I. Introduction
When you use Malaga Valley THE NETWORK, you trust us with your personal data. We’re committed to keeping that trust. That starts with helping you understand our privacy practices. This notice describes the personal data (“data”) we collect, how it’s used and shared, and your choices regarding this data. We recommend that you read this along with our privacy overview, which highlights key points about our privacy practices.

II. Overview
A. Scope
This notice applies to users of Malaga Valley THE NETWORK’s services anywhere in the world, including users of Malaga Valley THE NETWORK’s apps, websites, features, or other services. This notice describes how Malaga Valley THE NETWORK and its affiliates collect and use data. This notice applies to all Malaga Valley THE NETWORK users globally. This notice also governs Malaga Valley THE NETWORK’s other collections of data in connection with its services. For example, we may collect the contact information of
owners or employees of Service Providers or other merchants on the platforms; the contact information of individuals that manage and use accounts owned by Enterprise Customers; or data of individuals who start but do not complete their applications to be drivers or delivery persons. All those subject to this notice is referred to as “users” in this notice. Our privacy practices are subject to applicable laws in the places in which we operate. This means that we engage in the practices described in this notice in a particular country or region only if permitted under the laws of those places.

B. Data controller and transfer
Malaga Valley THE NETWORK S.L. ́s external Technology Partner FUTURE STACKS
No.73, Jawahar St, Karaikudi – 630001, GST: 33AAFFF0952R1Z5 | CONTACT@DEVFOOD.COM | WWW.DEVFOOD.COM is the data controllers for the data collected in connection with use of Malaga Valley THE NETWORKs services in the European Economic Area. Malaga Valley THE NETWORK operates, and processes personal data, globally; wherever and whenever you travel, your data travels with you so we can offer you a seamless experience.

We also respect your data protection rights whether you are in your home country or elsewhere. This means that we may transfer personal data to countries other than your home country in order to provide our services in a different country at your request. We may also transfer personal data to another country if that is necessary to respond to a customer support request that you submitted outside your region. And trip/order histories may be accessed by users in another country after they have left the country where services were rendered. Because our services involve multiple users at the same time, limited personal data may be accessible to the other user in another country.

We do so in order to fulfil our agreements with all of our users, or based on users’ instructions or prior consent, adequacy decisions for the relevant countries, or other transfer mechanisms as may be available under applicable law, such as the Standard Contractual Clauses.

We may also transfer data to other countries in order to respond to a request for personal data from a law enforcement agency. To provide additional safeguards to these data transfers, Malaga Valley THE NETWORK applies a robust internal procedure for
processing these requests. Malaga Valley THE NETWORK only discloses personal data to law enforcement agencies in a manner that is consistent with the regulatory requirements of applicable laws, such as the GDPR.

To help provide equivalent data protection wherever you use our services, Malaga Valley THE NETWORK has implemented the following measures across the globe:

• policies and procedures to limit access to, and the processing of personal data for defined purposes.
• specific training of personnel responsible for managing personal data;
• a government data access policy that refuses government access to data, except when disclosure is mandated by applicable laws including the EU GDPR, there is imminent risk of serious harm to individuals, or consent is obtained;
• robust protection of data while it is in transit between Malaga Valley THE NETWORK apps and our servers, and when the data is processed on our servers.

This includes encryption and the use of pseudonymized data to help protect users' full identity against unauthorized disclosure.
For your convenience, the exercise of your data protection rights can be directed to Malaga Valley THE NETWORK via any of the designated channels mentioned above and will be handled centrally on behalf of the relevant controller. Questions, comments, and complaints about Malaga Valley THE NETWORK’s data practices can be submitted via office@malagavalley-thenetwork.com. You may also use this address to submit a question to Malaga Valley THE NETWORK’s Data Protection Officer and to ask us for a
copy of the Standard Contractual Clauses or other transfer mechanisms in place for the data processing activity of your inquiry.

