Privacy Notice for Passengers

Last update: 8-1-2019

Short version

Data Controller Name

Bonju Ltd is the data controller of personal data of passengers.

The term “our”,”us” or “we” refers to the owner of the Bonju app, Bonju Ltd, a private limited company with established in Malta.

Legal basis for collecting your data

Bonju will maintain your personal details and associated transactions in order to provide you with the services you seek from us; and will retain these records in accordance with all applicable laws and regulations in Malta and the European Union.

How we collect your data

A Passenger account be may be created by signing up on our website, through the Bonju app and through Facebook or Google using your registration and profile information from that service.

How we retain your data

Personal data of passengers is retained for a minimum of three years from last trip or account closure for accounting, dispute resolution or fraud prevention purposes.

Do we sell your data?

No, we do not sell passenger data to other third parties.

Information we collect on you

  • Name, date of birth, gender, address, phone number, e-mail;
  • Payment information – click here for more information;
  • location of the passenger using GPS, IP address, and WIFI;
  • The time start and the destination of a journey;
  • Payment information;
  • Data of the device on which the Bonju app has been installed.
  • other data that you have provided while contacting us, data that you have sent to us through an online chat, phone call, email and support ticket.

Your rights

Passengers may request for information on personal data stored, data to be rectified, object to the processing of personal data for direct marketing purposes, withdrawal of consent, lodge a complaint and request for an export or transfer of your data where technically feasible.

Long version

As a data controller, Bonju Ltd collects and processes personal data of passengers for the purposes of allowing access to use its services and in order to move around Malta more efficiently.

Bonju Ltd (“Bonju”) a private limited company with registration number C 88787 with Registered Address: Cor Jesu, Suite 3, Triq il-Wied ta’ l-Imsida , Msida MSD 0057.

The purpose of this notice is to inform you about our policies for the collection, use and disclosure of personal information. Your information will not be shared with anyone except for the named parties in this privacy notice.

Bonju reserves the right to update this privacy notice at any time without prior notice. We shall at all times process data in accordance to the privacy notice that you have consented to at the time of your consent. Upon a change in policy, we will alert you with a website banner notice; your continued use of the website and/or its services will constitute your consent to the updated notice. Use the “Last updated” date in this notice to determine when it was last changed.

Purposes of the Data Processing

Bonju collects and processes your personal data from account opening stage in order to:

  • Provide you with the services that you seek from our website;
  • Connect drivers with passengers using geolocation data and phone number of passengers;
  • Use of Geolocation data collected only when the Bonju app is activated. The collection of geolocation data is stopped after closing the Bonju app.
  • Improve our website and services;
  • Obtain payment details to process passengers’ payment on behalf of drivers for transportation services – click here for more information;
  • Ensure the security of our website;
  • Better market relevant content generally, using anonymous or pseudonymized personal data;
  • Analyse route information in order to provide recommendations to the drivers about most efficient routes;
  • And, if you have additionally consented to it, market to you specifically, such as through email, SMS remarketing and web retargeting.
  • Beyond these purposes, we process your data only if you have granted consent for its stated purposes.

None of the above processing includes automated decision taking.

Cookies and Tracking Pixels on Visit

When you visit the Bonju website, our system automatically collects information about your visit, such as your browser, IP address, and the referring website.

This collection may be done in conjunction with our platform providers and partners (see data recipients list below). We may receive from them general demographic or usage data of our site visitors. We do not use automatically collected information to identify you personally without collecting additional consent.

This information is collected using cookies, embedded hyperlinks, and similar tools. The latest browsers can be set to disable or delete cookies. The list below contains the types of cookies we use and their purposes.

Necessary Cookies : enable the navigation and basic functionality of the websites, e.g., access to member areas of the websites.

Statistics Cookies : allow us to analyze your website usage and your selections on the website (e.g. your session key, language, or region), so we can save these settings and offer you a more personalized experience.

Marketing Cookies : allow us to gauge how effective our content marketing is. These cookies are provided by our partners to track site visits and new player signups from advertising. We do not share your personal information (such as name or email) to providers except for site visit data collected directly by such Marketing Cookies. However your site visit data may be linked with other personal information collected through other sources by the providers.

Opt-out: You can configure your browser to disable the Marketing Cookies. This may reduce site functionality.

More information on Cookies used can be found here.

Categories of Personal Data

Personal data means any information relating to an identified or identifiable natural person. Bonju collects, processes, or uses the following personal data:

  • Name, date of birth, gender, address, phone number, e-mail;
  • Payment information;
  • Location of the passenger using GPS, IP address, and wifi;
  • The time, start and the destination of a journey;
  • Payment information;Data of the device on which the Bonju app has been installed.
  • other data that you have provided while contacting us, data that you have sent to us through an online chat, phone call, email and support ticket.

For marketing purposes and to improve our websites and services, we also collect data sent by your web browser, e.g., information about your browser, your IP address, and your operating system.

Applicable Law

Bonju respects passenger privacy and is committed to protecting personal data and processing it in compliance with applicable laws notably: The Maltese Data Protection Act (Chapter 586 of the Laws of Malta) as well as the various subsidiary legislation issued under the same – the ‘DPA’; The Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data – the ‘GDPR’.

