Tugu Breakdown Recovery Privacy Policy
Effective Date: 01/01/2025
1. Introduction
This Privacy Policy is provided by Tugu Assist Ltd (Company Number 16266784) with registered office at 7 Wrose Brow Road, Shipley BD18 2NT.
and trading as Tugu (‘we’, ‘our’ or ‘us’) for use of our products and services including our website and driver and passenger Apps (Services).
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on how and why we collect, store, use and share any information relating to you (your personal data).
It also explains your rights in relation to your personal data and how to contact us or the relevant regulator in the event you have a complaint. Our collection, storage, use and sharing of your personal data is regulated by law, including under the UK General Data Protection Regulation (UK GDPR).
We are the controller of personal data obtained via the Services, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
2. What this policy applies to
This privacy policy relates to your use of the Services only.
The Services may link to or rely on other apps, websites, APIs or services owned and operated by us or by certain trusted third parties to enable us to provide you with Services. These other apps, websites, APIs or services may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to these other apps, websites, or services, please consult their privacy policies as appropriate. For more information see the section ‘Who we share your personal data with’ below.
3. Personal data we collect about you
The personal data we collect about you depends on the particular activities carried out through the Services. We will collect and use the following personal data about you:
Identity and account data you input into the Service
- Name
- Address
- Email Address
- Phone Number
- Licence and Vehicle details
- Gender
- Profile Image
- Your account details, such as username and password
Phone Number: - To log in or register phone number is required.
- Phone Number: To send you the OTP we use the phone number.
- To provide and maintain our services.
- Email: To notify you about changes to our services.
- To allow you to participate in interactive features of our services.
- Email: To provide customer support.
- Email: To gather analysis or valuable information to improve our services.
Identity and account data you input into the Services
Registration is mandatory in order to use the Services. - When you grant permission to access your contacts, we may collect the following information:
- Name and phone number. Purpose and Usage of Collection:
- We have SOS feature in our app, and we give user option to pick 3 contacts from contacts list. Then user can send SOS request to these contacts in case of emergency.
Data Security: - We take appropriate measures to protect your contacts’ information from unauthorized access, alteration, disclosure, or destruction. We implement industry-standard security practices and regularly update our systems to safeguard your data.
Gender: To monitor the usage of our services. To detect, prevent, and address technical issues. - Profile Image: To show users an image on their profile that other users can identify.
- Name: To show the name on the profile as well as on the user can identify other users.
Users image
We collect and use images you provide for the following purposes: - Profile Picture:
- We collect and display the profile picture you upload within the App for user identification and enhanced user experience.
- Document Verification:
- In certain cases, we may require you to submit images of documents for verification purposes. We use these images solely for verifying your identity or fulfilling legal/regulatory requirements.
- We take reasonable measures to protect your images from unauthorized access, alteration, or destruction.
- The App is not intended for individuals under 18. We do not knowingly collect information from children under 18.)
Data collected when you use specific functions in the Services
Data you store online with us using the Services including your usage history or preferences (while such data may not always be personal data as defined at law in all cases, we will assume it is and treat it in accordance with this policy as if it were)
Data collected when you permit the collection of location data
Details of your location with a high degree of precision, see the section ‘Location services/data’ below data concerning location is collected when using the Maps function of the Services
Other data the Services collects automatically when you use it
Your activities on, and use of, the Services which reveal your preferences, interests or manner of use of the Services and the times of use, device operating system, time zone settings
If you do not provide personal data we ask for where it is required, including the geo-localisation services, it may prevent us from providing services and/or the Services to you.
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
4. Location services/data
We use location services to precisely identify your location in order to enable us to identify recovery vehicles in close proximity to a customer’s location and in order to enable drivers and customers to locate each other in respect of a recovery to be completed.
If you do not provide your consent, you may use the Services but that will mean the “maps” feature on the Services will not be available. To withdraw your consent at any time you can turn off the localisation permissions for our app on your device.
The location services in the Services will not operate unless location services/data are generally enabled on your device. You may disable such functionality at any time by turning your device’s location on “off” using the device’s settings app. When you allow your device to use location services/data, data will also be collected by Google in accordance with their Privacy Policy, as this is the map service we integrate to our app.
