Privacy Policy

Last updated on 01 May 2019

At BRIZ, we are committed to protecting your privacy. Please, read this Privacy Policy to become familiar with further details of our approaches towards your personal data.

What we need and why?

Our Privacy Policy governs the processing of your personal data, including but not limited to collection, process, use, storage, transfer etc. connected with your use of services, as defined in our Terms of Use.

What do we do with it?

We process your personal data. No third party providers have access to your personal data unless specifically required by law or duly encrypted.

1. Responsible Controller

BRIZ Mobility Limited Ltd., Clifton House, Fitzwilliam Street Lower, Dublin 2, D02XT91, Ireland (hereinafter: “we” or “BRIZ“) is the operator both of the Website www.briz.app (hereinafter, the “Website”) and the BRIZ app (hereinafter, the “Application”) and therefore the responsible party of the personal data of the users (hereinafter: “you”, “your” “users” or “users”) of the Website and the Application in terms of the General Data Protection Regulation (“GDPR”).

2. Contact

If you have any questions regarding the use of your personal data, please do not hesitate to contact us at hello@briz.app or via our customer service hotline.

3. General Info and Personal Data

3.1 We protect your privacy and your personal data. We collect, process, and use your personal data in accordance with the content of this Privacy Policy and the GDPR and only as far as this is necessary to provide a functional Website and Application as well as our content and services.

3.2 Personal data within the meaning of this Privacy Policy means any information relating to an identified or identifiable natural person. This includes the personal data required for registration in the Application and its usage, such as:

  • your name,
  • telephone number,
  • billing information
  • location,
  • camera`s access,
  • information about the WLAN connection,
  • information about Bluetooth connection,
  • the IP-address of your computer/phone,
  • the operating system of your computer/phone,
  • the type of browser you are using (Firefox, Google Chrome, etc.) and its version,
  • the request of your browser,
  • the time of this request,
  • the status of the request,
  • the amount of personal data transferred in the context of this request,
  • date and time of access,
  • the URL of the Website from which you accessed our Website (so-called referrer URL),
  • the URL of the Website you are visiting from our Website.
  • your device and card identification,
  • the name of your telephone, if you have named it using your own name,
  • the quantity of the transferred personal data with respect to that request,
  • personal data related to usage of the Electric Scooter, such as the place of departure, arrival, rental period, insofar as required for performance of the BRIZ`s services as stated in its Terms of Service.

 

3.3 Personal data also includes information about your use of our Website and the Application. This includes, for example, information about the location from which you access data from our Website or Application or the extent of the data transfer. This personal data is usually processed using server log files and cookies.

4. Processing Purposes

4.1 Your personal data will be processed in order to allow access to the services provided by BRIZ and to have access to information hosted on our Website and the Application and provide the information and the services requested by you in the Application and in the Website.

4.2 We process your personal data to comply with the legal obligations that we are subject to.

4.3 We will also process your personal data for sending commercial communications in the case that you have authorized us to do so.

4.4 In addition, we can process your personal data in the following cases:

  • in order to reply to any request you may send to us,
  • in order to understand your needs, provide services that are relevant to you and boost the quality of our services,
  • in order to communicate with you as a possible member of our great team.

5. Origin and Legal Basis for the Processing of Your Personal Data

5.1 The personal data that we process has been provided by you.

5.2 Some personal data may only be processed with your consent in accordance with Art. 6 para. 1 lit. a GDPR. You can withdraw this consent at any time for the future. “For the future” means that your withdrawal has no effect on the processing of personal data that we have made between the granting of your consent and your withdrawal. You do not have to justify your withdrawal. An informal message via e-mail to hello@briz.app. is sufficient.

5.3 We process personal data that we require to fulfil or conclude a contract with you or to carry out pre-contractual measures on the basis of Art. 6 para. 1 lit. b GDPR.

