Privacy Policy

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Pineapple Samoa Express Ltd

1. INTRODUCTION: DATA CONTROLLER AND WHO TO CONTACT

Pineapple Samoa Express Ltd. (we) are committed to the highest standards of privacy and data protection compliance. We are bound by privacy requirements in the countries in which we operate as may be applicable to you depending on where you are using our products or services (local laws), including:

a. If you are a resident of Asia Pacific, you are protected by:

· Australia’s Privacy Act,

· New Zealand’s Privacy Act,

· Malaysia’s Personal Data Protection Act, 

· Singapore’s Personal Data Protection Act 2012 of Singapore (PDPA), and

· Thailand’s Personal Data Protection Act, and in each case the regulations enacted under those (as may be amended from time to time).

b. If you are a resident of the European Union, you are protected by and enjoy additional rights under the European Union’s General Data Protection Regulation 2016/679 (GDPR);

c. If you are a resident of the United Kingdom, you are protected by the Data Protection Act 2018; and

d. If you are a resident of Canada, you are protected by the Personal Information Protection and Electronic Documents Act (Canada) and, as applicable, the following substantially similar legislation:

o Personal Information Protection Act (British Columbia),

o Personal Information Protection Act (Alberta), and

o Act Respecting the Protection of Personal Information In the Private Sector (Quebec).

(As each of those laws may be updated from time to time.)

This Privacy Policy sets out how and why we collect, store, use, transfer and disclose your personal information or personal data, as defined by local laws (personal data), and how you may access your personal data and correct it. This Privacy Policy also explains the use of cookies on our websites https://pineapplesamoa.com. This Privacy Policy applies to our collection, use and disclosure of your personal data. It does ‎not impose any limits on the collection, use or disclosure information or data that is not personal data under local laws, which may include business contact information and certain publicly-available information.‎

For the purposes of local laws the relevant legal entity is Pineapple Samoa Express Ltd. of Fugalei Street, Savalalo PO Box 2914, Apia Samoa… will collect and control your information, but your information may be processed by Pineapple Samoa or other third parties as set out below.

Personal data includes reference to personal information as defined by relevant local laws.

2. INFORMATION YOU PROVIDE AND INFORMATION WE COLLECT

Information you provide:

Where you create an account on our websites and other platforms, including any mobile applications (apps), and purchase services from us (including rental of scooters), you must provide us with your name, contact information (email address and mobile number), identity and licence information (where applicable) and payment information (including card details). This information is contractually mandatory and we are unable to provide the services unless this is provided.

You may also choose to allow us to use your contact information (e.g. email address) to receive marketing materials in compliance with local laws or so that we can respond to an inquiry you make.

You may also create or upload data when using our websites and other platforms, including apps. This may include user feedback, messages, and photographs (e.g. end trip photos, helmet verification photos, scooter fault photos).

When you choose to enter into our marketing and social media campaigns and/or competitions, you may provide us with personal information in connection with the campaign including your name, email address, social media username, and photographs.

Information we collect about your browser and devices:

While you use our websites and other platforms, including apps, we will also collect GPS data relating to your device and the scooter to trace any trips and provide map functionality which is strictly necessary for the services. This information is contractually mandatory, and we are unable to provide the services effectively without this data.

We also collect general information of the sort that web browsers, servers and network operators typically make available, which may include unique identifiers (e.g. IP address, IMEI numbers), browser type and settings, device type and settings and operating system (including mobile network information such as operator name and phone number and application version number). This information is necessary for us to provide basic functionality, including troubleshooting.

Some of this information could be “personal data” or “personally-identifiable” (that is they could be used to directly or indirectly identify you as an individual and natural person) for example IP addresses, phone numbers, and unique identifiers. We treat such information in the same way that we treat all other personal data (such as your name) and will only use and disclose such personal data as described in this Privacy Policy.

Information we collect about how you use our apps, websites, and services:

As you use our apps, websites and services, we may (provided that we are permitted by local law or you have provided your consent) collect information about how you interact with our platform and how you use our services (your activity), such as the links that you click, content that you view, terms, products and services that you search for, products and services that you buy, and how you interact with promotional materials or advertisements (if any), language preferences, crash reports, system activity, and the date, time and referral URL of each visitor request. This information will be collected using cookies and other technologies (including local storage). Learn more from our Cookie Policy available here.

