1. General

This privacy policy (the ”Privacy Policy”), together with the rental agreement (the “Agreement”), available on www.bicelo.com, describes how Bicelo, (We, Our) as a data controller, process its customer’s (“You”) personal data when using the Services.

For rentals in Sweden and Italy the data is processed by;

Majestic Mobility AB, a company registered under the laws of Sweden with TAX ID 559232-2597, and having its registered address at Slakthusplan 3, 121 62, Johanneshov, Sweden.

For rentals in Spain the data is processed by;

Majestic Mobility Spain S.L. a company registered under the laws of Spain with Tax ID number B13725379, and having its registered address at Diagonal, Avenida 458, 7, 08006, Barcelona, Spain.

Both entities are mentioned below as Bicelo, We or Our.

Unless otherwise stated in this Privacy Policy, the definitions used herein will have the same meaning as in the Agreement. Questions regarding this Privacy Policy and Bicelo’s processing of Your personal data can be sent to hello@bicelo.com

2. Collection, purpose and use of personal data

Bicelo will collect personal data which You submit when creating an account in the Bicelo app or which is created when You are using the Bicelo app or the Services.

Bicelo processes Your personal data in accordance with the following:

a) For the purposes of entering into, fulfilling and administering our contractual relationship (including handling payment) with You we process the following personal data:

• Location data;
• Contact details (such as name, address, e-mail address and phone number);
• Device ID; and

Our lawful basis for the processing of your personal data for this purpose is to fulfil our contractual obligations with You (Article 6(1)(b) GDPR).

b) For the purposes of performing statistical analyses and analyze data in order to develop the Services regarding functionality, security and methods, as well as analyze markets and customers, we process the following personal data:

• IP address;
• Information about Your device; and
• Information about Your use of the Biceo app and the Services.

Our lawful basis for the processing of your personal data for this purpose is our legitimate interest to be able to develop the Services and to increase Our understanding of the markets and customers (Article 6(1)(f) GDPR). For the purposes described above, We will perform Our analysis on anonymized data/aggregated data. However, the processing described above will take place within the scope of the process to anonymize and/or aggregate the data.

c) For the purposes of segmenting and analyzing position data in order to provide custom information based on Your specific preferences and behavior patterns, we process the following personal data:

• Position data

The lawful basis for the processing of your personal data for this purpose is to fulfil Our contractual obligations with You, i.e. in order for Us to provide the Services (Article 6(1)(b) GDPR).

In addition to the above, Bicelo may process Your personal data (all categories of personal data as described above) in order to comply with laws and regulations or by court order (in which case the lawful basis is a legal obligation (Article 6(1)(c) GDPR)) or to protect Bicelo’s or any third parties’ rights, e.g. defending, exercising or establishing legal claims (in which case the lawful basis is Our legitimate interest in protecting Bicelo’s or any third parties’ rights (Article 6(1)(f) GDPR), except where such interests are overbidden by interests or fundamental rights and freedoms of the data subject which require protection of personal data. Furthermore, processing is also lawful for the protection of the vital interests of the data subject and for the performance of a task carried out in the public interest (2016/679/EU).

3. Transfer of personal data

Pursuant to the Ar. 13 par. 1(f) and Ar. 14 par. 1(f) of the Regulation 2016/679/EU the subject of the personal data shall be informed about the recipients or categories of recipients, even if the personal data are obtained from the data subject or not. Therefore, Bicelo will transfer personal data to the following categories of recipients, indicatively and restrictively mentioned:

• IT service providers. The purpose for these transfers is to be able to offer to You all of the functions of the Services. Such service providers process Your personal data in the capacity as data processors upon Our commissioning and on Our behalf. We only provide personal data in the context of legally permissible processing, to service providers that have been carefully selected and commissioned in writing. The service providers will receive only such personal data which is required for them to perform their tasks.
• Marketing partners. The purpose for these transfers is to perform marketing campaigns and the lawful basis is our legitimate interest to be able to perform marketing campaigns (Article 6(1)(f) GDPR).
• Group companies. The purpose for these transfers is internal administration and to provide Our Services to You. The lawful basis is our legitimate interest in being able to administer our business and thereby provide Our Services (Article 6(1)(f) GDPR).
• Insurance companies. The purpose for these transfers is to handle insurance claims and administer Our insurance policies. The lawful basis is our legitimate interest in handling insurance claims and administrating Our insurance policies on an ongoing basis (Article 6(1)(f) GDPR).
• Courts and counter parties. The purpose for these transfers is to defend, exercise and establish legal claims (or if we are subject to a case of bankruptcy). The lawful basis is Our legitimate interest to defend, exercise and establish legal claims (Article 6(1)(f) GDPR).
• Law enforcement agencies, including the Police. The purpose for these transfers is to assist law enforcement agencies and the Police in its investigations, to the extent we are obligated to do so. The lawful basis is to comply with legal obligations (Article 6(1)(c)GDPR). We may also under some circumstances have a legitimate interest in assisting the Police in its investigations even if We do not have a legal obligation to do so. In these cases We may transfer personal data to the Police on the basis of Our legitimate interest in assisting the Police and also the Police’s (in its capacity as a third party) legitimate interest in law enforcement (Article 6.1(f) GDPR).
• Potential buyers and seller The purpose for these transfers is to share information with potential buyers and sellers in a business transaction (e.g. a merger or acquisition) involving Bicelo. The lawful basis is our legitimate interest to carry through an acquisition or merger (Article 6(1)(f) GDPR).
  