We exert no control over Google’s Privacy Policy, and we therefore recommend that you consult their privacy policy for further information on how Google protect personal data please visit their site – https://policies.google.com/privacy?hl=en-US. For more information see the section ‘Who we share your personal data with’ below.
5. How your personal data is collected
We collect personal data from you directly when you sign up to the Services, contact us directly or reach out to us via social media, make submissions via the Services when a forum element is available, or indirectly, such as your activity while using the Services.
At this point in time, we do not collect any personal information about you using cookies or similar technologies. In the event that this were to change and if we were to decide to collect personal data about you using cookies, you would be notified of this change by means of in-app notification, with detailed information regarding our use of cookies and similar technologies to be made available in the relevant cookies policy.
6. How and why, we use your personal data
Under data protection law, we can only use your personal data if we have a proper reason, e.g.: - where you have given consent
- to comply with our legal and regulatory obligations
- to deliver our services and make the functionality of our app available to you at your request or to take steps at your request, or
- for our legitimate interests or those of a third party
- A legitimate interest is when we have a business or commercial reason to use your information, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
Create and manage your account with us
To perform our contract with you or to take steps at your request before entering into a contract
Providing services and/or the functionalities of the Services to you
Depending on the circumstances: - To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
- The Maps Function will use data relating to your location only based on your consent as described in ‘Location services/data’ (above)
To enforce legal rights or defend or undertake legal proceedings
Depending on the circumstances: - To comply with our legal and regulatory obligations
- In other cases, for our legitimate interests or those of a third party, i.e. to protect our business, interests and rights or those of other
Communications with you not related to marketing, including about changes to our terms or policies or changes to the Services or service or other important notices
Depending on the circumstances: - To comply with our legal and regulatory obligations
- In other cases, for our legitimate interests or those of a third party, i.e., to provide the best service to you
Protect the security of systems and data
To comply with our legal and regulatory obligations we may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests or those of a third party, i.e., to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us
Operational reasons, such as improving efficiency, training, and quality control or to provide support to you
For our legitimate interests or those of a third party, i.e., to be as efficient as we can so we can deliver the best service to you
Statistical analysis to help us manage our business, e.g., in relation to our performance, customer base, app and functionalities and offerings or other efficiency measures
For our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service to you and improve and develop our app
Updating and enhancing user records
Depending on the circumstances: - To perform our contract with you or to take steps at your request before entering into a contract (in this case, the contract means the Terms and Conditions of Use which apply to the Services)
- To comply with our legal and regulatory obligations
- Where neither of the above apply, for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about their accounts and new products or functionalities related to the Services and our services
7. Who we share your personal data with
We routinely share personal data with service providers we use to help us run our business or provide the services or functionalities in the Services, including developers, cloud storage providers and Google, Inc. for Google Maps location functionality. We exert no control over their Privacy Policies, and we therefore recommend that you consult their privacy policy for further information on how they protect personal data.
We only allow service providers to handle your personal data if we are satisfied that they take appropriate measures to protect your personal data. We also impose contractual obligations on service providers to ensure they can only use your personal data to provide services to us and to you.
We or the third parties mentioned above may occasionally also need to share your personal data with: - external auditors, e.g., in relation to the audit of our accounts and our company —the recipient of the information will be bound by confidentiality obligations
- professional advisors (such as lawyers and other advisors)—the recipient of the information will be bound by confidentiality obligations
- law enforcement agencies, courts or tribunals and regulatory bodies to comply with legal and regulatory obligations
- other parties in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency—usually, information will be anonymised, but this may not always be possible, however, the recipient of the information will be bound by confidentiality obligations
If you would like more information about who we share our data with and why, please contact us (see ‘How to contact us’ below).
We will not share your personal data with any other third party.
8. How long your personal data will be kept
We will keep your personal data for as long as you have an active account with us and for a period of up to 6 years thereafter to comply with any accounting or legal obligations including in the event of the pursuit or defence of legal claims. Once you have closed your account with us, we will move your personal data to a separate database so that only key stakeholders in our business on a ‘need to know basis have access to such data.