III. Data collections and uses
A. The data we collect
Malaga Valley THE NETWORK collects data:

• provided by users to Malaga Valley THE NETWORK, such as during account creation
• created during use of our services, such as location, app usage, and device data
• from other sources, such as other users or account owners, business partners, vendors, insurance and financial solution providers, and governmental authorities Malaga Valley THE NETWORK collects the following data:

1. Data provided by users. This includes:

• User profile information: We collect data when users create or update their Malaga Valley THE NETWORK accounts, or place orders via guest checkout features. This may include their name, email, phone number, login name and password, address, profile picture, payment or banking information (including related payment verification information), driver’s license and other government issued documents (which may include identification numbers as well as birth date, gender, and photo). This also includes vehicle or insurance information of drivers and delivery persons, emergency contact information, user settings, and
evidence of health or fitness to provide services using Malaga Valley THE NETWORK apps.

• Background check information (Service Providers): This includes information submitted during the delivery person application process, such as driver history or criminal record (where permitted by law), license status, known aliases, prior addresses, and right to work. This information may be collected by an authorized vendor on Malaga Valley THE NETWORK’s behalf.

• Identity verification photos: This includes photos of users (such as, selfies) and/or their government issued identifications (such as, driver’s license or passports). Such photos may be used to verify a user’s identity, such as through facial verification technologies. Please see the section titled “How we use personal data” for more information regarding how user photos are used for safety and security purposes, including identity verification.

• Demographic data: We may collect demographic data about users, such as birth date/age, gender or occupation, when required for certain Malaga Valley THE NETWORK services or programs. We may also infer demographic data from other data collected from users. For example, we may infer a user’s gender based on their first name to enable safety features or to display personalized ads for third party products or services. See the section titled “How we use personal data” below for more information. We may also collect demographic data through user surveys.

• User content: We collect the data submitted by users when they contact Malaga Valley THE NETWORK customer support, provide ratings or feedback for other users, Service Providers or merchants, or otherwise contact Malaga Valley THE NETWORK. This may include photographs, or audio or video recordings submitted by users in connection with a customer support request. This also
includes metadata relating to the method you use to communicate with Malaga Valley THE NETWORK. The contents of photos and recordings submitted by users are subject to Malaga Valley THE NETWORK’s Community Guidelines. In certain jurisdictions, users can record the audio and/or video of their trips through an in-app feature or using a dashcam. In app recordings are encrypted
and stored on users’ devices and are only shared with Malaga Valley THE NETWORK if submitted by the users in connection with safety incidents.

2. Data created during use of our services. This includes:

• Location data: We collect precise or approximate location data from drivers’ and delivery persons’ mobile devices when the Malaga Valley THE NETWORK app is running in the foreground (app open and on-screen) or background (app open
but not on-screen).

• Location data: We collect precise or approximate location information from riders’ and order recipients’ mobile devices if they enable us to do so via their device settings. Malaga Valley THE NETWORK collects such data from the time a ride or order is
requested until it is finished, and any time the app is running in the foreground (app open and on-screen). See “Choice and transparency” below for information on how riders and order recipients can enable precise location data collection.
Riders and order recipients may use the Malaga Valley THE NETWORK apps without enabling collection of location data from their mobile devices. However, this may affect certain features in the Malaga Valley THE NETWORK apps. For example, a rider who has not enabled precise location data will have to manually enter their pickup address. In addition, precise location data collected from a driver’s device during a trip is linked to the rider’s account, even if the rider has not enabled precise location data to be collected from their device. This data is used for purposes such as receipt generation, customer support, fraud detection, insurance, and litigation.

• Transaction information: We collect transaction information related to the use of our services, including the type of services requested or provided; trip or order details (such as date and time, requested pick-up and drop off addresses, distance travelled and items ordered); and payment transaction information (such as a restaurant’s or merchant's name and location, amount charged, and payment method). We also associate a user’s name with that of anyone who uses their promotion code.

• Usage data: We collect data about how users interact with our services. This includes access dates and times, app features or pages viewed, browser type, and app crashes and other system activity.

• Device data: We collect data about the devices used to access our services, including the hardware models, device IP address or other unique device identifiers, operating systems and versions, software, preferred languages, advertising identifiers, device motion data, and mobile network data.

