PRIVACY
POLICY
In this
document (hereinafter - the Privacy
Policy) we explain how we process your personal data collected by us in
CityBee mobile app during your use of CityBee vehicles – cars, bicycles,
scooters (hereinafter – the Vehicles). We invite you to review this Privacy Policy
carefully.
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.
We
process personal data in accordance with Regulation (EU) 2016/679 of the
European Parliament and of the Council of 27 April 2016 on the protection of
individuals with regard to the processing of personal
data and on the free movement of such data and repealing Directive 95/46/EC
(the General Data Protection Regulation) (hereinafter - GDPR) and other
legal acts governing personal data protection and this Privacy Policy.
The
terms used in the Privacy Policy must be interpreted in accordance with the
definitions contained in GDPR and in the terms and conditions of CityBee
vehicle rent and service provision unless otherwise provided in this Privacy
Policy.
We may
update the Privacy Policy from time to time, therefore we recommend that you
review it periodically. We will inform you of any changes by posting the
updated Privacy Policy on the Mobile App. In case we materially amend the
Privacy Policy, we will send you the respective notification by e-mail.
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 info@citybee.lt 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.
Important:
-
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
The device will function properly only
if the Mobile App is given permission to use the following device’s data: the
device’s operating system and the device model. If you disagree that the Mobile Apps receives these data, do not
install the Mobile App on your device. If you have already installed the Mobile
App, without reading this Privacy Policy available on Google Play and App Store
platforms first, you should immediately delete the Mobile App from your device.
For analysis and
advertising purposes, we use third-party tools such as Google
Firebase, Google Ads, and Facebook Ads, to enable ourselves to collect aggregated
and depersonalised information about how people use the Mobile App, understand
how we can improve and provide relevant non-personalised advertising of our
services. If you disagree with the processing
of data for the purposes described above, do not install the Mobile App on your
device and do not select its settings. If you have already installed the Mobile
App without reading this Privacy Policy available on Google Play and App Store
platforms first, you should immediately delete the Mobile App from your device.
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: info@citybee.lt,
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: info@citybee.lt, 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 info@citybee.lt
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 ada@ada.lt). 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 info@citybee.lt or by telephone +370 700 44844.
This policy was last updated on 2021-01-14.