Privacy Policy

Last update 31 March 2020

Cityscoot SAS (“we”, “our”, or “Cityscoot”) is committed to protecting the privacy of all visitors to our Website www.cityscoot.eu, or our Application and all Users of the CITYSCOOT Service.

Capitalised terms not defined herein have the meanings given to them in the General Conditions of Use of the CITYSCOOT Service.

The data controller of the information you provide us with or which is collected by CITYSCOOT or its affiliates is CITYSCOOT, a simplified joint-stock company (Société par actions simplifiée) registered with the PARIS Trade and Companies Register under number 800 862 021 whose registered office is at 8 rue Bayen, 75017 Paris, France.

We are responsible for collecting and processing the information you provide to us.

Please read the following privacy policy which explains how we use and protect your information. It applies to all visitors (registered or not) to our Website and Application.

 

What personal data do we collect and for what purpose do we use your personal data?

We may collect and process the following data:

Data:
The data necessary for registration to the CITYSCOOT Service, such as your contact information (name, email address, postal address), your age and other information contained on your identity card, passport and/or driving licence.
A photograph of your identity card, driver’s licence and face (selfie).

Processing purposes: 
To create your User account and allow you to access the CITYSCOOT Service.
To check the authenticity of your identity documents and verify that you are the holder.
For the purposes of direct marketing operations, to communicate to you, by email, telephone or post, our commercial offers and those of our partners complementary to the CITYSCOOT Service. We only use your contact information for marketing purposes if you have agreed to this use.
To deal with fines and road traffic or parking violations.

Legal basis for processing:
Your consent.
Our legitimate interest in verifying your ability to use the CITYSCOOT Service and/or comply with our legal obligations.
Your consent.
Our legal obligations.

Data:
Your payment information or bank details.
The complete details of your credit card are recorded in anticipation of the payment of your invoices for the use of the CITYSCOOT Service.

Processing purposes:
To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service.
For administrative purposes, including invoicing.

Legal basis for processing:
The performance of our respective contractual obligations.

Data:
Information relating to your reservations and journeys made using the CITYSCOOT Service.

Processing purposes:
To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service and to deal with your possible complaints.
For administrative purposes, including invoicing.
To deal with fines and road traffic or parking violations.

Legal basis for processing:
The performance of our respective contractual obligations and/or compliance with our legal obligations.
Our legal obligations.

Data:
The data we may ask you to provide when you report a problem with our Application, one of our Scooters or the CITYSCOOT Service, such as the initiation of our support procedure.

Processing purposes:
To ensure the safety of our Scooters and Users.
To improve the CITYSCOOT Service.
Processing claims and thefts.
To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service.
To deal with any complaints you may have.

Legal basis for processing:
Our legitimate interest in ensuring the quality and safety of the CITYSCOOT Service and our Users and equipment.
The performance of our respective contractual obligations.

Data:
The location of the Scooter data collected by means of an on-board geolocation device for safety reasons in the Scooters.

Processing purposes:
To enable Scooters to be found in the event of theft or abandonment and to provide real-time emergency assistance or relief to Users in the event of an incident or accident.
To be able to handle any complaints you may have.

Legal basis for processing:
Our legitimate interest in ensuring the quality and safety of the CITYSCOOT Service and our Users and equipment.
The performance of our respective contractual obligations.

Data: 
The smartphone location data collected by the Application if such location access is enabled on your smartphone.

Processing purposes:
To be able to display the Scooters available for reservation in the Application.
To be able to send messages relating to the use of the CITYSCOOT Service based on the user’s location.

Legal basis for processing:
Your consent.

Data: 
Information relating to the devices on which you use the CITYSCOOT Service, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, the advertising ID of your device, and any telephone number used to contact us.

Processing purposes:
To manage and secure our Application and Website and perform internal technical operations in the context of problem solving and data analysis.
To improve and optimise our Application and Website, in particular to ensure that the display of our content is adapted to your device.
To allow you to use the interactive features of the CITYSCOOT Service.
For the purposes of our advertising campaigns, as long as you have not objected to the use of your data.

