Article 1. Definitions
1.1 In this privacy policy, the terms defined below, which are capitalised, are used with the following meanings, unless explicitly stated otherwise or unless the context indicates otherwise:

1.2 Provider: The legal entity or natural person acting in the exercise of their profession or business who is a customer of Skopei and who offers an item for rent/use for which the User enters into or can enter into a User Agreement through the Application;

1.3 Account: Application: GDPR: Service: User: User Agreement: Personal Data: Skopei: The account that the User has created with Skopei for the use of the

1.4 Application; The mobile application named “Topology” developed by Skopei;

1.5 General Data Protection Regulation; The service that Skopei provides to the User: The provision of the Application through which the User can enter into a User Agreement with a Provider and the payment service; The natural person who has created an Account; The agreement that has been established through the Application between the User and the Customer, such as a rental agreement or parking agreement;

1.6 Data about an identified or identifiable natural person; The user of this privacy policy: Skopei B.V. located at Saturnusstraat 60 Unit 17&18 in The Hague, registered with the Chamber of Commerce under Chamber of Commerce number 61048747. Unless the context indicates otherwise, defined terms in the singular also refer to the plural. Where in this privacy policy “he” or “his” is mentioned, it can of course also be read as “she” or “her.

Article 2. Data Controller
2.1 Skopei is the data controller regarding the Personal Data being processed. The contact details of Skopei are:

Skopei B.V.
Fleminglaan 10
2289 CP Rijswijk
E-mail: office@skopei.com
Tel: +31 (0)85 00 464 00

2.2 Skopei processes personal data of Users. It is very important for Skopei to handle Personal Data carefully. Regarding the processing of Personal Data, Skopei acts in accordance with the GDPR.

Article 3. Collection of Personal Data
3.1 Skopei collects Personal Data when the User provides it during the creation of an Account or when using the Service via the Application, when the User makes use of the Service, or when the User contacts Skopei and provides their Personal Data.

Article 4. Personal Data processed
4.1 The following Personal Data is processed by Skopei:
a. First and last name;
b. Phone number;
c. E-mail address;
d. Address details;
e. Payment details;
f. License plate;
g. Location;
h. Login details;
i. Driving license details;
j. Date of birth.

4.2 Skopei does not process special Personal Data of Users.

4.3 To create an Account, the User must provide the details mentioned in article 4.1 a. to d. to Skopei. Without these Personal Data, the Account cannot be created. Without an Account, the Service cannot be used.

4.4 To enter into a User Agreement related to a vehicle other than a bicycle, the User must provide their driving license. Without the driving license, such a vehicle cannot be rented from a Provider.

4.5 To enter into a User Agreement for reserving a parking space in a closed parking lot of the Provider, the User must provide their license plate. Without the license plate, the parking space cannot be reserved.

4.6 To use the User's location for the Service, permission is requested from the User via the Application. The User's location is not stored by Skopei.

Article 5. Legal basis and purposes of the processing of Personal Data

5.1 The legal basis for the processing of Personal Data is the provision of the Service, the User's consent, the legitimate interest of Skopei, and compliance with legal obligations.

5.2 Skopei processes the Personal Data for the following purposes:
a. Creating and managing the Account;
b. Checking whether the e-mail address provided by the User is an existing e-mail address used by the User;
c. Verifying the payment method chosen by the User to determine the credit risk;
d. Providing the Service, such as, but not limited to: Establishing the User Agreement;
- Locating the User to display the nearest item in the Application;
- Unlocking the item for use; Opening the barrier to grant the User access to the Provider's parking lot or garage;
- Billing the amounts that the User owes to Providers for the User Agreements on behalf of the Providers and collecting these amounts on behalf of the Providers via the payment method chosen by the User;

5.3 Processing penalties incurred by the User during the use of the item.
e. Checking on behalf of the Provider whether the User has a valid driving license to operate the vehicle that the User rents from the Provider under a User Agreement;
- Communication purposes, such as sending notification e-mails regarding the Service;
- Meeting legal obligations. Skopei will not process Personal Data for purposes other than those described above.

5.4 Skopei will not retain Personal Data longer than strictly necessary to achieve the aims described in article 5.1 for which the Personal Data is processed, unless there is a legal obligation that requires longer retention.

5.5 Skopei only processes the Personal Data that is minimally necessary for the existing purposes. Skopei aims for minimal data processing.

Article 6. Tracking and tracing system in the vehicle
6.1 If the User rents a vehicle from a Provider in the context of the User Agreement, the vehicle is equipped with a tracking system that allows the vehicle to be tracked. This will record how long, at what times, and how many kilometers have been driven with the vehicle by the User, based on which the User will be billed for the rental and any incurred fines. This tracking system belongs to the Provider.

Article 7. Security measures
7.1 To prevent access to Personal Data by unauthorized persons, loss, theft, and unlawful use of Personal Data, Skopei has implemented various security measures, including measures against unauthorized access, use, alteration, unlawful and unintended destruction, and unintentional loss of Personal Data. Skopei has taken the following security measures, among others:
a. Using secured systems with strong passwords to prevent unauthorized access to information systems;
b. Using antivirus software;
c. The Application uses an SSL certificate;
d. Regularly performing software updates.