• Communications data: We collect data regarding phone, text or in-app communications between users that are enabled through Malaga Valley THE NETWORK’s apps. This includes date and time, as well as the content of text or in-app messages. We may also collect the content of phone calls solely where users are notified in advance that the call may be recorded.

3. Data from other sources. These include:
• users participating in our referral programs. For example, when a user refers another person, we receive the referred person’s data from that user.

• Malaga Valley THE NETWORK account owners who request services for or on behalf of other users (such as friends or family members), or who enable other users to request or receive services through their business accounts.

• users or others providing information in connection with claims or disputes.

• Malaga Valley THE NETWORK business partners through which users create or access their Malaga Valley THE NETWORK account, such as payment providers, social media services, or apps or websites that use Malaga Valley THE NETWORK’s APIs or whose APIs Malaga Valley THE NETWORK uses.

• Malaga Valley THE NETWORK business partners in connection with debit or credit cards issued by a financial institution in partnership with Malaga Valley THE NETWORK to the extent disclosed in the terms and conditions for the card.

• vendors who help us verify users’ identity, background information, and eligibility to work, or who screen users in connection with sanctions, anti-money laundering, or know-your-customer requirements.

• insurance, vehicle, or financial services providers for drivers and/or delivery persons.

• partner transportation companies (for drivers or delivery persons who use our services through an account associated with such a company).
• publicly available sources.
• marketing service providers or data resellers whose data Malaga Valley THE
NETWORK uses for marketing or research.
• law enforcement officials, public health officials, and other
government authorities.

B. How we use personal data
Malaga Valley THE NETWORK uses data to enable reliable and convenient transportation, delivery, and other products and services. We also use such data:
• to enhance the safety and security of our users and services
• for customer support
• for research and development
• to enable communications between users
• for marketing and advertising
• to send non-marketing communications to users
• in connection with legal proceedings

We use the data we collect:
1. To provide our services. Malaga Valley THE NETWORK uses data to provide, personalize, maintain, and improve our services.
This includes using data to:
• create/update accounts.
• enable transportation, delivery and other services/features, such as:

o using location data to navigate, calculate ETAs, and track the progress deliveries.

o features that involve data sharing, such as sharing driver first name and vehicle information with riders to facilitate pick-ups, user profile and trip details for ETA sharing and fare splitting, and user ratings and compliments.

o match available drivers and delivery persons to users requesting services. Users can be matched based on availability, location/proximity, user settings/preferences and other factors such as likelihood to accept a trip based on their past behaviour or preferences.

• enable dynamic pricing, in which the price, or the delivery fee for Malaga Valley THE NETWORK orders, is determined based on factors such as estimated time and distance, predicted route, estimated traffic, and the current number of users requesting or providing services.
• process payments.
• personalize users’ accounts. For example, we may present a Malaga Valley THE NETWORK user with personalized restaurant or food recommendations based on their prior orders.
• facilitate insurance, vehicle, invoicing, or financing solutions.
• provide users with trip or delivery updates, generate receipts, and inform them of changes to our terms, services, or policies.
• perform necessary operations to maintain our services, including to troubleshoot software bugs and operational problems.
Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, are compatible with such uses, or on the grounds that they are necessary for purposes of Malaga Valley THE NETWORK’s and its users’ legitimate interests.

2. Safety and security. We use data to help maintain the safety, security, and integrity of our services and users. This includes:
• verifying users' identity and eligibility to provide transportation or deliveries, including through reviews of background checks, to help prevent use of our services by unsafe drivers and/or riders. In certain regions, this includes Malaga Valley THE NETWORK’s Real-Time ID Check feature, which prompts drivers and delivery persons to share a selfie before going online to help ensure that the driver or delivery person using the app matches the Malaga Valley THE NETWORK account we have on file. We may also use this feature for other verification purposes such as verifying change of bank account information or regaining account access.
In addition, we may use facial recognition technology to process user profile photographs, identification photographs, or other user-submitted photographs to prevent identity-borrowing or use of our services by unauthorized drivers or delivery people.
We may also use selfies to verify that users are wearing masks, helmets or other safety gear through the use of object verification technology. Similarly, order recipients may be required to provide their age and an image of their government issued identification to verify their eligibility to order and receive alcohol deliveries. Please see here for more information about order recipient identity verification.

