Article 1. Definitions

1.1   In this privacy policy, the following terms written with an initial capital letter are used in the following meaning, unless expressly stated otherwise or if the context indicates otherwise:

Provider: The legal entity or the 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 via the Application. 

Account: The account created by the user with Skopei for the use of one of the applications.

Application: The mobile or web application, named “Topology”, or “Connect portal” developed by Skopei.

GDPR: General Data Protection Regulation.

Device: A hardware product, sensor, access system, vehicle module or other connected device delivered or managed by or on behalf of Skopei and which can generate data during the use of the Service.

Device Data: Data automatically generated by a Device during its use, including technical data, usage data, status information, activation data, times of use and location-related data.

Service: The service provided by Skopei to the User: Making available the Application with which the User can enter into a User Agreement with a Provider and the payment service.

User: The natural person who has created an Account.

User Agreement: The agreement concluded via the Application between the User and the Customer, such as a rental agreement or granting access to a room or building

Personal Data: Data about an identified or identifiable natural person.

Product Data: All data generated by a Device or by software connected to a Device during the use of the product or the Service.

Skopei: The user of this privacy policy: Skopei B.V. located at Fleminglaan 10 Rijswijk, registered with the Chamber of Commerce under CoC number 61048747.

1.2 Unless the context indicates otherwise, defined terms in the singular also refer to the plural.

1.3 Wherever "he" or "his" is mentioned in this privacy policy, "she" or "her" can of course also be read.

Article 2. Data Controller

2.1 Skopei is the data controller with respect to the Personal Data that is processed.

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

2.2 Skopei processes personal data of Users.

2.3 For Skopei, careful handling of Personal Data is of great importance. With regard to the processing of Personal Data, Skopei acts in accordance with the GDPR and other applicable European and national legislation regarding data protection and data access, including the European Data Act.

Article 3. Collection of Personal Data

3.1 Skopei collects the Personal Data when the User provides Personal Data via the Application during the creation of an Account or when using the Service, because the User makes use of the Service, or when the User provides their Personal Data to Skopei when contacting Skopei.

3.2 If the User uses Devices that are part of the Service, data may also be automatically generated by these Devices. This data may consist of technical data, usage data and operational data necessary for the functioning of the Devices and the Service.

3.3 Transparency about which data is collected and processed by specific Devices is provided in a separate document called “Device Data Specification Skopei”. In this document, it is described per Device which data is generated, for what purpose it is used and how long it is stored.

Article 4. Personal Data processed

4.1 The following Personal Data is processed by Skopei:

a. First and last name

b. Telephone number

c. Email address

d. Address details

e. Payment details

f. Licence plate

g. Location

h. Login details

i. Driving licence details

j. Date of birth

4.2 Skopei does not process special categories of Personal Data of Users.

4.3 To create an Account, the User must provide Skopei with the data or part thereof mentioned in article 4.1 a to d.

4.4 In order to enter into a User Agreement relating to a vehicle other than a bicycle, the User must provide their driving licence.

4.5 To use the User's location for the benefit of the Service, permission is requested via the Application

4.6 When using Devices, data necessary for the functioning of the Service may also be processed, including:

• usage data of the Device

• activation and access moments

• technical status information

• times of use

• location-related data if necessary for the Service

Insofar as this data relates to an identifiable natural person, it is classified as Personal Data.

Article 5. Legal basis and purposes of the processing

5.1 The legal basis for the processing of Personal Data is the provision of the Service, the consent of the User, 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 email address provided by the User is an existing email address

c. Verifying the payment method

d. Providing the Service

• establishing the User Agreement

• locating the User to display the nearest Item

• unlocking an Item

• opening device or access systems

• invoicing and collecting amounts

• processing fines

e. Checking driving licence details

f. Communication purposes, such as sending notifications, text messages or email messages regarding the service

g. Complying with legal obligations

h. Allowing Devices that are part of the Service to function, be managed and secured

i. Analysing technical data from Devices to detect malfunctions, perform maintenance and ensure the safety of the Service

5.3 Skopei will not process the Personal Data for purposes other than those described above.

5.4 Skopei will not store the Personal Data longer than is strictly necessary to realise the purposes, as described in article 5.1, for which the Personal Data are processed, unless there is a legal obligation that requires longer storage.

