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Data Privacy Notice for the use of our mobile Apps

 

 

§ 1 Information about the collection of personal data

 

  1. Preamble

 

As an addition to our online offerings, we supply a mobile app, which you can download to your mobile device. In the following, we will inform you about the processing of personal data through using our mobile app.

 

Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person; e.g. name, address, e-mail-address, log-data, gender, weight, height, age, or GPS information. All other terms are in accordance with the GDPR.

 

  1. Controller

 

The controller according to Art. 4 par. 7 GDPR is

ZF Micro Mobility GmbH
Escher-Wyss-Str. 25
88212 Ravensburg
Germany

 

Website: www.zfmicromobility.com

E-Mail: info@zfmicromobility.com

You can reach our data protection officer under (Jens Engelhardt / Erdem Durmus, Heidelberger Str. 6, 64283 Darmstadt, Germany , datenschutz@notos-xperts.de).

 

  1. General information on data processing; legal basis, purposes of processing, duration of storage, objection, and possibility of erasure

    1. General information on the legal basis

Where we obtain the consent of the data subject for the processing of personal data, Article 6(1)(a) of the EU General Data Protection Regulation (GDPR) serves as the legal basis for the processing of personal data.

Art. 6 para. 1 lit. b GDPR serves as the legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations that are necessary for the implementation of pre-contractual measures.

Insofar as the processing of personal data is necessary to fulfil a legal obligation to which our company is subject, Art. 6 para. 1 lit. c GDPR serves as the legal basis.

Art. 6 para. 1 lit. d GDPR serves as a legal basis in the event that vital interests of the data subject or another natural person necessitate the processing of personal data.

If the processing is necessary to safeguard a legitimate interest of our company or a third party and if the interests, fundamental rights and fundamental freedoms of the data subject do not outweigh the first-mentioned interest, Art. 6 para. 1 lit. f GDPR serves as the legal basis for the processing.

    1. General information on data erasure and storage duration

The personal data of the data subject will be deleted or blocked as soon as the purpose of storage no longer applies. In addition, the data may be stored if the European or national legislator has provided for this in EU regulations, laws or other provisions to which the controller is subject. The data shall also be blocked or deleted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.

We retain usage data including IP addresses for the purpose of detecting and – as the case maybe – prosecuting misuse of the ZF Micro Mobility Apps. Unless required for prosecution purposes, the data will be deleted after 7 days. The retention and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the App purchase and use agreement; or (2) ZF Micro Mobility has a legitimate interest in ensuring the functionality and security of the ZF Micro Mobility Apps. After 2 years of inactivity, all personal data will be deleted.



    1. General information on processing in our app

Data protection, data security and secrecy protection have high priority for us. The permanent protection of your personal data, your company data and your trade secrets is particularly important to us.

Your personal data will be processed in accordance with the requirements of the General Data Protection Regulation and in accordance with the country-specific data protection regulations applicable to us. By means of this data protection note, we would like to inform you about the type, scope and purpose of the personal data processed by us. In addition, we will inform you of your rights by means of this data protection notice.

 

ZF Micro Mobility has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk of data destruction, loss, alteration, unauthorized disclosure or access, and misuse. These measures include data encryption and use of firewalls, physical access controls to our data centres and information access authorization controls.



  1. E-mail contact

It is possible for contact to be made via the e-mail address that is provided. In this case the personal data of the user transmitted with the e-mail is stored.

In this connection no data is passed on to third parties. The data is used exclusively for the processing of the conversation and will immediately be erased if it is no longer needed.

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is as a rule Article 6 Para. 1 lit. b. GDPR in the case of enquiries via the contact form and/or e-mails.

(contract fulfilment; pre-contractual measures);

Article 6 Para. 1 lit. c. GDPR (fulfilment of a legal obligation, e.g. answering of questions on data protection) and

in addition, Article 6 Para. 1 lit. f GDPR

(legitimate interest).

 

The processing of the personal data from the input mask / e-mail serves us solely for the processing of the contact. This is also the necessary legitimate interest in the processing of the data.

The other personal data processed during the sending-off process serve to prevent misuse of the contact form and to ensure the security of our IT systems.



 

The data is deleted as soon as it is no longer needed for achieving the purpose of their collection. This is the case for the personal data from the input mask of the contact form and those which are sent by e-mail when the particular conversation with the user has ended.

The conversation has ended when the circumstances allow the conclusion to be drawn that the matter in question has been finally clarified.

The above does not hold good if the correspondence is subject to a retention obligation under commercial law

The additional personal data collected during the sending-off process is deleted at the latest after a period of seven days.

