This is the Privacy Statement of UMOB B.V., having its registered office in Rotterdam, registered in the Chamber of Commerce under number 82484724 (“we” and/or ” UMOB “).

1. Who are we and what do we do?

The UMOB platform enables consumers to travel more easily and independently using a single app. With just one registration and one payment method, you are able to explore your mobility options and book your own customised trip within five minutes.

UMOB offers mobility services from different mobility providers in one app. More information about our services can be found on the website: www.umob.app.

In this Privacy Statement, we explain which personal data we process when you use our services. The protection of your privacy is of great importance to UMOB. UMOB treats your personal data confidentially in accordance with the provisions of the General Data Protection Regulation (GDPR). We act as a data controller within the meaning of the GDPR with respect to the processing activities described in this Privacy Statement.

We encourage you to read this Privacy Statement carefully.

2. What personal data do we process, for what purposes and on what legal grounds?

Registration and use of app

To use our services, you must register as a user and create an account. When you register with UMOB, we request the following account details:

• First name
• Surname
• Phone number
• E-mail address
• Address (country, postal code, house number, street, city)

We use this data to register you as a user, create an account for you and send you notifications.

We may process this data because it is necessary for the performance of the contract with you, namely the provision of the services available through our app (Article 6(1)(b) GDPR).

If you wish to use a means of transport that requires a driving licence, we will ask for the following details of your driving licence:

• Photo of the front and back of your driving licence
• Photo of yourself

We ask for these details because we need to verify that you have a (valid) driving licence. The validation is not done by us, but by Onfido. You can view Onfido’s privacy statement here: https://onfido.com/privacy/. We therefore do not store the above data ourselves. What UMOB does register with regard to your driving licence are the following details:

• Driving licence expiry date
• Driving licence type

We may process this data because it is necessary for the performance of the contract with you, namely checking whether you are allowed to use the means of transport (Article 6(1) under b GDPR). We also have a legitimate interest in this regard for the purpose of combating fraud (Article 6(1) under f GDPR).

When you use the app, we also process the location of the device you are using.

• Location details

We use this data to see where you are currently located, to show you available vehicles nearby and, to ensure you can reserve and unlock a vehicle near you and to record your travel movements.

We may process your location data because it is necessary for the performance of the contract with you, i.e. to enable you to reserve and unlock one of the means of transport (Article 6(1)(b) GDPR).

In some cases, your device requests your consent to share your device’s location with us (Article 6(1)(a) GDPR). This consent is required to use the app. However, you can withdraw your consent at any time within the app and/or your device’s settings.

While using our app, we process the details of your trip.

• Vehicle registration number
• Pick-up and drop-off point
• Date and time
• Duration
• Price

We use this data to provide you with an overview of your rides, an overview of the price of the rides, to match fines received and to improve the use of the app. We may process this data because it is necessary for the performance of the contract with you, namely to display the details of your rides and forward the fines to the relevant user (Article 6(1)(b) GDPR). Moreover, we also have a legitimate interest to process such data to ensure that the fine is linked to the correct user and to improve the app (Article 6(1)(f) GDPR).

Furthermore, we process your payment details:

• Payment method
• Account number
• Account holder
• Payment amoun
• Time transaction

We use this data to send you invoices, process payments and impose fines and penalties.

We may process this data because we need it to execute our agreement contract with you (Article 6 paragraph 1 sub b GDPR). We are also legally obliged to process this data (Article 6 paragraph 1 sub c GDPR).

When you contact us, or we contact you

When you contact us, we process the following contact data:

• Name
• Email address
• Phone number

We use this data to answer your questions and/or handle complaints. We also support you in using our services. We may process this data because we have a legitimate interest in contacting and assisting you (Article 6(1)(b f GDPR).

When we contact you in response to a fine, we process the following fine data:

• Name
• Contact details
• Details of the trip during the period of the fine
• Type and amount of fine

It varies per mobility provider whether we forward the fines to you or the mobility provider does. When the fines are sent to us, we forward this fine to the user who was driving the vehicle at the time of the fine. We may process this data because we need this data to execute our agreement with you and to arrange payment of the fines (Article 6(1)(b) GDPR).

Newsletters

For the purpose of sending newsletters and updates on our services, we process the following contact data:

• E-mail address
• First and last name

We may send you newsletters if you have given us your consent to do so (Article 6 paragraph 1 sub a GDPR). If you have an account and use our services, we may also send you newsletters and updates based on our legitimate interest to inform you about our services and similar services (Article 6(1)(f) GDPR). It is always possible to unsubscribe from our newsletter via the link at the bottom of each newsletter.

Website

When you visit our website, we process the following technical information:

• Information about the device you are using;
• IP address;
• Browser settings.

We process this data so that you can access our website and services. We have a legitimate interest to provide you with a well-functioning website and to be able to improve the website (Article 6(1)(b f GDPR).

3. How long does UMOB store your personal data?

We do not retain your personal data for longer than necessary for the purpose for which we process your data. How long we keep data depends on the purposes for which we collected the data.

A request for deletion of your personal data can be sent to support@umob.app.  You will receive a response from us within 4 weeks of receipt. We will remove your personal data if there are no urgent reasons not to do so. Urgent reasons may include outstanding invoices or fines.

If we cannot, or cannot fully, determine to which personal data a request for inspection, modification or deletion relates, we ask you to specify this request via our support department. We will put the implementation of your request on hold until we have received further specification.

