Privacy Policy

In this document (the Privacy Policy) we explain how we process your personal data that we collect at E-FLY mobile app for your E-FLY vehicles - electric (hereinafter - Vehicles). Please read this Privacy Policy carefully.

Using the personal data we collect, we ensure smooth service and consistent quality of service and E-FLY mobile application (hereinafter referred to as Mobile App). If we do not receive the requested personal information, we may not be able to rent you E-FLY vehicles and provide services related to their use.

The terms used in this Privacy Policy must be construed in accordance with the definitions given in E-FLY unless otherwise stated in this Privacy Policy.

We may update this Privacy Policy from time to time, and we recommend that you periodically review it. We will notify you of any changes by posting an updated Privacy Policy on the Mobile Gadget. If we make a material change to our Privacy Policy, we will send you an email notification.

1. WHO IS RESPONSIBLE FOR THE PROCESSING OF YOUR PERSONAL DATA?         

The Data Controller („We“ the Company ), which processes personal data provided by You in the Mobile App and collected by the Vehicle, is: 

E-Fly Scooters

Kuwait City, Kuwait

Contacts that we can address the personal data protection issues: [email protected], +965 9888 0403. 

2. WHAT LEGAL BASIS DO WE RELATE TO THE PROCESSING OF PERSONAL DATA?         

 We process your data in accordance with:

- With your consent:        

    You explicitly acknowledge it by installing the Mobile App on your device and selecting its settings;       

    Your permission for the Mobile App to access your device's integrated camera and geolocation data separately;         

    Your consent to record your telephone conversation with our Customer Service Center.       

- Our contractual agreements with you regarding Vehicle Rental and Services:        

    E-FLY terms and conditions of vehicle rental and service provision.        

- existing laws (legal obligation) such as tax, financial accounting, road safety and other legislation.        

 - Our legitimate interests include fraud prevention, analysis, debt management, debt reporting to debt collection agencies and credit rating agencies, creditworthiness assessment, network and information security, sharing of evidence of potential criminal activity with public authorities, GPS tracking to ensure our property security and implement the E-FLY agreement with you ! vehicle rental and service provision and other legitimate interests.             

Important:

- If you do not authorize the processing of your personal data for direct marketing purposes, you will only receive non-promotional emails and messages regarding E-FLY use of services.          

 3. WHAT PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSES DO WE USE IT?         

3.1. When you install the Mobile App and select its settings    

Your device will only work properly if you allow the Mobile App to use the following device data: Device operating system and device model. If you do not consent to the Mobile App receiving this data, please do not install the Mobile App on your device or select its settings. If you have already done so without carefully reading this Privacy Policy on the Google Play and App Store platforms, please delete the Mobile App from your device immediately prior to installation.   

We use third-party tools such as Google Firebase, Google Ads, Facebook Ads for analytics and advertising to collect aggregated and personalized information about how individuals use the Mobile App, to understand how we can improve it and to provide relevant non-personalized advertising of our services. If you do not consent to the processing of the data for the purposes described above, please do not install the Mobile App on your device or select its settings. If you have already done so without carefully reading this Privacy Policy on the Google Play and App Store platforms, please delete the Mobile App from your device immediately prior to installation.       

3.2. Create an account in the Mobile App   

If you wish to start using the Mobile App, you must register for it by submitting to E-FLY terms and conditions of vehicle rental and provision of services required personal data. We have the right to ask for and process the following information: Your name, contact information (phone number, email address), address, credit card information (card type, bank name, card number, period of validity ).

3.3. Using the Mobile App 

When you use the Mobile App, we record your actions (such as booking a vehicle, locking / unlocking it, etc.), and collecting other data related to your use of the Services (the vehicles you use, date and time of use, where the Vehicle was picked up and left, Vehicle Route, Speed, etc.). The mobile gadget will be able to access your device's geolocation data, the camera integrated with the device, and send mobile gadget notifications, if you give it permission in the mobile gadget and / or device settings. Please note that if you do not allow the above data (features), some features of the Mobile App may not work and you may not be able to rent a E-FLY Vehicles and / or Services.

Your contact details (email address, phone number (for text messaging)) may be used to provide information related to the services used, changes to E-FLY Vehicle rental and service terms and conditions, price list, etc.  

Please note that if national law permits, we are entitled to e-mail send general-purpose direct marketing messages by email or SMS based on your legitimate interest in offering the Services or asking you to comment on our Services. In addition, you can always give us permission to receive messages such as active messages. You have the right to withdraw your consent at any time by telephone: +965 9888 0403 or by email: [email protected].

3.4. Use of vehicles    

Each Vehicle is equipped with an electronic system that registers the Location of the Vehicle, the Distance traveled by the Vehicle, the Time of Use of the Vehicle, the speed and other data related to the Vehicle and their use and transmits such data to Us. That's what we need E-FLY vehicle rental and services based on E-FLY terms and conditions of vehicle rental and service provision.    

When you sign up for the Mobile App and use E-FLY vehicle rentals and services, we are entitled to take into account your creditworthiness, debt to the extent permitted by applicable law and in the light of our legitimate interests (risk assessment, protection of our property, security of third parties and their property, collection of fees for provided services) , driving experience, relevant traffic offenses, history of insurance incidents involving you during the lifetime of the Vehicle and making decisions based on this data, which may affect how we provide you with the Services (if you already use our Services).   