7.2 Individuals employed or contracted by Skopei who, in the course of their duties, gain knowledge of Personal Data are, for example, required by Skopei to maintain confidentiality, through employment contracts or confidentiality agreements.

7.3 Only those employees of Skopei for whom access to Personal Data is necessary for their roles/tasks are granted access to the Personal Data.

Article 8. Providing Personal Data to third parties
8.1 Skopei will provide the User's Personal Data to third parties if:
a. One of the legal bases is applicable on which the provision of Personal Data to a third party is allowed;
b. The User has granted their consent;
c. It is necessary for the provision of the Service, such as providing Personal Data to the Provider;
d. The User wishes to rent a vehicle other than a bicycle from a Provider. In such a case, Skopei provides the User's driving license number and date of birth to the Dutch Road Transport Authority (RDW) so that the RDW can check whether the driving license is valid;
e. The transfer is made to a third party engaged by Skopei for the purposes listed in this privacy policy, such as but not limited to, an ICT service provider or payment provider, with which third party Skopei has entered into an agreement or other legal act that assures the third party provides sufficient safeguards regarding technical and organizational security measures concerning the processing activities to be carried out. Engaged third parties only have access to the Personal Data as necessary to perform their tasks for Skopei and as permitted by law;
f. Requested by an authority, such as the police or judiciary. Before Skopei provides Personal Data to an authority, Skopei verifies the authority's powers.

Article 9. Deletion of Personal Data
9.1 Skopei will delete Personal Data from its systems without unreasonable delay, among other things, if:
a. The Personal Data is no longer necessary for the purposes for which it has been processed;
b. The User objects to the processing of their Personal Data and this objection is justified;
c. The Personal Data is inaccurate or outdated.

9.2 Skopei is not obliged to delete Personal Data if there is one of the situations described in law under which the “right to be forgotten” does not apply.

Article 10. Right of access, right to data portability, rectification, and deletion
10.1 At the User's request, Skopei will grant access to all Personal Data that Skopei holds about them and will provide the User with a free copy of this data in such a format that the User can provide the Personal Data to a third party themselves.
10.2 Skopei offers the User the possibility to have any incorrect data that Skopei holds about them corrected or deleted free of charge.

Article 11. Objection
11.1 The User can object to the processing of their Personal Data by Skopei if they have a good reason to do so given their specific situation. After Skopei has received the User's objection, Skopei will cease processing the User's Personal Data unless Skopei has legitimate interests in processing the Personal Data which outweigh the User's interests.

Article 12. Right to restriction
12.1 If the User has submitted a request regarding the alteration, supplementation, or deletion of their Personal Data or has filed an objection regarding the processing of their Personal Data and the consideration, processing, and execution of this request or objection takes some time, the User can request Skopei to restrict the processing of their Personal Data.

Article 13. Consent
13.1 The User can withdraw previously granted consent regarding the processing of their Personal Data at any time. A withdrawn consent has no retroactive effect.

Article 14. Questions, requests, and complaints
14.1 A request regarding Personal Data, including the exercise of one or more of the rights mentioned in articles 10, 11, or 12, the withdrawal of consent, or questions about this privacy policy can be submitted in writing or via email to Skopei; see article 2.1 for the contact details of Skopei.
14.2 If the User invokes one of the rights described in articles 10, 11, and 12, Skopei will inform the User within one month of receiving the request about the outcome of the request.
14.3 If Skopei corrects, supplements, or deletes the User's Personal Data at the request of the User, ceases or restricts the processing of the Personal Data, or processes a withdrawn consent, Skopei will notify the User of this.
14.4 If the User believes that the processing of Personal Data by Skopei is not in accordance with this privacy policy and/or with applicable laws and regulations, the User can file a complaint with the Dutch Data Protection Authority or with a supervisory authority in the country where the User resides.

Article 15. Security incident
15.1 If Skopei experiences a security incident during which Personal Data of a sensitive nature has been leaked or for any other reason has adverse consequences for the protection of the processed Personal Data, Skopei will, if possible, report this to the Dutch Data Protection Authority within 72 hours of becoming aware of the security incident and act in accordance with the Policy Rules for Reporting Data Breaches of the Dutch Data Protection Authority.
15.2 If there is a security incident at Skopei that adversely affects the User's privacy, Skopei will promptly inform the User of this.

Article 16. Changes
16.1 Skopei reserves the right to unilaterally make changes to this privacy policy, for example due to a change in law. The latest version of Skopei's privacy policy is visible through the Application.

Article 17. Privacy policy of Providers
17.1 This privacy policy contains information about how Skopei processes Personal Data and not about how Providers process Personal Data. Skopei does not accept any responsibility or liability regarding how Providers handle the User's Personal Data. For more information about how a Provider processes Personal Data, the privacy policy of the respective Provider should be consulted.

Article 18. Cookies
18.1 18.2 18.3 Skopei uses functional and analytical cookies for its applications and website(s).
18.2 Skopei uses functional cookies to ensure the Application works optimally.
18.3 With the help of analytical cookies, Skopei can collect and analyse information related to how the Application is used. By using analytical cookies, Skopei processes data about the use of the Application.
18.4 The Application only uses cookies that have no or very limited consequences for the User's privacy and for which no consent is required.
18.5 Through cookies, no Personal Data in the sense of the GDPR is processed.