Information note on the processing of personal data collected through the I’Velo Application
Version dated April 18, 2018.
- The personal data you provide us is collected and processed by the personal data operator Asociaţia Green Revolution, an association registered and operating in accordance with Romanian legislation, based in Avrig Street no. 21-31, bl. U2, sc. 1, 10th floor, apt. 43, district 2, Bucharest, registered in the Register of Associations and Foundations attached to the Bucharest district 2 Court of Law under no. 36 of March 25, 2009 (hereinafter referred to as “AGR” or “We”), registered in the Register of Personal Data Operators under no. 38265/2017.
- This information concerns all personal data collected through the I’Velo Application (“The Application” or “I’Velo App”).
For us, AGR, the security and privacy of your personal data are of significant importance. Therefore, we will take all necessary measures to ensure the security and confidentiality of personal data processed and to process personal data according to the applicable legal provisions and solely for the purposes specified below.
Personal data processed by us
In order to use, optimize and improve the performance of the Application, and to use the I’Velo bike-rental service available through this application (“I’Velo Urban Service”), we may collect the following personal data from you:
- Data we collect in order to install, use, optimize and improve the Application:
- Identification data: full name, age;
- Contact details: phone number and e-mail address or Facebook account address;
- The access password associated with the user account in I’Velo App;
- Optional data: job, favorite places (GPS coordinates), profile picture;
- Where applicable, data associated with the user’s Facebook account, to the extent that the Facebook account address has been used to create the I’Velo App account;
- Data about the device on which the application is used, i.e. the model of the telephone / device through which the application (user-agent) is used and the charge level of the battery thereof;
- Geo-location data.
- To access the I’Velo Urban Service through the Application, we will collect from you the following personal data, in addition to the personal data specified above:
- Personal identification number;
- Bank card data (to make payments by card, if applicable);
- Rental data: data automatically generated when the user purchases the I’Velo Urban Service through the Application interface, namely: the I’Velo Urban automated rental station, the date and time of taking a rented bike, the I’Velo Urban automated return station, the date and time of returning a rented bike, duration of rental (time interval between taking-over and handing-over the bike), the history of rentals, the history of transactions for the purchase of I’Velo Urban Services (payments of subscriptions, outstanding payments), history of the routes travelled by bikes rented through I’Velo Urban Services.
How we collect personal data
We collect only those personal data you provide to us on a voluntary basis in order to use the application, as well as for accessing and using its associated services. Your identification data, contact details, optional data, bank card details, and personal identification number are entered by you manually in the appropriate interface of the Application in order to register your I’Velo App account and / or to access the I’Velo Urban Service. Any other personal data relating to you are collected or generated automatically by the Application at the time of its installation or during its use.
Please note that there is no negative effect on you if you decide not to provide us with these personal data. However, your identification data, contact details, and password are necessary to create your I’Velo App User Account, which is required to install and use the Application. Your other personal data collected when accessing the I’Velo Urban Service are strictly necessary for the provision of this service, and it is not possible to provide it without collecting the additional categories of personal data listed above.
Purposes and legal grounds for processing
Personal data collected from you are processed solely for the purposes specified in this Information Note and only under a legal basis for processing as specified by the applicable legal provisions on the protection of personal data:
- The creation of the I’Velo App User Account
Your identification data, contact details, and access password will be processed by us to create your account to access the application and to optimally use it. These personal data will be processed based on the conclusion and performance of the Application Use Agreement concluded between you and AGR (“I’Velo App Agreement”). To achieve this purpose, we will process your personal data in the following ways:
- Validation of your I’Velo App User Account, monitoring and improving the security and accuracy of the operation of the application, including the detection of any unauthorized access to your I’Velo App User Account;
- Granting your access, as I’Velo App user, to the interaction facilities available in the Application interface, respectively for the purpose of being contacted by AGR, depending on the selected options in connection with the installation and use of the Application and / or for the purpose of transmitting specific alerts in the Application from the User or to the User;
- Provision of assistance services by AGR, at your request.
- Accessing the I’Velo Urban Service
Your identification data, contact details, personal identification number, bank card details will be processed by us to validate your identity (to the extent that you have, at the time of the application for the service, the status of I’Velo Relax user, to the extent that you have recently rented bikes from the I’Velo Relax rental centers) respectively for the payment of the related costs, in order to provide the I’Velo Urban Service (i.e. the conclusion and performance of the I’Velo Urban Rental Agreement, “I’Velo Urban Agreement”), so that we can hand over and recover from you, if you do not return it voluntarily, the bike made available under the I’Velo Urban Agreement concluded. The processing of your personal data is made on the legal basis of an Agreement, and all the data processed are indispensable for its conclusion and implementation.
