Personal data subject: stated when the consent is accepted.
I consent to the operator ByFly Group LLP (BIN 261040023460, address: Республика Казахстан, г. Алматы, ул. Айтеке би, д. 100, н. п. 71) collecting and processing my personal data in the ByFly Taxi service in accordance with the Law of the Republic of Kazakhstan "On Personal Data and Their Protection".
1.What data: phone number, name, information about the device and the app, pickup and destination addresses, route and time of trips, payments, requests to support, correspondence in the order chat with the driver or the rider; correspondence with support, ratings; names and phone numbers of trusted contacts I have added myself (up to three); e-mail address, if I write to the operator by e-mail myself; who invited me and whom I invited (up to five lines), accruals of points, reward credit and partner money; the device identifier and a bank card attribute without the card number; for drivers — also data of the identity card, the driving licence and the car, the face photo taken at registration and before going on the line, if the service asks for it, the medical organisation's certificate if the driver was referred for a medical check, the video before going on the line if the driver did not consent to the AI check, and the device's geolocation while working — on the line and during an order, including when the app is minimised or the screen is off; it is not collected outside the line and orders; bank details (IBAN) — for refunding the remaining advance and for payouts; for partners — the IIN or BIN of the individual entrepreneur and bank details (IBAN) — for paying remuneration.
2.Why: registration and sign-in, ordering and completing trips, settlements, trip safety, admitting a driver to a shift, support, meeting the requirements of the law, improving pickup places (pickup events are kept for 90 days); accruals under the Invitation Network Rules; checking the fairness of trips and of the invitation programme — comparing devices, cards, phone numbers and documents to find repeat registrations and collusion; decisions on sanctions are made by staff.
3.Where the data is stored: on servers in the Republic of Kazakhstan. The data is not published or disseminated in publicly available sources.
4.Foreign services: the voice assistant Eva runs on the ElevenLabs service (USA), and Eva's answers by phone and in the app chat are prepared by the Claude model of Anthropic (USA). From ByFly Taxi systems they receive only the order number and the role (rider or driver) — without name, phone number, addresses or route; these services process what I say to Eva by phone only to answer my request. In the chat with Eva in the app, the Claude model also receives the conversation on my request; phone numbers, e-mail addresses, names, addresses and other personal data are removed from it automatically, but removing everything is not guaranteed. All this happens only with my consent to cross-border transfer of data; without it Eva does not answer either by phone or in the chat, and the request goes to support staff. More details are in that consent. Service push notifications (about an order, a call, a trip) are delivered through Firebase Cloud Messaging (Google, USA) and Apple Push Notification service (Apple, USA): they receive the device identifier for notifications, the order number and the type of event — without name, phone number or addresses. The authenticity of the app on Android is verified by Google Play Integrity (Google, USA) — it receives the verification token and the app name. Address search may use Google Places and Geocoding (Google, USA) — they receive the text of the query and the coordinates of the point, without name or phone number. Traffic and routes may use TomTom (TomTom Global Content B.V., the Netherlands), and address search may also use 2GIS (DoubleGIS LLC, Russia): requests to them are sent by the ByFly server, and they receive only the coordinates of points, the map area and the text of the address query — without name, phone number, order number or user and device identifiers. Browser notifications to ByFly staff about orders and SOS are delivered through browser push notification services (Google, Mozilla, Apple, Microsoft, USA) only in encrypted form.