4. Storage of personal data

Your personal data is stored only as long as is necessary in order to fulfill the purposes for which Your personal data was collected, however, if personal data is processed on account of Your consent or Our legitimate interest, Your withdrawal of the consent or objection will put an end to the processing, without affecting any processing that happened until then and without affecting any legal obligation to process personal data. However, pursuant to the Ar. 17 GDPR you shall have the right to obtain from Bicelo the erasure of personal data concerning him or her (i.e. the right to be forgotten) without undue delay and Majestic bears the obligation to erase the without undue delay, but only where the personal are no longer necessary in relation to the purposes for which they were collected; where the is no other legal ground for the processing; where they have been unlawfully processed. After the exercise of this right Bicelo is obliged to erase the personal data, including technical measures.

The personal data which is processed to enter into, perform or administer an agreement between You and Bicelo, is processed for as long as You are a customer of Bicelo and have a Bicelo account. If Your account is terminated, We will delete the personal data from Your account, with the exception of personal data which needs to be stored by Us due to legal requirements or to safeguard Our legal interests.

5. Marketing

We may send You marketing regarding Bicelo’s Services as well as from third parties. The marketing can be sent both by e-mail, push notifications and in-app. The purpose to send marketing is to inform You about Our Services and relevant offers from third-parties. We may also process personal data for the purpose of evaluating a marketing campaign which may include that We will transfer some personal data, mainly e-mail addresses, to the relevant marketing campaign partners.

The lawful basis for sending marketing regarding Our Services and evaluating marketing campaigns is Our legitimate interests (Article 6(1)(f), GDPR) to inform You about the Services and to analyze the result of Our marketing campaigns. We also process personal data in order to send You marketing from third-parties on the basis of Your consent (Art. 6 (1) sentence 1 point (a) GDPR), which You may withdraw at any time.

You may always opt out from Our marketing efforts, either directly in the actual marketing message or by contacting Us at hello@bicelo.com

6. Rights and contact

You have certain rights in relation to Our processing of Your personal data. Your rights are the following:

• Right to access. You have the right to receive confirmation from Us that we process Your personal data, including a right to access Your personal data and receiving an electronic copy of Your personal data.
• Right to rectification. You have the right to request that incorrect or inadequate personal data about Your is updated or corrected.
• Right to withdraw consent. To the extent the processing of Your personal data is based on Your consent, You have the right to withdraw Your consent at any time.
• Right to object. When Bicelo is using legitimate interest (Article 6(1)(f) GDPR) as lawful basis for the processing, or if the processing concerns direct marketing, You have the right to object to the processing. In such case, we may be entitled to continue to process Your personal data if we can demonstrate a compelling legitimate interest to continue the processing operation.
• Right to erasure (“right to be forgotten”). Under certain circumstances, e.g. if you have objected to the processing and We do not have a compelling legitimate interest, You can request that Your personal data is erased. This does not, however, apply if we have a legal obligation to process the personal data or other legitimate purposes for which Your personal data is processed.
• Right to restriction. Under certain circumstances, You have the right to request that the processing of Your personal data is restricted, so that the personal data only may be stored by Bicelo and not processed for any other purposes.
• Right to data portability. If the processing is based on Your consent (Article 6(1)(a) GDPR) or a contract (Article 6(1)(b) GDPR) and the personal data has been obtained directly from You, You are entitled to request data portability, in which case you are entitled to receive Your personal data on a commonly used machine-readable format.

Please contact Us using the contact details below if You wish to exercise any of Your rights mentioned above. Bicelo will normally answer Your request within one month.

You may contact Us at hello@bicelo.com, or by sending mail to Bicelo AB, Markvardsgatan 8, 113 53 Stockholm.

7. Right to lodge complaints

If You have any complaints regarding Our processing of Your personal data, You have the right to lodge a complaint to Datainspektionen.

8. Security

The technology used by Bicelo, together with this Privacy Policy, aims to protect Your personal data from unauthorized access and unauthorized use. We may update these actions as new technology becomes available.

9. Changes to the Privacy Policy

Bicelo may change this Privacy Policy by publishing a new version of this Privacy Policy on the Website and in the Bicelo app. However, in case a change is due to any changes in Our processing operations, We will notify You by sending You an e-mail with information  regarding the amendements.  No further notification (i.e by phone or letter) is required.

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