Also, we will process the data generated automatically on the rental (with the exception of the routes travelled) for the calculation, processing and confirmation of payment of the I’Velo Urban Service you have benefited, as well as for the management of the future I’Velo Urban services (e.g. granting access to I’Velo Urban Services subject to confirmation of the payment of a subscription, maintaining access to I’Velo Urban Services during the subscription period, subject to confirmation of payment of any additional costs that may result).
- Ensuring the security of the rented goods
For the use of the I’Velo Urban service, we will automatically collect and store the GPS coordinates of the routes traveled during the rental period through the I’Velo mobile application in order to ensure the security of the leased property and its recovery in case of non-return or theft. Geo-location data will be processed based on our legitimate interest. After delivering the bike to one of the I’Velo Urban stations, you can choose to save the route to your I’Velo App User Account. Otherwise, route data will be anonymized and processed solely for statistical purposes.
- Direct marketing
If you declare your express consent, we can also process your personal data for the purposes of direct marketing, to send promotional offers on our products and services, as well as to transmit information and/or newsletter with regard to various events, campaigns and initiatives aligned with the purpose pursued by AGR. You can withdraw at any time, your consent with respect to this activity of processing by sending an e-mail to the e-mail address email@example.com, and AGR will consequently cease any processing of your personal data for direct marketing purposes.
- Provision of personalized services
We will process your geo-location data (both the real-time position and the history of the routes travelled), subject to your express consent, in order to identify and recommend locations of interest to you in the vicinity of the routes travelled by bike, monitored through the Application.
Geo-location data may be used by us, based on your express consent, in order to facilitate the interaction with other users who are in close proximity.
Also, we will process your optional data, based on your implicit and unambiguous consent by voluntarily introducing them into the Application and / or granting appropriate permissions to the Application, in order to improve the security and accuracy of the Services provided by the Application and its operation, as well as to customize the services provided by the Application, depending on the preferential settings you have selected.
You can withdraw at any time, your consent with respect to this activity of processing and require deletion of all data by sending a request to the address ivelo@greenrevolution. Thus, AGR will cease any processing of your personal data for that purpose.
- GPS monitoring
Geo-location data will be collected by us based on your implicit and unambiguous consent, manifested by activating the Race Start option, until the selection of the Race Stop button by the user or until a route is stopped in another way, provided that the GPS sensor is activated on the device on which the Application is installed, for the following purposes:
- Making and making available, based on the options selected by the user, a history of the routes traveled by bike, the travel, altitude, speed vectors (reported by GPS), GPS signal accuracy during the routes travelled, charge level of the battery of the device on which the application is used when initiating a route through the Application and completing the same route;
- Receiving and sending alerts about potential obstacles, theft or other incidents encountered or reported by the user on the routes travelled by bike, monitored through the Application, depending on your custom settings as an I’Velo App user;
- Interventions in the place indicated by you, in order to identify the exact location, if you ask for help from the AGR Support Team (e.g. troubleshooting a rented bike) or other users, depending on the settings customized by you through the Application;
- Processing of statistical data
Geo-location data (collected according to points 3 or 6 of this section), the data relating to rental and to the device on which the Application is used will be transmitted to AGR and will be used for statistical purposes in order to increase the technical performance of the Application and improve AGR services in the following ways:
- Optimizing the network of automated stations / rental centers by collecting information relating to the rental flow at hourly intervals;
- Mapping the routes travelled by the users of bikes rented from AGR in order to identify potential locations to set out new automated rental stations / centers;
- Improving the performance of the Application in the light of analyzing the feasibility of further changes (anonymized statistics on the types of subscriptions purchased, upgrading / downgrading between types of subscriptions, payment of accrued arrears).
- Correction of possible errors, malfunctions or interruptions, as well as improvement of the accuracy of the statistics and histories provided by the Application.
The data processed for statistical purposes will be anonymized, being processed in a manner that does not permit, in any form, your identification.
Taking into consideration that you are entitled to know the purpose for which we process your personal data, we will inform you before processing your personal data for any purpose other than those for which you have entrusted your personal data to us, unless this subsequent purpose is incompatible with the original purpose, in which case we will also require your consent for that subsequent processing.
