Article 1. Definitions
1.1 In this privacy policy, the terms written with a capital letter have the meanings used hereafter, unless expressly stated otherwise or unless the context indicates otherwise:

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 a
rental/use arrangement for which the User enters into a User Agreement via the Application;

Account: The account that the User has created with Skopei for using 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 so that 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 is established via the Application between the User and the Client, such as a lease agreement or parking agreement;

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

Skopei: The party using 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 the context indicates otherwise, defined terms in the singular also refer to the plural.

1.3 Where in this privacy policy "he" or "his" is mentioned, it may of course also be read as "she" or "her".

Article 2. Data Controller

2.1 Skopei is the data controller with respect to the Personal Data processed. The contact details of Skopei are:
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 respect to the processing of Personal Data, Skopei acts in accordance with the GDPR.

Article 3. Collection of Personal Data

3.1 Skopei collects the Personal Data because the User provides Personal Data through the Application when creating an Account or when using the Service, because the User is making use of the Service, or because the User provides their Personal Data to Skopei when contacting Skopei.

Article 4. Personal Data that is processed
4.1 The following Personal Data is processed by Skopei:
a. First and last name;
b. Phone number;
c. Email address;
d. Address details;
e. Payment details;
f. License plate;
g. Location;
h. Login details;
i. Driver's 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 information mentioned in article 4.1 a. to d. to Skopei. Without this Personal Data, the Account cannot be created. Without an Account, use of the Service is not possible.

4.4 To enter into a User Agreement relating to a vehicle that is not a bicycle, the User must provide their driver's license. Without the driver's 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, consent will be requested from the User via the Application. The User's location is not stored by Skopei.

Article 5. Basis and purposes of processing Personal Data
5.1 The basis for the processing of Personal Data is the provision of the Service, the consent of the User, Skopei's legitimate interests, and compliance with legal obligations.

5.2 Skopei processes Personal Data for the following purposes:

a. To create and manage the Account;
b. To check if the email address provided by the User is an existing email address used by the User;
c. To verify the payment method selected by the User to determine the debtor risk;
d. To provide the Service, such as, but not limited to:
- Establishing the User Agreement;
- Locating the User to display the nearest rental property in the Application;
- Unlocking the rental property 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 amounts owed by the User to Providers for User Agreements and collecting these amounts on behalf of the Providers via the payment method chosen by the User;
- Processing fines incurred by the User while using the rental property.
e. To check on behalf of the Provider whether the User has a valid driver's license to operate the vehicle rented from the Provider under a User Agreement;
f. Communication purposes, such as sending notification emails regarding the Service;
g. Compliance 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 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 strives for minimal data processing.

Article 6. Tracking and tracing system in vehicle
6.1 If the User rents a vehicle from a Provider as part of the User Agreement, the vehicle is equipped with a tracking system that allows it to be followed. This checks how long, at what times, and how many kilometers the User has driven with the vehicle, based on which the User is billed for the rental and any fines incurred. This tracking 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 employed by or contracted by Skopei who become aware of Personal Data in the course of their duties are obligated to confidentiality by Skopei through, for example, an employment contract or confidentiality agreement.

7.3 Only Skopei employees for whom access to Personal Data is necessary as part of their function/work will be granted access to 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 for providing Personal Data to a third party applies;
b. The User has granted consent for this;
c. It is necessary for providing the Service, such as providing Personal Data to the Provider;
d. The User wishes to rent a vehicle that is not a bicycle from a Provider. In such a case, Skopei provides the User's driver's license number and date of birth to the Central Vehicle Office (RDW), so that the RDW can verify if the driver's license is valid;
e. The transfer occurs to a third party engaged by Skopei for the purposes outlined in this privacy policy, such as, but not limited to, an ICT service provider or payment provider, with which third party Skopei has agreed through a contract or other legal action that the third party offers sufficient safeguards regarding technical and organizational security measures concerning the processes to be carried out. Engaged third parties will only have access to Personal Data as is necessary for performing their tasks for Skopei and only to the extent legally permitted;
f. Requested by an authority, such as police or justice. Before providing 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 undue delay if:
a. The Personal Data is no longer necessary for the purposes for which it was processed;
b. The User objects to the processing of their Personal Data and this objection is justified;
c. The Personal Data is incorrect or outdated.

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

Article 10. Right of access, right to data portability, rectification and deletion
10.1 Upon request, Skopei grants the User access to all Personal Data that Skopei holds about them and provides the User with a copy of this data free of charge in such a form that the User can provide the Personal Data to a third party.
10.2 Skopei offers the User the opportunity to correct or delete any incorrect data that Skopei holds about them at no charge.

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

Article 12. Right to restriction
12.1 If the User has submitted a request related to amending, supplementing, or deleting their Personal Data or has submitted an objection to the processing of their Personal Data and handling, processing, and executing 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 any consent granted 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 exercising one or more of the rights mentioned 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 Skopei's contact details.
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 receipt of the request about the outcome of the request.
14.3 If Skopei corrects, supplements, or deletes the User's Personal Data at the User's request, ceases or restricts the processing of the Personal Data, or processes 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 a supervisory authority in the country where the User resides.

Article 15. Security incident
15.1 If a security incident occurs at Skopei in which sensitive Personal Data has been leaked or in which there is otherwise a serious adverse consequence for the protection of the processed Personal Data, Skopei will report this to the Data Protection Authority within 72 hours of detecting the security incident, if possible, and will act in accordance with the Data Breach Notification Policy of the Data Protection Authority.
15.2 If a security incident at Skopei has adverse effects on the User's personal life, 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 the law. The latest version of Skopei’s privacy policy is available via 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 regarding how Providers handle the User's Personal Data. For more information on how a Provider processes Personal Data, the privacy policy of the relevant Provider should be consulted.

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 works optimally.
18.3 With the help of analytical cookies, Skopei can collect and analyze 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 consent is not required.
18.5 No Personal Data in the sense of the GDPR is processed via cookies.