If you default on your financial obligations under E-FLY and within 30 calendar days of receipt of the notice, we have the right, subject to applicable law, to transfer your account and personal data to persons who have a legitimate interest, joint debtors' data files for debt management and / or recovery purposes, in the legitimate interest of Us and third parties.   

In the event of a traffic accident with the Vehicle, we will process the personal data collected in connection with the accident so that we can indemnify those involved in the accident, together with Our and / or the accident insurance companies.

In order to improve and improve the quality of E-FLY vehicle rental and service provision, we may analyze non-personal, statistical data (such as Vehicle Use Date and Time, Places where the Vehicle was Picked up and Left, Vehicle Route, Speed) and the like) collected by you through E-FLY Vehicle Rental and Services through the Mobile App.    

4. WILL YOUR INFORMATION SHARE WITH OTHERS?         

 We may use third party services (third party data centers, servers, document, photo verification, administration, payment, audit, accounting, legal and consulting services, debt collection, mobile app usage analysis and statistics services, direct marketing services, email applications, text messaging, etc.) or collaborate with partners on providing services that require access to your personal data to a limited extent. In this case, we ensure that third parties comply with their obligations regarding confidentiality and adequate protection of personal data.

Where appropriate, your personal data may be submitted to the competent state and municipal authorities in accordance with applicable law and / or our legitimate interests.

In the event of an accident involving the Vehicle, your data will be passed on to the insurance companies and, if necessary, to other parties involved in the accident.

Based on the Vehicle Data available to us, we have the right and, where appropriate, the obligation to forward information about traffic offenses to the responsible authorities.

How long do we keep your personal data?         

 E-FLY personal data collected for leasing and provision of services must be kept for the time necessary to achieve the purposes for which the personal data were collected, except where the data may be kept for longer than is necessary: 

(i) to comply with legal obligations requiring the processing of submitted data;

(ii) retain information relating to alleged criminal activities;

(iii) to assert, pursue or defend legal claims.

Your personal data is stored:

(i) for the administration of the Vehicle Sharing Service (ie customer registration and accounting, contract management and enforcement, debt collection and fines): 3 months in the event of withdrawal; 5 years after the expiry date of the contract. Clients who have failed to meet their financial and / or property obligations or have caused damage to the Company are retained for an additional 5 years;   

(ii) 3 years for the purpose of securing the security of the Company's property (Rental Vehicle) and performing the contract (GPS data) ; 

iii) for direct marketing purposes - for a period of 3 years, but not exceeding your consent;

iv) records of telephone conversations with you are retained for up to 6 months. 

5. WHAT DO YOU HAVE?         

In order to exercise your rights as a data subject, we strive to ensure that your personal data is processed in a transparent manner. As a personal data subject, you have the following rights:

(i) you have the right to be informed about the processing of personal data and to request access to them or copies of your personal data so that you can know for what purposes your personal data are being processed, for how long, etc.

(ii) you have the right to request that we modify or update your personal data if it is inaccurate or incomplete;

(iii) you have the right to request that some or all of your personal data be withheld temporarily or permanently;

(iv) you have the right to request the cessation of the processing of your personal data if we no longer have a legitimate interest or legal need to process it;

v) have the right, in certain cases, such as when personal data are processed for direct marketing purposes, to request the deletion of your personal data used for sending direct marketing messages;

vi) you have the right to request the transfer of your personal data in a systematic, computer readable format to another service provider.  

We do not use automated decision-making processes, including profiling, which may have legal consequences or have a significant impact on your personal data. However, when we process your personal data for the purposes of direct marketing, we may place you in the appropriate category of customer, and you have the right to request human intervention to express your views or to object.

If you intend to exercise your rights, you should email us to [email protected] but you will need to prove your identity by electronic or other means before we can properly identify you in accordance with the law. 

We will provide the information immediately, but no later than one month after your request. The information will be provided to you free of charge, but if the requests are manifestly unfounded or disproportionate, in particular because of their repetitive content, we may charge you a reasonable fee to cover the administrative costs or refuse to comply with your request.

6. HOW DO WE CARE ABOUT THE SECURITY OF YOUR PERSONAL DATA?         

We use appropriate organizational and technical measures to ensure the security of personal data, including protection against unauthorized or unauthorized processing of data and against accidental loss, destruction or damage. These measures have been selected based on the risks that your rights as a data subject and your freedoms may pose.

We strictly control access to the personal data we process, providing only those employees of the Company who need personal data to carry out their work, and we monitor how they use the access granted. Employees of the company who have access to personal data are made aware of personal data protection requirements and ensure the confidentiality of personal data processed.  

We regularly monitor our systems for potential breaches or attacks. However, the security of information transmitted over the Internet cannot be guaranteed. Accordingly, you provide us with information through the Mobile App at our sole discretion and at your own risk, using the Internet Connection.

We provide access to personal data with the appropriate level of passwords and make arrangements for the protection of confidential information with individuals who have access to your personal data.

7. HOW CAN YOU CONTACT US ABOUT THIS POLICY?         

If you have any additional questions or comments, you can contact us by email [email protected] or phone +965 9888 0403 .