The user has the opportunity to object at any time to the storing of his personal data. In such a case the conversation cannot be continued.

 

 

  1. In case we hire additional service providers for single functions of our offerings, or we want to use your data for commercial purposes, we will inform you about the particular actions in detail. In such a case, we will inform you about the criteria of the storage period.

 

 

§ 2 Collection of personal data through usage of our mobile app

 

  1. Processing of your personal data for the download of the app

 

With downloading the mobile app, the required information will be transferred to the App Store, such as usernames, e-mail-addresses and client number of your account, moment of download, paying information and the individual hardware identification number. We have no impact on this data collection and are not responsible for this. We process data only insofar, as it is required for the download of our App.

After the download and before opening the app, the user will be asked by the OS to allow the folling services:

    • Bluetooth

    • Location (GPS)

    • Push-notifications

 

  1. In-App registration

 

In order to provide the advertised services, the app requires user-registration with your personal email-address and password. If you want to use our app, we collect the following data:

 

    • First name

    • Last name

    • IP-address

    • Requesting server (so-called user agent)

    • Type, version of the operating system and app, and language of the end device

    • ID of the end device (so-called UUID)

    • Content of the requirement (specific site)

 

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. b. GDPR

(contract fulfilment; pre-contractual measures);

The purpose of storing the data is to provide a technical stable and secure App.

Through utilization of our mobile app, we automatically collect the personal data in order to enable a user-friendly functionality

The personal data provided according to the registration will be stored until the purpose expires.

As a user you have the possibility to cancel the registration at any time. You can change the data stored about you at any time.

 

 

  1. Additional information provided by you

 

In the setup-assistant when first opening the app and in the app-settings, the user has the non-mandatory option to provide the following information. This information is used for fitness functions like calculating calories burnt during a bike ride.

 

    • Gender

    • Weight

    • Height

    • Age

    • Bicycle Type

    • Bicycle Weight

 

This information is stored in the end device and is transferred only in anonymized form in order to provide service and related features as well as to improve the features and performance of the app.

 

 

  1. Third-party service providers (recipients of personal data)

 

For the provision of our service we are dependent on the following external companies and service providers:

 

    • GPS Tuner Systems Kft, Vérmezö út 4, 1012 Budapest. Hungary

    • Doubleslash Net-Business GmbH, Otto-Lilienthal-Straße 2, 88046 Friedrichshafen, Germany

    • Microsoft Ireland Operations Limited, South County Business Park, Leopardstown, Dublin 18, Irland

 

Any transmission of personal data is legitimate because we have carefully selected our third-party companies and external service providers as processors in accordance with Art. 28 (1) GDPR, regularly checked them and contractually obliged them to process all personal data exclusively in accordance with our agreement with said companies.

 

  1. Push notification

 

We provide you with the option of activating push notifications. Push notifications is a service, which provides you with information about your bike or other useful information even when the app is not open.

 

To deliver push notifications, the platform you are using (Android, iOS) will generate an identifier in the form of a device token for your mobile device. This device token is then issued with a hash in the App.

ZF Micro Mobility or its partners are not able to use this hash to identify you personally. The hash is stored in the administration back-end to identify your mobile device and to deliver push notifications to your mobile device. If a push notification is triggered, it is sent via the respective provider of the smartphone operating system (e.g. Android Firebase Messaging or Apple Push Services).

You can receive app push notifications about news and information regarding your bike or bike drive system.

 

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. a. GDPR

(consent);

The purpose of storing the data is to provide you with push notifications. If you activate the notification function (“push notifications”) after a separate query by the app, you will have the option of receiving up-to-date information regarding your bike.

The personal data provided according to the push notification will be stored until you withdraw your consent or the purpose of the processing is no longer valid.

As a user you have the possibility to withdraw your consent at any time.

 

 

  1. Further data processed by us

 

If you want to use all functionalities of our app, we collect the following data from your vehicle when connected to the mobile app, which is necessary for providing the functions and services of our app. Due to an anonymization of your person, this data is not related to you as a person.