• using data from drivers’ or delivery persons’ devices to detect unsafe driving behaviour such as speeding or harsh braking and acceleration, and to inform them of safer driving practices. We also use data from delivery persons’ devices to verify the type of vehicles they used to provide deliveries.

• using driver location information, and communications between riders and drivers, to identify cancellation fees earned or induced through fraud. For example, if we determine that a driver is delaying a rider pickup in order to induce a cancellation, we will not charge the rider a cancellation fee and will adjust the amounts paid to the driver to omit such a fee. To object to such an
adjustment, please contact Malaga Valley THE NETWORK customer support under office@malagavalley-thenetwork.com.

• using device, location, user profile, usage, and other data to prevent, detect, and combat other types of fraud. This includes identifying fraudulent accounts or uses of our services, preventing use of our services by unauthorized drivers or delivery persons, verifying user identities in connection with certain payment methods, and preventing and combating unauthorized access to users’ accounts.

In some cases, such as when a user is determined to be abusing Malaga Valley THE NETWORK’s referral program or has submitted fraudulent documents, such behaviour may result in automatic deactivation, or in the European Union or where otherwise required by law, deactivation after human review. To object to such a deactivation, please contact Malaga Valley THE NETWORK
customer support under office@malagavalley-thenetwork.com

• using user ratings, reported incidents, and other feedback to encourage compliance with our Community Guidelines and as grounds for deactivating users with low ratings or who otherwise violated such guidelines in certain countries. In the European Union or where otherwise required by law, such deactivation occurs only after human review and/or the possibility to appeal.

• using driver data (such as location, ratings and gender where legally permitted) and rider data (such as ratings, origin and destination) to predict and help avoid pairings of users that may result in increased risk of conflict (for instance, because one user previously gave the other a one-star rating).

• sharing user name, location, phone number, vehicle details and other relevant information with third-party companies that support the management and de-escalation of interpersonal conflicts that may occur between users while on a trip or in the process of making a delivery.

Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, and/or for purposes of the legitimate safety and security interests of Malaga Valley THE NETWORK, our users and members of the general public.

3. Customer support. Malaga Valley THE NETWORK uses the information we collect (which may include call recordings) to provide customer support, including to investigate and address user concerns and to monitor and improve our customer support responses and processes. Malaga Valley THE NETWORK performs the above activities on the grounds that they are
necessary to fulfil the terms of our agreements with users or for purposes of Malaga Valley THE NETWORK’s legitimate interest in monitoring and improving its customer support services.

4. Research and development. We use data for testing, research, analysis, product development, and machine learning to improve the user experience. This helps us make our services more convenient and easy-to-use, enhance the safety and security of our
services, and develop new services and features. Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary for purposes of Malaga Valley THE NETWORK’s legitimate interests in improving and developing new services and features.

5. Enabling communications between users. For example, a driver may message or call a rider to confirm a pick-up location, a rider may call a driver to retrieve a lost item, or a restaurant or delivery person may contact an order recipient with information about
their order. Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users.

6. Marketing and Advertising. Malaga Valley THE NETWORK uses data (other than Guest Users’ data) to market its services, and those of Malaga Valley THE NETWORK partners. This may include:

• Sending emails, text messages, push notification, and in-app messages or other communications marketing or advertising Malaga Valley THE NETWORK products, services, features, offers, promotions, sweepstakes, news and events. This may include using location, trip and order history, and usage data to send marketing communications that are personalized based on users’ observed or inferred interests and characteristics. For example, we may send push notifications suggesting a user’s favourite destinations or merchants, or in-app messages offering discounts or promo for products or merchants similar to those a user has previously ordered.

• Displaying Malaga Valley THE NETWORK advertising on third party apps or websites. This includes using location, trip and order history, and usage data, and sharing hashed email addresses and device or user identifiers with advertising partners, to personalize such ads to users’ interests.

