This privacy policy (the “Privacy Policy”) is adopted by Vok Bikes (Optigon OÜ, registry code 14424376, address Kassi 17, 12618 Tallinn, Estonia telephone +372 56 64 2861, email [email protected]) (“Vok Bikes”, “we”, “us” and “our”).
This Privacy Policy sets out the principles of processing Your personal data by Vok Bikes when You use our services, including when You make bookings (the “Booking”) for renting the Vehicles in accordance with our General Terms (available here for the UK, here for Estonia, and here for Lithuania) on the Vok booking site provided by Cachet OÜ (the “Vok Site”). If You have any questions about how we process Your personal data or if You wish to submit an application for exercising Your rights related to processing Your personal data, please contact us through the contact information provided in the section “Contacts” below.
Unless defined in this Privacy Policy, the terms used in Privacy Policy are used in the meaning given to them in our General Terms or in Article 4 of the General Data Protection Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”).
1. DEFINITIONS
| “Personal data” | 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 on the basis of such a record as the name, personal identification code, place of location information or network identifier, or on the basis of one or more physical, physiological, genetic, mental, economic, cultural or social identities. |
| “Data subject” or “You” | A natural person whose personal data is processed by Vok Bikes. |
| “Processing” | Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction. |
| “Data controller” | Natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. |
| “Data processor” | Natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller. |
| “Services” or “Service” | Services provided by Vok Bikes pursuant to our General Terms. |
2. WHY WE PROCESS PERSONAL DATA AND WHAT PERSONAL DATA DO WE PROCESS?
2.1 When You have opted to use our Services, we need to process Your personal data to enable the Services to You.
2.2 We process personal data that is submitted to us directly by You in the course of using our Services or that we obtain in the course of Your use of the Services.
2.3 We may also process personal data that is submitted to us directly by You also if You contact us with a query or question via Website or via any other channel (by sending an e-mail, for example). In such a case we process Your personal data included in the inquiry to the extent that is necessary to respond to You.
2.4 Personal data we process about You in the course of using our Services may include the following data about You:
2.4.1 general personal information: first name, last name, and personal identification code and/or a courier ID that You disclose to us when You purchase our Services;
2.4.2 login details: login details for Your account;
2.4.3 contact details: email address, phone number;
2.4.4 payment data: if Your use of the Services is subject to a fee, then the payment data related to the Services purchased by You;
2.4.5 usage data: we also collect information about how You use our Services, to amend and better adapt the Services to You;
2.4.6 company data: we may collect information about Your employer or service provider with whom You are associated (if applicable);
2.4.7 geolocation data: our Vehicles are equipped with GPS devices. As a rule, we keep personal data and GPS data separate, and we do not track locations of Vehicles in real-time. However, we may have access to this information if necessary, for example, if a Vehicle is lost, stolen or when we are in doubt the vehicle is not being used according to its purpose.
3. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
3.1 We process Your personal data to provide Services to You (please read Vok Bikes General Terms). The legal basis for such data processing is GDPR Article 6-1-(b), i.e. processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract.
3.2 We process Your personal data when processing is necessary for compliance with a legal obligation to which we are subject, for example for accounting purposes under applicable accounting legislation. The legal basis for such data processing is GDPR Article 6-1-(c).
3.3 In certain specific situations, we might also process Your personal data where this is necessary for the purpose of our legitimate interests pursued by us. The legal basis for such data processing is GDPR Article 6-1-(f). For example, for the purpose of our legitimate interest, we may analyze how our Services are used by our customers so we can provide better service.
3.4 In certain specific situations, we may also process Your personal data based on Your consent. The legal basis for such data processing is GDPR Article 6-1-(a). In those situations, we process Your personal data on the terms provided in the consent that You have granted to us.