Legal basis for processing:
Your consent.

Data: 
The information we obtain from your use of our Website, through the use of cookies, such as data concerning your browsing experience, including your visit to the various URL pages of our Website, the content you access or consult, the length of time you spend viewing certain pages, and your interactions with the page.

Processing purposes:
To provide you with a better service when you browse our Website and also to improve our Website.

Legal basis for processing:
Your consent.

 


Data


Processing purposes


Legal basis for processing

The data necessary for registration to the CITYSCOOT Service, such as your contact information (name, email address, postal address), your age and other information contained on your identity card, passport and/or driving licence.

A photograph of your identity card, driver’s licence and face (selfie).

To create your User account and allow you to access the CITYSCOOT Service.

To check the authenticity of your identity documents and verify that you are the holder.

For the purposes of direct marketing operations, to communicate to you, by email, telephone or post, our commercial offers and those of our partners complementary to the CITYSCOOT Service. We only use your contact information for marketing purposes if you have agreed to this use.

To deal with fines and road traffic or parking violations.

Your consent.

Our legitimate interest in verifying your ability to use the CITYSCOOT Service and/or comply with our legal obligations.

Your consent.

Our legal obligations.

Your payment information or bank details.

The complete details of your credit card are recorded in anticipation of the payment of your invoices for the use of the CITYSCOOT Service.

To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service.

For administrative purposes, including invoicing.

The performance of our respective contractual obligations.
Information relating to your reservations and journeys made using the CITYSCOOT Service.

To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service and to deal with your possible complaints.

For administrative purposes, including invoicing.

To deal with fines and road traffic or parking violations.

The performance of our respective contractual obligations and/or compliance with our legal obligations.

Our legal obligations.

 

The data we may ask you to provide when you report a problem with our Application, one of our Scooters or the CITYSCOOT Service, such as the initiation of our support procedure.

To ensure the safety of our Scooters and Users.

To improve the CITYSCOOT Service.

Processing claims and thefts.

To execute the contract(s) concluded between us and allow you to use the CITYSCOOT Service.

To deal with any complaints you may have.

Our legitimate interest in ensuring the quality and safety of the CITYSCOOT Service and our Users and equipment.

The performance of our respective contractual obligations.

The location of the Scooter data collected by means of an on-board geolocation device for safety reasons in the Scooters.

To enable Scooters to be found in the event of theft or abandonment and to provide real-time emergency assistance or relief to Users in the event of an incident or accident.

To be able to handle any complaints you may have.

Our legitimate interest in ensuring the quality and safety of the CITYSCOOT Service and our Users and equipment.

The performance of our respective contractual obligations.

The smartphone location data collected by the Application if such location access is enabled on your smartphone.

To be able to display the Scooters available for reservation in the Application.

To be able to send messages relating to the use of the CITYSCOOT Service based on the user’s location.

Your consent.
Information relating to the devices on which you use the CITYSCOOT Service, such as your IP addresses, connection data, types and versions of Internet browsers used, types and versions of plugins in your browser, operating systems and platforms, the advertising ID of your device, and any telephone number used to contact us.

To manage and secure our Application and Website and perform internal technical operations in the context of problem solving and data analysis.

To improve and optimise our Application and Website, in particular to ensure that the display of our content is adapted to your device.

To allow you to use the interactive features of the CITYSCOOT Service.

For the purposes of our advertising campaigns, as long as you have not objected to the use of your data.

Your consent.

The information we obtain from your use of our Website, through the use of cookies, such as data concerning your browsing experience, including your visit to the various URL pages of our Website, the content you access or consult, the length of time you spend viewing certain pages, and your interactions with the page. To provide you with a better service when you browse our Website and also to improve our Website. Your consent.

 

We may also process your personal data at the request of an inspection body, a government entity or as part of an official investigation, in accordance with our legal obligations. We will inform you of such processing unless we are legally prohibited from doing so.

