Thank you for choosing Zwings. We wish you many happy, safe, enjoyable hours of responsible riding on our e-scooters and e-bikes.
(last updated: 8th September 2021)
This is our Privacy Statement which explains how we obtain, use and keep your personal data safe in relation to the Zwings website, Zwings App and Zwings Account.
Your personal data is data which, by itself or with other data available to us, can be used to identify you. Zwings respects your privacy and we are committed to keeping your personal information safe in accordance with applicable data protection laws.
This Privacy Statement will tell you about your privacy rights and how the law protects you. It is important that you read it together with our Terms and Conditions and User Agreement (“Terms”) which govern your use of our Services, Cookies Policy and any other policies we have in place at any time.
This Privacy Statement supplements our Terms and other policies and is not intended to override them.
The data controller is Blue Zoom Transport Solutions Limited trading as Zwings (“we”, “us” or “our”). The data controller is responsible for your personal data.
Data Control Officer: Joe Lewin
Email address: support@Zwings.co.uk
Telephone: 020 3882 0611
Postal address: 83 Lavender Hill, London SW11 5QL
It is important that the personal data we hold about you is accurate and current. Please ensure that you keep us informed of changes to your personal data.
THE TYPES OF PERSONAL DATA WE COLLECT AND USE
Information you give to us: your name, date of birth, gender, your contact information including your email address, telephone and residential address you provide us for contacting you, your preferred method of payment such as your credit or debit card details, your marketing preferences for receiving information about our services, and communications you exchange with us.
Location data: When you download the Zwings App and register an account to use our Services we use location data which includes details of your location at the time. We do this using GPS technology. We need this data to show you the location of Zwings vehicles available to rent, to show you the routes you take and whether or not your ride is still active.
If you do not consent to the processing of Location Data then you may withdraw your consent by disabling location data from the settings of your electronic device however you but it may mean that you will not have access to the full range of our Services.
In addition, we may receive personal data about you from various third parties and public sources including:
- Device Data from analytics providers, advertising networks and search information;
- Contact, Financial and Transaction Data from providers of payment services;
- Identity and Contact Data from data brokers or aggregators;
- Identity and Contact Data from publicly available sources;
- Information about install and uninstall services; and
- Sensitive categories of personal data potentially revealing ethnic origin and health conditions.
WHAT HAPPENS IF YOU FAIL TO PROVIDE PERSONAL DATA
We will tell you if providing some personal data is optional, in which case we will ask you for your consent. Otherwise, if you fail to provide the requested personal data, we may be unable to process or respond to your query or supply the Services under the Terms in full or in part.
Under certain circumstances, we may be under compulsion of law to collect personal data. If you fail to provide that data when requested, we may have to cancel Services or close your account but we will notify you if this is the case at the time.
HOW WE WILL PROCESS YOUR PERSONAL DATA
We will only use your personal and location data for the purpose for which we collected it which include the following:
1. As necessary to perform our contract under the Terms with you:
- To take steps at your request prior to entering into it;
- To decide whether to enter into it;
- To manage and perform that contract;
- To update our records; and
- To trace your whereabouts to contact you about your account and recovering debt.
2. As necessary for our own legitimate interests or those of other persons and organisations, e.g.:
- For good governance, accounting, and managing and auditing our business operations;
- To monitor emails, calls, other communications, and activities on your account;
- For market research, analysis and developing statistics; and
- To send you marketing communications including informative emails and SMS.
3. As necessary to comply with a legal obligation, e.g.:
- When you exercise your rights under data protection law and make requests;
- For compliance with legal and regulatory requirements and related disclosures;
- For establishment and defence of legal rights;
- For activities relating to the prevention, detection and investigation of crime; and
- To monitor emails, calls, other communications, and activities on your account.
4. Based on your consent, e.g.:
- When you request us to disclose your personal data to other people or organisations;
- When we process any special categories of personal data about you at your request (e.g. your racial or ethnic origin, biometric data, etc); and
- To send you marketing communications where we’ve asked for your consent to do so.