5.5 Skopei only processes data that is minimally necessary for the purposes.

Article 6. Track and trace system in vehicle

6.1 If the User rents or uses a vehicle or means of transport, this vehicle may be equipped with a track and trace system with which the vehicle can be tracked for invoicing, usage registration and safety.

Article 6A. Data generated by Devices

6A.1 Devices that are part of the Service can generate data during use.

6A.2 Insofar as Device Data relates to an identifiable natural person, this data is considered Personal Data.

6A.3 Users have the right to access the data generated by Devices insofar as it relates to their use of the Service.

6A.4 Upon request, Skopei can make this data available, insofar as technically possible, to the User or to a third party designated by the User.

6A.5 Further information on Device Data is included in the document “Device Data Specification Skopei”.

Article 7. Security measures

7.1 To prevent access to Personal Data by unauthorised persons, loss, theft and unlawful use, Skopei has taken various security measures.

7.2 Persons who take note of Personal Data in the context of their work are obliged to maintain confidentiality.

7.3 Only employees for whom this is necessary have access to Personal Data.

a. Using secure systems with strong passwords to prevent unauthorised access to information systems;

b. Using antivirus software

c. The Application uses an SSL certificate

d. Regularly performing software and firmware updates.

Article 8. Providing Personal Data to third parties

8.1 Skopei provides Personal Data to third parties if this is necessary for providing the Service, when permission has been given for this or when this is legally required.

8.2 Data generated by Devices may be shared with technical service providers, maintenance parties, cloud providers and Providers if this is necessary for the functioning of the Service.

8.3. Therefore requested by an authority, such as police or justice. Before Skopei provides Personal Data to an authority, Skopei checks the powers of this authority.

Article 9. Erasure of Personal Data

9.1 Skopei removes Personal Data without unreasonable delay if they are no longer needed.

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

Article 10. Right of access, portability and erasure

10.1 Upon request, Skopei grants access to all Personal Data.

10.2 Users can have data corrected or removed.

10.3 The right of access may also relate to data generated by Devices insofar as it relates to the User.

Article 11. Objection

11.1 The User can object to Skopei against the processing of their Personal Data if they have a good reason to do so given their specific situation. After Skopei has received the User's objection, Skopei will stop processing the User's Personal Data, unless Skopei has legitimate interests in processing Personal Data that outweigh the interest of the user.

Article 12. Right of restriction

12.1 If a request has been submitted by the User in connection with adjusting, supplementing or erasing their Personal Data or an objection has been submitted in connection with the processing of their Personal Data and the handling, processing and execution of this request or that objection takes some time, the User can request Skopei to restrict the processing of their Personal Data.

Article 13. Consent

The User can withdraw consent.

Article 14. Questions and complaints

Requests can be submitted in writing via the contact details of Skopei.

Article 15. Security incident

15.1 If a security incident has occurred at Skopei in which Personal Data of a sensitive nature has been leaked or which for any other reason results in a serious adverse effect on the protection of the processed Personal Data, Skopei will, if possible, report this to the Dutch Data Protection Authority within 72 hours after discovery of the security incident and act in accordance with the Policy Rules on Duty to Report Data Breaches of the Dutch Data Protection Authority.

15.2 If there is a security incident at Skopei that has adverse consequences for the private life of the User, Skopei will inform the User thereof without delay.

Article 16. Changes

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

Article 17. Privacy policy of Providers

17.1 This privacy policy contains information about the way Skopei processes Personal Data and not about the way Providers process Personal Data. Skopei accepts no responsibility or liability whatsoever with regard to the way Providers handle the User's Personal Data. For more information about the way a Provider processes Personal Data, the privacy policy of the respective Provider should be consulted.

Article 18. Cookies

Skopei uses functional and analytical cookies.

18.1 Skopei uses functional and analytical cookies for its applications and website(s).

18.2 Skopei uses functional cookies to make the Application work optimally.

18.3 With the help of analytical cookies, Skopei can collect and analyse information associated with the way the Application is used. Through the use of 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 privacy of the User and for which no consent is required.

18.5 No Personal Data within the meaning of the GDPR is processed by means of cookies.