Last Updated: 16/01/2019
1. Who processes your personal data?
2. Which type of personal data is collected?
3. For what purposes does Scooty collect your personal data?
4. What happens if you fail to provide certain personal data?
5. Who are the data recipients of the personal information we collect about you?
6. For what period will Scooty retain your personal data?
7. What rights can You exercise with respect to the processing of your personal data?
8. How Scooty protects your personal data?
9. What choices do you have in regard to the use of your personal data?
10. Our commitment to children’s privacy
11. Who to contact when you have a query regarding the processing of your personal data?
12. Changes and updates to this Policy
Scooty is an electric mobility service in Belgium proposed by Ubeeqo SPRL, a Belgian company registered with the CBE under number 0548.662.385, whose registered office is located at Avenue Louise 279, 1050 Brussels, Belgium (“We”, “Scooty”).
We have created a network for sharing electric scooters through a mobile application (“App”) that enables users to locate, rent, and operate electric scooters from the available locations (“Scooty Service”). The Scooty Service is designed to offer its users (“Users” or “You”) a means of transportation with electric scooters (“Scooter”) via a short-term self-service rental model. We maintain a corporate Web site at https://scooty.brussels (“Site”) as well as all related applications, widgets, software, tools and other services provided by us and on which a link to this policy is displayed.
We take Your privacy seriously and make it a priority to protect personally identifiable information that we obtain from and about You both online and offline. If You have questions about our Policy, please send an email to firstname.lastname@example.org.
All access and use of the Scooty Service implies respect for the Policy by the User. The Services, including but not limited to the access and use of the Scooty Service, are provided only on the condition that the Users agree to the present Policy as well as the the Scooter-sharing rental terms and conditions (the “Scooter-sharing Agreement”) located at https://scooty.brussels/terms-and-conditions/.
A. When You register and set up an account (“User Account”), You may provide personal data to Scooty. Whenever a field is not marked with “*” symbol it means that You are free not to communicate the requested personal data and that Your registration can go ahead notwithstanding the absence of this information. The personal data collected by Scooty for registration purposes are: first name, last name, email, phone number, day of birth. In addition, Scooty’s Payment Service Provider will process Your Credit Card data (i.e.: name of the credit card holder, credit card number, expiration month and CVC number).
Moreover, the images of the driving license and national identity card or passport are collected and processed for the purpose of validating the driving licence and national identity card or passport. The driving licence and national identity card or passport data are manually transcribed by our customer service team from the images of User’s driving licence and national identity card or passport.
B. When You use or visit the Services, or contact us by e-mail or other means for any reason, You may provide personal data to Scooty. Personal data may also be collected if You provide such information in connection with creating a profile or group, leaving comments, posting content, sending an email or message to another User or participating in any features of the Services. In addition, from time to time we may collect other personal data You provide in connection with Your participation in promotional offers and other activities on the Services. If You use the Services with Your mobile device, we may have access to Your phone number, Unique Device Identifier or other device information that uniquely identifies individual smartphones or mobile devices.
C. You understand that when You use the Services, information You post in Your public profile and in any other interactive areas of the Services will be available to other Users and in some cases may be publicly available and You provide that information at Your sole risk.
D. Payment Information. If You purchase services or products from the Services, we will collect the billing and financial information necessary to process Your charges, which may include Your postal and email addresses. In addition, Scooty’s Payment Service Provider shall collect Your credit card data (name of the credit card holder, credit card number, expiration month, CVC number). We may also receive the billing and payment information that You provide when Your purchase is processed by another party.
E. Invitation Service. Scooty may offer an invitation service to tell a friend about the Services. If You choose to use our invitation service to tell a friend about the Services, we may ask You for information needed to send the invitation, such as Your friend’s email address or phone number. We may also offer You the opportunity to invite Your friend via third party services such as Facebook, Instagram or Twitter. We will automatically send Your friend a one-time email or text message inviting him or her to try the Service. By providing email addresses or phone numbers of non-Users, You represent that You have the right to do so and that such information may also be provided to the third party service that You have designated to contact the non-User. We store and use this information to send this invitation, to register a friend if Your invitation is accepted, and to track the success of our invitation service. Your friend may contact us at email@example.com to request that we remove this information from our database.
A. We use analytics tools to track how You reach our Site and to understand how You use the Site after You arrive. Although this allows us to see and analyze Your movements around the Site, our systems do not provide a way for that information to be tied to any personal data You choose to give us.