5.4 Other personal data we process according to Art. 6 para. 1 lit. f. GDPR for the protection of our legitimate interests, e.g. for the technically error-free and optimized provision of our services.

5.5 It may be also necessary to process personal data in order to fulfil a legal obligation that we are subject to (Art. 6 para. 1 lit. c GDPR) or to protect your vital interests (Art. 6 para. 1 lit. d GDPR).

5.6 In addition, we may be legally process your personal data when the following applies:

  • processing is necessary to provide you our services according to our Terms of Service, which constitutes a contract between you and us as regards to information services of our Website;
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party on the conditions prescribed by the data protection legislation;
  • processing is necessary for compliance with our legal obligations;
  • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us.

6. Recipients

Your personal data may be transferred to public administrations, including courts, when it is required in accordance with the current legislation in force. Additionally, companies that provide services to us and are contracted by BRIZ, such as payment providers, can have access to your personal data. To the extent BRIZ uses such contractors, a description of their services can be found below. Unless noted otherwise below, these external companies process data for BRIZ as data processors, i.e. based on BRIZ’s instructions.

7. Duration of Storage

Your personal data will be kept as long as it is necessary for the purposes established in this policy. However, it may happen that the European or national legislator requires a longer storage period. In these cases, the personal data is not deleted or locked until the corresponding retention period has expired. After this period, the personal data will be definitively deleted.

8. Download / Installation of the Application

8.1 When you download/install our Application, we will ask for permission to use interfaces to access functions and contents of your device in order to collect certain personal data including:

– your location,

– your camera`s access,

– information about the WLAN connection,

– information about your Bluetooth connection (possibly).

8.2 Since we require the personal data to fulfil our contract with you, the legal basis is Art. 6 para. 1 lit. b GDPR.

8.3 We need access to the above interfaces and personal data in order to provide you with the functions and services of our Application and thus to fulfil our obligations under the general agreement as well as to enable the booking of an Electric Scooter. For example, your location is needed to show you the next Electric Scooter in your area and how to get there. In addition, if you rent an Electric Scooter, we track your location when locking and unlocking the Scooter. If a Scooter is rented, we retrieve the location of the Scooter directly via a GPS module integrated into the Scooters and not via your device. Location tracking only takes place to ensure a proper lending and return process or to assist you in the event you report a service case.

8.4 Access is possible from the moment the Application is installed on your mobile device. Depending on your settings, this access is permanent or only for the duration of the actual use of the Application. For the highest possible level of personal data protection, we recommend that you only allow access during the actual use of the Application. The personal data retrieved in each case are generally stored only for the duration of the actual use of the Application. We store your location retrieved in the event you report a service case for a maximum duration of one year at the time of reporting. We store the location data that we collect in connection with locking and unlocking our Electric Scooters for a maximum duration of 3 years. The location data will then be made anonymous or will be blocked and deleted according to the rules stated in clause 7 of this Policy regarding “Duration of the Storage”.

9. Google Maps, Google Analytics and Amazon Web Services

9.1 Our Application uses Google Maps API applications. This is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. In this context, we must store your IP address. Usually, this information is transferred to a Google server in the USA and stored there. However, this transmission is made anonymous and Google LLC has subscribed to the EU-U.S. Privacy Shield Framework. A conclusion on your person is thus excluded. This enables us to display interactive maps directly in the Application and enables you to use the map functions. This application is essential for the functionality and complete provision of our content and services. You can view the Google Terms of Use here: https://policies.google.com/terms?hl=en. The additional terms of use for Google Maps/Google Earth can be found here: https://www.google.com/help/terms_maps.html. You can find Google’s privacy policy here: https://policies.google.com/privacy?hl=en-GB.

9.2 We use Google Analytics. This is an analysis tool provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Inc, has subscribed to the EU-U.S. Privacy Shield Framework. We use this technology to make our Website more interesting for you and to optimize its functionality. The following personal data is processed in this context:

– the IP address of your computer,

– if necessary, the operating system of your computer,

– the type of browser you are using (Firefox, Google Chrome, etc.) and its version,

– the referrer URL,

– the time of the request.