Where the legal basis for processing is your consent, you may withdraw such consent at any time without it affecting the validity of any processing of your personal data carried out prior to the withdrawal of your consent.

 

When do we collect your personal data?

We collect personal data about you each time you use the CITYSCOOT Service, our Website or Application, and when you interact with us by electronic means or through our Customer Service.

 

Is your data secure?

The information you provide us is stored in our systems, located on our premises or on the servers of a designated third party.

We put in place the necessary administrative, technical and organisational measures to ensure an appropriate level of security according to the specific risks we have identified. We protect your personal data from destruction, loss, alteration, unauthorised disclosure or access. In particular, we have taken the following measures:

  • During transmission, we use encryption procedures to ensure the security of your personal data.
  • Access to the network and systems limited to staff with access rights
  • Users with unique passwords (password management to ensure strong passwords)
  • Firewall

 

Access permissions requested by the Application?

You will be requested to give the following authorisations to the Application in order for us to collect the data necessary for your registration and to facilitate your use of the CITYSCOOT Service.

Camera: authorisation is required to transmit and then check your identity document and driver’s licence. Such authorization is necessary while we process your registration but may be deactivated once you have been registered as a User.

Location: authorisation is requested to locate you on the map (MapBox), tell you the position of the Scooters nearby and how to access them.

Identification number of your device: authorisation is requested to send you notifications related to the CITYSCOOT Service or your rental or reservation.

You can still use the CITYSCOOT Service even if you refuse or deactivate the authorisations requested for the location and identification number of your device.

 

Use of cookies on our Website

We use certain cookies on our Website. Some are essential to the operation of our Website, while others allow us to provide you with an improved, faster and more secure user experience.

Cookies are data stored on your computer via your browser. We use the following types of cookies:

Functional cookies: these cookies are necessary for the operation of the Website and cannot be disabled in our systems. Generally, they are only configured in response to your actions that constitute a service request, such as setting your privacy preferences, identifying or completing forms. You can have your browser block cookies or send you alerts about them. However, this may prevent some parts of our Website from working.

Performance cookies: these cookies allow us to track visits and traffic sources so that we can measure and improve the performance of our Website. They help us to know which pages are the most or least popular, and to observe the behaviour of visitors to the Website. All the information collected by these cookies is aggregated and therefore anonymous.

 

How can you manage/delete these cookies?

All major Internet browsers allow you to manage cookies installed on your computer or mobile device.

If you do not want our Website to place cookies on your computer or mobile device, you can limit or delete them easily by setting your browser or mobile device. In addition, you can have your computer or mobile device send you a notification each time you receive a cookie on your computer or mobile device, so that you can decide whether or not to accept it.

When you disable some of the cookies we use, please remember that some parts of our Website may no longer function properly, and you may no longer enjoy an optimal user experience.

 

AppsFlyer SDK

In the Application, we use AppsFlyer Software Development Kit (SDK) provided by AppsFlyer Ltd. 141 5th Avenue Suite 9, New York, NY 1001, USA. AppsFlyer allows various evaluations for the success of our advertising campaign and the installation of the Application on a mobile device. For this purpose, our Application sends pseudonymized data to AppsFlyer and information indicating that the application has been started on the phone. The pseudonym is used as an advertising identifier. On AppsFlyer, only statistical evaluations are created. Information on the user’s identity is not transmitted.

AppsFlyer is certified under the Privacy Shield agreement, which ensures compliance with European data protection legislation.

More information about AppsFlyer SDK can be found at https://www.appsflyer.com/product/security-and-privacy/

You can deactivate this data processing at any time via https://www.appsflyer.com/optout. To do this, you must have the advertising ID (IDFA number) of your mobile device. 

 

Under what circumstances do we contact you?

Verification of your contact details by email and/or SMS

When you register, your email address and telephone number are verified by sending an email and/or SMS, so that we can be sure that we can contact you if necessary (only when you use the CITYSCOOT Service).

