Data protection declaration
We at Donkey Republic take the protection of your personal data very seriously. We shall therefore handle your personal data with due care, conscientiously and in accordance with the applicable laws.?
The purpose of this document is to provide you with information about the data we collect and process when you use our services.
Section 1: Information on the collection of personal data
- Personal data means any information relating to you personally, e.g. name, address, e-mail addresses, user behaviour, location.
- The data controller within the meaning of Article 4 (7) of the EU General Data Protection Regulation (GDPR) is?
Donkey Republic Admin ApS
Christian IXs gade 7, 5.sal
Kopenhagen K, 1111
Directors: Mr. Erdem Ovacik and Mr. Rune Thorenfeldt Kokholm
Central business register (Denmark), CVR-number: 38049488
VAT-ID: DK 38049488?
E-Mail: [email protected]
Telephone: (+45) 89 88 7227
You can contact our data protection officer at [email protected] or through our postal address, stating clearly: “Data protection officer”.
- When you contact us by email or through our contact form, we store and process the data you provide (e.g. email address, name and any telephone number, contents of your message, etc.) in order to be able to respond to your inquiry. Data processing for purposes of contacting us is done in accordance with Article 6 (1) (1) point (a) of the GDPR, based on the consent you have given voluntarily. We shall erase the data we collected on this basis when it is no longer required (at least after 90 days), e.g. because we have answered your query.
- To prevent unauthorised access by third parties to your personal data and in particular, financial data, the ordering process is encrypted using SSL (Secure Socket Layer). We also take reasonable physical, technical and administrative security measures to protect your personal data from loss, misuse, unauthorised access, disclosure and alteration. These security measures include firewalls, data encryption, physical access restrictions to our data centres, and access authorisation controls.
- We store all the personal data in data centres in EU countries.
Section 2: Collection of personal data when visiting our website
- If you use the website for information purposes only, we only collect the personal data that your browser transmits to our server. This information is temporarily stored in a so-called log file. If you would like to visit our website, we shall collect the following data:
- IP address
- Date and time of the request
- Time zone difference to Greenwich Mean Time (GMT)
- Content of the request (specific page)
- Access status/ HTTP status code
- Amount of data transferred
- The referring website
- Operating system and its interface
- Language and version of the browser software
We process this data for the following purposes:
- To ensure smooth connectivity of the website,
- To ensure that our website is user-friendly,
- To evaluate the security and stability of the system, and
- for other administrative purposes.
The aforementioned data will be deleted no later than 14 days after you visited our website.?
- This website uses the following types of cookies, the scope and functionality of which will be explained below:
- Transient cookies
- Persistent cookies.
- Transient cookies are automatically deleted when you close your browser. These include, in particular, session cookies. They save a so-called session ID which is used to assign different requests from your browser to the common session. This allows your computer to be recognised when you return to our website. Session cookies are deleted when you log out or close the browser.
- Persistent cookies are automatically deleted after a specified period, which may differ, depending on the cookie. You can delete cookies at any time in the security settings of your browser.
- You may configure your browser settings according to your preferences and, for example, block the acceptance of third-party cookies or all cookies. Please note that if you do this, you may not be able to use all the functions and features of this website.
- For information about the length of storage, please refer to the overview in the cookie settings of your browser.
- We use Amplitude (Amplitude Inc., Attn: Privacy, 501 2nd Street, Suite 100, San Francisco, CA 94107) to track your behaviour on the website for example clicking a button to download the Donkey Republic app. It helps us to improve our services. This data will be deleted no later than 60 days after you visited our website.?
- The legal basis for aforementioned data processing is Article 6 (1) (1) point (f) of the GDPR. The purposes of data processing named above constitute our legitimate interests.
Section 3: Collection of personal data when renting a Vehicle or becoming a member
- If you like to rent a bike, eScooter etc. (“Vehicle”) or becoming a member, you will need to provide personal data (e.g. name, email address, mobile number, payment method, credit card number etc.) in order to conclude the contract. In addition, we need this personal information in order to process your order. The legal basis for this is Article 6 (1) (1) point (b) of the GDPR. We store these data as long as you are our customer with an active account. Your account is regarded inactive, if you have not made use of the account for 36 consecutive months, after which point in time the order data will be erased, if we are not obliged to retain the data as described below.?
- Under the provisions of the applicable commercial and tax laws, we are obliged to retain your order data for the legally prescribed period. The legal basis for this is Article 6 (1) (1) point (c) of the GDPR. At the end of the statutory retention periods stipulated by the commercial and tax laws, we shall erase your order data.?
- We also collect and process the following data when you use a Vehicle:
- Location and route of the Vehicle
- Duration of the use of the Vehicle
- Vehicles locks and unlocks
- Occurred errors
We collect and process this data at various cities and periods, analyse the resulting data to drive our strategic and operations decisions such as where to place hubs or how many mechanics to employ to take care of the Vehicles. We also use the data to optimise our App.
Location data is only collected when your phone has location services turned on. Turning off location services will automatically opt-out of the collection of location data. Unlocking and locking the Vehicle requires location services to be on for Android users as this is a requirement from the Android operating system. Ending rental also requires location services to be on so that we know where you dropped the Vehicle.
The legal basis for this type of data processing is Article 6 (1) (1) point (f) of the GDPR. The aforementioned purposes constitute our legitimate interests. We store this data for as long as it is necessary to improve our services.
- We sometimes use external service providers, in particular payment service providers (e.g. credit card company etc.) to process your order. To process your order, we have to pass on your order data to these companies. The legal basis for data processing in this case is Article 6 (1) (1) point (b) of the GDPR.?
