Valid from 01.01.2022
The protection of your privacy is important to us when processing personal data. That is why we pay special attention to it in our business activities. We process personal data collected during the use of our website, application and/or mobile application confidentially and in accordance with the law.
Personal data is any information about an identified or identifiable natural person, and processing is an automated or non-automated operation performed on personal data (e.g. collection, documentation, arrangement, structuring, storage, adaptation, modification, deletion, destruction, etc.).
HOOG MOBILITY OÜ is the data controller of all users of Hoog applications and the authorized processor of collected data. This means that we determine the purposes and means of processing the personal data collected from you. We only use data for purposes related to our business and services.
Our electric scooters that you may use from time to time are equipped with an electronic system that is connected to a server. It helps to locate the electric scooter and view its travel path and technical data such as battery status and usage time. In order to use our services, you must also download our mobile application (hereinafter: Application) on your mobile device. The app needs access to other apps on the mobile device, such as camera and location.
Our Service is not intended for children under the age of 16 or under the applicable age limit in your jurisdiction, and we do not knowingly collect information related to children.
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, which deals with the protection of natural persons in the processing of personal data and the free movement of such data and repeals Directive 95/46/EC (hereinafter: the General Regulation on the Protection of Personal Data), and according to other legislation that regulates the protection of personal data and the data protection conditions here.
Collection and processing of personal data
Business data
Service user data that we collect and process
- first and last name
- cellphone number
- email address
- password (password is stored encrypted and never displayed as text)
- payment data (bank card number, card validity period, owner's name, bank and/or issuer data)
Purpose
We collect, store and process business data to identify you, register you as a customer/user, create a user account for you on our application, charge you for the service and send you invoices or resolve billing issues related to your account.
We process business data to continue the contractual relationship between us and the customer, which includes providing services, communicating with you and exchanging information with third party service providers to manage business assets and accounts.
Business data may be processed to comply with legal obligations applicable to us.
When you call our customer service center, you give your consent for the conversation to be recorded. We store the information and data you provide (including personal data) for the proper processing of your request.
If you get into a traffic accident with a Hoog electric scooter, your data will be forwarded to the insurance company and other parties involved in the accident.
Based on the information available about the electric scooter, we have the right and in some cases the obligation to inform the competent authority (e.g. the police) about violations of traffic rules (e.g. speeding, drunk driving, theft of a rental vehicle, etc.).
Legal basis for processing
Legal interest to perform the contract and provide services.
Your consent where processing is only permitted on this basis.
Shelf life
If the user has not deleted or requested us to delete his account, business data is stored in our active database. We retain data in case there are disputes about the terms of use or compliance with the law and we need to clarify the circumstances. After deleting the user account of the mobile application, all personal data of the user are automatically deleted from the Hoog database.
Transaction related data
Data we collect and process
- Bank account and bank card data (issuer, card owner, card number, card validity period). Your bank card data (name of the card holder, card number, user IP address, email address, billing address) is stored by the third-party service provider and payment processor Stripe, Inc. Stripe, Inc. provides its service to AS LHV Pank.
- Data related to purchasing and paying for our services.
- Information about your driving and compliance with the terms of use of the service (payments, fines, damages, interest, etc.).
Purpose
We process transaction-related data to provide services and manage your user account in our application.
AS LHV Pank and Stripe, Inc. process data for payment processing and fraud prevention.
Processing is necessary to fulfill a legal obligation applicable to us.
Legal basis for processing
Legal interest to perform the contract and provide services.
Your consent where processing is only permitted on this basis.
Shelf life
We store transaction-related data in our database for an unlimited period of time. The data is then archived and stored until the deadline for filing a claim has passed.
Usage data
Data we collect and process
- location related data (GPS)
- IP address
- login details
- vehicle data
- battery data
- data on the display
- electric scooter manufacturer and model
- speed
- distance
- battery charge level
- data generated by the app and the electric scooter, such as location, driving style, speed
- information about your use of our website, app and electric scooter (including history of rides and locations)
- browser/mobile phone type and version
- time zone settings
- operating system and platform and other technical data about your device that you use to use our website, app and electric scooter
Purpose
Our legitimate interest is to monitor the performance of our service, identify shortcomings and analyze how our customers use our electric scooters, application and website in order to improve our service and ensure its legality, security and reliability.
