PRIVACY POLICY

This document was last updated on August 31st, 2020.

This privacy policy (“Policy”) describes how personally identifiable information (“Personal Information”) you may provide in the “Ride Fleet” mobile application (“Mobile Application” or “Service”) and any of its related products and services (collectively “Services”) is collected, protected and used. It also describes the choices available to you regarding our use of your Personal Information and how you can access and update this information. This Policy is a legally binding agreement between you (“User”, “you”, or “your”) and this mobile application developer or its business associates (“Operator”, “we”, “us” or “our”). By accessing and using the mobile application and services, you acknowledge that you have read, understood and agree to be bound by the terms of this Policy.

Automatic Collection of information

When you use the Mobile Application, our servers automatically record information that your device sends. This data may include information such as your device’s IP address and location, device name and version, operating system type and version, language preferences, information you search for in the Mobile Application, access times and dates, and other statistics. The legal basis for the temporary storage of Personal Information automatically collected by us is based on the EU General Data Protection Regulation 2016/679 (“GDPR”).Information collected automatically is used only to identify potential cases of abuse and establish statistical information regarding the usage of the Mobile Application and Services. This statistical information is not otherwise aggregated in such a way that would identify any particular user of the system.

Collection of Personal Information, Automatic decisions and profiling

You can access and use the Mobile Application and Services without revealing any information by which someone could identify you as a specific, identifiable individual. If , however, you wish to use some of the features in the Mobile Application, you may be asked to provide certain Personal Information. We receive and store any information you knowingly provide to us when you create an account, make a purchase or fill any online forms in the Mobile Application. When required, this information may include the following:

You can choose not to provide us with your Personal Information, but then you may not be able to take advantage of some of the features in the Mobile Application. Users who are uncertain about what information is mandatory are welcome to contact us.

Profiling is an automatic processing of your Personal Information. We use profiling and data modeling to enable us to offer you specific services and products that meet your preferences, to prevent money laundering, to set prices for services and products, to detect fraud and the risk of fraud, to assess the likelihood of default, and for marketing purposes.

We use our systems to make decisions based on the information we have about you. We use automated decisions to prevent fraud. Automated decisions enable us to ensure that our decisions are fast, fair, efficient and correct based on the information we have.

Use and processing of collected information

In order to make the Mobile Application and Services available to you, or to meet a legal obligation, we need to collect and use certain Personal Information. The legal basis for our collection of your Personal Information is based on the GDPR in connection with the performance of our contractual obligation to render the Services in the Mobile Application to you. If you do not provide the information that we request, we may not be able to provide you with the requested products or services. Some of the information we collect is directly from you via the Mobile Application and Services. However, we may also collect Personal Information about you from other sources. Any of the information we collect from you may be used for the following purposes:

Processing your Personal Information depends on how you interact with the Mobile Application and Services, where you are located in the world and if one of the following applies: (i) you have given your consent for one or more specific purposes; this, however, does not apply, whenever the processing of Personal Information is subject to the European Data Protection Regulation; (ii) provision of information is necessary for the performance of an agreement with you and/or for any contractual obligations in terms of Art. 6 (1) (b) of the General Data Protection Regulation; (iii) processing is necessary for compliance with a legal obligation to which you are subject; (iv) processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us; (v) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party as permitted by article 6 of the GDPR.

Billing and payments

We use Stripe as a third party payment processor to assist us in processing your payment information securely. Such third party processors’ use of your Personal Information is governed by their respective privacy policies which may or may not contain privacy protections as protective as this Policy. We suggest that you review their respective privacy policies on this link https://stripe.com/de/privacy.

Managing Information

You are able to delete certain Personal Information we have about you. The Personal Information you can delete may change as the Mobile Application and Services change. When you delete Personal Information, however, we may maintain a copy of the unrevised Personal Information in our records for the duration necessary to comply with our obligations to our affiliates and partners, and for the purposes described below. If you would like to delete your Personal Information or permanently delete your account, you can do so on the settings page of your account in the Mobile Application.

Disclosure of information

Depending on the requested Services or as necessary to complete any transaction or to provide any service you have requested, we may contract other companies and share your information with your consent with our trusted third parties that work with us, any other affiliates and subsidiaries we rely on to assist in the operation of the Mobile application and Services available to you. We do not share Personal Information with unaffiliated third parties. These service providers are not authorised to disclose your Personal Information except as necessary to perform services on our behalf or to comply with legal requirements.

In addition to the above, we share your Personal Information with our Business Associates as amended from time to time. Business Associates are companies that use our Mobile Application and Services to operate their own vehicle sharing business within specific locations. Each Business Associate is responsible for the operations in a different location.

In some cases, we may be required to share your Personal Information with third parties, eg if:

We will disclose any Personal Information we collect, use or receive if required or permitted by law, such as to comply with a subpoena, or similar legal process, and when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

In the event we go through a business transition, such as a merger or acquisition by another company, or sale of all or a portion of its assets, your user account, and Personal Information will likely be among the assets transferred.