Notifications on your phone

These “push messages” allow you to be informed of the confirmation of your reservation and its cancellation, or to be alerted when a Scooter has been inactive for a certain period of time. They also allow us to warn you in case of exceptional situations (failure of the CITYSCOOT Service, adverse weather conditions, etc.). Very convenient to use, you can still disable notifications in your smartphone settings.

SMS

In exceptional cases relating to the use of the CITYSCOOT Service, SMS messages can replace the sending of notifications if they do not reach you.

Email

We will use your name and email address to send you information about your registration, your rental, your payments, but also to send you promotional offers or information about the CITYSCOOT Service. If you do not wish to receive offers or general news, you can unsubscribe from the mailing lists at any time by clicking on the link at the bottom of the email.

Telephone

We may contact you by telephone in exceptional circumstances in order to quickly and personally resolve a problem that occurred during your rental (for example if a fall was detected on the Scooter during the rental period).

 

How long do we keep your personal data?

We only keep your personal data for the time necessary for the operations for which it was collected and in compliance with the regulations in force. In general, we keep personal data only as long as it is necessary to meet the contractual or legal obligations for which we have collected the data or to fulfil a legitimate interest as mentioned above. We then delete the personal data, unless we still need it until the expiry of the legal limitation period for evidence purposes for civil law actions, which may not exceed 5 years, or due to legal retention obligations.

The retention period varies according to the type of personal data.

Your browsing and login data (cookies) are stored for a maximum period of 13 months.

Your bank details are kept for payment purposes until the date of termination of your User account. They can then be archived for evidence purposes for a limited period of time of 13 months from the last debit made by us.

We will keep your photos for documentation purposes, as long as you use the CITYSCOOT Service.

Your location data is kept at the end of the journey for a maximum period of 2 years and can only be consulted by us in the event of a dispute concerning an invoice, a claim or a traffic offence as well as in the event of litigation or judicial requisition, with access limited only to CITYSCOOT’s services and/or to the authorities needing to investigate and process the files concerned.

You can consult the history of your journeys (arrival and departure addresses) in your Personal Space for a maximum of 2 years.

If you agree to receive commercial offers and advertisements, and unless you subsequently object, your data may be retained for that purpose for a period of 24 months from the collection of your data or last contact from you.

If your User account is closed, your data will be deactivated and will no longer be accessible to you online. Any personal data about you that we are required to retain after your account is closed due to regulatory, insurance, dispute handling or other legal requirements will be archived and will only be accessed by us in the event of any dispute, claim or road traffic or parking violations.

 

Users accessing our Service via the Uber application

If you access the Cityscoot Service via the Uber application, you agree that some of your personal data may be shared between Uber and Cityscoot in order for you to use the Cityscoot Service.

The following data will be shared with us by Uber:

– your contact information (name, email address, phone number) as it appears in your Uber account;

– the number of the scooter you wish to reserve via the Uber Application.

In the event of a road traffic or parking violation, the Uber User may be asked to provide us with his/her date of birth and postal address for the processing of the corresponding fine.

We will provide the following personal data to Uber in connection with your use of the Cityscoot Service via the Uber application:

– information regarding the journey made with the Cityscoot Service and the amount due so that Uber can bill you for the use of our service;

– your trip history (date, departure and arrival times, information about the route you took, the distance you travelled, and the registration number of the Scooter) so that you can view this history via your Uber account.

This data is shared by Uber and Cityscoot to enable Uber users to access the Cityscoot Service via the Uber application, to prevent and detect fraud, and to ensure the security of users of the Cityscoot Service and our equipment. The data exchanged may also be used by Uber to provide Uber users with offers and benefits relating to the Cityscoot Service or to inform them about other products or services.

The data communicated to us or collected by us in the context of your use of the Cityscoot Service are kept by Cityscoot under the same conditions as those collected for Users registered with Cityscoot. The closure of your Uber account will be automatically reported to Cityscoot and will result in the deletion of your data from our systems, except for the data that we are obliged to keep as indicated above for Users registered with Cityscoot.