Legal basis for processing
If the law requires your consent for such processing, we will ask for your consent before processing the data for analytical purposes. For example, we ask for your consent to access your mobile device's camera and location.
Shelf life
If the user has not deleted or requested us to delete his account, the usage data is stored in our active database. We retain data in case there are disputes about the terms of use or compliance with the law and we need to clarify the circumstances. After deleting the user account of the mobile application, all personal data of the user are automatically deleted from the Hoog database.
Profile data
Data we collect and process
This data includes your advertising and marketing preferences, feedback and survey responses, and other similar data you provide to us.
The presence of profiling analysis and the consequences of such analysis and whether or not it involves automated decision-making.
Purpose
Operating our App and Services and improving and optimizing the user experience.
Analyzing and segmenting customers and users in order to better understand our customers and provide better and customized services to users (including you).
Statistical purposes.
Legal basis for processing
Legal interest to perform the contract and provide services.
Your consent where processing is only permitted on this basis.
We only send you direct marketing messages and personalized direct marketing messages with your consent.
Shelf life
Profile data will be stored until the end of your consent or the end of the contract between us, whichever comes first.
We process personal data according to the following principles.
- The collected personal data is relevant, important and limited to what is necessary to achieve the above-mentioned goals.
- The collected personal data is correct and, if necessary, updated.
- Personal data is processed fairly, legally and transparently.
- Personal data is processed only for precisely and clearly defined and legitimate purposes.
- Unnecessary data will be deleted.
- Personal data is automatically deleted from our database if the user has deleted their mobile application account or requested us to delete it.
- We implement appropriate technical and organizational measures, including protection against unauthorized or illegal processing and against accidental loss, destruction or damage.
- Personal data is transferred only to countries with the same level of personal data protection and to entities that ensure the same level of personal data protection.
We process sensitive personal data only with express and unequivocal consent received from a specific user or to protect life, health and freedom or to fulfill legal regulations and contractual obligations applicable to us.
Other purposes of personal data processing are:
(a) ensuring compliance with applicable legal, regulatory or professional requirements;
(b) processing requests submitted by the competent authority or communicating with the authority;
(c) user relationship management, accounting, internal compliance, risk assessment procedures and customer relationship purpose;
(d) use of (hosted or in-house) systems and applications for IT and information system services.
If you register as a user of our service and enter your contact information when logging in, you give us your consent that we may collect, process and use this data and general personal data voluntarily provided during the use of the service to the extent necessary for the provision of contractual services. You also confirm that all personal data provided to us is correct and up-to-date and undertake to update the personal data as soon as they expire or become incorrect or misleading.
HOOG MOBILITY OÜ stores and uses anonymous/aggregated data to develop and improve applications according to the user's wishes. We reserve the right to anonymize the data and disclose it on our platform for statistical purposes or use it in some other way.
Cookies
Our website and app may use cookies. More detailed information about the use of cookies is provided in our cookie policy, which can be found in the footer of our website and in the application.
The purposes of data processing collected using cookies are as follows:
- operation of the website and its services and improvement and optimization of the user experience;
- analyzing and segmenting customers and users in order to better understand our customers and provide better and customized services to users (including you);
- statistical purposes.
Disclosure, transfer and making available of personal data to the recipient
disclosure, transfer and making available of personal data to the recipient
We disclose and transmit your personal data to recipients (natural or legal person, public sector institution, agency or other body to which personal data is disclosed) as little as possible and ensure an adequate level of personal data protection.
Personal data may be disclosed or made available to recipients in the following cases.
- The recipient provides services on our behalf, such as hosting, cloud processing, payment service, online identification service, IT support, marketing, administrative and training services or other data processing. Such recipients may only process personal data in accordance with our instructions and the relationship with the recipient is governed by a written data processing agreement;
- to create, present or defend legal benefits;
- if you have previously consented to the disclosure of personal data to the recipient;
- according to the principles of using cookies.