Following the end of the of the aforementioned retention period, we will delete or anonymise your personal data
9. Transferring your personal data out of the UK
At this point in time, we do not transfer your personal data outside of the UK. If this changes, we would comply with applicable UK laws designed to ensure the continued protection and privacy of your personal data. Any updated destinations to which we send your personal data, would be indicated in the present section and notified to you in accordance with the section on ‘Change to this privacy policy’ below.|
Furthermore, under UK data protection laws, we can only transfer your personal data to a country outside the UK where: the UK government has decided the particular country ensures an adequate level of protection of personal data (known as an ‘adequacy regulation’) further to Article 45 of the UK GDPR; there are appropriate safeguards in place, together with enforceable rights and effective legal remedies for you; or a specific exception applies under relevant data protection law. Accordingly, if we were to start transferring your personal data from the UK to: - The EEA: we would rely on the adequacy finding granted by the UK to the EU under the Withdrawal Agreement to do; for any transfers from the EU to the UK, we would rely on the adequacy regulation granted to the UK under the Adequacy Decision.
- Any country located outside the UK/EEA: we would rely on an appropriate safeguard under the UK GDPR, such as by including the relevant Standard Contractual Clauses in our data processing agreements
In the event we could not or choose not to continue to rely on either of those mechanisms at any time we would not transfer your personal data outside the UK unless we could do so based on an alternative mechanism or exception provided by UK data protection law.
10. Your rights - You generally have the following rights, which you can usually exercise free of charge. For more information regarding these rights, please visit the ICO website here.
Access to a copy of your personal data
The right to be provided with a copy of your personal data.
Correction (also known as rectification)
The right to require us to correct any mistakes in your personal data.
Erasure (also known as the right to be forgotten)
The right to require us to delete your personal data—in certain situations.
Restriction of use
The right to require us to restrict use of your personal data in certain circumstances, e.g., if you contest the accuracy of the data.
Data portability
The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations.
To object to use
The right to object:
· at any time to your personal data being used for direct marketing (including profiling)
· in certain other situations to our continued use of your personal data, e.g., where we use your personal data for our legitimate interests.
Not to be subject to decisions without human involvement
The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you
We do not make any such decisions based on data collected by the Services.
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below). You may also find it helpful to refer to the guidance from the UK’s Information Commissioner on your rights under the UK GDPR. - If you would like to exercise any of those rights, please complete a request form—available on our website at [insert link] or email, call or write to us—see below: ‘Tugu Assist LTD’. When contacting us please:
- provide enough information to identify yourself (e.g., your full name and username) and any additional identity information we may reasonably request from you, and
- let us know which right(s) you want to exercise and the information to which your request relates
11. Keeping your personal data secure
We have appropriate security measures to prevent personal data from being accidentally lost or used or accessed unlawfully. We limit access to your personal data to those who have a genuine business need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
If you want detailed information from, Get Safe Online on how to protect your information and your computers and devices against fraud, identity theft, viruses and many other online problems, please visit www.getsafeonline.org. Get Safe Online is supported by HM Government and leading businesses.
12. How to complain
Please contact us if you have any queries or concerns about our use of your information (see below ‘How to contact us’). We hope we will be able to resolve any issues you may have.
You also have the right to lodge a complaint with the Information Commissioner.
The Information Commissioner can be contacted at https://ico.org.uk/make-a-complaint or telephone: 0303 123 1113.
13. Changes to this privacy policy - We may change this privacy policy from time to time. When we make significant changes, we will take steps to inform you, for example via the Services or by other means, such as email.
14. How to contact us
You can contact us by post, email or telephone if you have any questions about this privacy policy or the information we hold about you, to exercise a right under data protection law or to make a complaint.
Our contact details are shown below:
Contact Information
For privacy-related inquiries, contact us at:
Company Name:- Tugu Assist Ltd
Support Email: – [email protected]
Phone Number:- 01274 019320
Developed By:- TUGU Assist Ltd
Tugu Assist Ltd
7 Wrose Brow Road Shipley West Yorkshire
01274 019320
[email protected]
By using our website and services, you consent to the terms of this Privacy Policy. Thank you for trusting Tugu Assist Ltd with your personal information.