Limits on collection, use and disclosure of personal data:

We will not collect personal data indiscriminately but will limit collection of personal ‎data to ‎that which is reasonable and necessary. We may also collect personal data as ‎authorized or required by law. Your personal data will only be used or disclosed for the purposes set out below and as ‎‎authorized or required by law.‎

3. HOW WE USE THE INFORMATION WE COLLECT

We collect information to enable you to receive the benefit of our websites, platforms, apps, products, and services. Subject to this Privacy Policy and your data preferences, we may use the information we collect for some or all of the following purposes:

· carry out our obligations and to provide you with agreed products and services;

· process payment from you in consideration of the receipt of the products and services (if applicable) and issue receipts;

· secure and protect you, us, our websites, platforms, apps, products, and services, and the public;

· establish, maintain and administer your account, including to verify your identity;

· maintain, troubleshoot, and improve our websites, platforms, apps, products, and services

· understand how and where visitors use our app, websites, and services to allocate and balance resources;

· monitor speed locations / track where helmets are placed to end trips;

· measure performance of our websites, platforms, apps, products, and services which helps us to understand customer preferences, optimise our websites and other platforms, including apps;

· develop new products and services;

· if your preferences permit, to provide you with recommendations and personalised products and services;

· communicate with you about our websites, platforms, apps, products, and services—such as to notify of changes and updates, alert you to data or security breaches, and to provide you with customer support;

· for quality assurance and training purposes;

· to create or distribute promotional and marketing material that is relevant to you, with any required consent if required by local laws;

· to carry out marketing and social media campaigns or competitions which you have entered into;

· to contact you to let you know about products and services that we believe may be of interest to you, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what’s going on with us and our products and services and/or products, to promote and market ourselves, our products and services, and our websites (including any social media pages maintained or operated by us such as Facebook, Instagram, Tiktok, Twitter, YouTube etc) via email and (if applicable) in-app notifications, with any required permissions / consent if required by local laws;

· meeting our legal, regulatory, and tax reporting obligations;

· Comply with requests from local authorities and government bodies (including local transport departments, police, public health agencies and similar bodies);

· investigating incidents of potential or suspected breaches of our Terms of Service (including any accidents or incidents involving our scooters) or applicable laws; and

· any other uses identified to you at the time of collecting your personal data or as reasonably contemplated by this Privacy Policy and our Terms of Service,

(the Purposes).

We take steps to ensure that we minimise the collection of personal data and personally-identifiable information. Where the use of personal or personally-identifiable information is not necessary for any of the above listed Purposes, we will process the personal data or personally-identifiable information in such a way as to render it non-personally identifiable before use (pseudonymisation or anonymisation as required by local law).

If you are a resident of the European Union or United Kingdom, we have set out details of the “legal basis” for our processing as required by the GDPR and UK Data Protection Act 2018 in Annex 1. 

If you are a resident of Canada, we will obtain your consent to collect, use or disclose personal data except where we are authorized or required by law to do so without consent. Your consent can be express, implied or given through an authorized representative such as a lawyer, ‎agent/mandatary or broker.‎ Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to ‎notify us that you do not wish your personal data collected/used/disclosed for various ‎purposes after you have received notice of those purposes) or otherwise.‎ You may withdraw consent at any time, subject to legal, contractual and other restrictions, provided ‎that you give us reasonable notice of withdrawal of consent. If you notify us that you withdraw ‎consent, we will inform you of the likely consequences of that withdrawal of consent, which may ‎include our inability to provide certain services for which that data is necessary.‎

4. WHEN WE SHARE YOUR PERSONAL DATA WITH OTHERS

Data Recipients

We may disclose personal data or personally-identifiable information in the following circumstances:

· when you give us explicit consent to share your data;

· when we share it with our affiliated and group companies for the Purposes specified above; if we do disclose your information to our affiliated and group companies, their use and disclosure ‎of your information will be subject to this Privacy Policy‎;

· when we share it with our partners, and other trusted organisations we work with to provide products and services to you;

· when you enter into our social media or marketing campaigns and competitions and you consent to publishing of your information on public social media platforms for marketing purposes;

