: [Your Company Address]

15. Supervisory Authority

If you are located in the European Economic Area and believe we have not addressed your privacy concerns, you have the right to lodge a complaint with your local data protection authority. A list of EU data protection authorities can be found at:

https://edpb.europa.eu/about-edpb/about-edpb/members_en

16. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or our data practices, please contact us:

Email: privacy@yourway.com
Data Protection Officer: dpo@yourway.com
Address: [Your Company Address]
Phone: [Your Phone Number]