General notes
Effective from: 1st of January 2019
Scope of the Privacy Policy
Free2Move is a service that gives you access to thousands of carsharing vehicles. You can switch between cars, scooters and bicycles of different providers with just one click. Searching between different apps for the cheapest or nearest vehicle belongs to the the past. You can now easily compare ALL vehicles on a map and book your next trip.
This Privacy Policy applies to the Free2Move website and our facebook fan page.
Controller
GHM Mobile Development GmbH is responsible for data processing within the meaning of the General Data Protection Regulation (GDPR). We decide about the purposes and means of processing personal data. Our contact details are: GHM Mobile Development GmbH, represented by Michel Stumpe and Fabian Kofler, Dessauer Straße 28-29, 10963 Berlin. You can reach us by e-mail at info@free2move.me
Data protection officer
Our data protection officer is:
activeMind AG Technologie- und Managementberatung
Chairman: Klaus Foitzick
Chairman of the supervisory board: Manfred Keßler
Kurfürstendamm 56
10707 Berlin
HRB 135796 AG München
Email: free2move@activemind.de
activeMind AG Technologie- und Managementberatung
Chairman: Klaus Foitzick
Chairman of the supervisory board: Manfred Keßler
Kurfürstendamm 56
10707 Berlin
HRB 135796 AG München
Email: free2move@activemind.de
1. Provision of the website
To ensure a smooth connection and a comfortable use of our website, we temporarily collect information about your browser and operating system, the type of device used, the date and time of access, the requested website or file and the IP address in anonymous form. This information does not allow the identification of the site visitor and is deleted after 24 months at the latest.
Legal basis for such data processing is Art. 6 (1) lit. f) GDPR.
2.Contact form
If you contact our customer service via the form provided on our website, the personal data transmitted with your request will be stored. We use this data for answering your inquiry only.
For the management of support requests we use Zendesk, a customer service software from Zendesk Inc. ("Zendesk"). Support requests, including e-mail addresses, are stored on a Zendesk server (in the EU or US) secured against unauthorized access.
Legal basis for such data processing is Art. 6 (1) lit. f.) GDPR. The data will be deleted when the purpose of the processing no longer applies, e.g. the request has been answered conclusively.
3. Business contact
Potential business partners can use the business contact on our website to send us an e-mail request. We process any personal data transmitted with this e-mail for answering the inquiry only.
Legal basis for such data processing is Art. 6 (1) lit. f.) GDPR. The data will be deleted when the purpose of the processing no longer applies, e.g. the request has been answered conclusively.
4. User feedback
If you send us feedback on your own initiative or as part of one of our surveys, we process the data provided by you for performing the survey and for evaluating and, if necessary, implementing your feedback. Legal basis for this data processing is Art. 6 (1) lit. f) GDPR or Art. 6 (1) lit. a) GDPR, if we request your consent to participate in the survey. If you have not agreed to a longer-term use and legal regulations do not require a longer storage, the data will be deleted if you delete your user account.
5. Newsletter and own market research
If you have registered for our newsletter, we will use your e-mail address to send you information about our service (e.g. new functions of our app) on a regular basis. You can unsubscribe from the newsletter at any time by clicking the unsubscribe link in the newsletter. Legal basis for such data processing is Art. 6 (1) lit. a) GDPR.
We are always working on further improving our service. We depend on the feedback and participation of our users. To this end, we send e-mails to individual users to invite them to participate in – of course voluntary – usability tests. Legal basis for such data processing is Art. 6 (1) lit. f) GDPR. You may opt out of receiving these e-mails at any time by sending an email to help@free2move.me.
6. Registration with carsharing providers
We introduce various carsharing providers on our website. If you would like to register with one of these providers, you can use the link to the registration form on the website of the respective provider. We store the information that you have registered with a provider via our website (but not the information that you provide on the provider's website). We use this information in aggregated form to generate reports on the use of our services. These reports do not contain any personal data.
Legal basis for such data processing is Art. 6 (1) lit. f) GDPR.
7. Applications to Free2Move
You have the opportunity to apply for a job at Free2Move via our website, Indeed or LinkedIn. The information you provide as part of your application (first and last name, e-mail address, telephone number, possibly c.v. and certificates or additional information such as salary expectations or student status) will be processed by us for processing your application.
We use RecruiteeHR, an application software provided by Recruitee B.V. ("Recruitee") for application management. The data of our applicants are stored on a server operated by Recruitee in the European Union and are protected against unauthorized access by third parties.
Legal basis for such data processing is Art. 6 (1) lit. b) GDPR. The data will be deleted after six months unless it is necessary for the processing of an employment relationship. In this case we will inform you separately about the type and scope of data processing.