9.3 We use Amazon Web Services Inc. 410 Terry Avenue North, Seattle WA 98109, USA. Amazon Web Services Inc. has subscribed to the EU-U.S. Privacy Shield Framework. In this context, information is transmitted exclusively to servers in and stored with Amazon Web Service.

Amazon may not use the personal data for other purposes. In addition, Amazon is obliged to treat the information in accordance with this data protection declaration and the relevant data protection laws.

More information can be found in Amazon’s privacy policy: https://services.amazon.com/privacy-policy.html.

9.4 These personal data are processed on the basis of Art. 6 para. 1 lit. b GDPR for the conclusion and performance of a contract as well as a legitimate interest in improving the services of our Website and our advertising.

9.5 We process this personal data to show you the location of the nearest Electric Scooter and how to get there. Furthermore, we can show you the expected running distance and running time to the selected Electric Scooter.

9.6 In addition the purpose of the processing is our legitimate interest in improving the services of our Website and our advertising.

9.7 The personal data will only be stored for the duration of the respective booking period and will then be deleted.

9.8 If you only wish to accept our own cookies, but not those of our service providers and partners, you can select the setting in your browser “Block third-party cookies”.

10. Registration with your Telephone Number, Facebook Connect or Google Authentication

10.1 In order to use our Application, you have to register. You can register by entering your telephone number in the input screen provided for this purpose.

10.2 You also have the option to register in our Application via Facebook Connect. This is a service of Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Ireland. As the registration is performed through Facebook Connect BRIZ cannot control the procedure to sign on in the registration. For that reason, BRIZ dissociates from any responsibility arising from any breach, action or inaction of Facebook Connect or any breach of third parties that can be performed in the registration procedure. By clicking on the button integrated into our Application for this purpose, you can register with your Facebook login data and thus speed up the login process. This process links our Application to your Facebook profile and you consent to the processing of the public data on your Facebook profile.

10.3. You also have the option to register in our Application via Google Authentication. This is a service of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Inc. As the registration is performed through Google Authentication BRIZ cannot control the procedure to sign on in the registration. For that reason, BRIZ dissociates from any responsibility arising from any breach, action or inaction of Google Authentication or any breach of third parties that can be performed in the registration procedure. By clicking on the button integrated into our Application for this purpose, you can register with your Google login data and thus speed up the login process. This process links our Application to your Google profile and you consent to the processing of the public data on your Google profile.

10.4 The personal data will be processed with your consent and therefore on the basis of Art. 6 para. 1 lit. a GDPR. You can revoke your consent at any time for the future. “For the future” means that your revocation has no effect on the processing of personal data that we have made between the granting of your consent and your revocation. You do not have to give reasons for your revocation. An informal message by e-mail to us is sufficient.

10.5 The processing of your personal data during registration is carried out on the basis of Art. 6 para. 1 lit. b GDPR for the conclusion and fulfilment of a contract.

10.6 These personal data are processed solely in order to provide you with the functionality of our Application. Without registration as a user, there is no way to rent and use an Electric Scooter through the Application.

10.7 As soon as you uninstall the Application and the legal retention periods have expired, the personal data entered during registration will be deleted.

11. Payment Method Credit Card via PayAlly, Stripe, PayPal, Apple Pay and Google Pay.

11.1 As soon as you have registered by one way or the other, you have the possibility to choose a payment method. For payment by credit card, we use the payment service provider PayAlly, PayAlly Limited is a company registered in England and Wales (company number 10600055), Authorized Payment Institution license Nr. 774327 issued by Financial Conduct Authority of United Kingdom.

If you decide to pay via PayAlly, the personal data you enter will be transmitted to PayAlly for payment during sign-up. PayAlly may not use them for other purposes. PayAlly is also subject to bank client confidentiality and is obliged to treat the information in accordance with the relevant data protection laws.