Please see Uber’s Privacy Policy (link here: https://help.uber.com/en/riders/article/privacy-notice-information?nodeId=e1f427a1-c1ab-4c6a-a78a-864f47877558) for more information about Uber’s treatment of your personal data, including how long it will be kept.

We do not share any data with Uber regarding users accessing the Cityscoot Service via a Cityscoot account.

 

Sharing of your personal data

We may share your personal data with our subsidiaries and affiliates to enable them to provide the CITYSCOOT Service or process data on our behalf.

We may also share your personal data with our service providers and suppliers, including for the purpose of processing your payments or authenticating your documents.

We may share your personal data with our business partners for marketing purposes if you have previously agreed to the use of your personal data for this purpose.

We only share personal data with third parties who ensure that appropriate security measures are in place, so that processing activities comply with the requirements of applicable personal data protection law, and to ensure the protection of your individual rights.

In the event of accidents, theft, fines or road traffic or parking violations, your personal data will be communicated to our insurance company (and/or our brokerage company), which undertakes to formally respect the confidentiality of the data transmitted and, where applicable, to the police, gendarmerie and justice services. We will communicate your identity to the competent police authorities, in accordance with the laws in force, if you are alleged to have committed an offence and your identity could not be detected at the time of the offence.

We may also be required to provide certain data relating to the use of the CITYSCOOT Service to municipal authorities in order to improve transport services. We take appropriate measures to ensure that you cannot be identified by the data transmitted.

 

Transfer of your personal data outside the European Economic Area (“EEA”)

We are required to ensure that any personal data processed by us and our service providers outside the EEA is protected in the same way as it would be if processed in the EEA.

Thus, in the event of a transfer of your personal data to a service provider, supplier or business partner located in a country outside the EEA that is not considered by the European Commission to provide an adequate level of protection, we undertake to guarantee the protection of your personal data by signing contractual clauses based on the model of the European Commission, or by any other mechanism in accordance with the law in force.

 

What are your rights?

Right to be informed: you have the right to receive clear, transparent and easily understandable information about how we use your information and rights.

Right of access: you have access to the personal information we process.

Right of rectification: you may request the correction of your information if it is inaccurate or incomplete and ask us to correct any errors contained in the information we hold.

Right of cancellation (right to be forgotten) and right to limit processing: you may request the deletion or removal of the information we hold about you. However, deletion is only possible for data that we do not need to close our contractual relationship with you or to comply with legal archiving obligations. As a matter of principle, we only use your data as long as you use the CITYSCOOT Service.

Right to data portability: you also have the right to receive the data you have provided to us, in a structured, commonly used and machine-readable format and/or, to the extent that it is technically feasible, to request that the data be transmitted to a third party.

Right to object to processing: you have the right to object to certain types of processing, including for reasons relating to your particular situation or concerning processing based on our legitimate interest, as well as to any processing for direct marketing and profiling purposes. You may object to the processing of your data for direct marketing and profiling purposes by changing your contact preferences. Please note that this right of objection does not apply if our legitimate interests in pursuing the processing prevail over yours (for example, the geolocation of the Scooter is essential to ensure the provision and security of the CITYSCOOT Service and cannot be disabled).

Right to organise the fate of your data after your death: you can also define guidelines on the fate of your personal data after your death.

 

To exercise these rights, please contact us at: [email protected]. Please attach a photocopy of your identity document to your request.

  

Right to file a complaint: you have the right to file a complaint about the way we use or process your personal data with the national data protection authority: Commission Nationale de l’Informatique et des Libertés (CNIL), 3 Place de Fontenoy – TSA 80715 – 75334 PARIS CEDEX 07 (01 53 73 22 22 – www.cnil.fr).  You also have the right to seek compensation from the competent courts if you consider that we have not respected your rights.

 

How can I be informed of a change in our privacy policy?

Any changes to our privacy policy will be posted on the Website and the Application. We invite you to regularly consult this policy. In the event of significant changes, we will inform you of these changes by email and/or by means of a push notification on your smartphone.