Voi Technology AB
Data protection officer: Mikael Söderberg, Email: email@example.com
Visiting address: Warfvinges väg 34, 112 51 Stockholm, Postal address: c/o Box 3147, 103 62 Stockholm
2. Collection, purpose and use of personal data
Voi will collect personal data which You submit when creating an account in the Voi App or which is created when You are using the Voi App or the Services.
Voi processes Your personal data in accordance with the following:
a) For the purposes of entering into, fulfilling and administering our contractual relationship (including handling payment) with You we process the following personal data:
- Location data;
- Contact details (such as name, address, e-mail address and phone number);
- Device ID; and
- Photos of scooters which You upload in the Voi App.
Our lawful basis for the processing of your personal data for this purpose is to fulfil our contractual obligations with You (Article 6(1)(b) GDPR).
b) For the purposes of performing statistical analyses and analyze data in order to develop the Services regarding functionality, security and methods, as well as analyze markets and customers, we process the following personal data:
- IP address;
- Information about Your device; and
- Information about Your use of the Voi App and the Services.
Our lawful basis for the processing of your personal data for this purpose is our legitimate interest to be able to develop the Services and to increase Our understanding of the markets and customers (Article 6(1)(f) GDPR). For the purposes described above, We will perform Our analysis on anonymized data/aggregated data. However, the processing described above will take place within the scope of the process to anonymize and/or aggregate the data.
c) For the purposes of segmenting and analyzing position data in order to provide custom information based on Your specific preferences and behavior patterns, we process the following personal data:
- Position data
The lawful basis for the processing of your personal data for this purpose is to fulfil Our contractual obligations with You, i.e. in order for Us to provide the Services (Article 6(1)(b) GDPR).
In addition to the above, Voi may process Your personal data (all categories of personal data as described above) in order to comply with laws and regulations or by court order (in which case the lawful basis is a legal obligation (Article 6(1)(c) GDPR)) or to protect Voi’s or any third parties’ rights, e.g. defending, exercising or establishing legal claims (in which case the lawful basis is Our legitimate interest in protecting Voi’s or any third parties’ rights (Article 6(1)(f) GDPR)).
3. Transfer of personal data
Voi will transfer personal data to the following categories of recipients:
- IT service providers. The purpose for these transfers is to be able to offer to You all of the functions of the Services. Such service providers process Your personal data in the capacity as data processors upon Our commissioning and on Our behalf. We only provide personal data in the context of legally permissible processing, to service providers that have been carefully selected and commissioned in writing. The service providers will receive only such personal data which is required for them to perform their tasks.
- Marketing partners. The purpose for these transfers is to perform marketing campaigns and the lawful basis is our legitimate interest to be able to perform marketing campaigns (Article 6(1)(f) GDPR).
- Group companies. The purpose for these transfers is internal administration and to provide Our Services to You. The lawful basis is our legitimate interest in being able to administer our business and thereby provide Our Services (Article 6(1)(f) GDPR).
- Insurance companies. The purpose for these transfers is to handle insurance claims and administer Our insurance policies. The lawful basis is our legitimate interest in handling insurance claims and administrating Our insurance policies on an ongoing basis (Article 6(1)(f) GDPR).
- Courts and counter parties. The purpose for these transfers is to defend, exercise and establish legal claims (or if we are subject to a case of bankruptcy). The lawful basis is Our legitimate interest to defend, exercise and establish legal claims (Article 6(1)(f) GDPR).
- Law enforcement agencies, including the Police. The purpose for these transfers is to assist law enforcement agencies and the Police in its investigations, to the extent we are obligated to do so. The lawful basis is to comply with legal obligations (Article 6(1)(c)GDPR). We may also under some circumstances have a legitimate interest in assisting the Police in its investigations even if We do not have a legal obligation to do so. In these cases We may transfer personal data to the Police on the basis of Our legitimate interest in assisting the Police and also the Police’s (in its capacity as a third party) legitimate interest in law enforcement (Article 6.1(f) GDPR).
- Potential buyers and seller The purpose for these transfers is to share information with potential buyers and sellers in a business transaction (e.g. a merger or acquisition) involving Voi. The lawful basis is our legitimate interest to carry through an acquisition or merger (Article 6(1)(f) GDPR).
If Voi transfers Your personal data outside the EU / EEA, this will only happen after protection measures have been taken to ensure an adequate level of data protection, for example by entering into EU standard contractual clauses for transfers of personal data or by making certain that the recipient of the personal data is subject to the Privacy Shield with regard to data transfers to the USA. You can obtain more details of the protection given to personal data when it is transferred outside the EEA by contacting Us.