Furthermore, we protect your interests, rights and freedoms in an appropriate manner. Personal data is stored in a secure location and it is also protected while in transit. Data that is no longer necessary to reach the goal is deleted.
Personal data minimization
Collection of your personal data is limited to what is strictly necessary for the attainment of the goals described above.
Duration of storage
The personal data provided by you, as well as personal data generated automatically by the Application will be stored throughout the use of the Application, but not more than 2 (two) years from your last interaction with the Application. In any case, you will be warned 5 (five) days prior to the expiry date about your personal data deletion, and to the extent that you will not log into your user account until the expiry of this period, these data will be automatically deleted.
You can delete at any time, the optional data provided, as well as the data on the routes travelled, through a direct request sent to the address firstname.lastname@example.org.
Your bank card data will be stored for the period of time selected by you at the time of the first payment and recording the bank card in the application, being automatically deleted at the time of expiry of the period in question.
Your personal data will be processed for the purpose of direct marketing and in order to provide customized services, for a period of not more than 2 (two) years from the time you have given your consent in this respect, being automatically deleted after the expiry of this period. If you withdraw your consent at any time for the processing of personal data for the purposes of direct marketing or for the provision of personalized services, we will cease any activity of processing for that purpose and we will proceed to delete the processed personal data, as soon as possible, but not later than 30 (thirty) days, with the exception of personal data the processing of which is necessary for the use of the Application or the execution of the I’Velo Urban Agreement.
Similarly, if the storage of other personal data is necessary under express legal provisions, we may still store your personal data for the time period provided for by those legal provisions.
Recipients of the personal data
Your card details will be disclosed to the payment processor, Euro Payment Services SRL, for the purpose of processing payments by card for bike rental through I’Velo Urban Service. Also, the personal data collected through the Application will be transferred abroad for technical reasons relating to the operation of the Application, to a cluster of servers located in Amsterdam, The Netherlands and owned by Digital Ocean LCC.
Subject to your consent, your contact details will be disclosed to Raiffeisen Bank S.A. and Kaufland Romania, for marketing purposes, so that the latter can send offers and other promotional messages with regard to the products and services offered.
We will not disclose or transfer your personal data to other persons, except for the cases where such disclosure or transmission is made under mandatory legal obligations, in which case we will inform you as soon as possible of their transmission.
Security of personal data
For us, AGR, the security and privacy of your personal data are very important. Therefore, we will take all necessary measures in order to ensure the security and confidentiality of the personal data processed. The security measures implemented are in accordance with Order no. 52/2002 concerning the approval of the minimum security requirements for the processing of personal data issued by the Ombudsman. If we find an incident about the security of personal data posing a risk to your rights and freedoms, we will notify the National Supervisory Authority for Personal Data Processing (ANSPDCP) within 72 hours. Also, you will be personally informed about the security incident if it is likely to pose a high risk to your rights and freedoms.
Know your rights
You have the following rights with regard to the processing of personal data which concerns you: (1) the right of access to personal data; (2) the right to obtain rectification or erasure of personal data; (3) the right to obtain restriction of the processing of personal data; (4) the right to the portability of personal data; (5) the right to object to the processing of personal data.
Exercise your rights
If you have any questions about the processing of your personal data or if you want to make any request to us, and to exercise any of your rights regarding the processing of your personal data, please contact us at the e-mail address: email@example.com, telephone number: 021 327 57 78 or at our location at the following address: Intrarea Valului no. 2, district 1, Bucharest.
We will review each request as soon as possible, but no later than one month. In case we need more information from you or we have difficulties in solving your request, we will inform you without delay that we need extra time to properly analyze your request.
In the event that you consider that we have not resolved all your requests or you are dissatisfied with our answers, you can file a complaint against us to ANSPDCP.
You can also make an appeal against us directly to the competent courts.
Thank you for entrusting us with your personal data and for making time to read the information about how we process those data. If you have any questions, please do not hesitate to contact us.
o I declare that I am aware of the provisions of this information note on the processing of personal data.
o I agree to the processing of my contact details for direct marketing purposes and I am aware of the provisions of this information note on the processing of personal data for direct marketing purposes.
o I agree to the processing of my geo-location data, in order to provide customized services and I am aware of the provisions of this information note on the processing of personal data to this effect.
o I agree that my contact details can be transferred to Raiffeisen Bank S.A. and Kaufland Romania for direct marketing purposes, in order to receive offers and other promotional materials on the services and products they offer.