• Displaying third party advertising in Malaga Valley THE NETWORK’s apps or in connection with our services.
This includes ads for Service Providers or merchants that are available on Malaga Valley THE NETWORK . These ads (which are identified as “Sponsored Listings” in Malaga Valley THE NETWORK’s apps) include recommendations that are personalized based on users’ location and order histories. This also includes ads for other third party products or services that are personalized based on users’ observed or inferred interests and characteristics, which we determine using data such as approximate location, trip information and history, usage data, demographic data (which may include inferred gender), and device or user identifiers.

This also includes ads that are personalized based on data about the current trip or delivery request, including time of request and services requested. For example, if a user requests a trip to a supermarket, we may display in-app ads for third party products that may be available at that supermarket.

• Measuring the effectiveness of Malaga Valley THE NETWORK’s ads, and of third party ads displayed in Malaga Valley THE NETWORK’s apps or in connection with our services. Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary for purposes of Malaga Valley THE NETWORK’s legitimate interests in informing users about Malaga Valley THE NETWORK services and features or those offered by Malaga Valley THE NETWORK partners. See the sections titled “Choice and transparency” and “Marketing and advertising choices” for information on your choices regarding how Malaga Valley THE
NETWORK may use your data for marketing and advertising.

7. Non-marketing communications. Malaga Valley THE NETWORK may use data to send surveys and other communications that are not for the purpose of marketing the services or products of Malaga Valley THE NETWORK or its partners. We may also send
users communications regarding elections, ballots, referenda, and other political processes that relate to our services. For example, Malaga Valley THE NETWORK has notified some users by email of ballot measures or pending legislation relating to Malaga Valley THE NETWORK’s services in those users’ areas. Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary to fulfil the terms of our agreements with users, or for purposes of Malaga Valley THE NETWORK’s and its users’ legitimate interests in informing users about events that may have an impact on their use of Malaga Valley THE NETWORK services.

8. Legal proceedings and requirements. We use data to investigate or address claims or disputes relating to use of Malaga Valley THE NETWORK’s services, to satisfy requirements under applicable laws, regulations, or operating licenses or agreements, or pursuant to legal process or governmental request, including from law enforcement. Malaga Valley THE NETWORK performs the above activities on the grounds that they are necessary for purposes of Malaga Valley THE NETWORK’s legitimate interests in
investigating and responding to claims and disputes relating to use of Malaga Valley THE NETWORK’s services and features, and/or necessary for compliance with applicable legal requirements.

C. Cookies and third-party technologies
Malaga Valley THE NETWORK and its partners use cookies and other identification technologies on our apps, websites, emails, and online ads for purposes described in this notice, and Malaga Valley THE NETWORK’s Cookie Notice. Cookies are small text files that are stored on browsers or devices by websites, apps, online media, and advertisements. Malaga Valley THE NETWORK uses cookies and similar technologies for purposes such as:
• authenticating users
• remembering user preferences and settings
• determining the popularity of content
• delivering and measuring the effectiveness of advertising campaigns
• analyzing site traffic and trends, and generally understanding the online behaviours and interests of people who interact with our services We may also allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, SDKs, and other technologies to identify the devices used by visitors to our websites, as well as when they visit other online sites and services. Please see our Cookie Notice for more information regarding the use of cookies and other technologies described in this section.

D. Data sharing and disclosure
Some of Malaga Valley THE NETWORK’s services and features require that we share data with other users or at a user’s request. We may also share such data with our affiliates, subsidiaries, and partners, for legal reasons or in connection with claims or disputes.

Malaga Valley THE NETWORK may share data:

1. With other users

This includes sharing:
• riders’ first name, rating, and pickup and/or dropoff locations with drivers.
• riders’ first name with other riders in a carpool trip. Riders in carpool trips may also see the dropoff location of the other riders.
• order recipients’ first name, delivery address, and order information with the restaurant or merchant and, for order deliveries, with the delivery person. We may also share ratings and feedback, or other information to the extent required by law, with the restaurant or merchant and, for order deliveries, the delivery person.
• for drivers and delivery persons, we may share data with the rider(s), order recipient(s) and Service Providers or merchants, including name and photo; vehicle make, model, colour, license plate, and vehicle photo; location (before and during trip); average rating provided by users; total number of trips; period of time since they signed up to be a driver or delivery person; contact
information; and driver or delivery person profile, including compliments and other feedback submitted by past users.
We also provide riders and order recipients with receipts containing information such as a breakdown of amounts charged, driver or delivery person first name, photo, and route map. We also include other information on those receipts if required by law.
• for those who participate in Malaga Valley THE NETWORK’s referral program, we share certain data of referred users, such as trip count, with the user who referred them, to the extent relevant to determining the referral bonus.