· when we share it with trusted external service providers and data processors we work with to operate our business and provide products and services to you, such as data centres, web hosts, cloud storage and cloud software providers, customer support providers, payment processors, identity verification services, debt collectors, accountants, and insurers;

· when we share it with prospective sellers or buyers of our business or assets and if we, or substantially all of our assets, were acquired, or in the event that we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. If such transfers occur, any acquirer of our business will continue to use your personal data as set forth in this Privacy Policy unless otherwise notified to you; or

· when we are required or requested to share it with regulators, law enforcement agencies and other relevant parties for the purpose of enforcement action, legal or contractual compliance and reporting purposes, in accordance with applicable laws and regulations

Data transfers

We partnered with global organisation and accordingly data may be processed and shared outside of the country in which you live (as part of intra-group transfers and also to the recipients noted above including service providers); however we will only do this when we comply with local laws and put in place appropriate measures in accordance with the requirements prescribed under the local laws to ensure that the recipient of data provides a standard of protection to the personal data transferred that is comparable to the protection under the PDPA, GDPR, other applicable data protection law and this Privacy Policy. Nonetheless, you acknowledge that your personal ‎data may be processed and stored in foreign ‎jurisdictions and that governments, courts, law ‎enforcement or government or regulatory agencies in those jurisdictions may be able to ‎access or obtain disclosure of your personal data ‎under a lawful order or otherwise through the ‎laws of the foreign jurisdiction, irrespective of the ‎safeguards we have put in place for the protection of ‎your personal data.‎ Where you are a resident of the European Union or the United Kingdom, we will only transfer your personal data: (a) to countries that have been deemed to provide an adequate level of protection for personal data listed here (or equivalent in the United Kingdom); (b) where we have specific contracts approved by the European Commission which give personal data the same protection it has in Europe (or equivalent in the United Kingdom); and/or (c) where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield see EU-US Privacy Shield here (or equivalent in the United Kingdom).

5. YOUR DATA RIGHTS

Right of access

You may access and review any personal data we hold about you. On your specific request we will be able to, as soon as reasonably possible, provide you with some or all of (as requested) the following information, where available:

· personal data about you that is in our possession or under our control and the source of such data;

· the ways in which your personal data has been or may have been used or processed by us, including the logic behind any automated decisions (if applicable), during the two years preceding the date of the request;

· the ways in which your personal data has been or may have been disclosed by us, and information on to whom or to which categories of recipients such data has been disclosed, during the two years preceding the date of the request;

· how long we expect to hold on to your data, or if specific information is not available, the criteria we use to determine such a time period;

· the purpose of any use, processing, or disclosure; and

· any other information that we are required to provide pursuant to local law.

However, to the extent permitted by law, we reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:

· threaten the safety or physical or mental health of another individual;

· cause immediate or grave harm to your safety, physical or mental health;

· reveal personal data about another individual;

· reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity;

· affect the prevention, investigation, detection, and prosecution of criminal offences, or of breaches of ethics for regulated professions; or

· be contrary to national and public security, defence needs, or the national interest (including important economic, financial, monetary, budgetary and taxation matters).

If you wish to exercise your right of access, you should contact us at admin@pineappleexpress.ws and we will respond to your request within a reasonable period after the request is made and in any event within the timescales required by local law. We aim to process all requests within a month for simple requests, however where permitted by local law, complex and/or voluminous requests may take up to three months to process but we will notify you if there is likely to be a delay within a month. If we deny you access, we will provide our reason for doing so.

In order to respond to any request in relation to your data access rights, we may need to request specific information from you to help us confirm your identity. We may also contact you to ask you for further information in relation to your request to speed up our response.

We do not typically charge a fee for reasonable requests for access to your personal data. However, in some countries (as permitted by law) we may charge a reasonable fee, which will be notified to you before we move forward with the request, for time and cost in the following circumstances:

· if an extended amount of time is required to collate and prepare material for you; and

· if you wish to receive and we are able to provide hard copies or physical media (i.e. CDs, USB drives or other storage media); and/or

· if your request is clearly unfounded, repetitive or excessive.