If the recipient is located outside the EU/EEA and does not ensure an adequate level of personal data protection, we will only transfer your data to such a recipient if a written personal data transfer agreement based on the European Commission's standard contract terms has been concluded.
Automated individual decisions
Automated decision-making may be used based on your personal data. Automated decisions are only made if the decision is:
- necessary for the conclusion or performance of the contract between you and HOOG MOBILITY OÜ;
- permitted by the Union or Member State law applicable to HOOG MOBILITY OÜ, which stipulates measures to protect your rights, freedoms and legal interests;
- permitted with your consent.
We implement appropriate security measures when using automated decision making.
Under no circumstances will sensitive personal data be used for automated decision-making - unless you have given your express consent or processing is necessary for reasons of significant public interest under applicable law.
Your consent
As stated above, some processing operations require your consent. In this case, you have the right to withdraw your consent at any time.
Please note that the withdrawal of consent does not affect the lawfulness of the processing that took place before the withdrawal. If you withdraw your consent, we may not be able to fulfill your requests or provide the service.
Data security
To protect your personal data, HOOG MOBILITY OÜ implements appropriate organizational and technical security measures to ensure a level of security that corresponds to the risks associated with the processing and the nature of the personal data to be protected, taking into account the latest developments in science and technology and the implementation costs of the measures.
HOOG MOBILITY OÜ has assessed the data security risk and implements measures to protect personal data from accidental or illegal destruction, accidental loss, modification and unauthorized disclosure or access to them, especially if the processing includes
transmission of personal data via the network, and for any other possible illegal processing.
Schooling
All employees who constantly or regularly come into contact with personal data must undergo in-house data protection training. This is to ensure that we always comply with applicable data protection legislation and requirements and that our employees are aware of such legislation.
Your rights
You have the right to request more detailed information about the collection and processing of your personal data. You also have the right to correct your personal data (if necessary).
We will delete or correct any data that is incorrect or out of date because a certain amount of time has passed since collection or for any other reason known to us.
If you submit a written request to us, we will delete your personal data without undue delay - unless we have a legal basis to continue processing the data, for example if the processing is necessary for the establishment, exercise or defense of a legal claim or the performance of a contract with you.
To use the rights listed above, send an e-mail to the email address info@hoogmobility.ee.
When you submit your application, please also include the information necessary to process it, such as your first and last name, mobile phone number and email address, so that we can identify you. We will respond to your request for data collection information as soon as possible and within 10 (ten) business days at the latest.
If you do not agree to the processing of your personal data, you have the right to lodge a complaint with your local data protection authority.
Complaints
If you have complaints about how HOOG MOBILITY OÜ processes your personal data, send us an e-mail at info@hoogmobility.ee.
We will assess and analyze your complaint and contact you for further information if necessary.
We aim to process any complaint or objection within 10 (ten) working days. If a decision is not reached within this time, we will inform you of the reason for the delay and the expected deadline for the decision (up to 6 months after the invoice is issued).
You can also submit a complaint to the Data Protection Inspectorate at the address Tatari 39, Tallinn 10134 or on the website www.aki.ee before, during and after processing the complaints described above .
Links to other websites, etc
The Hoog website and application may contain links to third-party websites whose operators are not affiliated with us. If you click on a link, we have no influence on the collection, storage and processing of personal data that was transmitted to a third party when you clicked on the link (eg the IP address or URL of the linked website), as we have no control over the behavior of the third party. Therefore, HOOG MOBILITY OÜ does not take any responsibility for such processing of personal data by third parties.
Changing the data protection conditions
We reserve the right to change the data protection conditions here in the future, if this is due to changes in applicable laws, terms of use of HOOG MOBILITY OÜ services or work processes. We will notify you of any changes.
HOOG data protection specialist
HOOG's data protection specialist monitors internal compliance and ensures that personal data is processed in accordance with the General Data Protection Regulation and other applicable data protection laws.
Our data protection specialist can be contacted at info@hoogmobility.ee.
General contact details
If you want to submit a request or have any questions about the processing of personal data and our data protection conditions, please contact our customer support at the email address info@hoogmobility.ee.
