KEEGO MOBILITY PRIVACY NOTICE
Welcome to Keego Mobility’ Privacy Notice. At Keego Mobility, we want you to know that we have your best interests at heart and in this Privacy Notice, we give you information on how we collect and process your personal data when you use our website or mobile applications, take part in any of our competitions, sign-up as a member with us, apply for a job with us, or are a service provider to us. As data protection is really important to Keego Mobility, we may provide you with additional data privacy notices or information that is specific to your situation – and if we do, you need to read that additional information alongside this Privacy Notice (which is our key document and will always apply). As Keego Mobility takes managing your personal data seriously, we have a team who are responsible for overseeing the management and security of your personal data as well as answering any questions that you have about this Privacy Notice. If you would like to get in touch with this team, please kindly contact firstname.lastname@example.org. We also need to let you know that if you have any concerns and/or you’re not happy with our approach, you have the right to make a complaint at any time to your local data protection regulator. This Privacy Notice is kept under regular review and was last updated in August 2020.
WHAT PERSONAL DATA DO WE COLLECT ABOUT YOU AND HOW?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
A) Different kinds of personal data
In general, we collect, use, store and transfer different kinds of personal data and we’ve grouped them together below for you:
- Identity Data includes first name, maiden name, last name, username or similar identifier, title, Social Security number, driver’s license number, state identification card number, passport number, and date of birth.
- Contact Data includes billing address, email address, and telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments from you and other details of products and services you have registered for with us.
- Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Where you are a member with us, it also includes data on your rides, and the locations that you have travelled to with our bike (as our bikes are installed with devices that track this data).
- Profile Data includes your username and password, agreements signed with you (such as rental or rent-to-own agreements), your interests, preferences, feedback, and survey responses.
- Usage Data includes information about how you use our website and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.We also collect, use and share
- Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Notice.We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).Our products and services are not intended for children and therefore, we do not knowingly collect data relating to children.
B) Our relationship with you
The personal data that we collect from you depends on our relationship with you. Below we’ve made a chart which explains the personal data that we collect, how we collect this data, and what our legal basis is for collecting it (as we will only collect and process your personal data when the law allows us to do so).
Who are you? What data do we collect about you? How do we collect this personal data about you? What’s our legal basis for collecting this personal data? I am using the Keego Mobility websites and/or applications and I am keen to find out more about what Keego Mobility can offer.
Technical Data and Usage Data (for tracking purposes). Identity Data, Contact Data and Marketing and Communications Data (if you enter into a competition, promotion or survey or sign-up for more information, etc.). Automated technologies — As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies. Direct interactions — If you decide to contact us through our website or through other means, you will be directly providing us with your personal data. Consent, in that you are choosing to provide us with your details so that we know to contact you about your query.Necessary for our legitimate interests (i.e. for running our business, provision of services, to develop our business, and to inform our marketing strategy).
I am a Keego Mobility member (i.e. a rider that has entered into or is in the process of entering into a contractual agreement with Keego Mobility).
Technical Data and Usage Data (for tracking purposes and information on your riding). Identity Data, Contact Data, Financial Data, Transaction Data, Profile Data and Marketing and Communications Data (for when you enter into a formal relationship with us for a service or product). Automated technologies—As you interact with our website (and/or products), we automatically collect personal data about you by using cookies and similar technologies.Direct interactions—If you decide to contact us through our website or through other means, you will be directly providing us with your personal data.We may receive personal data about you from third-parties (as detailed below) and public sources.Performance of a contract with you.Necessary for our legitimate interests (i.e. to recover debts due to us, to keep records to develop our business strategy, check eligibility for special offers).Necessary to comply with a legal obligation (i.e. in respect to our financial, tax, and legal affairs).
I am a candidate applying for a job with Keego Mobility (and/or am subsequently in the process of signing an employment contract with Keego Mobility).
Technical Data and Usage Data (if you apply through our website).Identity Data and Contact Data (information submitted as part of your application).Automated technologies—As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies.Direct interactions—If you decide to apply for a job at Keego Mobility, you will be directly providing us with your personal data.Third-parties or publicly available sources—We may receive personal data about you from various third-parties (such as recruitment agents or your referees) and public sources.Consent, in that you are choosing to provide us with your details so that we know to contact you about a vacancy.Performance of a contract with you.
I am a service provider to Keego Mobility.
Technical Data and Usage Data (for tracking purposes)Identity Data and Contact Data (if you register your interest).Automated technologies—As you interact with our website, we automatically collect personal data about you by using cookies and similar technologies.Direct interactions—If you agree to provide us with a service, we will hold the personal data of your staff that have engaged with us.Performance of a contract with you.Necessary for our legitimate interests (i.e. for running our business).Necessary to comply with a legal obligation (i.e. in respect to our financial, tax and legal affairs).Please contact us on email@example.com if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table above.It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
C) If you fail to provide personal data
Where we need to collect personal data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods and/or services). In this case, we may have to cancel goods and/or services you have with us – but we will notify you in advance.
D) Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If this does occur and you wish to get an explanation as to how the processing for a new purpose is compatible with the original purpose, please contact us on firstname.lastname@example.org. If we need to use your personal data, however, for an entirely unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
DO WE DISCLOSE YOUR PERSONAL DATA TO OTHERS AND IF SO, WHO?
We may share your personal data with the parties set out below for the purposes set out in the table above.Internal third-parties such as those within our group that are based outside of your country of residence
External third-parties such as: Potential and existing customer tracking and engagement providers – for us to be able to track our engagement with potential and existing customers as well as be able to communicate with them through different methods (such as online chat, text and telephone).
Telematics device and software providers – for us to be able to monitor bike data, riding behavior, and bike location.
Payment service providers – for us to process any payments made by our customers to us.
Insurers and claims processors – for us to deal with any accidents or bike issues that our customers face.
Bike servicing, maintenance, and repair organizations – for us to ensure that the bikes that our customers are driving are roadworthy.
Candidate tracking, assessment, and background screening organizations – for us to manage and evaluate candidates that are applying for vacancies with us and to confirm their details and credentials.
Technology companies that provide us with desktop and cloud-based products – for us to conduct our business and back-up data (which may include your personal data) whilst you are reviewing our website, applying to be our customer, applying for a vacancy with us, or acting as one of our suppliers.
Professional advisers such as law firms, banks, and accountancy firms – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).
Delivery Platform Partners – which we partner with to provide discounts and other special offers to eligible Keego Mobility riders.
Regulators and other governmental authorities – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your personal data).Third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Privacy Notice.We require all third-parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions, except for when such third-parties are regulators and other governmental organizations.
EEA Residents Only:We share your personal data within the Keego Mobility group and with some of our third-party suppliers. This will involve transferring your data outside the EEA. Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the U.S. For further details, see European Commission: EU-US Privacy Shield.Please contact us on email@example.com if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
HOW LONG DO WE RETAIN YOUR DATA?
We will only retain your personal data for as long as reasonably necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data; the potential risk of harm from unauthorized use or disclosure of your personal data; the purposes for which we process your personal data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting or other requirements.By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they cease being customers for tax purposes.In some circumstances you can ask us to delete your data: see “What are your legal rights?” below for further information.In some circumstances we will anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
WHAT ARE YOUR LEGAL RIGHTS?
Under certain circumstances, you have rights under data protection laws in relation to your personal data which we have summarized for you below.
What’s it all about? Request access to your personal data (commonly known as a “data subject access request”)
This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you
This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data
This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data
This applies when we are relying on a legitimate interest (or those of a third-party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request the restriction of processing of your personal data.
This enables you to ask us to suspend the processing of your personal data in the following scenarios:If you want us to establish the data’s accuracy.Where our use of the data is unlawful, but you do not want us to erase it.Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims.You have objected to our use of your data, but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third-party
We will provide to you, or a third-party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data
This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.If you wish to exercise any of the rights set out above, please contact us on firstname.lastname@example.org. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.We try to respond to all legitimate requests within 1 month. Occasionally it could take us longer than 1 month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
California Residents Only:
California residents have additional rights to limit sharing. Please see the enclosed “Important Privacy Choices for Consumers” notice provided to you describing your right to control the sharing.
Vermont Residents Only:
We will not disclose your personal information or financial information to non-affiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal data to those employees, contractors and other third-parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
Connecticut Residents Only:
Pursuant to Connecticut General Statutes Sec. Section 42-471, it is the policy of Keego Mobility to protect the privacy of your personal information by doing the following: Safeguarding any data, computer files and documents containing your personal information from any misuse by third parties; Destroying, erasing or making unreadable any data, computer files and documents containing your personal information prior to their disposal;Protecting the confidentiality of your Social Security number and other personal information;Prohibiting the unlawful disclosure of your Social Security number and other personal information;Limiting and/or restricting the access to your Social Security number and other personal information to other third parties; andLimiting the access of your Social Security number and other personal information only to our employees who need access to your personal information in order to allow us to provide legal services to you, limiting the access of these employees to the extent that it is needed, and otherwise imposing restrictions and reasonable safeguards on our employees to prevent them from accessing your personal information.In the event that there is ever a breach of security regarding your personal information, we intend to comply with applicable state and federal law requirements regarding the notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach.“Personal information” for this section is defined as any information that you may provide to us that can be used to identify you individually, including but not limited to your name, email address, home address, telephone or fax numbers, Social Security number, driver’s license number, state identification card number, bank account number, credit card or debit card number, passport number, alien registration number, as well as any company account number that we assign to you.
Our websites and applications may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites and applications, we encourage you to read the privacy documentation of every website you visit.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third-party for marketing purposes. You can ask us or third-parties to stop sending you marketing messages at any time by contacting us at any time on email@example.com and withdrawing your consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you a result of performing a contract that we have with you (e.g. as we may be required to contact you about a payment due).