Section 4: Newsletter
- If you subscribe to our newsletter, we will regularly send you an email to inform you about interesting offers regarding renting Vehicles, among other things. Subscription to our newsletter is voluntary.
- The only information we need from you for sending the newsletter is your email address. We store your email address for the purpose of sending you the newsletter. The legal basis for this is Article 6 (1) (1) point (a) of the GDPR.
- In addition, we store your IP addresses and the date and time of your subscription and confirmation. This process allows us to prove that you have subscribed to the newsletter and to investigate any possible misuse of your personal data. The legal basis for this is Article 6 (1) (1) point (f) of the GDPR. The purposes listed above constitute our legitimate interests.
- We use the so-called double opt-in process for subscriptions to our newsletter. This means that once you have subscribed to our newsletter, we will send you an email to the email address you have provided, in which we ask you to confirm that you wish to receive the newsletter.
- You can withdraw your consent and unsubscribe from the newsletter at any time. To unsubscribe, you can use our contact details specified above to send us a message, or the unsubscribe link in our newsletters or you can send us an email to [email protected]
Section 5: Surveys or ratings
- If we ask for your opinion as part of a survey or rating, we shall store and process the personal data you provide to us in this context to improve our products and services. The legal basis for this is Article 6 (1) (1) point (a) of the GDPR. Your participation in such a survey or rating is voluntary.
- We will store your personal data for as long as it is necessary to improve our products and services or until you withdraw your consent to this type of data processing.
Section 6: Google Analytics
- The website uses functions from the web analytics service Google Analytics. Provider is Google Ireland Ltd. (?Google“). Google Analytics uses so called ?cookies”. They are text files that are being saved on your PC and that enable analytic of the use of the website by you. The information created by the cookies about your use of the website is usually transmitted to a Google server in the USA and saved there. If the IP anonymization is activated on this website, Google will shortened your IP address within Member States of the European Union or in other states party to the Agreement on the European Economic Area beforehand. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity and to provide the website operator with other services relating to website and Internet use.
- You can prevent the saving of the cookies by choosing the respective setting; however we point out that you cannot use all functions of the website fully if you do so. You can furthermore prohibit the registration of the of you use of the website related data created by the cookie (including your IP-address) to Google as well as the processing of this data by Google by downloading and installing the browser plugin provided by this link: http://tools.google.com/dlpage/gaoptout?hl=de.
- The website uses Google Analytics with the extension ?_anonymizeIp()“. As a result, IP addresses are further processed in a shortened form, so that direct reference to persons can be ruled out. As far as the data collected about you is personal, it will be excluded immediately and the personal data will be deleted immediately.
- As an alternative to the browser plugin you can use the following link to prevent future acquisition of data by Google Analytics on this website. If you do so, an opt-out cookie is stored on your terminal device. If you delete your cookies, you must click the link again.
- We use Google Analytics to analyze and be able to regularly improve the use of our website. With the gained statistics we can improve our offer and make it more interesting for you as a user. The legal basis for the use of Google Analytics is?Article?6?para.?1?S.?1 lit. a GDPR.
- Contact information Europe:
Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436?1001.
- After our purpose of the use of Google Analytics has ceased and the use has ended, the data collected in this context will be deleted.
Section 7: Google maps
- We use Google Maps to visually display geographic information. Furthermore, to show the places where you can pick up and return the Vehicles (“hubs”). Google Maps is a service of Google Ireland Ltd.
- The legal basis for aformentioned data processing is Article 6 (1) (1) point (b) and (f) of the GDPR. The purposes of data processing named above constitute our legitimate interests.
- The data processing takes place on the basis of an agreement between jointly responsible persons according to Art. 26 GDPR, which you can see here (https://privacy.google.com/intl/de/businesses/mapscontrollerterms/).
Section 8: 3rd parties with whom personal information may be shared
- We share the following data with 3rd parties to provide our service. Some of the service provider are located in the US and are certified under the EU-US Privacy Shield. This means that US-based companies certified under the EU-US Privacy Shield can provide an adequate level of data protection.?
Section 9: Your rights
- You have the following rights with respect to personal data concerning you:
- Right to information (Article 15 of the GDPR)
- Right to rectification of data (Article 16 of the GDPR)
- Right to erasure of data (Article 17 of the GDPR)
- Right to restriction of processing (Article 18 of the GDPR)
- Right to data portability (Article 20 of the GDPR)
- In addition, you have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes against this regulation (Article 77 of the GDPR).
- You have the right to withdraw the consent you once gave to us with regard to data processing any time (Legal basis: Article 6 (1) (1) point (a) of the GDPR). As a result, we shall no longer be allowed to process data based on this consent going forward. The withdrawal of consent shall not affect the legality of the processing done on the basis of this consent before its withdrawal.
- Right to object to processing (Article 21 of the GDPR)
Right to object
- You have the right, for reasons arising from your particular situation, to object to the processing of your personal data which is based on Article 6 (1) point (f) of the GDPR (Data collection for purposes of safeguarding legitimate interests), any time; this includes profiling based on those provisions. If you make use of this right to object, we shall no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or unless the processing is for purposes of asserting, exercising or defending legal claims.
- Where we process your personal data for direct advertising purposes, you will have the right to object at any time to the processing of your personal data for such advertising purposes; this also includes profiling to the extent that it is related to such direct advertising. The existence of a special situation, as in (a), is therefore, not necessary for an effective objection to direct advertising. If you object to processing for direct advertising purposes, your personal data will no longer be processed for such purposes.
Donkey Republic, January 2020