4. With whom does UMOB share your data?

We share your personal data with third parties only insofar as this is necessary for the performance of our services and in line with the purposes mentioned in this Privacy Statement. Such processing occurs because it is necessary for the performance of the contract (Article 6(1)(b) GDPR) and on the basis of a legitimate interest (Article 6(1)(f) GDPR).

Mobility providers and taxis:

If you book a vehicle from or a ride through one of the affiliated mobility providers via our app, we need to provide certain information to the relevant mobility provider to ensure that you can use the means of transport.

These mobility providers are independently responsible for processing personal data shared in connection with the execution of the vehicle rental and/or ride.

In principle, we share no or as little data as possible with affiliated mobility providers. Exactly what information we share varies per mobility provider and is limited to the data that the provider in question needs in order for you to be able to carry out the journey, to render support to you and to handle any complaints, accidents, loss, theft or (other) damages and traffic fines, such as your first name, surname, e-mail address and/or telephone number.

For more information on the privacy policies of these mobility providers, please consult the privacy statements via the links below:

• Donkey Republic: https://www.donkey.bike/privacy-policy/
• Go Sharing: https://nl.go-sharing.com/en/privacy/
• Felyx: https://felyx.com/t-and-c/privacy-statement/
• Bolt: https://bolt.eu/en/legal/privacy-for-riders/
• BAQME: https://www.baqme.com/en/privacy-policy/
• Greenwheels: https://www.greenwheels.nl/media/dg4pdh43/gw_privacystatement_2020_nl.pdf
• Bolt Rentals (Micro-Mobility): https://bolt.eu/en/legal/md/privacy-for-riders/
• BIRD: https://www.bird.co/privacy/

For the use of Public Transport the information on the privacy policies of these providers can be found via the links below:

NS: http://www.ns.nl/voorwaarden
Connexxion: https://www.connexxion.nl/nl/voorwaarden
Arriva: https://www.arriva.nl/over-je-reis/reizigersrechten-en-plichten/
QBUZZ: https://www.qbuzz.nl/gd/actueel/voorwaarden
Keolis: https://www.keolis.nl/vervoerbewijzen/voorwaarden-vervoerbewijzen
HTM: https://www.htm.nl/productvoorwaarden
RET: https://www.ret.nl/home/reisproducten/productvoorwaarden.html
GVB: https://www.gvb.nl/klantenservice/reisregels/algemene-voorwaarden-stads-en-streekvervoer
EBS: https://www.ebs-ov.nl/contact/vervoervoorwaardenov

Other service providers

We may use processors to support us in providing our services, such as payment providers, hosting providers and driving licence verification providers. In such cases, we are required to provide certain data to these parties. These include the following service providers:

• Onfido (driving licence verification): https://onfido.com/privacy/  
• Buckaroo (payment provider): https://www.buckaroo.nl/privacyverklaring
• Twillio (SMS services): https://www.twilio.com/legal/privacy

5. Transfer of personal data outside the EU/EEA

We do not provide personal data to parties located outside the EU/EEA unless these countries and/or parties provide an adequate level of protection in accordance with the GDPR.

6. What are your rights under the GDPR?

Under the GDPR, you have the following rights regarding the processing of your personal data:

• right to withdraw your consent;
• right to object to the processing of your personal data (Art. 21 GDPR);
• right to access your personal data processed by us (Art. 15 GDPR);
• right to rectification of your personal data incorrectly stored with us (Art. 16 GDPR);
• right to data erasure (‘right to be forgotten’) (Art. 17 GDPR);
• right to restrict the processing of your personal data (Art. 18 GDPR);
• right to data portability (Art. 20 GDPR);
• right to complain to a supervisory authority (Art. 77 GDPR).

You can send an e-mail to support@umob.app with your request. You will receive further notice from us within four weeks of receiving your request.

7. How can you file a complaint?

If you believe your personal data has been processed in a way that violates the GDPR, you can file a complaint with the Dutch Data Protection Authority.

8. How does UMOB secure your personal data?

UMOB takes the protection of your personal data seriously and, taking into account the state of the art, ensures appropriate technical and organisational measures to ensure a risk-appropriate level of security following Article 32 GDPR.

For example, access to personal data is only granted on a strict need-to-know basis. UMOB has further taken, inter alia, the following measures to secure your personal data:

• Security software;
• Security testing;
• Encryption

9. Cookie statement

We use functional, analytical and tracking cookies on our website. Cookies are small information files that the server of www.UMOB.app  sends to your browser with the intention of having this information sent back to the server of www.UMOB.app on your next visit.

UMOB uses at least functional cookies. These cookies are intended to make the website work properly. Without these cookies, the website is not functionally usable. Functional cookies do not require website visitors to ask for permission first.

Furthermore, UMOB may set analytical and tracking/marketing cookies. On your first visit to our website, we will inform you about the use of these cookies and ask your consent to place the different types of cookies. Analytical cookies allow us to measure website visits: for example, how often our site is visited and what information visitors search for. Tracking cookies can read visits to other websites and are often used for marketing purposes. Once you have given permission for these cookies to be placed, you can always withdraw your permission via your browser settings.

10. Changes and contact

As we are constantly improving our services, we may also need to change this Privacy Statement from time to time. At the bottom of this page you can see when the Privacy Statement was last amended. You are responsible for reviewing this Privacy Statement periodically.

For questions and or comments on our Privacy Statement, please email info@umob.app.

Last modified: 31 December 2022