4. Storage of personal data
Your personal data is stored only as long as is necessary in order to fulfill the purposes for which Your personal data was collected, however, if personal data is processed on account of Your consent or Our legitimate interest, Your withdrawal of the consent or objection will put an end to the processing, without affecting any processing that happened until then and without affecting any legal obligation to process personal data. The personal data which is processed to enter into, perform or administer an agreement between You and Voi, is processed for as long as You are a customer of Voi and have a Voi account. If Your account is terminated, We will delete the personal data from Your account, with the exception of personal data which needs to be stored by Us due to legal requirements or to safeguard Our legal interests.
We may send You marketing regarding Voi’s Services as well as from third parties. The marketing can be sent both by e-mail, push notifications and in-app. The purpose to send marketing is to inform You about Our Services and relevant offers from third-parties. We may also process personal data for the purpose of evaluating a marketing campaign which may include that We will transfer some personal data, mainly e-mail addresses, to the relevant marketing campaign partners.
The lawful basis for sending marketing regarding Our Services and evaluating marketing campaigns is Our legitimate interests (Article 6(1)(f), GDPR) to inform You about the Services and to analyze the result of Our marketing campaigns. We also process personal data in order to send You marketing from third-parties on the basis of Your consent (Art. 6 (1) sentence 1 point (a) GDPR), which You may withdraw at any time.
You may always opt out from Our marketing efforts, either directly in the actual marketing message or by contacting Us at firstname.lastname@example.org.
6. Rights and contact
You have certain rights in relation to Our processing of Your personal data. Your rights are the following:
- Right to access. You have the right to receive confirmation from Us that we process Your personal data, including a right to access Your personal data and receiving an electronic copy of Your personal data.
- Right to rectification. You have the right to request that incorrect or inadequate personal data about Your is updated or corrected.
- Right to withdraw consent. To the extent the processing of Your personal data is based on Your consent, You have the right to withdraw Your consent at any time.
- Right to object. When Voi is using legitimate interest (Article 6(1)(f) GDPR) as lawful basis for the processing, or if the processing concerns direct marketing, You have the right to object to the processing. In such case, we may be entitled to continue to process Your personal data if we can demonstrate a compelling legitimate interest to continue the processing operation.
- Right to erasure (“right to be forgotten”). Under certain circumstances, e.g. if you have objected to the processing and We do not have a compelling legitimate interest, You can request that Your personal data is erased. This does not, however, apply if we have a legal obligation to process the personal data or other legitimate purposes for which Your personal data is processed.
- Right to restriction. Under certain circumstances, You have the right to request that the processing of Your personal data is restricted, so that the personal data only may be stored by Voi and not processed for any other purposes.
- Right to data portability. If the processing is based on Your consent (Article 6(1)(a) GDPR) or a contract (Article 6(1)(b) GDPR) and the personal data has been obtained directly from You, You are entitled to request data portability, in which case you are entitled to receive Your personal data on a commonly used machine-readable format.
Please contact Us using the contact details below if You wish to exercise any of Your rights mentioned above. Voi will normally answer Your request within one month.
You may contact Us at: email@example.com, or by sending mail to Voi Technology AB, c/o Box 3147, 103 62 Stockholm.
7. Right to lodge complaints
If You have any complaints regarding Our processing of Your personal data, You have the right to lodge a complaint to the relevant data protection authority in Your country.
- In Sweden, please contact the Swedish Data Protection Authority (Sw. Datainspektionen)
- In Denmark, please contact the Danish Data Protection Agency (Da. Datatilsynet)
- In Norway, please contact the Norwegian Data Protection Authority (No. Datatilsynet)
- In Finland, please contact the Finnish Data Protection Authority (Fi. Tietosuojavaltuutettu)
- Sie haben das Recht, eine Beschwerde bei Ihrer lokal zuständigen Datenschutzbehörde einzureichen.
- En España, sírvase ponerse en contacto con la Agencia Española de Protección de Datos.
- En France, veuillez contacter la Commission Nationale de l’Informatique et des Libertés (CNIL)
- Per l’Italia, si prega di contattare l’Autorità garante per la protezione dei dati personali italiana (It. Garante per la protezione dei dati personali)
- In Switzerland :
- veuillez Vous adresser au Préposé fédéral à la protection des données et à la transparence
- wenden Sie sich bitte an den Eidgenössischen Datenschutz- und Öffentlichkeitsbeauftragten. (Dt. Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter)
- si prega di contattare l’Incaricato federale della protezione dei dati e della trasparenza. (Dt. Eidgenössischer Datenschutz- und Öffentlichkeitsbeauftragter)