A. Technical Data. Scooty provides its Services in a fully digital and automated way through Scooty’s software platform and onboard Scooter technology. As a result, Scooty’s fleet is equipped with devices which feature internet connectivity generating technical data (eg. mileage, vehicle ignition power-on/power-off status, vehicle locating alert status, vehicle alarm status, information relating to the battery use and health etc…).
B. Geolocation Data. Scooters are monitored based on geolocation systems and its internet access devices. As a result, User must be aware that (i) geolocation systems and (ii) internet connection devices are embedded in Scooty´s fleet of Scooters.
C. Location Information. Scooty may offer features designed to help You use the Services, such as to locate Scooters available through the network, including in whole or in part based on Your location. You will be given the opportunity to opt-in to location-based services, normally through an opt-in screen on the App. If You choose to enable location-based services, we may collect Your location based on information provided by You or Your mobile device, including, if available, GPS, IP address or cell tower information. If You, as a User, do not opt-in to location-based services, You may not have access to the features necessary to use the Services.
A. We may receive information about You, including personal data, from third parties and third party Web sites (e.g., Facebook, Twitter, etc.) (“Third Party Sites”), in accordance with the policies and terms of such Third Party Sites. Scooty may combine this information with other personal data we maintain about You. If we do so, this Policy governs any combined information that we maintain in a personally identifiable format.
B. We may permit Users with accounts on certain Third Party Sites (including social networking, search, sharing, and other services delivered by third parties) to bypass standard registration processes on our Services. If You connect to our Services through an authorized Third Party Site, You may be able to use Your third party login information to log into our Services, and You may be able to publish Your comments and any other activity on our Services to the Third Party Site. We are not responsible for the sharing, posting, commenting, or other content and information-gathering practices on any Third Party Site. Please review their terms of service and privacy policies carefully before using their services and connecting to our Services.
By using any Third Party Site to log in to our Services, or otherwise connecting to any Third Party Site, You permit us to access and use all information related to Your account on the Third Party Site that may be accessible to us through the Third Party Site pursuant to this Policy. To limit or control the information that is available to us through such Third Party Site, or to disconnect the Third Party Site from our Services, You should check (and, if applicable, modify) the applicable settings on the Third Party Site.
A. “Cookies” and Clear Gif Information. We may automatically collect certain information through the use of “cookies” and/or clear gifs. Cookies are small data files that are stored on a User’s hard drive at the request of a Site to enable such Site to recognize Users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any personal data, we would treat this information as personal data. Clear gifs (also known as web bugs or web beacons) are small, invisible graphic images that may be used by the Services or in emails relating to the Services to collect certain information and monitor user activity on the Services and may be combined with Your IP address or other information that we have gathered with respect to a User’s use of the Services.
Scooty may use “cookies” or clear gif information for a number of reasons related to the Services, including to: (a) remember Your information so that You will not have to re-enter it during Your visit or the next time You use the Services; (b) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (c) track Your entries, submissions, and status in any promotions or other activities.
If You wish to block, erase, or be warned of cookies, please refer to Your browser instructions or help screen to learn about these functions. However, if a browser is set not to accept cookies or if a User rejects a cookie, some portions of the Services may not function properly. For example, You may not be able to sign in and may not be able to access certain features of the Services.
The processing relating to such cookies are governed by Scooty’s Cookies Policy, which we encourage you to review.
B. When You use the Services, some information is also automatically collected, such as Your Internet Protocol (IP) address, Your operating system, the browser type, the address of a referring Site and Your activity on the Services. We treat this information as personal data if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate only and is not considered by Scooty to be subject to the restrictions in this Policy.
C. Personal data provided online may be linked together or merged with other personal data so that we may better understand Your needs and inform You about our products or services and those of our partners. In addition, if we receive information from third parties (see below) with whom we have business relationships, we may combine this information with the other Personal data we maintain about You. In either case, this Policy governs this information.
Through our Site and App Scooty provides You with Services. To that end Scooty processes User Provided personal data, in general, to process Your requests or transactions, to provide You with information or services You request, to inform You about other information, events, promotions, products or services we think will be of interest to You, to facilitate Your use of, and our administration and operation of, the Services, and for the purpose for which the information was provided. For example, we may use the information we collect, for the following purposes:
A. Your registration as a User of Services which is necessary to identify You and to prepare and facilitate your future booking of Services.