3.5 More specifically, we rely on the following legal bases when processing Your personal data:
| Purpose of processing | Types of personal data | How have we obtained personal data | Legal basis for processing | Retention period |
| Enabling the creation of a user account. | First name, last name, e-mail address, phone number, personal identification code, courier ID | Directly from each data subject. | Performance of the contract under the General Terms– GDPR art. 6 (1) (b). After the termination of the contractual relationship with the data subject (under the General Terms) – legitimate interest of Vok Bikes– GDPR art. 6 (1) (f). | During the term of the contract with the data subject under the General Terms. After the termination of the contract under the General Terms – 3 years based on our legitimate interest until the end of the limitation periods under applicable law. |
| Enabling the use of the Services. | Information about the usage of our Services. | Automatically in the course of Your use of the Service. | Performance of the contract under General Terms with the data subject – GDPR art. 6 (1) (b). After the termination of the contractual relationship with the data subject (under the General Terms) – legitimate interest of Vok Bikes– GDPR art. 6 (1) (f). | During the term of the contract with the data subject under the General Terms. After the termination of the contract under the General Terms – 3 years based on our legitimate interest until the end of the limitation periods under applicable law. |
| Payment for the Service. | Information concerning the payment card and the amounts paid or unpaid by You to us for the use of the Service. | Automatically in the course of Your use of the Service. | Performance of the contract under the General Terms with the data subject – GDPR art. 6 (1) (b). After the termination of the contractual relationship with the data subject (under the General Terms) – legitimate interest of Vok Bikes– GDPR art. 6 (1) (f). | During the term of the contract with the data subject under the General Terms. After the termination of the contract under the General Terms – 3 years based on our legitimate interest until the end of the limitation periods under applicable law. |
| Answering the inquires of the data subject. | Name, e-mail and other personal data that is submitted to us directly by You also if You contact us with a query or question via Website or via any other channel (by sending an e-mail, for example). | Directly from each data subject. | To answer to the request of the data subject and our legitimate interest – GDPR art. 6 (1) (b) and GDPR art. 6 (1) (f). | Until the end of the limitation period of the claim related to which the inquiry is submitted. Generally, such term is 3 years. |
| Provision of marketing content. | First name, last name, e-mail address. | Directly from each data subject; statistics concerning Your use of the Services and the Platform is collected by Vok Bikes. | Consent by data subject – GDPR art. 6 (1) (a). | Until the withdrawal of the consent. |
| Geolocation data of the Vehicles. | Geolocation data of the Vehicles. | Automatically. | Our legitimate interest – GDPR art. 6 (1) (f). |
4. WHEN DO WE SHARE YOUR PERSONAL DATA?
4.1 To the extent this is necessary for the provision of our Services, we may share Your personal data with certain third parties. For example, we may share Your name, personal identification code, and/or courier ID with the company You have indicated as Your employer or to whom You are providing services.
4.2 We may also share Your personal data with third-party suppliers providing services to us, e.g. IT suppliers or other service providers. At the moment of adopting this Privacy Policy, the most important service providers we use are the following:
4.3 Cachet OÜ (a limited liability company, established and existing under the laws of Estonia under commercial register code 14560702, with the registered address at Kohtu 2-21, 10130 Tallinn, Estonia) to enable a virtual environment (Vok Site) to enable You to rent Vehicles.
4.4 Mailchimp service by Rocket Science Group LLC d/b/a Mailchimp, to send newsletters and marketing; privacy terms for Mailchimp are available here: https://mailchimp.com/legal/; we are aware the Mailchimp is located outside the EEA and have entered a DPA including Standard Contractual Clauses as adopted by European Commission, available here: https://mailchimp.com/legal/data-processing-addendum/
4.5 We may also transfer Your personal data to third countries, i.e. countries outside the EU/EEA area, for the purposes explained in this Privacy Policy. When transferring Your personal data to third countries, we will ensure that the transfer is subject to appropriate safeguards under GDPR and that Your rights are protected, such as the Commission’s model contracts for the transfer of personal data to third countries (i.e., the standard contractual clauses. You may request a copy of the safeguards we have put in place with respect to the transfer of personal data by contacting us via the contact details below.
5. HOW LONG IS YOUR PERSONAL DATA RETAINED?
5.1 Vok Bikes does not retain personal data longer than it is necessary for the purposes of processing personal data or pursuant to applicable law.
5.2 Personal data related to contracts can be retained during the term of the contract and based on our legitimate interest pursuant to Article 6 (1) (f) of the GDPR until the end of the statutory limitation periods under applicable law. Accordingly, as a general rule, Vok Bikes retains Your personal data as long as it is necessary for the provision of the Services during the term of the contract concluded between You and Vok Bikes and for three years after the term of the contract. In this regard, as a general rule, if You have not used our Services for 3 years, Your profile and all personal data therein will be deleted, unless we have a legal basis for retaining Your personal data for a longer time period.
5.3 Pursuant to the Accounting Act, we may retain accounting documents for 7 years.
5.4 More specific terms concerning the retention periods of Your personal data are outlined in the table in Section 3 above.