2. At the user’s request
This includes sharing data with:
• Malaga Valley THE NETWORK business partners. For example, if a user requests a service through a partnership or promotional offering made by a third party, Malaga Valley THE NETWORK may share certain data with those third parties. This may include, for example, other services, platforms, apps, or websites that integrate with our APIs; vehicle suppliers or services; those with an API or service with which we integrate; or Service Providers, merchants or other Malaga Valley THE NETWORK business partners and their users in connection with promotions, contests, or specialized services.

• Emergency services: We offer features that enable users to share their data with police, fire, and ambulance services in the event of an emergency or after certain incidents. For more information, please see the sections below titled “Choice and Transparency” and “Emergency Data Sharing”.

3. With the general public
Questions or comments from users submitted through public forums such as Malaga Valley THE NETWORK blogs and Malaga Valley THE NETWORK social media pages may be viewable by the public, including any data included in the questions or comments
submitted by a user.

4. With the Malaga Valley THE NETWORK account owner If a user receives services through an account owned by another party, we may share their order information, including location data, with the owner of that account. This occurs, for example, when:
• a rider uses their employer’s Malaga Valley THE NETWORK for Business profile, such as when they take trips arranged through Malaga Valley THE NETWORK Central.
• a driver or delivery person uses an account owned by or associated with a Malaga Valley THE NETWORK partner transportation company or restaurant.
• a rider takes a trip or a delivery recipient receives an order arranged by a friend or under a family profile.

5. With Malaga Valley THE NETWORK subsidiaries and affiliates We share data with our subsidiaries and affiliates to help us provide our services or conduct data processing on our behalf.

6. With Malaga Valley THE NETWORK service providers and business partners
These include:
• payment processors and facilitators
• background check and identity verification providers
• cloud storage providers
• Google, in connection with the use of Google Maps in Malaga Valley THE NETWORK’s apps (see Google’s privacy policy for information on their collection and use of data)
• social media companies, including Facebook and TikTok, in connection with Malaga Valley THE NETWORK’s use of their tools in Malaga Valley THE NETWORK’s apps and websites
• marketing partners and marketing platform providers, including social media advertising services, advertising networks, third-party data providers, and other service providers to reach or better understand our users and measure advertising effectiveness
• research partners, including those performing surveys or research projects in partnership with Malaga Valley THE NETWORK or on Malaga Valley THE NETWORK’s behalf
• vendors that assist Malaga Valley THE NETWORK to enhance the safety and security of Malaga Valley THE NETWORK apps and services
• consultants, lawyers, accountants, and other professional service providers
• insurance and financing partners
• providers of bike and scooters that can be rented through Malaga Valley THE NETWORK apps
• third-party vehicle suppliers, including fleet and rental partners

7. For legal reasons or in the event of a dispute
Malaga Valley THE NETWORK may share users’ data if we believe it’s required by applicable law, regulation, operating license or agreement, legal process or governmental request, or where the disclosure is otherwise appropriate due to safety or
similar concerns.

This includes sharing data with law enforcement officials, public health officials, other government authorities, or other third parties as necessary to enforce our Terms of Service, user agreements, or other policies; to protect Malaga Valley THE NETWORK’s rights or property or the rights, safety, or property of others; or in the event of a claim or dispute relating to the use of our services. In the event of a dispute relating to use of another person’s credit card, we may be required by law to share your data, including
trip or order information, with the owner of that credit card. This also includes sharing data with others in connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

8. With consent

Malaga Valley THE NETWORK may share a user’s data other than as described in this notice if we notify the user and they consent to the sharing.