8. Google Analytics
For the statistical evaluation and analysis of the use of our website we use Google Analytics, a service of Google Inc. "("Google). We do not process any personal data, but only anonymous demographic information, such as technical information about the device and operating system used, language settings and screen resolution as well as the location from which our website is used. The information generated by Google Analytics about your use of our website is usually transferred to a Google server in the US and stored there. The function for IP anonymization is activated. This means that your IP address will previously be shortened by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the US and shortened there. The IP address is not merged with other Google data.
You may prevent the use of cookies by selecting the appropriate settings in your browser. In this case you may not be able to use all functions of our website. You can prevent the collection of information generated by the cookie and data processing by Google Analytics by following this link: https://tools.google.com/dlpage/gaoptout?hl=en
Further information on data processing within the framework of Google Analytics and Google's privacy policy can be found here: https://support.google.com/analytics/answer/6004245?hl=en.
Google holds a Privacy Shield certification that ensures an adequate level of data protection.
Legal basis for such data processing is Art. 6 (1) lit. f) GDPR. These data will be deleted after 26 months at the latest.
9. Social Plugins
In order to increase the user-friendliness of our website, we have integrated various social plugins.
Facebook
We use plugins from Facebook. The plugins are marked with the Facebook logo. When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to the Facebook servers. By integrating the plugins, Facebook receives the information that you have called up the corresponding page of our website. If you are logged in to Facebook, Facebook can associate your visit with your Facebook account. The purpose and scope of data processing and your rights and setting options for protecting your privacy are set out in Facebook's privacy policy at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
You can find the various opt out options here: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
To prevent data processing through the Facebook plugin, you must log out of Facebook before visiting our website.
Instagram
Our website includes a plug-in from Instagram, operated by Instagram Inc. 1601 Willow Road, Menlo Park, CA 94025, USA („Instagram“). When you visit a page on our website that contains such a plugin, your browser establishes a direct connection to Instagram's servers. By integrating the plugin Instagram receives the information that you have accessed the corresponding page of our website.
The purpose and scope of data processing and your rights and setting options for protecting your privacy are set out in Instagram's privacy policy at https://help.instagram.com/155833707900388.
To prevent data processing through the Instagram plugin, you must log out of Instagram before visiting our website.
Twitter
We also use plugins from Twitter Inc. 1355 Market St, Suite 900, San Francisco, CA 94103, USA ("Twitter"). When you access a page of our website that contains such a plugin, your browser establishes a direct connection to Twitter's servers. The content of the plugin is transmitted directly from Twitter to your browser and integrated into the page. By integrating the plugin Twitter receives the information that you have called up the corresponding page of our website, even if you do not have a profile on Twitter or are not logged in at Twitter. If you are logged in to Twitter, Twitter can associate your visit to our website with your Twitter account. The purpose and scope of data processing and your rights and setting options for the protection of your privacy are set out in the Twitter privacy policy at https://twitter.com/privacy
If you do not want Twitter to associate the data collected via our website with your Twitter account, you must log out of Twitter before visiting our website. You can find the various opt out options here: https://twitter.com/personalization
LinkedIn
Our website also includes a LinkedIn plugin (a service of LinkedIn Corporation, 2029 Stierlin Court, Mountain View, CA 94043, USA - "LinkedIn"). When you visit a page of our website that contains such a plugin, your browser establishes a direct connection to LinkedIn's servers. By integrating the plugin LinkedIn receives the information that you have called up the corresponding page of our website. If you are logged in to LinkedIn, LinkedIn can associate your visit to our website with your LinkedIn account. The purpose and scope of data processing and your rights and setting options for the protection of your privacy are set out in LinkedIn's privacy policy at https://www.linkedin.com/legal/privacy-policy
If you do not want LinkedIn to associate the data collected via our website with your LinkedIn account, you must log out of LinkedIn before visiting our website.
10. Google Maps API
We use the Google Maps API on our website to display a map of our location. When using Google Maps, Google collects and processes data about the use of this function by visitors of the website. Further information about the purpose and scope of data processing by Google and the rights of the persons concerned can be found in Google's privacy policy at https://policies.google.com/privacy?hl=de.
11. Our facebook page
When you visit our fan page on Facebook, Facebook collects personal data. This also applies if you do not have a Facebook account. Unfortunately, we cannot control the type and extent of data processing by Facebook. Facebook only provides us with anonymous demographic information in aggregated form, which helps us to get to know our audience better. The purpose and scope of data processing by Facebook as well as your rights in this respect vis-à-vis Facebook and setting options for the protection of your privacy are set out in Facebook's privacy policy at https://www.facebook.com/policy.php.