Data Recipients

Bonju does not sell or rent personal information to third-parties. We do not share your personal information, except as provided in this privacy notice. These employees of Bonju will have access to personal data:

  • Booking agent
  • Driver assigned to your journey for up to 24 hours to resolve issues specific to the journey
  • Data protection officer
  • Director of operations

Bonju’s employees who have access to, or are associated with the processing of the passenger’s personal information, have signed confidentiality agreements to respect the confidential nature of the passenger’s information pursuant to applicable data protection laws.

Third parties

Bonju may disclose your personal information if required by law, regulation, or other legal subpoena or warrant. We may also disclose your personal information to a regulatory or law enforcement agency if we believe it to be necessary to protect the legitimate interests of Bonju, its customers or any third party.

Personal data will only be disclosed to third parties in the following cases:

  • Where Bonju is required to do so by law;
  • If Bonju needs to share data with its payment processors to facilitate payment transactions in accordance with their privacy policies;
  • To comply with Bonju’s legal duties and responsibilities owed under applicable legislation in Malta;
  • When Bonju feels that disclosure is necessary to protect Bonju’s or the passenger’s safety, or the safety of others including drivers, investigate fraud, or respond to a government request;
  • If Bonju is involved in a merger, acquisition, or sale of all or a portion of its assets, the passenger will be notified via email and/or a prominent notice on www.bonju.com.mt ;
  • If Bonju’s marketing service providers require the data to carry out their tasks;
  • If you link, connect, or login to your Bonju Account with a third party service (e.g. Google, Facebook), the third party service may send us information such as your registration and profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
  • Any personal data collected in the course of providing the services is transferred to and stored in the data centres of BRND WGN. and/or Amazon Web Services, Inc., which are located in the territories of a Member States of the European Union. Only authorised employees of Bonju group companies and partners have access to the personal data and they may access the data only for the purpose of resolving issues associated with the use of the services (including disputes regarding transportation services).
  • For research and scientific purposes, the data is used in unidentified form (anonymized).
  • To any other third party with the passenger’s prior consent to do so.

We use third-party data processors to process limited personal data on our behalf. Such service providers support Bonju, especially relating to hosting and operating the websites, marketing, analytics, improving the websites, and sending email newsletters. These processors are located outside the European Economic Area. Bonju shall ensure that the transfer of the Personal Data to the recipient is compliant with Applicable Data Protection Legislation and that the same obligations are imposed on the processor as is imposed on Bonju under the respective Services Agreement.

Our content may link to third party websites to provide relevant references. We are not responsible for such external content, which may contain separate privacy policies and data processing disclosures.

Direct Marketing

An email address collected for purposes of communication or promotion, will be used to contact you and also to send you promotional emails. You may revoke your consent to receive emails for promotional purposes any time, by clicking on an unsubscribe link or updating your account preferences on our website and the Bonju app.

Further, with your consent, we may make use of email tracking technology to obtain data on if you open an email or if you click on links in an email. This data will be used only to help improve future marketing messaging including prioritizing follow-ups based on perceived communications relevance. Without your consent, we will not make use of personal data unique to you, such as your IP address, your device and browser information, or the time and number of times you open an email or click on a link.

Data Retention

Passenger personal data will be stored as long as the passenger account is active. If your account is disabled, personal data will be deleted from the Bonju systems, unless such data is required to be retained for accounting, dispute resolution or fraud prevention purposes.

  • Financial data regarding transportation services provided to passengers will be stored for 3 years after the last journey.
  • Data required for accounting purposes will be stored for 7 years [after the last journey].
  • In the event that there are suspicions of a criminal offence, fraud or false information having been provided, the data will be stored for 10 years
  • In case of payment disputes, data will be retained until the claim is satisfied or the expiry date of such claims.
  • Journey history data will be stored for 3 years, after which the data will be anonymized.
  • Please note that the deinstallation of Bonju app in your device does not cause the deletion of your personal data.
  • If the Bonju app has not been used for 3 years, we will notify you and ask you to confirmwhether account is still active. If no reply is received, the account will be closed and personal data will be deleted unless such data is required to be stored for accounting, dispute resolution or fraud prevention purposes.

Technical and Organizational Data Protection

Bonju implements feasible technical and organizational measures to protect your personal data against abuse and loss. We store such data in secure environments that undergo regular inspections and audits as per international security standards in the European Union. We provide training to our employees on data protection best practices and require them to enter into a confidentiality agreement.

While we use all reasonable efforts to protect your personal information, we cannot guarantee the absolute security of your data submitted through our websites.

Rights and Contact Info

You may request for information on what personal data we store in relation to you. Should your personal data be incorrect, you may have the data rectified. You may object to the processing of your personal data for direct marketing purposes, and to withdraw consent. You may request for an export of your data or transfer to another controller. You may lodge a complaint to a supervisory authority as per Article 77 of the GDPR, in particular in the Member State of your habitual residence, place of work or place of an alleged infringement.

Please feel free to direct such requests, or other questions and comments regarding this privacy notice or the privacy practices of Bonju.com.mt to our Data Protection Officer:

Data protection officer
Bonju Ltd
Email: privacy@bonju.com.mt