PayAlly’s privacy policy can be found here: https://payally.eu/privacy-policy.

11.2 In addition, we can use the payment service provider Stripe, Stripe, Inc. 185 Berry Street, Suite 550 San Francisco, CA 94107, USA; or PayPal, PayPal (Europe) S.à r.l et Cie, S.C.A., so you can also pay via your PayPal account.

If you choose to pay via Stripe or PayPal, the information you provide will be sent to Stripe or PayPal for payment at sign-up. Stripe or PayPal may not use them for other purposes. In addition, Stripe or PayPal is required to treat the information in accordance with this Privacy Policy and the applicable data protection laws.

You can find Stripe’s privacy policy here: https://stripe.com/de/privacy.

You can find PayPal’s privacy policy here: https://www.paypal.com/ch/webapps/mpp/ua/privacy-full?locale.x=de_CH.

PayPal may pre-authorize your PayPal account on behalf of BRIZ by debiting your users account with EUR 1, but this amount will be refunded immediately.

11.3 In addition, we use the payment service provider Apple Pay of Apple lnc., so iOS users can pay via your Apple Pay account.

You can find Apple Pay’s security and privacy overview here: https://support.apple.com/en-us/HT203027

You can find Apple’s Privacy Policy here:

https://www.apple.com/legal/privacy/en-ww/

11.4 In addition, we use the payment service provider Google Pay of Google lnc., so Android users can pay via your Google Pay account.

You can find Google’s Privacy Policy here: https://policies.google.com/privacy.

11.5 The personal data are transmitted on the basis of Art. 6 para. 1 lit. b GDPR for the conclusion and performance of a contract.

11.6 The personal data are transmitted exclusively for the purpose of providing you with the functions and services of our Application. Without depositing a method to pay the rental price of an Electric Scooter (both for single trips and for subscriptions or to top up your credit in the Application), there is no way to rent and use an Electric Scooter through the Application.

11.7 All the payment data is stored by PayAlly and PayAlly or other payment operator mentioned above itself. Please also note PayAlly’s and other privacy policy linked above.

11.8 The users have the right to receive, free of charges, the corresponding invoices if it is requested.

12. Using BRIZ Website and Application

12.1 Whenever you access our Website, we collect the following information about your computer:

– the IP-address of your computer,

– the operating system of your computer,

– the type of browser you are using (Firefox, Google Chrome, etc.) and its version,

– the request of your browser,

– the time of this request,

– the status of the request,

– the amount of personal data transferred in the context of this request,

– Date and time of access,

– the URL of the Website from which you accessed our Website (so-called referrer URL),

– the URL of the Website you are visiting from our Website.

12.2 Every time you open our Application, we collect so-called server log files. These personal data log all requests and accessed by visitors to the Application and record all error messages from an Application. These include:

– the IP address of your mobile device,

– your device and card identification,

– the name of your telephone, if you have named it using your own name,

– the time of the request,

– the status of the request,

– the quantity of the transferred personal data with respect to that request.

12.3 The legal basis for this is Art. 6 para. 1 lit. f GDPR. The operator of Application has a legitimate interest in the storage of this personal data because he needs it to detect and eliminate errors of the Website and Application, to determine the utilization of the Website and the Application or to make improvements.

12.4 The purpose of this type of personal data processing results from our legitimate interest mentioned above: This personal data is processed to detect and eliminate Website and Application errors in order to determine the utilization of the Website and Application or to make improvements.

12.5 The IP address of your computer will only be stored for the duration of your visit and will subsequently be deleted immediately or made anonymous by shortening it. The remaining personal data is stored anonymously for an unlimited period of time.

