Electra is an electric mobility service offered by DIGITAL VALLEY Ltd., a company incorporated in Cyprus with its registered office at Digeni Akrita, 51, GROUND FLOOR, 1070, Nicosia, Cyprus. Electra operates vehicle rentals according to the model of short-term, self-service eScooter-sharing for registered customers. We established a network of sharing electric scooters (hereinafter referred to as “eScooters”) via a mobile application that allows the customer to locate, rent and operate an eScooter.
1. Who processes your personal data?
2. Which type of personal data is collected?
1. User-provided Personal Data
You may provide personal data to Electra during registration and setting up of your user account. The compulsory information collected and stored by Electra during registration are: First Name, Last Name, email, phone number, date of birth and home address.
Furthermore, your debit/credit card data will be processed by Electra’s eCommerce Payment Service provider Stripe, Inc (www.stripe.com): Name of Card Holder, Card Number, Expiration Date and CVC Number.
Our in-app license verification system uses a photo-based process. The user will be prompted to photograph their driver’s license. Additionally, we ask you to take a selfie to verify that the provided documents are yours.
The images of the driving license are collected and processed by Veriff for automatic validation purposes. The driving license may be manually transcribed by our Customer Engagement Team from the images provided by the user during the online registration.
Communication data: any other particular data communicated by the user in the course of their communications with Electra (email or other means) in order to establish contact or resolve any claim with Electra.
2. Usage Data
Electra uses analytical tools to identify how the user reaches the website and social media pages and its subsequent usage. This data is not tied to any personal information, and the user, therefore, remains anonymous.
3. Service Data
. The software platform and onboard scooter technology facilitate the fully digital and automated services provided by Electra. Consequently, technical data (time and place of start of the rental, date, time and place of completion of the rental, route, actions performed with the vehicle sensors (seat, stand, switch on /switch off / pause)) is generated by the onboard devices, featuring internet connectivity.
. Geolocation systems and internet connection devices are embedded in the fleet to monitor the geolocation of all eScooters.
4. Information from other sources
Personal information may be received by Electra from third parties and third party websites (e.g. FB, Instagram, Twitter, etc) according to the policy and terms of the third party. Electra may combine and maintain this data with other personal data we hold about you.
3. For what purpose does Electra collect your personal data?
1. User-provided Personal Data
Electra processes user provided data generally to process the user’s requests or transactions, provide information on services, inform about events, promotions and other products we think may be of interest to the user. For instance, we may use the provided information for the following purposes:
- Welcome email and contact about use of services, products or information you requested
- Enable your use of the services
o Determine service eligibility
o Credit-worthiness (if needed)
o These include your driving safety records
- Respond to emails, submissions, comments, requests or complaints
- Confirm, cancel or modify your reservation of the eScooter
- Manage Invoices
- Manage payment of delayed payments
- Manage recovery of potential damages to the eScooter
- Process service payments (Only the Payment Service Provider shall store and process credit card information)
1. Service Data
Technical data collected through connected devices are processed to monitor the state, the performance and the functionalities of the eScooter (e.g. assessing whether battery level is appropriate for further use).
Geolocation data is used to verify the presence of the rented scooter within the service area, at the start and at the end of the rental. This data allows Electra to ensure that the eScooters are situated in their designated areas and are available for booking. The geolocation data is also used to identify the location of the scooter in the event of theft or suspected theft, prevent fraud and/or damaging actions, and provide assistance or emergency medical treatment in the event of an accident.
2. Usage Data
The usage data captured when accessing the Electra website and mobile app is solely processed to permit user’s navigation of the site and improve the user’s navigation experience. Electra may use this data to adapt the website to ensure an easier and quicker navigation.
Usage data is also processed for the purpose of carrying out anonymous and aggregated statistical analyses.
4. What happens if you do not provide certain Personal Data?
If the user fails to provide certain personal data that is necessary for the performance of the scooter-sharing framework contract, to carry out pre-contractual activities, or for the purpose of fulfilling duties and obligations laid down in applicable laws and regulations, Electra may not be able to perform the scooter- sharing framework contract entered into/to be entered with the user. In this case, we may have to cancel our engagement or said agreement. We shall notify if this is the case at the time.