Right to rectification and erasure

Please contact us at admin@pineappleexpress.ws as soon as possible if there are any changes to your personal data or if you believe the personal data we hold about you is not accurate, complete, up-to-date, no longer necessary for the purpose for which it was collected or processed, or lacks a valid legal ground for processing so that we can update your file accordingly. Depending on the circumstance we may change, erase, or block from use any inaccurate, incomplete, or outdated information. We may require documentary proof or evidence for certain requests. We will process any legitimate requests to correct inaccurate data as soon as practicable, and incomplete data within a reasonable time frame and in any event in accordance with timescales required by local law. Where required by local law, we will send the updated personal data to other organisations to which the data was disclosed during the year preceding the date of the correction, unless it is impossible, involves disproportionate effort, the other organisations no longer require the corrected personal data for any legal or business purpose, or you otherwise agree that we do not need to resend the corrected information to any other organisation. Where information is not corrected, you can request that there be attached to the information a statement of the correction sought but not made. 

Right to object to the collection of personal data due to your personal situation

You have the right to object to processing of your personal data where 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 and for other reasons where permitted by local law. You also have the right to object where we are processing your personal data for direct marketing purposes. Please contact us at admin@pineappleexpress.ws if you wish to make such a request, along with details of your personal situation and your reasons for objection. We will respond to all requests within a reasonable time frame and in any event in accordance with timescales required by local law. If we disallow your objection (for example in some cases we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms), we will inform you of our reasons for doing so.

Where you are a resident of the European Union or United Kingdom, you also have the right to:

· Request 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: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) 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; or (d) 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; and

· Withdraw consent at any time where we are relying on consent to process your personal data. However, 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 services to you. We will advise you if this is the case at the time you withdraw your consent. In particular, every directly addressed marketing contact sent or made by us will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us at admin@pineappleexpress.wsto make a request.

Automated Processing

In the United Kingdom, data subjects have the right not to be subject to automated decision making which produces legal effects concerning him or her or similarly significantly affects him or her. ‘Automated Decision Making’ refers to a decision which is taken through the automated processing of your personal data alone – this means processing using, for example, software code or an algorithm, which does not involve any human intervention. We do not do this.

However, where we have permissions or have the ability to do so in local laws, we may use profiling to ensure that marketing materials are tailored to your preferences and to what we think you will be interested in and to automatically pass discounts based on email addresses (e.g. for essential workers). We also use automated processing as part of the services for example, to manage auto ended trips and automated charging of users for lost helmets – this does not have a serious negative impact.

6. WE LOOK AFTER YOUR PERSONAL DATA

a. Accuracy

We take all reasonable steps within our control to ensure that the personal data we hold about you is accurate. We also take reasonable steps to ensure that the information is complete, up-to-date, relevant, and not misleading. However, we also rely on you to advise us of any changes to your personal data.

b. Protection of personal data

We take reasonable steps to ensure that your personal data is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Although we aim to create a safe, secure environment by trying to limit access to the websites to legitimate users, we cannot guarantee that unauthorised parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your personal data.

We will take reasonable steps to inform any relevant authority within the timescales required by local law and we will otherwise comply with any data breach notification obligations in applicable data protection law. We will also inform you without undue delay if the risk to your individual rights and freedoms is high — such as if the compromised data was not well encrypted. We may have other grounds for delaying or not notifying a data breach under applicable data protection law, which we may choose to rely on.

Please contact us at admin@pineappleexpress.ws immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security.

c. Retention of personal data

We will only retain your personal data to fulfil the Purposes we collected it for, including for the purposes of satisfying any legal, tax, accounting, or reporting requirements. Accordingly, we will cease to retain documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the Purpose for which that personal data was collected or further processed is no longer being served by retention of the personal data. In particular, we retain registration, account profile, transaction, trip and other information for as long as a user maintains their account. Users may request deletion of their account at any time through the profile settings in the app or by contacting us at admin@pineappleexpress.ws. Following such a request, we delete the data that it is not required to retain for purposes of legal, tax, accounting, reporting, insurance, litigation, or other regulatory requirements which we will retain for 6 years from collection or such longer period required by applicable law. In particular, we retain location, device, and usage data for these purposes for a minimum of 6 years during which time we may also use it for purposes of safety, security, fraud prevention and detection. In certain circumstances, we may be unable to delete a user’s account, such as if there’s an outstanding credit on the account or an unresolved dispute. Upon resolution of the issue, we will delete the account as described above.

