Article 1. Definitions
1.1 In this privacy policy, the following terms, which are capitalised, are used in the following meanings, unless explicitly stated otherwise or indicated otherwise by the context:

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

Account: The account that the User has created with Skopei for the use of the Application;

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

GDPR: General Data Protection Regulation;

Service: The service provided by Skopei to the User: Making the Application available through 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 that has come about through the Application between the User and the Customer, such as a rental agreement or parking agreement;

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

Skopei: 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 KvK number 61048747.

1.2 Unless otherwise indicated by the context, defined terms in the singular shall also refer to the plural.

1.3 Where this privacy policy refers to “he” or “his”, it may of course also be read as “she” or “her”.

Article 2. Controller

2.1 Skopei is the controller regarding the Personal Data being processed. The contact details of Skopei are:
Skopei B.V.
Saturnusstraat 60 Unit 17&18
2516 AH The Hague
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. 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 Personal Data via the Application during the creation of an Account or when using the Service, when the User makes use of the Service or when the User contacts Skopei and provides their Personal Data to Skopei.

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

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

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

4.4 To enter into a User Agreement relating 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 area 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. Grounds and purposes of the processing of Personal Data
5.1 The grounds for the processing of Personal Data are the provision of the Service, the consent of the User, the legitimate interests of Skopei and compliance with legal obligations.

5.2 Skopei processes Personal Data for the following purposes:

a. Creating and managing the Account;
b. Verifying whether the email address provided by the User is an existing email address used by the User;
c. Verifying the payment method chosen by the User to establish the debtor risk;
d. Providing the Service, such as, but certainly not limited to:
- Entering into the User Agreement;
- Locating the User to display the nearest Thing in the Application;
- Unlocking the Thing for use;
- Opening the barrier to grant the User access to the parking lot or parking garage of the Provider;
- Invoicing on behalf of the Provider for the amounts due by the User to Providers for the User Agreements and collecting these amounts on behalf of the Providers using the payment method chosen by the User;
- Processing fines incurred by the User during the use of the Thing.
e. Checking on behalf of the Provider whether the User has a valid driving license to operate the vehicle rented from the Provider under a User Agreement;
f. Communication purposes, such as sending notification email messages regarding the Service;
g. Complying with legal obligations.

5.3 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 purposes outlined in article 5.1 for which the Personal Data are processed, unless there is a legal obligation that requires longer retention.

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

Article 6. Tracking and tracing system in the vehicle
6.1 If the User rents a vehicle from a Provider under the User Agreement, the vehicle is equipped with a tracking & tracing system that allows the vehicle to be monitored. This will provide details on how long, at what times and how many kilometres the User has driven the vehicle, based on which the User is invoiced for the rental and any fines incurred. This tracking & tracing system belongs to the Provider.

Article 7. Security measures
7.1 To prevent unauthorized access to, 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 unintended loss of Personal Data. Skopei has taken the following security measures, among others:
a. Using secure 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 who are hired by Skopei or who enter into employment with Skopei and who, in the course of their duties, have access to Personal Data are bound by Skopei to confidentiality, for example through an employment contract or non-disclosure agreement.

7.3 Only the employees of Skopei who need access to Personal Data in the regular course of their function/work will be 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 grounds on which the provision of Personal Data to a third party is permitted applies;
b. The User has given their consent;
c. It is necessary for providing 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 will provide the User's driving license number and date of birth to the Road Traffic Agency (RDW) so that the RDW can verify 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 IT service provider or payment provider, with which third party Skopei has agreed via a contract or other legal act that the third party provides adequate safeguards regarding technical and organizational security measures in respect of the processing to be carried out. Engaged third parties only have access to the Personal Data if it is necessary to carry out their work for Skopei and as far as legally permitted;
f. Requested to do so 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 are no longer needed for the purposes for which they were processed;
b. The User objects to the processing of their Personal Data and this objection is justified;
c. The Personal Data are inaccurate or outdated.

9.2 Skopei is not obliged to delete Personal Data if one of the situations described in the law where the "right to be forgotten" does not apply occurs.

Article 10. Right of access, right to data portability, rectification, and deletion
10.1 Upon request, Skopei provides the User with access to all Personal Data that Skopei holds about them and provides the User with a copy of this data free of charge in a format that allows the User to pass the Personal Data on to a third party.
10.2 Skopei provides the User with the opportunity to have any incorrect data that Skopei holds about them corrected or deleted free of charge.

Article 11. Objection
11.1 The User may object to the processing of their Personal Data by Skopei if they have a valid reason to do so given their specific situation. Once Skopei receives the User's objection, Skopei will cease the processing of the User's Personal Data, unless Skopei has legitimate interests in the processing of Personal Data that outweigh the User's interest.

Article 12. Right to restriction
12.1 If a request has been made by the User in connection with the modification, completion, or deletion of their Personal Data or an objection has been made against the processing of their Personal Data and the consideration, processing, and execution of this request or objection takes time, the User may request Skopei to restrict the processing of their Personal Data.

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

Article 14. Questions, requests, and complaints
14.1 A request regarding Personal Data, including exercising one or more of the rights referred to in article 10, 11, or 12, withdrawing 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 1 month of receiving the request about the outcome of the request.
14.3 If Skopei corrects, completes, or deletes the User's Personal Data at their request, ceases or restricts the processing of the Personal Data, or has processed a withdrawn consent, Skopei will inform 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 applicable laws and regulations, the User may file a complaint with the Data Protection Authority or with a supervisory authority in the country where the User resides.

Article 15. Security incident
15.1 If a security incident occurs at Skopei involving the leakage of sensitive Personal Data or which otherwise results in a serious adverse effect on the protection of processed Personal Data, Skopei will report this, if possible, within 72 hours after discovering the security incident to the Data Protection Authority and act in accordance with the Data Breach Notification Policy of the Data Protection Authority.
15.2 If there is a security incident at Skopei that has adverse effects on the User's personal sphere, Skopei will promptly inform the User.

Article 16. Changes
16.1 Skopei reserves the right to make unilateral changes to this privacy policy, for example due to a change in the 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 accepts no responsibility or liability for the way Providers handle the User's Personal Data. For more information on how a Provider processes Personal Data, please refer to the privacy policy of the respective Provider.

Article 18. Cookies
18.1 Skopei uses functional and analytical cookies for its applications and website(s).
18.2 Skopei uses functional cookies to ensure the Application functions optimally.
18.3 Through analytical cookies, Skopei can gather and analyse information related to the use of the Application. By using analytical cookies, Skopei processes data regarding the usage 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 No Personal Data within the meaning of the GDPR are processed through cookies.