5. Cancellation of user account
The user may, at any time, delete his account and the data associated with it. In this case, Electra commits to solely use the said information for blocking obligations imposed by the GDPR. The user may also, at any time, unsubscribe from the payment services, which does not imply the cancellation of the user account. Cancellations of payment services, user account and newsletter subscriptions, follow independent cancellation processes.
6. How long will Electra retain your Personal Data?
7. How does Electra protect your Personal Data?
We only retain collected information for as long as necessary to provide you with your requested service. What data we store, we’ll protect within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. Electra is committed to keep the utmost discretion, confidentiality and secrecy on the private and personal information that the company has access to. Electra implements all necessary security measures as governed by the provisions of the EU General Data Protection Regulation (GDPR), depending on the type of data processed. In order to protect the security of your data during transmission, we use the latest state-of-the-art encryption procedures on our website and when using the app. The data entered by the users are stored on a server. This server is located in Frankfurt am Main and is operated and maintained by the global professional server infrastructure company Amazon Web Services (AWS).
8. Who are the recipients of your personal information Electra collects about you? Electra may pass on user personal information to the following categories of recipients:
- Authorized personnel of Electra
- Third party service providers that collect data in order to enable Electra to provide its products and services
- Relevant competent authorities to process the payment of fines and/or infringements
- Companies dedicated to the rental of vehicles and / or auxiliary services with which Electra has agreements
Except for the recipients under the categories stated above, no other data transfers are foreseen. The transfer of data will be carried out under strict compliance with the provisions of current regulations on Data Protection.
9. What are your rights with respect to the processing of your Personal Data?
The user can, at any time, exercise the rights of access, rectification, deletion and objection of their personal data held by Electra.
You have the right to obtain information on the personal data stored by us at any time. Please send us an e- mail to email@example.com. Electra may only process relevant data on your person. If you determine for example, that by exercising your right of information, a date about you is incorrect or has become incorrect, we are in principle obligated to correct it immediately.
In so far as you are entitled to a legal right of objection in respect of the data processing described in these data protection instructions, we will point out to you at the appropriate place.
10. Social Networks
Electra is present in social media networks. The treatment of the data that is carried out of people who become followers in social networks (and / or perform any link or connection action through social networks) of the official pages of Electra will be governed by this section, as well as for those conditions of use, privacy policies and access regulations that belong to the social network that is appropriate in each case and previously accepted by the user.
Electra will treat your data with the purpose of correctly managing your presence in the social network, informing you of activities, products or services, as well as for any other purpose that the regulations of the Social Networks allow.
Likewise, Electra reserves the right to remove, without notice from the website or the corporate social network, those contents that were deemed inappropriate.
If the user sends personal information through the social network, Electra will be exempt from liability in relation to the security measures applicable to this platform, and the user should, in case of wanting to know them, consult the corresponding specific conditions of the network in question.
11. Communications and Notifications
Any communication between the user and Electra will be incorporated into the information system. Information provided by the user when contacting Electra via email will be collected and processed for the purpose of dealing with the enquiry.
Electra will use your name as well as your email address to send information about exclusive offers at regular intervals. These are, for example, offers on discounted trips. If you are not interested in the offers and benefits communicated via email, you can unsubscribe at any time from our information service. If you have agreed to receive our newsletter separately, you will not receive a newsletter from us in this case either.
Push messages are used to inform the user about the status of the rental. For instance, if the user left the scooter outside of our business areas or forgotten to terminate the rental. If you do not want to receive push notifications, you can disable them at any time in your smartphone settings.
12. Policy changes and updates
13. Cookies Policy
On our website, we use “cookies” which are small text files that are transferred from a Web page server to your hard drive. This allows us to automatically obtain certain data such as IP address, used browser, operating system via your computer and your connection to the Internet.
Information received from third parties with whom we have business relationships, we may combine this information with the other personal data we maintain about the user. In either case, this Policy governs this information.