7. LINKS TO THIRD PARTY WEBSITES

Our websites may contain links to and from third party websites. If you click on such links, you do so at your own risk and subject to whatever privacy policy and/or website terms may govern the use of such websites. We have no control over, and are not responsible, nor liable for, the content, privacy practices or website terms of such websites or any information you provide to them. You should read the privacy policy of these third parties to find out how they handle your personal data when you visit their websites.

8. PRIVACY COMPLAINTS

If you believe that we have breached your privacy rights in any way, or you would like to discuss any issues about our Privacy Policy please contact us at admin@pineappleexpress.ws. Any breaches will be dealt with in accordance with applicable local laws. All such enquiries or complaints will be taken seriously and will be handled as soon as reasonably practicable, and where appropriate, we will work together with the Samoan Police Department or other relevant authority to address your complaint, and/or make improvements to our systems and processes. We would, however, appreciate the chance to deal with your concerns before you approach any regulator so please contact us in the first instance using the details at the start of this Privacy Policy.

9. PRIVACY POLICY CHANGES

We may change our Privacy Policy from time to time, and so we encourage you to frequently check our websites for any changes to our Privacy Policy. Any changes will comply with local laws. If we make significant changes to this Privacy Policy, we will provide a more prominent notice of the changes, such as by emailing you. If you do not agree with any changes, you should stop using our products and services.

Annex 1 – Further Details

Purpose

Type of Data

Legal Basis

To maintain   our websites and apps and to provide core functionality, including features   to protect rider safety.

Technical and   Usage 

GPS Location

Necessary for   our legitimate interests (to maintain the relevance of our brand and   reputation and to grow our business); and

Where   required by privacy laws (for example, in relation to cookies), consent.

Where   necessary to provide our services, performance of a contract.

Where   necessary to comply with applicable laws, legal obligation.

Where   necessary for protecting the life or physical safety of a person, vital   interests.

To tailor our   websites and apps and improve our marketing strategies and create profiled   audience segments (including custom and look-a-like audiences) so that we can   issue tailored marketing content and offers.

Name (if   provided)

Email address

GPS location

Marketing and   Communications

Technical and   Usage

Contact   (where we send direct electronic marketing)

Necessary for   our legitimate interests (to define types of customers for our products and   services, to develop our business and to inform our marketing strategy and   grow our business by issuing relevant tailored offers).

Where   required by privacy laws, consent.

Registration

Email address   (includes name and avatar if sign up with Google or Facebook)

Mobile number

Device   details (brand, model and operation system)

IP address   (provide city and country details)

Biometric   data (through the use of third party identity verification services)

Performance   of a contract 

Necessary for   our Legitimate interest (to authenticate and verify a customer, to provide a   product configured to the customer’s device system, to provide a service   specific to the customer’s location)

Where   necessary to comply with applicable laws, legal obligation.

Where   necessary for protecting the life or physical safety of a person, vital   interests.

Establishment   or defence of legal claims.

Process   payment transactions

Email address

Payment   details (name, card number, expiry and CCV)

PayPal email   address

Performance   of a contract 

Necessary for   our Legitimate interest (to verify customer’s payment details, to process   payment securely and to respond to any transaction disputes)

Establishment   or defence of legal claims

Trace trip   and understand pertinent details (distance, routes, speed)

GPS location

Technical and   Usage

Performance   of a contract

Necessary for   our Legitimate interest (to provide safety announcements and features for the   customer during the trip, to respond to any disputes or investigations, and   to collect data for the Samoa e-scooter trial)

Where   necessary to comply with applicable laws, legal obligation.

Where   necessary for protecting the life or physical safety of a person, vital   interests .

Where   required by privacy laws, consent

Customer   service communication for feedback, inquiries and incidents

Name (if   provided)

Email address

Mobile number

GPS location

Necessary for   our Legitimate interest (to respond to customer and third party enquiries,   disputes and investigations, to provide troubleshooting services, to enforce   riding rules and safe practices, and to maintain our brand and reputation)

Performance   of a contract

Where   necessary to comply with applicable laws, legal obligation.

Where   necessary for protecting the life or physical safety of a person, vital   interests.

Establishment   or defence of legal claims. vital interests.