 

    • Bike ID

    • Technical data concerning bike usage

    • Personal vehicle settings

    • Driving Statistics with anonymized location data (first and last 500 metres of each ride are not collected)

    • Type of bicycle, Weight of bicycle

    • Motor SW version

    • Engine type

    • Error codes

    • Speed

    • Torque

    • Cadence

    • Power

    • Support level

    • Odometer

    • Language

    • Units

    • Temperature

    • Total time

    • Total distance

    • Active Time

    • Date

    • Time

    • Battery software version

    • Cell temperature

    • Maximum cell temperature

    • Minimum cell temperature

    • Battery temperature

    • Battery Management System Power Supply

    • Battery Management System Voltage

    • State of charge

    • Battery condition

    • Remaining capacity

    • Full capacity

    • Maximum voltage

    • Minimum voltage

    • Charge current / discharge current (maximum, minimum and average respectively)

    • Range

    • Engine temperature

    • Power reduction

    • Elevation

    • Ascent

    • Descent

    • Gradient

    • Motor supporting profile

    • Downloaded maps

 

ZF Micro Mobility will not use your data for any purpose that is incompatible with the original purpose for which it was collected unless you provide your prior explicit consent for further use.

The processing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the ZF Micro Mobility App purchase and use agreement; or (2) ZF Micro Mobility has a legitimate interest in ensuring the functionality and error-free operation of the ZF Micro Mobility Apps and that it is tailored to the user’s needs.

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. f. GDPR

(legitimate interest);

We process and use the data specified above for the purposes of (1) providing ZF Micro Mobility Apps and its functionalities; (2) improving the ZF Micro Mobility Apps’ features and functionalities, (3) preventing and detecting misuse and malfunction of the ZF Micro Mobility Apps including troubleshooting and (4) for research and development activities for the system related to ZF Micro Mobility bike components.

The personal data provided according to the functionanlities are stored until the purpose is no longer valid or the user objects the processing

As a user you have the possibility to object against the processing of your personal data at any time.





  1. Additional information for special ways of utilization of mobile apps

 

 

    1. Location data

 

      1. Our offer includes so-called location based services, with which we offer you for purposes of navigating and recording your trip. You can only use this function after accepting via pop-up window, that we collect your location data via GPS as well as your IP-address in anonymous form. You can give or withdraw your consent at any time through your device settings. Your location will only be transferred to us, if you use functions of the app, which we can only offer you under acquaintance of your location. If the location data collection is active, your phone may show the data processing through a compass-symbol in the upper bar of your display.

 

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. a. GDPR

(consent);

We process and use the data to provide access to, improving and personalizing our services, including location-based services

The personal data provided is stored until the purpose of the location based service has expired or the user withdrew his consent

As a user you have the possibility to withdraw your consent at any time.

 

 

 

      1. For commercial or market research concerns as well as to provide adequate offers, we compile bike-usage profiles under appropriation of anonymization. This data will not be merged with other personal data.

 

Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. a. GDPR

(consent);

We process and use the data for the purpose of research and development

The personal data provided is stored until the purpose of the location based service has expired or the user withdrew his consent

As a user you have the possibility to withdraw your consent at any time.

 



The processing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) the processing is necessary for the performance of the App purchase and use agreement; (2) you have given prior consent to the processing of your Personal Data; or (3) ZF Micro Mobility has a legitimate interest in ensuring the functionality of the ZF Micro Mobility Apps and that it is tailored to the user’s needs.


    1. Connection with Social Media Platforms



When using our ZF Micro Mobility Apps, we allow you to share information with social media sites or other social portals like Komoot and Strava for purposes of exercise tracking or tour planning. Those social media sites give us automatically access to certain Personal Data retained by them about you consisting of content viewed by you, content liked by you and information about the advertisements you have been shown or have clicked on.





Legal basis

Storage purpose

Storage duration

Objection / opportunity for elimination

Legal basis for the processing of the data is Article 6 Para. 1 lit. a. GDPR

(consent);

We process and use the data specified above for the purposes of improving ZF Micro Mobility Apps’ features and functionalities.

The personal data provided to us by the social media plattform is stored until the purpose expires

As a user you have the possibility to withdraw your consent at any time.

 

 

The processing and use of the data is based on statutory provisions which justify those operations on the grounds that (1) ZF Micro Mobility has a legitimate interest in ensuring the functionality of the ZF Micro Mobility Apps and that it is tailored to the user’s needs; or (2) your consent. You can restrict our access to your Personal Data by changing your privacy settings on the respective social media sites.



  1. Transfers of personal data outside the EU

 

Your personal data will be processed exclusively within the EU.

 

 

§ 3 Your rights

 

If your personal data is processed, then you are the data subject in the sense of the GDPR and you are entitled to the following rights against the controller:

    1. Right of access by the data subject

You can demand from the controller confirmation as to whether personal data that relates to you has been processed by us.