12.6 The personal data will be deleted as soon as you close our Application.

12.7 The privacy of children is one of our concerns. Here at BRIZ we can provide services only in case you are aged 16 or older. If you are under 16 you will need to get your parent’s/guardian’s permission before submission of any personal data to BRIZ. If you are underage, and there are no data as to your parent’s/guardian’s permission to use our Website and Application, we will not collect or process your personal data, and you will have limited/restricted use of our Website and Application.

13. Cookies

We explain here what cookies are, how we use cookies, your choices regarding cookies and further information about cookies.

 

13.1 Does BRIZ use cookies?

Yes. BRIZ uses cookies and other technologies on our Website and within our related services. By using our Website or our related services, you consent to the use of cookies for the purposes we describe in this policy.

13.2 What are cookies and how do they work?

Cookies are small files comprising bits of text that are installed on your computer or mobile device each time you open a Website. These small files enable users to authenticate themselves on successive visits to the Website and gain access to the services.

Your browser tells our systems if any cookies files were installed in your computer and after our software systems connect to the cookies we are able to analyze the information the cookies files give us.

13.3 What cookies does BRIZ use and for what purposes?

We use the personal data we process using technically unnecessary cookies to tailor our Website to your individual interests. This includes, for example, advertising that corresponds to your personal interests.

13.4 What is the duration of cookies storage with BRIZ?

The duration of storage varies depending on whether the cookies are session cookies or temporary cookies. Session cookies are automatically deleted after you leave our Website. Temporary cookies are stored on your device for a certain period. Cookies that we use for statistical purposes are automatically deleted after a defined period.

13.5 Can I opt-out from the use of cookies after I agreed BRIZ will use it?

No, you may not opt-out from the session cookies used within the use.

13.6 What are your choices regarding cookies

As a user, you have full control over the use of cookies and the personal data processed in this way. If you do not want to use cookies, you can set your browser so that the storage of cookies will not be accepted. Please note that in this case, you may be able to use our Website only partially or not at all.

13.7 Finally, please be informed that you have the right to withdraw your consent so that we cannot use cookies, setting your browser in the terms mentioned below:

– If you use Microsoft Internet Explorer, in the menu option Tools, selecting Internet Options and accessing Privacy; For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835.

– If you use Firefox for Mac in the Preferences menu option, selecting Privacy, accessing the Show Cookies section, and in the Tools menu option, selecting Options, accessing Privacy and then using a custom configuration for the history; For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored.

– If you use Safari, in the Preferences menu option, selecting Privacy;

For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US.

– If you use Google Chrome, in the Tools menu option, selecting Options (Preferences in Mac), accessing Advanced and then in the Content Configuration option in the Privacy section, and finally checking Cookies in the Content Settings dialogue; For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050.

For any other web browser, please visit your web browser’s official web pages.

13.8 Where can you find more information about cookies?

You can learn more about cookies and the following third-party websites:

AllAboutCookies: http://www.allaboutcookies.org/.

Network Advertising Initiative: http://www.networkadvertising.org/.

14. Personal Data Security

14.1 We protect our Website and Application and other systems by technical and organizational measures against loss, destruction, access, modification, or dissemination of your personal data by unauthorized persons. These measures include but are not limited to access control, input control and order control.

14.2 BRIZ processes your personal data using computers and/or other IT enabled tools. BRIZ takes technical and organizational measures to ensure the information is processed in a manner that ensures appropriate security of information, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage. We also guide and train our personnel to process your personal data securely according to our internal personal data protection policies.

15. No Disclosure of Your Personal Data

We will not disclose your personal data to third parties, except if you have consented to the personal data transfer or if we are authorized or obliged to transfer personal data due to legal provisions and/or official or court directions. This may refer to cases including but not limited to the provision of information for the purposes of law enforcement, danger prevention or the enforcement of intellectual property rights.

16. Personal Data Protection and Third-Party Websites

16.1 This Website may contain hyperlinks to or from third-party websites. If you follow a hyperlink to one of these websites, please note that we cannot assume any responsibility or guarantee for external contents or personal data protection conditions. Please verify the respective applicable data protection provisions before you transfer personal data to these websites.