E. Data retention and deletion
Malaga Valley THE NETWORK retains user data for as long as necessary for the purposes described above, including to provide its services and comply with legal obligations. Malaga Valley THE NETWORK retains user data for as long as necessary for the purposes described above. The period for which we retain user data is determined by the type of data, the category of user to whom the data relates, and the purposes for which we collected the data.

The length for which Malaga Valley THE NETWORK retains user data may further be determined by legal and regulatory requirements, purposes of safety, security, and fraud prevention, or by issues relating to the user’s account such as an outstanding credit or an unresolved claim or dispute.

For example, we retain data:
• for the life of users’ accounts if such data is necessary to provide our services. E.g., user profile information and credentials.
• for 7 years if necessary to comply with tax requirements. E.g., drivers’ and delivery persons’ trip or delivery location information.
• for defined periods as necessary for purposes of safety or fraud prevention. E.g., we retain incomplete driver applications for 1 year, and rejected driver applications for 7 years.
• after requests for account deletion if necessary for purposes of safety, security, fraud prevention or compliance with legal requirements, or because of issues relating to the user’s account (such as an outstanding credit or an unresolved
claim or dispute). Users may request deletion of their accounts at any time. Malaga Valley THE NETWORK may retain user data after a deletion request due to legal or regulatory requirements or for reasons stated in this policy. Following an account deletion request, Malaga Valley THE NETWORK deletes the user’s account and data, unless they must be retained due to legal or regulatory requirements, for purposes of safety, security, and fraud prevention, or because of an issue relating to the user’s account such as an outstanding credit or an unresolved claim or dispute. Because we are subject to legal and regulatory requirements relating to drivers and delivery persons, this generally means that we retain their account and data for the applicable statutory retention period after a deletion request. For riders and order recipients, their data is generally deleted within 90 days of a deletion request, except where retention is necessary for the above reasons.

IV. Choice and transparency
Malaga Valley THE NETWORK enables users to access and/or control data that Malaga Valley THE NETWORK collects, including through:
• privacy settings
• device permissions
• in-app ratings pages
• marketing choices
Malaga Valley THE NETWORK also enables users to request access to or copies of their data, make changes or updates to their accounts, request deletion of their accounts, or request that Malaga Valley THE NETWORK restrict its processing of user data.

A. Privacy settings
The Settings > Privacy menu in the Malaga Valley THE NETWORK app allows riders and order recipients to set or update their preferences regarding location data collection and sharing, emergency data sharing, and notifications.
• Location data collection (Service Providers & Clients)
Riders and order recipients can enable/disable Malaga Valley THE NETWORK to collect location data from their mobile devices through their device settings, which can be accessed via the Settings > Privacy > Location menu.
• Share Live Location (Riders)
Riders can enable/disable Malaga Valley THE NETWORK to share their real-time location data from their mobile devices with their drivers through their device settings, which can be accessed via the Settings > Privacy > Location menu.
• Emergency Data Sharing
Riders may enable Malaga Valley THE NETWORK to share real-time location data from their mobile devices with emergency police, fire, and ambulance services. Such data may include approximate location at the time the emergency call was placed; the car’s make, model, colour, and license plate information; the rider’s name and phone number; pickup and dropoff locations; and the driver’s name. Riders may enable/disable this feature via the Settings > Privacy > Location menu, or the Safety Center.
Drivers and delivery persons can also enable/disable Emergency Data Sharing via the App settings > Emergency Data Sharing menu, or the Safety Toolkit.

• Notifications: account and trip updates
Malaga Valley THE NETWORK provides users with trip status notifications and updates related to activity on their account. These notifications are a necessary part of using the Malaga Valley THE NETWORK app and cannot be disabled. However, users may choose the method by which they receive these notifications through the Settings > Privacy menu.

• Notifications: discounts and news

Users may enable Malaga Valley THE NETWORK to send push notifications about discounts and news from Malaga Valley THE NETWORK. Push notifications may be enabled or disabled through the Settings > Privacy menus in the Malaga Valley
THE NETWORK app.