Fraud   detection

Name (if   provided) 

Email address   (from registration and/or PayPal)

Payment   details

Device   details

IP address

Driving   Licence details

Biometric   data (through the use of third party identity verification services)

Necessary for   our Legitimate interest (to respond to disputes and investigations from   customers, third parties, law enforcement and banks, to protect our business,   and to maintain our brand and reputation)

Establishment   or defence of legal claims

Compliance   with legal obligation 

Performance   of a task carried out in the public interest. 

Where   required by privacy laws (for example, in relation to biometric data),   consent.

Co-operating   with enforcement agencies, including when investigating possible criminal   activity

Name (if   provided)

Email address   

Device   details

IP address

Helmet selfie   (optional)

Parking   photos (optional)

Necessary for   our Legitimate interest (to respond to disputes and investigations from   customers and law enforcement, to protect our business, and to maintain our   brand and reputation)

Establishment   or defence of legal claims

Compliance   with legal obligation 

Performance   of a task carried out in the public interest. 

Co-operating   with public health agencies, including for contact tracing purposes or to   otherwise protect public health or safety or the life or health of an   individual.

Name (if   provided) 

Email address   

Device   details

IP address

Helmet selfie   (optional)

Parking   photos (optional) 

Necessary for   our Legitimate interest (to respond to disputes and investigations from   customers and law enforcement, to protect our business, and to maintain our   brand and reputation)

Establishment   or defence of legal claims

Compliance   with legal obligation 

Performance   of a task carried out in the public interest. 

Safety and   compliance audit

Helmet selfie   (optional)

Parking   photos (optional)

Where   required by privacy laws, Consent

Necessary to   protect vital interests of data subject 

Establishment   or defence of legal claims

Safety   contacts

Emergency   contact details (optional)

Where   required by privacy laws, Consent

Where   necessary for protecting the life or physical safety of a person, vital   interests.

Incident   management

Photos of   injuries (optional)

Medical   reports and records (optional)

Necessary for   our legitimate interest (to respond to customer communications, to   investigate incidents and to maintain our brand and reputation)

Necessary to   protect vital interests of data subject 

Establishment   or defence of legal claims

Analytics

Usage data

Where   required by privacy laws, consent

Necessary for   our legitimate interest (to improve our service and products, to develop new   technology relevant to our customers and localities, and to build our   business, brand and reputation)

Where   necessary to provide our services (eg troubleshooting and responding to   specific requests for support), performance of a contract.

Surveys

Email address

Mobile number

Name

Necessary for   our legitimate interest (to improve our service and products, to develop new   technology relevant to our customers and localities, and to build our   business, brand and reputation)

Where   required by privacy laws, consent.

Compliance   with local authorities as required for

e-scooter   trials.

Note: in some   instances, the local authorities may act in the capacity of controller.

Name

Email address

Mobile number

GPS location

Trip   information (start and end time, distance, duration, date and frequency)

Driving   Licence details

Legitimate   interest (to participate in e-scooter trials and launch in new locations, and   to comply with regulatory and contractual requirements)

Performance   of contract 

Performance   of task carried out in public interest. 

Processing is   necessary for scientific or historical research and statistical purposes

Marketing   purposes including managing social media campaigns and competitions

Name

Email address

Social media   usernames

Social media   content including posts and photos

Necessary for   our Legitimate interest (to administer social media campaigns and   competitions including awarding of prizes)

Where   required by privacy laws, consent.

To give   discounts and promotional benefits to eligible users

Name

Email address

Identification   or concession card details (full name, date of birth, card number,   residential address, and place of birth)

Photograph on   identification or concession card

Demographic   information (gender, ethnicity, age, postcode and health conditions)

Necessary for   our Legitimate interest (to verify customer’s account details and concession   card details, to provide accessibility of our products to customers, to   develop and grow our business through our marketing strategy).

Where   required by privacy laws, consent.

Where   necessary to comply with applicable laws, legal obligation.

To give   discounts and promotional benefits to eligible users

Name

Email address

Identification   or concession card details (full name, date of birth, card number,   residential address, and place of birth)

Photograph on   identification or concession card

Demographic   information (gender, ethnicity, age, postcode and health conditions)

Necessary for   our Legitimate interest (to verify customer’s account details and concession   card details, to provide accessibility of our products to customers, to   develop and grow our business through our marketing strategy).

Where   required by privacy laws, consent.

Where   necessary to comply with applicable laws, legal obligation.