If such processing has taken place, you can demand information on the following from the controller:

The purposes for which the personal data is processed;

The categories of personal data which are processed;

The recipients or, as the case may be, the categories of recipients to which the personal data relating to you has been disclosed or will be disclosed;

The planned duration of the storage of the personal data relating to you or - if concrete statements on this are not possible - the criteria for the laying down of duration of storage;

The existence of a right to correction or deletion of the personal data relating to yourself, of a right to a restriction of the processing by the controller or of a right of objection to this processing;

The existence of a right of appeal at a supervisory authority;

All the available information on the origin of the data if the personal data was not collected at the data subject;

The existence of an automated decision-finding process including profiling in accordance with Article 22 Para. 1 and 4 GDPR and – at least in these cases - meaningful information on the logic involved and its scope and the effects strived for of such a processing for the data subject in question.

You are entitled to the right to demand information on whether the personal data relating to yourself is transmitted to a third country or an international organization. In this connection you can demand to be instructed on the suitable guarantees in accordance with Article 46 GDPR in connection with the transmission.

    1. Right to rectification

You have a right to correction and/or complementing vis à vis the controller in so far as the personal data as processed and which relates to yourself is incorrect or incomplete. The controller has to carry out the correction without delay.

    1. Right to restriction of the processing

Subject to the meeting of the following preconditions you can demand restriction of the processing of the personal data relating to you:

if you dispute the correctness of the personal data relating to yourself for a period which makes it possible for the controller to check the correctness of the personal data;

the processing is unlawful and you reject deletion of the personal data and instead demand restriction of the use of the personal data;

the controller no longer needs the personal data for purposes of the processing but you need the data for the advancing, exercising or defending of legal claims, or

if you have advanced objection to the processing in accordance with Article 21 Para. 1 GDPR but it has not yet been established whether the justified reasons of the controller outweigh your reasons.

If the processing of the personal data relating to yourself has been restricted, then this data - apart from the storing of this - may only be processed with your consent or for the assertion, exercising or defending of legal claims or for the protection of the rights of another natural person or legal entity or for reasons relating to an important public interest of the European Union or of a member state.

If the restriction of the processing has been restricted in accordance with the afore-mentioned preconditions, then you will be informed by the controller before the restriction is removed.

    1. Right to erasure

      1. Deletion obligation

You can demand from controller that the personal data relating to yourself is deleted without delay and the controller is then obliged to delete this data without delay in so far as one of the following reasons applies:

The personal data relating to yourself is no longer required for the purposes for which it was collected or for which it was processed.

You revoke your consent, on which processing in accordance with Article 6 Para. 1 lit. a or Article 9 Para.2 lit. a GDPR was based, and there is no other legal foundation for the processing.

You submit an objection to the processing in accordance with Article 21 Para. 1 GDPR and there are no justified reasons for the processing with a higher priority, or you submit an objection to the processing in accordance with Article 21 Para. 2 GDPR.

The personal data relating to you was processed in an unlawful manner.

The deletion of the personal data relating to you is required to fulfil a legal obligation in accordance with European Union law or the law of the member states, which laws the controller is subject to.

The personal data relating to you was collected in relation to services offered by the information company in accordance with Article 8 Para. 1 GDPR.

      1. Information to third parties

If the controller has made the personal data relating to you public and if he/she is obliged to delete this data in accordance with Article 17 Para. 1 GDPR, then he/she shall take reasonable measures including ones of a technical nature - whereby account shall be taken of the available technology and the implementation costs - to inform the controller for the data processing which process the personal data that you as data subject have demanded from them the deletion of all links to this personal data or of copies or replicates of these.

      1. Exceptions

The right to deletion does not exist in so far as the processing is necessary for

the exercising of the right of free expression of opinion and to information;

for the fulfilment of a legal obligation, which requires the processing in accordance with the law of the European Union or the law of the member states, which laws the controller is subject to, or for the carrying out of a task, which lies in the public interest or which is carried out in the exercising of public authority, which authority was transferred to the controller;

for reasons of public interest in the field of public health in accordance with Article 9 Para. 2 lit. h and i as well as Article 9 Para. 3 GDPR;

for archiving purposes, scientific or historical research purposes lying in the public interest or for statistical purposes in accordance with Article 89 Para. 1 GDPR, in so far as the right named in section a) probably makes the reaching of the objectives of the processing impossible or impairs it seriously, or

for the advancing, exercising or defending of legal claims.

Moreover, the right to deletion does not exist in so far as the personal data has to be stored by the controller in order to fulfill legal duties to preserve records and legal retention periods. In such a case instead of deletion blockage of the personal data applies.

    1. Right to information

If you have advanced the right to the correcting, deleting or restricting of the processing vis à vis the controller, then the latter is obliged to inform all recipients, to which the personal data relating to you was disclosed, of this correction or deletion of the data or of the restricting of the processing, unless this proves itself to be impossible or linked with unreasonable expenditure.