• Communications from Service Providers and merchants

While placing an order in the Malaga Valley THE NETWORK app, users may opt- in to share their contact details with certain Service Providers or merchants in order to receive communications from them. Those who opt-in may choose to cease receiving such communications through the Settings > Account > Data Sharing menus in the Malaga Valley THE NETWORK app.

B. Device permissions
Most mobile device platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without the device owner’s permission, and these platforms have different methods for how that permission can be obtained. Please
check the available settings on your device or check with your provider.

C. In-app ratings pages
After every order Service Providers & Clients are able to rate each other on a scale from 1 to 5. An average of those ratings is associated with a user’s account and is displayed to other users for whom they provide or receive services. For example, rider ratings are available to drivers from whom they request transportation, and driver ratings are available to their riders.

This 2-way system holds everyone accountable for their behaviour. Accountability helps create a respectful, safe environment for drivers and riders. Riders can see their average rating in the main menu of the Malaga Valley THE NETWORK app.
Drivers can see their average rating after tapping their profile photo in the Malaga Valley THE NETWORK Driver app.

Delivery persons may also be rated by order recipients, Service Providers and merchants.

D. Marketing and advertising choices
Malaga Valley THE NETWORK provides users with the following choices regarding how their data is used for purposes of marketing and advertising:

• Personalized marketing communications from Malaga Valley THE NETWORK: Users may choose whether Malaga Valley THE NETWORK may use their data to send personalized communications (such as, emails, push notifications, and in-app messages) about Malaga Valley THE NETWORK products and services. Users may also choose whether to receive any marketing emails or
push notifications from Malaga Valley THE NETWORK.

• Malaga Valley THE NETWORK ads: Users may choose whether their data is used and shared with advertising partners to deliver personalized ads about Malaga Valley THE NETWORK products and services on third party apps and websites, or
to measure the effectiveness of such ads.

• Restaurant and merchant ads: Users may choose whether Malaga Valley THE NETWORK may use their order and search history to display personalized ads for Service Providers or merchants that are available on Malaga Valley THE NETWORK.

• Third party ads: Users may choose whether Malaga Valley THE NETWORK may use their data to display ads for third party products or services that are personalized based on users’ observed or inferred interests and characteristics.

• Cookies and related technologies: For information on how to control Malaga Valley THE NETWORK’s use of cookies and related technologies, including for purposes of displaying personalized ads, please see our Cookie Notice.

E. User data requests

Malaga Valley THE NETWORK provides users with a variety of ways to learn about, control, and submit questions and comments about Malaga Valley THE NETWORK’s handling of their data.

• Accessing data: Users can access data including their profile data and trip or order history through the Malaga Valley THE NETWORK apps or via Malaga Valley THE NETWORK’s website. Users can also request access to their data via
office@malagavalley-thenetwork.com.

• Data portability: Users can also request access to their data via office@malagavalley-thenetwork.com.

• Changing or updating data: Users can edit the name, phone number, email address, payment method, and photo associated with their account through the Settings menu in Malaga Valley THE NETWORK’s apps or driver portal.

• Deleting data: Users may request deletion of their account at any time through Malaga Valley THE NETWORK’s Privacy Center, or in the Settings > Privacy menus in the Malaga Valley THE NETWORK app.

• Objections, restrictions, and complaints: Users may request that we stop using all or some of their data, or that we limit our use of their data. This includes objecting to our use of data that is based on Malaga Valley THE NETWORK’s legitimate interests. Malaga Valley THE NETWORK may continue to process data after such objection or request to the extent required or permitted by law.
In addition, depending on their location, Users may have the right to file a complaint relating to Malaga Valley THE NETWORK’s handling of their data with the data protection authority in their country. For example, users in the European Union may submit such requests to the data protection authorities in the country in which they live.

V. Updates to this notice
We may occasionally update this notice. We may occasionally update this notice. If we make significant changes, we will notify
users in advance of the changes through the Malaga Valley THE NETWORK apps or through other means, such as email. We encourage users to periodically review this notice for the latest information on our privacy practices. Use of our services after an update constitutes consent to the updated notice to the extent permitted by law.