We use the collected personal data to ensure seamless provision of services and continuous improvement of service quality and functioning of CityBee mobile app (hereinafter - the Mobile App). We may be unable to rent you CityBee vehicles or provide the services related to their use unless we get the requested personal data.
I. WHO IS IN CHARGE OF YOUR PERSONAL DATA PROCESSING?
The controller (hereinafter - We, the Company) which processes your personal data provided in the Mobile App and collected during the use of the Vehicles is:
Prime Leasing UAB
Company registration number 302565318,
Ozo g. 10A, 08200 Vilnius, Lithuania
You can contact us by e-mail firstname.lastname@example.org or telephone +370 700 44844, regarding personal data protection issues.
II. WHAT IS OUR LEGAL BASIS FOR PERSONAL DATA PROCESSING?
Your data will be processed on the basis of:
- Your consent (-s) which you have given, clearly confirming this:
· as you are installing the Mobile App in your mobile device and selecting its settings;
· as you are uploading the image of your driving license’s first side and the image of your face to the Mobile App in order to establishing your identity and online verification of your right to drive;
· by choosing in your device to receive direct marketing offers via e-mail and using active push notifications on the phone;
· by choosing in your device to receive personalised direct marketing offers via e-mail and using active push notifications in your device;
· by letting for the Mobile App to in your device to access the data of your device’s camera and geolocation data of your device;
· before the recording your telephone conversation with our customer service centre.
- Our contractual arrangements with you for Vehicle rent and services:
· The terms and conditions of CityBee vehicle rent and service provision.
- Applicable laws (legal obligations), such as taxes, financial accounting, traffic safety regulations and other legislation.
- Our legitimate interests including fraud prevention, analysis, debt management, transmission of data about debts to debt recovery companies and credit rating agencies, creditworthiness assessment, network and information security, sharing evidence of possible criminal actions with the state authorities, providing information about services or asking for an opinion on the provision of services, GPS tracking to ensure our asset security and the implementation of agreement with you on CityBee vehicle rent and services, and other legitimate interests.
- After installing and using the Mobile App, We may send you direct marketing communications in accordance with our legitimate interest in notifying You of Our services and seeking an opinion on Our services in accordance with Our legal rights. You can opt out of these notifications in your Mobile Gadget settings as soon as you install the gadget or at any time later. If you refuse to receive such messages, you will be sent only non-promotional e-mails and messages (short messages (SMS), push notifications) in relation to the use of CityBee services;
- you may refuse all active phone push notifications by changing your device's operating system settings.
III. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES THEY ARE USED?
3.1. Upon the installation of the Mobile App and selection of its settings
3.2. Account creation in the Mobile App
If you intend to start using the Mobile App, you need to register in the App by providing the personal data required in accordance with the terms and conditions of CityBee vehicle rent and service provision. We have the right to request provision of and process the following personal data: your name, contact information (telephone number, e-mail address), address, credit card information (card type, bank name, card number, validity period), the image of your driving license’s first side, the data provided on the first side of your driver’s license (name, personal identification number, date of birth, driving license expiration date, the image of your face).
We need the image of your face (a selfie), the photo on your driving license and the data provided in your driving license to be able to establish your identity and the right to drive cars as you rent them. For this purpose, before the start of service provision, we will have to verify your driving license, i. e.: to check whether the image of your face made using the Mobile App matches the image of the face on the driving license (by automated means using algorithms selected by the service provider); and to check the validity of the driving license. You may choose to have this verification performed, by uploading the image through the Mobile App or, if you disagree to provide data in this way, you may call Us at the phone number +370 700 44844 and We will find the best solution to suit your expectations. For the purposes of the aforementioned verification, We will use third-party services and, in the legitimate interest of ensuring that only authorized customers have access to Our services, We contact the driving license authority to verify that the document provided is valid. We will use third-party services for the purposes of the aforementioned verification.
We have the right to perform periodical checks or updates of your driving license according to the verification procedure while you are using CityBee vehicles and services. If we find that your driving license is about to expire, we may contact you (by e-mail, SMS or by push notifications) and notify you about the expiry of the driving license.
3.3. Use of the Mobile App
When you use the Mobile App, we record your activities (e. g., reservation of Vehicles, their locking/unlocking, etc.); besides, we collect other data related to service use (Vehicles you have used, date and time of use, places where the Vehicle was taken and left, route of the Vehicle, speed, fuel and fuel card usage, etc.). The Mobile App will be able to use your device’s geolocation data, the camera integrated on your device and to send you Mobile App messages if you give such permission in the Mobile App and/or in your device’s settings. Please remember that if you do not permit using the aforementioned data/functions, some Mobile App functions may not function, and you may not be able to start renting CityBee Vehicles and/or using the services.