B. to send You a welcoming email and to contact You about Your use of the Services, to provide other services, products or information You request and to complete any transactions in connection therewith;
C. to enable Your use of the Services, including to determine your service eligibility and, the case being, credit-worthiness, including Your driving safety records;
D. to respond to Your emails, submissions, comments, requests or complaints;
E. to confirm, cancel or modify your Reservation of the Scooter;
F. to manage your Reservation of a Scooter (delivery and return of the Scooter);
G. to manage your invoices;
H. to manage the payment of arrears;
I. to manage the recovery of potential damages to the Scooter;
J. to process Service payments. To that end, Scooty’s Payment Service Provider shall process your credit card information (Name of the credit card holder, credit card number, expiration month, CVC number, type of credit card).
Legal Basis: The processing purposes highlighted above are necessary for the performance of the Scooter-sharing Agreement or to carry out pre-contractual activities at Your request pursuant to Art. 6 para. 1 lit. b) GDPR.
A. to request feedback and to enable us to develop, customize and improve the Services;
B. we use all of the information that You provide or that we collect and/or aggregate to understand and analyze the usage trends, interests, and preferences of our Users, to improve the way the Services work and look and to create new features and functionality.
Legal basis: This processing, which aims to better understand our Users needs and to offer customized functions to enhance your experience of the Services, is based on Scooty “legitimate interest” pursuant to Art. 6 para. 1 lit. f) GDPR.
A. to contact You about third party’s services, products, activities, special events or offers and for other marketing, informational, product development and promotional purposes;
Legal basis: Direct marketing processing, i.e. any commercial message from Scooty aiming at promoting the Services, are subject to your express consent pursuant to Art. 6 para. 1 lit. a) GDPR.
By exception: If You are already an existing Scooty User and that the message concerns services similar to those you have already purchased, the underlying processing will not be based on your consent but on Scooty “legitimate interest” pursuant to Art. 6 para. 1) lit. f) GDPR.
A. Technical data collected through connected devices are processed for the purpose of:
– monitoring the state, the performance and the functionalities of the Scooter (for example, this allows Scooty to verify whether the vehicle battery level is appropriate or not). Such information aims to ensures that each Scooter is in good working condition and is available for User bookings;
– identifying potential breaches of the Scooter-sharing Agreement (for example making sure that the User has (i) returned the Scooter within the mandatory geographic perimeter defined by Scooty in each relevant city (the “Perimeter”);
Legal basis: This processing, aiming at protecting the integrity of Scooty’s fleet, is based on Scooty “legitimate interest” pursuant to Art. 6 para. 1 lit. f) GDPR.
B. Geolocation systems have been installed by Scooty to verify the presence of the rented Scooter within the Perimeter, at the start of the rental and to verify the presence of the rented Scooter in the correct Perimeter at the end of the rental. Such geolocation systems allow Scooty to make sure that the Scooters are situated in their designated area and are available for booking.
Such information shall also be used for the purposes listed below:
i. to prevent any fraud and/or damaging action against its property as well as to provide Users with a better service. For example, geolocation systems allow Scooty to make sure its Scooters are returned on time in their designated Business Area or alternatively (i) allow Users to extend their booking or (ii) mitigate any consequences for the User whose Scooter has been delayed.
ii. Location of the Scooter in the event of theft or suspected theft;
iii. Location of the Scooter in the event of a suspected accident in order to provide assistance or emergency medical treatment.
The location of the User based on geolocation systems installed by Scooty is collected solely for the above purposes.
Legal basis: This processing, aiming at protecting the integrity of Scooty’s fleet, is based on Scooty’s “legitimate interest” pursuant to Art. 6 para. 1 lit. f) GDPR and is necessary for the performance of the Scooter-sharing Agreement between You and Scooty pursuant to Art. 6 para. 1 lit. b) GDPR.
A. We may use the location information that You provide or that we collect to provide content and services to You based on Your location, such as for making You offers based on your geographic location.
Legal basis: This processing of your location information provided by You or Your mobile device, including, if available, GPS, IP address or cell tower information aiming at allowing You to have access to the features necessary to use the Services is based on Scooty “legitimate interest” pursuant to Art. 6 para. 1 lit. f) GDPR and is necessary for the performance of the Scooter-sharing Agreement between You and Scooty pursuant to Art. 6 para. 1 lit. b) GDPR.
Usage Data of the User is solely processed to permit the navigation of the User on Scooty’s sites and applications from an operational and technical point of view and to improve the User’s navigation experience. Based on such Usage Data, Scooty will be able to adapt its Site to ensure an easier and quicker navigation. For example, Usage Data allows us to make sure Scooty’s Site is the most relevant to you depending on your language and country of origin.
Furthermore, Usage Data are processed for the purpose of carrying out anonymous and aggregated statistical analyses of the Usage Data of the User.