You are entitled to the right vis à vis the controller to be informed about these recipients.

    1. Right to data portability

You have the right to receive the personal data relating to you, which you made available to the controller, in a structured, conventional and machine-readable format. In addition, you have the right to transmit this data to another controller without hindrance by the controller to whom the personal data was made available, in so far as

the processing is based on a consent in accordance with Article 6 Para. 1 lit. a GDPR or Article 9 Para. 2 lit. a GDPR or on a contract in accordance with Article 6 Para. 1 lit. b GDPR and

the processing is carried out with the aid of automated processes.

In exercising this right, you have in addition the right to bring about the situation that the personal data relating to you is transferred directly from one controller to another controller in so far as this is technically possible. The freedoms and rights of other persons may not be impaired thereby.

The right to data portability does not hold good for the processing of personal data, which is necessary for the carrying out of a task, which lies in the public interest or in the exercising of public authority and which task was transferred to the controller.

    1. Right to object

For reasons which result from your particular situation you have the right to advance at any time objection to the processing of the personal data relating to you, which processing is carried out on the basis of Article 6 Para. 1 lit. e or f GDPR; this right also holds good for profiling based on these provisions.

The controller shall then no longer process the personal data relating to you, unless he/she can demonstrate compelling reasons worthy of protection, which reasons overweigh your interests, rights and freedoms or where the processing serves the advancing, exercising or defending of legal claims.

If the personal data relating to you is processed for the carrying out of direct advertising, then you have the right to advance at any time objection to the processing of the personal data relating to you for purposes of such advertising; this holds good too for profiling in so far as this is carried out in connection with such direct advertising.

If you object to the processing for purposes of direct advertising, then the personal data relating to you will no longer be processed for these purposes.

You have the opportunity - in connection with the use of services of the information company and regardless of directive 2002/58/EC – to exercise your right of objection with the aid of automated processes in which technical specifications are used.

    1. Right to withdraw from the declaration of consent under data protection law

You have the right to withdraw your consent at any time and without giving reasons. In the event of withdrawal we immediately will delete your personal data and no longer process it. The legality of the processing carried out on the basis of your given consent and carried out prior to your withdrawal is not affected by you withdrawal.

    1. Automated decision-making in individual cases including profiling

You have the right to not subject yourself to a decision based solely on an automated processing process - including profiling - which unfolds a legal effect vis à vis yourself or which impairs you significantly in a similar way. This does not hold good if the decision

is necessary for the concluding or fulfilment of a contract between you and the controller,

is permissible on the basis of legal regulations of the European Union or of its member states, which the controller is subject to, and these regulations contain reasonable measures for the maintenance of your rights and freedoms as well as for your legitimate interests or

is carried out with your explicit consent.

However, these decisions may not be based on particular categories of personal data in accordance with Article 9 Para. 1 GDPR, in so far as Article 9 Para. 2 lit. a or g does not hold good and reasonable measures have been taken for the protection of the rights and freedoms as well as of your legitimate interests.

In respect of the cases named in (1) and (3) above the controller shall take reasonable measures to ensure the rights and freedoms as well as your legitimate interests, whereby belonging thereto is at the least the right to the affecting of the intervention of a person on the side of the controller for the representation of the controller’s standpoint and to the challenging of the decision.

    1. Right to complain at a supervisory authority

Regardless of another regulatory or judicial remedy, you are entitled to the right to lodge a complaint at a supervisory authority and here in particular at a supervisory authority in the member state of your place of residence, of your place of work or of the place where the suspected infringement took place when you are of the opinion that the processing of the personal data relating to you infringes the GDPR.

In this situation the supervisory authority, at which the complaint was lodged, shall inform the complainant on the status and the results of the complaint including the possibility of a judicial remedy in accordance with Article 78 GDPR.

 



§ 4 Contact



In case of any request concerning our use, integrity and/or accuracy of your Personal Data or in case you want to assert any of your rights mentioned under Section 3, you may contact us by email at datenschutz@notos-xperts.de.



The contact details of our data protection officer are as follows:







NOTOS Xperts GmbH

Jens Engelhardt / Erdem Durmus

Heidelberger Str. 6

64283 Darmstadt

Germany



§ 5 Changes to this Data Protection Information



As our collection and processing of your data may change over time, we might also modify this Data Protection Notice in order for it to always correctly reflect our data processing practices. We encourage you to review it from time to time.



For more information on data protection, please visit our website at https://zfmicromobility.com/data-protection/?lang=en



Last modified Tuesday, February 7, 2023

 

Controller: ZF Micro Mobility GmbH