Your contact information (e-mail address, telephone number (send via SMS)) can be used to provide information relating to the services used, amendments of the terms and conditions of CityBee vehicle rent and service provision, the price list, etc. The information referred to above can also be sent as push notifications of the Mobile App. You can opt-out Mobile App push notifications at any time by changing the settings of your device's operating system.
We process your personal data (name, e-mail address, CityBee vehicle use data) for the purposes of personalised direct marketing (including the marketing of our partners, e. g., catering, vehicle maintenance, custodial service providers, etc.) using e-mails or push notifications only after obtaining your explicit and unambiguous consent through the Mobile App. You have the right to withdraw your consent at any time by phone: +370 700 44844; e-mail: email@example.com, by clicking on the link “Unsubscribe newsletter subscriptions” at any time or by unchecking the option to receive marketing messages in the Mobile App.
Please note that if permitted by the national legislation, we have the right to send general direct marketing messages of a general nature by e-mail or SMS based on your legitimate interest for offering services or for asking you to express your opinion about our services. In addition, you can always give us permission to receive such messages as push notifications. You have the right to withdraw your consent at any time by telephone: +370 700 44 844; e-mail: firstname.lastname@example.org, by clicking on the link “Unsubscribe newsletter subscriptions” at any time, by replying to SMS with the word “STOP” or by unchecking the option to receive marketing messages in the Mobile App.
In case you give permission to use Your device’s functionality to use fingerprint or face image for user recognition, We will not receive and/or process such data (we will only process device’s system information that the user log in was successful/unsuccessful).
3.4. Use of vehicles
Each Vehicle is equipped with an electronic system which records the location of the Vehicle, the distance travelled by the Vehicle, the Vehicle operating time, speed and other Vehicle-related data their use and transmits such data to us. We need this for CityBee vehicle rent and service provision in accordance with the terms and conditions of CityBee vehicle rent and service provision.
If during your use of the Vehicle by connecting your device to wired or wireless devices of the Vehicle, including but not limited to navigation, multimedia systems, your device’s data, e.g. given name and Bluetooth ID, will be stored in the Vehicle, unless you remove them in accordance with the Vehicle manufacturer's instructions. While using a Vehicle you must remove the data of your device from the memory of the Vehicle devices yourself. If you have failed to remove the data, we do not accept any liability in respect thereof.
When you register in the Mobile App and are using CityBee vehicle rent and services, we have the right, to the extent permitted by applicable law and subject to our legitimate interests (risk assessment, our asset protection, ensuring the security of third parties and their property, collection of charges for the provided services), take account of your creditworthiness, debt, driving experience, the respective road traffic offenses, history of insured events related to you (e. g., for speed) over the period of Vehicle use, and make decisions based on these data, which may affect the provision of our services to you (if you already use our services).
If you fail to comply with your financial obligations under the terms and conditions of CityBee vehicle rent and service provision and fail to pay your debt within 30 calendar days from the date of receipt of the notice, to the extent permitted by applicable law, we are entitled to transfer your data about your debt and personal data (including name, personal identification number and other and other data substantiating the fact of debt) to the persons who have a legitimate interest obtain such data, joint debtor files for debt management and/or recovery purposes based on our and third parties’ legitimate interest.
If during your registration in the Mobile App and/or use of CityBee vehicle rent and services we have any doubts that you will not be able to pay for the services rendered and We suffer damage as a result, based on their legitimate interest (risk assessment, protection of our assets, collection of charges for the services rendered), in certain cases (e. g., if you intend to rent an exclusive vehicle, are planning a trip abroad, are planning to use the vehicle for longer than usual, or you request to defer the payment, as well as in cases where the travel price exceeds 250 euros, and/or if there are other serious circumstances which may cause any kind of risk), we may ask Creditinfo Lietuva UAB to provide lawfully available data about you (including your credit rating, etc.) and to assess them for solvency, debt management and/or recovery purposes.
If you contact our customer service centre by telephone and give your consent to the recording of your telephone conversation, We will record the information, including personal data (the phone number you are calling, other information related to your request, including, but not limited to, name, car number, fault, car accident details, request content, and etc.), provided by you to be able to duly process your request.
In case of car accident, We will process the collected personal data related to the accident to be able to compensate the damage to the persons involved in the accident jointly with our insurance companies and/or the ones of the persons involved in the accident.
In order to improve and refine the quality of CityBee vehicle rent and services, we may analyse non-personal, statistical data, such as Vehicle use date and time, the location where the vehicle was taken and left, the Vehicle route, speed, fuel and fuel card use, we have collected during your use of CityBee vehicle rental and services via the Mobile App.