12. Your rights with regard to the processing of personal data
As a person concerned, you have various rights in connection with the processing of your personal data.
If you wish to assert your rights to information, correction, deletion, restriction of processing, object to data processing or revoke your consent to data processing, please send an e-mail to help@free2move.me
Right to information
You have the right to information about your personal data processed by us and to the following information:
- the processing purposes;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom the personal data have been or are being disclosed, in particular recipients in third countries or international organisations;
- if possible, the planned duration for which the personal data will be stored or, if this is not possible, the criteria for determining this duration;
- the existence of a right to rectification or deletion of your personal data, to restricting the processing of your personal data or to object to such processing;
- the existence of a right of appeal to a supervisory authority;
- if the personal data is not collected from you, all available information about the origin of the data;
- the existence of automated decision-making, including profiling in accordance with Article 22 (1) and (4) GDPR and, at least in these cases, meaningful information on the logic involved and the scope and intended impact of such processing on the data subject.
- in the case of the transfer of personal data to a third country or an international organisation, on the appropriate safeguards under Article 46 GDPR in relation to the transfer
Right to rectifaction
You have the right to immediately request the rectifcation of inaccruate personal data concerning you and, taking into account the purposes of the processing, the completion of incomplete personal data - also by means of providing a supplementary statement.
Right to erasure
You have the right to request the immediate erasure of personal data concerning you and we are obliged to delete this data immediately if one of the following reasons applies:
- The personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
- You revoke your consent on which the processing was based under Article 6 (1) lit. a) or Article 9 (2) lit. a) of the GDPR and there is no other legal basis for the processing;
- You object to the processing pursuant to Article 21 (1) GDPR and there are no overriding legitimate grounds for processing or you object tot he processing pursuant to Article 21 (2) GDPR;
- Your personal data has been processed unlawfully;
- The deletion of your personal data is necessary to fulfil a legal obligation under Union law or the law of the Member States to which we are subject;
- The personal data have been collected in relation to information society services provided in accordance with Article 8 (1) GDPR.
If we have made personal data public and are obliged to erase personal data in accordance with Art. 17 (1) GDPR, we will take appropriate measures, including technical measures, taking into account the available technology and the implementation costs, to inform controllers who process the personal data you have requested the erasure by such controllers of any links to or copies or replications of, those personal data.
These rights do not apply to the extent that processing is necessary.
- to exercise the right of freedom of expression and information;
- to fulfil a legal obligation required for processing under the law of the Union or of the Member States to which we are subject;
- to assert, exercise or defend legal claims.
Right to restriction of processing
You have the right to request us to restrict processing if one of the following conditions is met:
- the accuracy of the personal data is contested by you, for a period of time that enables us to verify the accuracy of the personal data;
- the processing is unlawful and you oppose to delete the personal data and instead requests the restriction of the use of your personal data;
- we no longer need your personal data for the purposes of processing, but you do need it to assert, exercise or defend legal claims, or
- you have objected to the processing pursuant to Article 21 (1) GDPR pending the verifcation whether the legitimate interests of our company override your legitimate interests.
Right to data portability
You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit this data to another controler without hindrance, provided that the processing is based on a consent pursuant to Article 6 (1) lit. a) or Article 9 (2) lit.a ) GDPR or on a contract pursuant to Article 6 (1) lit. b) GDPR and the processing is carried out by automated means.
When exercising your right to data portability, you have the right to have your personal data transferred directly by us to another controller, insofar as this is technically feasible.
Right of objection
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you which is based on Article 6(1) lit. e) or f) GDPR, including profiling based on these provisions. We will no longer process your personal data unless we can desmonstrate compelling legitimate reasons for the processing that override your interests, rights and freedoms or the processing serves to assert, exercise or defend legal claims.
Right of revocation
You have the right to revoke your consent tot he processing of your personal data at any time. The revocation of consent does not affect the legality of the processing carried out on the basis of the consent until revocation.
Right to lodge a complaint
If you consider that the processing of personal data concerning you infringes the GDPR, you can lodge a complaint with a superverisory authority, in particular in the Member State of your habitual residence, your place of work or the place of the alleged infringement.
The supervisory authority which is competent at our place is: Berliner Beauftragte für Datenschutz und Informationsfreiheit, Friedrichstraße 219, 10969 Berlin, Visitors' Entrance: Puttkamer Straße 16 - 18 (5th floor), Phone: 030/138 89-0, Fax: 030/215 50 50, E- Mail: mailbox@datenschutz-berlin.de
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