Retention of Personal Information

We will retain and use your Personal Information for the period necessary to comply with our legal obligations, resolve disputes, and enforce our agreements unless a longer retention period is required or permitted by law. We may use any aggregated data derived from or incorporate your Personal Information after you update or delete it, but not in a manner that would identify you personally. Once the retention period expires, Personal Information shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after the expiration of the retention period.

Your Personal Information will be deleted by us as soon as the information is no longer necessary to achieve the purposes for which it was given.

Transfer of information

Depending on your location, data transfers may involve transferring and storing your information in a country other than your own. You are entitled to learn about the legal basis of information transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by us to safeguard your information. If any such transfer takes place, you can find out more by checking the relevant sections of this Policy or inquire with us using the information provided in the contact section.

The rights of users

You may exercise certain rights regarding your information processed by us. In particular, you have the right to do the following: (i) you have the right to withdraw consent where you have previously given your consent to the processing of your information; (ii) you have the right to object to the processing of your information if the processing is carried out on a legal basis other than consent; (iii) you have the right to learn if information is being processed by us, obtain disclosure regarding certain aspects of the processing and obtain a copy of the information undergoing processing; (iv) you have the right to verify the accuracy of your information and ask for it to be updated or corrected; (v) you have the right, under certain circumstances, to restrict the processing of your information, in which case, we will not process your information for any purpose other than storing it; (vi) you have the right, under certain circumstances, to obtain the erasure of your Personal Information from us; (vii) you have the right to receive your information in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that your information is processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

The right to object to processing

Where Personal Information is processed for the public interest, in the exercise of an official authority vested in us or for the purposes of the legitimate interests pursued by us, you may object to such processing by providing a ground related to your particular situation to justify the objection.

Data protection rights under GDPR

If you are a resident of the European Economic Area (EEA), you have certain data protection rights and the Operator aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Information. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. In certain circumstances, you have the following data protection rights:

How to exercise these rights

Any requests to exercise your rights regarding your personal Information s can be directed to the Operator through the contact details provided below:

Wunder Fleet GmbH

Hongkongstrassße 2

20457 Hamburg, Germany

Mail: dpo@wundermobility.com

All inquiries to us regarding your Personal Information can be made via the contact information provided above.

Please note that we may ask you to verify your identity before responding to such requests. Your request must provide sufficient information that allows us to verify that you are the person you are claiming to be or that you are the authorised representative of such person. You must include sufficient details to allow us to properly understand the request and respond to it. We cannot respond to your request or provide you with Personal Information unless we first verify your identity or authority to make such a request and confirm that the Personal Information relates to you.

The Mobile Application and Services contain links to other resources that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other resources or third parties. We encourage you to be aware when you leave the Mobile Application and Services and to read the privacy statements of each and every resource that may collect Personal Information.

Cookies

We use cookies and other tracking technologies to distinguish you from other users of the Mobile Application, the distribution platform (Appstore) or and to remember your preferences. This helps us to provide you with a good experience when you use our Mobile Application and also allows us to improve the Mobile Application.

A cookie is a small file of letters and numbers that we store on your browser or mobile device, if you agree. Cookies contain information that is transferred to your mobile device.

We use the following cookies:

Information security

We secure information you provide on computer servers in a controlled, secure environment, protected from unauthorised access, use, or disclosure. We maintain reasonable administrative, technical, and physical safeguards in an effort to protect against unauthorized access, use, modification, and disclosure of Personal Information in its control and custody. However, no data transmission over the Internet or wireless network can be guaranteed. Therefore, while we strive to protect your Personal Information, you acknowledge that (i) there are security and privacy limitations of the Internet which are beyond our control; (ii) the security, integrity, and privacy of any and all information and data exchanged between you and the Mobile Application and Services cannot be guaranteed; and (iii) any such information and data may be viewed or tampered with in transit by a third party, despite best efforts.

Data breach

In the event we become aware that the security of the Mobile Application and Services has been compromised or users Personal Information has been disclosed to unrelated third parties as a result of external activity, including, but not limited to, security attacks or fraud, we reserve the right to take reasonably appropriate measures, including, but not limited to, investigation and reporting, as well as notification to and cooperation with law enforcement authorities. In the event of a data breach, we will make reasonable efforts to notify affected individuals if we believe that there is a reasonable risk of harm to the user as a result of the breach or if notice is otherwise required by law. When we do, we will send you an email.

Changes and amendments

We reserve the right to modify this Policy or its terms relating to the Mobile Application and Services from time to time in our discretion and will notify you of any material changes to the way in which we treat Personal Information. When we do, we will post a notification in the Mobile Application. We may also provide notice to you in other ways at our discretion, such as through contact information you have provided. Any updated version of this Policy will be effective immediately upon the posting of the revised Policy unless otherwise specified. Your continued use of the Mobile Application and Services after the effective date of the revised Policy (or such other act specified at that time) will constitute your consent to those changes. However, we will not, without your consent, use your Personal Information in a manner materially different from what was stated at the time your Personal Information was collected.

Acceptance of this policy

You acknowledge that you have read this Policy and agree to all its terms and conditions. By accessing and using the Mobile Application and Services you agree to be bound by this Policy. If you do not agree to abide by the terms of this Policy, you are not authorized to access or use the Mobile Application and Services.