IV. DO WE SHARE YOUR INFORMATION WITH OTHERS?
We may use third-party services (third-party data centres, servers, verification of documents, photos, administration, payment, auditing, accounting, legal and consulting services, debt collection, Mobile App usage analysis and statistical services, direct marketing services, e-mail programs, short messages, payment intermediaries, etc.) or cooperate with partners in relation to the provision of services when we need access to your personal data to a certain extent. In this case, we shall ensure that third parties comply with their obligations of confidentiality and appropriate protection of personal data.
If necessary, your personal data may be produced to the competent state and municipal authorities, in accordance with applicable legislation and/or on grounds of our legitimate interests.
In case of a car crash, your data will be transmitted to insurance companies and, if necessary, to the other parties involved in the accident.
Based on the available data on the Vehicle we have the right and, in certain cases, an obligation to report information on road traffic offences (such as speeding, drunk driving) to the competent authorities (e. g., the police).
V. FOR HOW LONG SHALL WE STORE YOUR PERSONAL DATA?
Personal data collected for CityBee rent and service provision must be stored as long as they are necessary for the purposes for which the personal data were collected or obtained, except in the following cases in which data can be stored longer than for the required period:
(i) for the performance of legal obligations which require personal data processing;
(ii) for preserving information on suspected criminal acts;
(iii) for the establishment, exercise or defence of legal claims.
Your personal data shall be stored:
(i) for Vehicle sharing service administration purposes (i. e., client registration and accounting, contract management and monitoring of their performance, debt recovery and fines) for 3 months if the services are rejected; for 5 years after the date of expiry of the contract. Details of the clients who failed to fulfil their financial and/or property obligations or caused damage to the Company shall be stored for an additional period of 5 years;
(ii) for ensuring the protection of the assets (rented Vehicles) possessed by the Company (GPS data) – for 3 years;
(iii) for direct marketing purposes – when We have Your consent for 3 years, but not beyond the validity period of your consent; on the basis of a legitimate interest, until the end of the contract.
(iv) the records of telephone conversations with you shall be stored for a period not exceeding 6 months.
VI. WHAT ARE YOUR RIGHTS?
As a personal data subject, you have the right:
(i) to be informed about the processing of personal data and to request access to them or copies of your personal data so that you were able to know the purposes of your personal data processing, their storage period, etc.;
(ii) to request us to modify or update your personal data if they are inaccurate or incomplete;
(iii) to request that all or some of your personal data are not processed temporarily or in general;
(iv) to request to terminate your personal data processing if We no longer have any legitimate interest or legal obligation to process them;
(v) in certain cases, e. g., when personal data are processed for direct marketing purposes, you have the right to request deletion of your personal data used for direct marketing messaging;
(vi) to request to transfer your personal data to another service provider in a structured and machine-readable format.
For the purposes of your personal data processing, we do not use automated decision-making processes, including profiling, which may produce legal effects on you or similarly significantly affect you. However, when processing your personal data for direct marketing purposes, we may assign you to a certain category of customers, therefore you have the right to require human intervention to express their views or to oppose such assignment.
To exercise your rights, contact us by e-mail email@example.com or come to our customer service department. Along with the request, please provide an identity document (if you apply locally), sign your application by certified electronic signature
or attach a notarized copy of your identity document with your application by post.
We will provide information as soon as possible, but no later than within one month from the date of your application. We will provide information free of charge, however, if your requests are manifestly unfounded or excessive, in particular, because of their repetitive character, we may charge a reasonable fee based on administrative costs or refuse to act on the request.
You have the right to lodge complaints to the State Data Protection Inspectorate (L. Sapiegos g. 17, LT10312 Vilnius, e-mail firstname.lastname@example.org). However, we recommend that you contact us first and we will try to resolve all your requests with you.
VII. HOW WE WILL TAKE CARE OF YOUR PERSONAL DATA SECURITY?
We use appropriate technical and organisational measures to ensure personal data security, including protection of data against unauthorised processing and accidental loss, destruction or damage. These measures are selected taking account of the risks that may arise to your as data subject's rights and freedoms.
We strictly control access to personal data processed and provide it only to the employees of the company who need personal data to perform their work and monitor how they use the granted access. Company employees who have access to personal data are acquainted with personal data protection requirements and ensure the confidentiality of personal data processed.
We regularly monitor our systems for possible violations or attacks. However, it is impossible to fully ensure the security of information transmitted via the internet. Having this in mind, you transmit information via the Mobile App using the internet connection at your own discretion and your own risk.
We provide access to personal data with passwords of the required level and prepare arrangements for the protection of confidential information with individuals or partners who have access to your personal data.
VIII. YOU CAN CONTACT US
If you have any additional questions, please contact us via e-mail email@example.com or by telephone +370 700 44844.
This policy was last updated on 2021-01-14.