Legal basis: We use this information to fulfil our legitimate interests ursuant to Art. 6 para. 1 lit. f) GDPR, which are to analyse overall trends, administer our Site, track users’ use of the Site, help us improve our Site, and to better understand the Users’ experience on our Site.
A. This processing aims at conducting aggregate analysis of the performance of the Services.
A. We may disclose personal data in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of the Services, our Users, our employees or the public, including without limitation to protect Scooty or our Users from fraudulent, abusive, inappropriate or unlawful use of the Services.
B. We may disclose personal data in connection with the reorganization, reincorporation, acquisition, debt financing, merger, sale of Scooty relevant assets or business or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which personal data is transferred to one or more third parties as one of our business assets.
Legal Basis: The processing aiming at reducing Scooty risk exposure and its negative implication in the performance of the Scooter-sharing Agreement highlighted above is based on Scooty “legitimate interest” pursuant to Art. 6 para. 1 lit. f) GDPR and/or for the purpose of fulfilling duties and obligations laid down in applicable laws and regulations pursuant to Art. 6 para. 1 lit. c) GDPR.
Where the processing of Your personal data is necessary for the performance of the Scooter-sharing Agreement or to carry out pre-contractual activities at Your request or for the purpose of fulfilling duties and obligations laid down in applicable laws and regulations and You fail to provide that personal data when requested, we may not be able to perform the Scooter-sharing Agreement entered into/to be entered with You. In this case, we may have to cancel our engagement or said agreement. We shall notify if this is the case at the time.
Your personal data will be disclosed, as necessary and/or relevant to:
B. the sub-processors of Scooty, which are third-party service providers that collect data in order to help Scooty in providing you with its products/services. The legal basis is Art. 6. para. 1 lit. b) GDPR. To know more about the list or categories of such service providers, please click here.
C. regarding the information processed for the payment of fines, to the relevant competent authority – in the country where the User made the booking – dealing with the processing of fines. The legal basis is Art. 6 para. 1 lit. c) GDPR;
D. Scooty can also disclose your personal data to the extent required by law and/or by competent authorities. The legal basis is Art. 6 para. 1 lit. c) GDPR.
We limit the personal data that is provided to these above-mentioned recipients to that which is reasonably necessary to provide us with a specific service and not for any other purpose and we require them to maintain the confidentiality of the Personal data to the extent legally possible.
The Services may be linked to Third Party Sites operated by other companies (including facebook.com), products, or services that we do not own or operate. Some of these Third Party Sites may be co-branded with our name or logo, even though they are not operated or maintained by us. If You choose to visit or use any third party products or services, please be aware that this Policy will not apply to Your activities or any information You disclose while using third party products or services or otherwise interacting with third parties. We are not responsible for the privacy practices of these Third Party Sites and third party services. Additionally, please be aware that the Services may contain links to Web sites and services that we operate but that are governed by different privacy policies. We encourage You to carefully review the privacy policies applicable to any Web site or service You visit other than the Services before providing any Personal data on them.
As necessary or useful to provide you with the Services, Scooty will – for the purposes set forth herein – transfer your personal data outside the EU to third-parties, as identified in Appendix 2.
Depending on the case, certain recipients may be located in countries which have been recognized by the European Commission as ensuring an adequate level of data protection or in countries which has not been recognized as ensuring such a level of protection. In any case, Scooty has put in place appropriate safeguards to protect your personal data, in compliance with the EU regulation no.2016/679 (the “GDPR”).
To find more information regarding the countries where your personal data can be transferred, their level of data protection and the potential safeguards put in place by Scooty, please click here.
Your personal data are retained for different period, depending on the purposes of the processing:
At any time, you can view and/or update your personal profile, which includes member registration, driver information and rental preferences information, through the “My profile” section accessible on the Scooty Site. You will be able to change your password, update or correct phone number, address, and driving licence information and update your Scooter rental and travel preferences including means of payment.
As per GDPR, you can also benefit from the following rights:
A. right of “access”: right to obtain confirmation as to whether or not your personal data are being processed by Scooty, and, where that is the case, to access to these personal data and to obtain further information on the characteristics of their processing;
B. right “to rectification”: right to obtain the rectification of inaccurate personal data or, taking into account the purposes of the processing, the right to have incomplete personal data completed, including by means of providing a supplementary statement;
C. right to “erasure” (or the so-called “right to be forgotten”): right to obtain the erasure of your personal data in certain circumstances;
D. right to “restriction”: right to obtain restriction of processing under certain circumstances. Should the processing of your personal data be restricted, such data can only be further processed subject to your consent (save for storage purposes) and you will be informed before the restriction of processing is lifted;
E. right to “object”: at any time, a right to object to the processing of your personal data to prevent Scooty from continuing to carry out such processing:
i. where your data are processed for direct marketing purposes;
i. where your personal data are processed on the basis of Scooty legitimate interest. In that case, your request will be satisfied only if you provide Scooty with a description of the particular situation legitimating your request and save if Scooty can demonstrate overriding legitimate grounds in light of your particular situation.