6. HOW DO WE PROTECT YOUR PERSONAL DATA?
To protect Your personal data from unauthorized access, unlawful processing or disclosure, accidental loss, modification, or destruction, we use appropriate technical and organizational measures that comply with applicable laws. These measures include but are not limited to the implementation of appropriate computer security systems, protection of paper and electronic format files by technical and logical means, controlling and limiting access to documents and buildings.
7. COOKIES
7.1 Our Services and website www.vokbikes.com (the “Website”) use cookies. This section incorporates our cookie policy (the “Cookie Policy”).
7.2 Cookies are small data files stored on Your hard drive by a website. Cookies help us monitor and improve the functionality and usage of our Website and Your experience when using our Services. We can use cookies to see which areas and features are popular and to count visits to our Website to recognize You as a returning visitor and to tailor Your experience of the Website according to Your preferences. We may also use cookies for targeting or advertising purposes.
7.3 Cookies may be session cookies or persistent cookies:
7.3.1 session cookies are temporary cookie files, which are erased when You close Your browser;
7.3.2 persistent cookies remain in the browser’s subfolders until You delete them manually or Your browser deletes them based on the duration period contained within the persistent cookie’s file.
7.4 Cookies may be first-party cookies or third-party cookies:
7.4.1 first-party are cookies set by the website You’re visiting and only that website can read them;
7.4.2 third-party cookies are cookies set by external services.
7.5 The specific cookies we use are the following:
| Cookie | Description | Duration | Type |
| _fbp | This cookie is set by Facebook to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising, after visiting the website. | 3 months | Third-party advertisment. |
| _ga | This cookie is installed by Google Analytics. The cookie is used to calculate visitor, session, campaign data and keep track of site usage for the site’s analytics report. The cookies store information anonymously and assign a randomly generated number to identify unique visitors. | 2 years | Third-party analytics. |
| _gid | This cookie is installed by Google Analytics. The cookie is used to store information on how visitors use a website and helps in creating an analytics report of how the website is doing. The data collected includes the number of visitors, the source where they have come from, and the pages visited in an anonymous form. | 1 day | Third-party analytics. |
| _gat_gtag_UA_*_* | This is a pattern type cookie set by Google Analytics, where the pattern element on the name contains the unique identity number of the account or website it relates to. Set by Google to distinguish users. | 1 minute | Third-party analytics. |
7.6 You can delete or block cookies on the Website through Your browser settings at any time. However, some cookies might be necessary for the functionality of the Website. Therefore, You understand that when blocking or deleting the cookies some features of the Website might not function correctly.
7.7 For more general information about cookies including the difference between session and persistent cookies please see www.allaboutcookies.org.
7.8 In case You have any questions concerning Cookie Policy, You may contact us via the contact details provided below.
8. YOUR RIGHTS
8.1 Vok Bikes is dedicated to ensuring that all data subject rights arising under applicable law are always guaranteed to You. In particular, any data subject has:
8.1.1 the right to access the personal data that Vok Bikes processes about You;
8.1.2 the right to request that Vok Bikes rectify any inaccurate personal data about You;
8.1.3 the right to request Vok Bikes to erase Your personal data and/or restriction of processing of Your personal data if we do not have a valid legal basis for processing;
8.1.4 the right to receive Your processed personal data in a structured, commonly used and machine-readable format and have the right to transmit Your personal data to another controller;
8.1.5 the right to object to the processing of Your personal data.
8.2 If You believe that Your rights have been infringed, You may contact and lodge a complaint to the supervisory authority applicable for Your jurisdiction (Data Protection Inspectorate in Estonia address Tatari 39, Tallinn 10134, [email protected] or other competent authority in Your jurisdiction).
9. GOVERNING LAW AND JURISDICTION
This Privacy Policy shall be governed by the laws of the Republic of Estonia. Any disputes arising from this Privacy Policy shall be settled in the Harju County Court in the Republic of Estonia unless You have a right to turn to the court of Your residence pursuant to statutory law.
CONTACTS
If You have any questions about this Privacy Policy or Cookie Policy or if You have any concerns about how we use Your personal or if You want to exercise Your rights as described above, You may contact us via e-mail or in writing using the following contact information:
Vok Bikes OÜ
E-mail: [email protected]. Address: Kassi 17, 12618 Tallinn, Estonia.