16.2 Personal data communication via the internet cannot be guaranteed to be error-free and/or available at all times according to the current state of technology. In this respect, we are not liable for the constant and uninterrupted availability of our trading system.

17. Amendments

We reserve the right to amend this Privacy Policy at any time with future effect. The respective latest version is available at all time on the Website and the Application. Please access the Website and Application regularly to find out about the applicable Privacy Policy.

18. Your Rights and Contact Information

18.1 Right to withdraw your consent acc. Art. 7 para. 3 GDPR: In cases where the processing of your personal data is only possible with your consent, you can revoke this consent at any time in the future. “For the Future” means that your revocation has no effect on the processing of personal data that we have made between the granting of your consent and your revocation. You do not have to justify your withdrawal. An informal message via e-mail to us is sufficient.

18.2 Right of access by the data subject in acc. Art. 15 GDPR: you may request confirmation from us at any time whether we process personal information concerning you. In this case, you have the right to request information about:

– the purposes for which we process your personal information

– the categories of personal data we process,

– the recipients or categories of recipients to whom we have disclosed or will disclose the personal data,

– the storage duration (as far as possible),

– the right of rectification, erasure or restriction of our processing, as well as the right of opposition to such processing,

– the existence of a right of appeal to a supervisory authority,

– the origin of your personal data, as far as they were not collected by us,

– the existence of automated decision-making including profiling and, where appropriate, detailed information on the logic, scope and impact of such processing.

For this purpose and / or for more information, please contact us via hello@briz.app. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.3 Right to rectification acc. Art. 16 GDPR: you can view your personal data at any time free of charge and, if necessary, request their correction and supplementation.

For this purpose and / or for more information, please contact us via hello@briz.app.. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.4 Right to erasure acc. Art. 17 GDPR: you can view your personal data at any time free of charge and request cancellation if:

– these are no longer needed for the purpose for which they were processed,

– you have revoked your consent and there is no other legal basis for the processing,

– you have filed an objection against the processing of your personal data acc. Art. 21 GDPR,

– we have processed your personal data unlawfully,

– the deletion is required to fulfil a legal obligation under EU or national law.

For this purpose and / or for more information, please contact us via hello@briz.app. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.5 Right to the restriction of processing acc. Art. 18 GDPR: you can view your personal data at any time free of charge and, if necessary, request their blocking if:

– you deny their accuracy,

– the processing is illegal, but you reject the deletion of the personal data,

– we no longer need the personal data, but you need it for the assertion, exercise or defence of legal claims,

– you have filed an objection against the processing of your personal data acc. Art. 21 GDPR, but it is not yet certain whether our interests in processing outweigh your interests.

For this purpose and / or for more information, please contact us via hello@briz.app. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.6 Right to data portability acc. Art. 20 GDPR: At our request, we are required to provide you with data that we process automatically based on your consent or in fulfilment of a contract in a portable and secure format. The direct transfer of personal data to another person responsible is also possible at your request. However, it only takes place if technically feasible.

For this purpose and / or for more information, please contact us via hello@briz.app. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.7 Right to object acc. Art. 21 GDPR: In cases where we use your personal data on the basis of Art. 6 para. 1 lit. f GDPR, you have the right to appeal against the processing, as far as there are reasons for this, which result from your particular situation or the objection against direct mailing.

For this purpose and / or for more information, please contact us via hello@briz.app. If you have any questions, comments or inquiries regarding the processing of your personal data, please also contact us at the contact details provided.

18.8 Right to lodge a complaint with a supervisory authority acc. Art. 77 GDPR: If you think that we have violated data protection regulations, you can contact a regulatory authority for personal data protection in the non-public area, in particular, the supervisory authority of your habitual residence, your work-place or the location of such violation.

BRIZ Mobility Limited Ltd.

May 2019