5.Data is passed to third parties only when it is needed for a trip (to the driver — the rider's name, the pickup address, stops and the destination; to the rider — the driver's name and photo, the car's make, colour and number, where the car is on the way to the pickup and during the trip, and in the trip details and the receipt — the carrier: the name or the name of the individual entrepreneur, the IIN or BIN, the number in the register of carriers; to the person the rider ordered the trip for — one SMS with the car's make, colour and number; to the person the rider sent the "share" link to — where the car is and the trip route; when SOS is called — to the 112 service, the police and the ambulance; to my trusted contacts — an SMS with a link to the trip (where the car is, the driver, the vehicle and the route) when I press SOS) or when the law requires it. The person who invited me, if I am in their first line, can see my first name and the first letter of my surname and what the "My Network" section shows for the first line; for further lines — only numbers, without names. Phone numbers, addresses and routes are not shown to the person who invited me. ByFly LLP (BIN 231040040048), on the operator's instructions, sends service SMS (together with the SMS service SMSC in Kazakhstan — only the phone number and the text of the SMS), receives calls to the hotline +7 702 075 72 82, +7 727 353 33 33 and e-mails to info@byfly.kz, and passes the requests to the operator on the same day.
6.Term of the consent: while my ByFly Taxi account exists or until I withdraw the consent. After that the data is kept only for the periods in point 7 and then deleted or anonymised.
7.Retention periods:
- the consent log (which edition I accepted or withdrew, when and how) — for the whole period of processing and 3 more years after it ends or after the consent is withdrawn;
- contracts and accepted offers — 5 years after the contract ends;
- payments, receipts, remuneration, payouts and taxes — 5 years from 1 January of the year following the year of the transaction;
- requests to support and complaints with answers — 5 years after the request is closed;
- correspondence in the order chat between the driver and the rider — 30 days after the trip; if there is a complaint, a dispute, an SOS or a request from an authority — until the case is closed;
- correspondence with support — like requests, 5 years after the request is closed;
- trusted contacts — until I delete them or while the account exists;
- invitation links — while the account exists; accruals — like payments, 5 years;
- the device identifier and the bank card attribute without its number — while the account exists;
- photos of the driver's and the car's documents — while the contract is in force; after the driver is disconnected they are deleted within 30 days. A record of the check remains (document type, masked number, validity date, result) for 5 years after the contract ends;
- the driver's face photo taken at registration — for a staff member to compare it with the photo in the documents; the rider of the order also sees it to recognise the driver; there is no automatic face recognition. It is kept while the contract is in force; after the driver is disconnected it is deleted within 30 days. The photo taken before going on the line — for the same comparison by a staff member; it is kept for 30 days after the shift. A record of the comparison remains (who compared it and when, the result) for 5 years after the contract ends;
- the medical organisation's certificate, if the driver was referred for a medical check, — 30 days, and if an objection is filed — until the decision and 30 more days; only the staff member who checks it sees it, and it is not passed to external services; we take from it only "admitted" or "not admitted", the date, the time and who carried out the check. The staff member's decision — 3 years after the end of the contract. The record of admission to the shift (time, result, method) — 3 years after the end of the year of the shift;
- the video before going on the line — for a driver, a courier by car and a carrier's driver who did not consent to the AI check or withdrew consent: a ByFly staff member compares the face with the profile photo and looks at the condition (signs of intoxication, glasses if the licence requires them), without artificial intelligence programs or biometric templates; the video is kept for 30 days, and if there is a signal or an objection — until the decision and 30 more days; the check result and the staff member's note — 3 years after the end of the contract; the data is stored in the Republic of Kazakhstan;
- blocks and other sanctions with evidence — 3 years after the final decision, and if money was withheld — 5 years;
- trip geodata, tracks and call recordings — for the periods in the separate consents and in the Rules for recording trips and calls. When my account is deleted at my request, the photos are deleted together with it. If there is a complaint, an accident review, a dispute, an inspection or a request from the police or a court about a trip, a driver or a rider, the related data is not deleted until the case is closed.
8.Withdrawal: in the app — for riders in the profile, section "Documents", for drivers in the section "Documents and vehicle" — or through the contact of the person responsible for personal data processing (директор ТОО «ByFly Group», info@byfly.kz). After withdrawal the account is closed; the data is deleted or anonymised, except data that must be kept for the periods in point 7. The answer to the withdrawal is given within 15 working days.