F. right to “withdraw your consent”: where the processing of your personal data is based on your consent, a right to withdraw your consent to the processing of your personal data at any time and to prevent Scooty from continuing to carry out such processing;
G. right to “data portability”: where the processing of your personal data is based on your consent and by automated means, the right to receive the personal data you provided to Scooty, in a spreadsheet and to transmit those data to a third party;
If you wish to exercise any of these rights, please contact us via the relevant email address, as set out below under Section 12. In addition, in Scooty promotional and marketing emails and other communications, Scooty also includes instructions on how to unsubscribe.
To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making corrections.
As per article 77 of the GDPR, you can lodge a complaint about the processing of your personal data with the body regulating data protection in your country if you consider that the processing of your personal data infringes the said GDPR.
Scooty is committed to protecting the information it collects through this Site. In particular, Scooty uses appropriate physical, technical and organizational security measures to prevent unauthorized or unlawful processing, accidental loss of or destruction of or damage to your personal data.
Scooty systems are configured with data encryption, or scrambling technologies, and industry-standard firewalls. When you send personal information to a Scooty Site over the Internet, your data is protected by the SSL (Secured Socket Layer) encryption/decryption to ensure safe transmission.
If Scooty learns of a security systems breach is likely to result in a high risk to the rights and freedoms, then We shall notify You, without undue delay, electronically through the contact information that You have provided to Scooty so that You can take appropriate protective steps. Scooty may also post a notice on the App and/or the Site if a security breach occurs.
You may, of course, decline to share Your personal data with Scooty, in which case Scooty will not be able to provide to You some of the features and functionality found in the Services. If You register as a User of Scooty, You may update, correct, or delete Your profile information and preferences at any time by emailing us at firstname.lastname@example.org.
You may “opt out” of receiving promotional and marketing materials by emailing us at email@example.com. However, this shall not affect our ability to send You service and account related emails and to use Your personal data as otherwise described in this Policy. Please be aware that if You “opt out” of receiving commercial email from us, it may take up to ten business days for us to process Your “opt out” and You may receive commercial email from us during that period.
To protect Your privacy and security, we take reasonable steps to verify Your identity before granting You account access or making corrections to Your information but You are solely responsible for maintaining the secrecy of Your unique password and account information at all times.
Protecting the privacy of young children is especially important. For that reason, our Services are not directed to persons under 21 years-of-age and Scooty does not knowingly collect or maintain personal data from persons under 21 years-of-age, including children under the age of 13. If Scooty learns that personal data of persons under 13 years-of-age has been collected in the Services without verifiable parental consent, then Scooty will take the appropriate steps to delete this information. If You are a parent or guardian and discover that, for any reason, Your child under the age of 13 has obtained a Scooty User Account, then You may alert Scooty at firstname.lastname@example.org and request that Scooty delete that child’s personal data from its systems.
Our Services are hosted in Europe and generally are intended for European visitors. If You visit from the United States of America or other regions with laws governing data collection and use that may differ from European Union law, please be aware that You are transferring personal data to the European Union. By providing personal data to us, You consent to the transfer of it to the European Union and the use of it in accordance with this Policy and applicable law.
A. Please contact Scooty with any questions or comments about this Policy, Your personal data, our third-party disclosure practices, or Your consent choices by email at email@example.com or by mail at:
Attention: User Service
Avenue Louise 279,
1050 Brussels, Belgium.
B. To exercise your rights listed in Section 7 of this Policy:
This Policy may be revised periodically, and this will be reflected by a “Last Updated” date above. We may not notify You of any changes to this Policy except by posting a new Policy. Please revisit this page to stay aware of any changes. Your continued use of the Services constitutes Your agreement to this Policy and any future revisions. However, if we change this Policy in a manner that is materially less restrictive of our use or disclosure of Your personal data, we will use reasonable efforts to notify You of the change and to obtain Your consent prior to applying the change to any personal data that we collected from You prior to the date the change becomes effective. We encourage You to periodically review this Policy to stay informed about how we collect, use and disclose personal data.