You are free at any time to change your mind and withdraw your consent. The consequence might be that we can’t do certain things for you.
HOW IS YOUR PERSONAL DATA COLLECTED?
We will use the information you submitted during the creation of your customer account as well as automatically-collected information, such as:
- Direct interactions, for example when you provide us with your Identity, Contact and Financial Data by filling in forms or by corresponding with us by email, phone, or post.
- Notices of receipt and read confirmations of messages;
- Information about your device and the browser used;
- Your activities in our apps;
- Your history of using Zwings services.
We may receive personal data about you from various third parties and public sources such as analytics providers, e.g. driving license verification platforms, Google, advertising networks, Contact, Financial and Transaction Data from providers of technical, payment and delivery services, Identity and Contact Data from data brokers or aggregators; and Identity and Contact Data from publicly availably sources such as Companies House.
SPECIAL CATEGORIES OF DATA
We will process the special categories mentioned in this Privacy Statement for sharing with Government or Local Government and they, in turn, will process such data for the purpose of gathering information to better regulate e-scooters and e-bikes in order to improve safety, provide sustainable alternative travel and help promote the Secretary of State promote its obligations under the Public Sector Equality Duty as set out under section 149 of the Equalities Act 2010.
WHEN WILL WE MAKE DISCLOSURES OF YOUR PERSONAL DATA
We will share your personal data to third parties in circumstances as follows:
- Service providers acting as processors based in and outside of the UK who provide payment processing services, App development, IT and other system services;
- Professional advisers acting as processors or joint controllers including banks, lawyers, auditors and insurers;
- Government, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances, or if we believe it is necessary to do so to meet legal requirements or to prevent accidents and or crime, to defend our legal rights, to improve road safety and the usage of E-scooters and E-bikes;
- Department for Transport and DfT’s third party research contractors, Arup and NatCen Social Research the purposes of assessing the safety of vehicles, regulation of e-scooters.
- Third parties to whom we may choose to acquire, merge, or transfer our assets or parts of our business. In these circumstances, new owners may use your personal data.
Data sharing with the Department for Transport (DfT)
This securely shared data will enable DfT to understand the effects of e-scooters and to allow ministers to take an informed decision in the future about how they should be regulated to promote safe and sustainable travel.
DfT’s privacy statement for e-scooter trials is available at: https://www.gov.uk/government/publications/dft-online-form-and-survey-privacy-notice/e-scooter-trials-privacy-statement
The data that will be shared includes:
- Pseudonymised data: Details of the length, duration and location of trips. Please note neither DfT nor its research contactor will be able to attribute this data to any personally identifiable data.
- Personal data: contact details (for the sole purpose of follow-up research); Month and day of the week, and a time band (i.e. a Wednesday in March, between 7-12am) for the trip; the duration and distance of the trip; and the area (the ONS Lower Super Output Area that corresponds to a trip’s start point). Operators will also share responses you may provide to questions asked after each trip.
DfT and Zwings take data protection extremely seriously and are ensuring the collection of this data is compliant with Data Protection Legislation.
For more information about the standards you can expect when DfT asks for, or holds, your personal information, read DfT’s Personal information charter.
DfT is also preparing a separate survey that you may be asked to respond to as a participant in these rental e-scooter trials. The survey will ask for information about your gender, ethnicity, age and first-part post code to enable the DfT’s research contractor to assess the impact of e-scooter use on equality and opportunity, and to compare different experiences of e-scooter use according to those characteristics. Further details of this will be provided with the survey.
We are required to share personal data with the DfT and do so under Art. 6(1)(e) GDPR i.e. public task; The DfT requires this data in order to enable the Secretary of State for transport (SoS) to gather sufficient evidence to assess the use and impacts of e-scooters. The results of the insights will be used towards developing the regulations which will be applied to e-scooters in ways that promote safe and sustainable travel and fulfill the SoS obligations under the Public Sector Equality Duty as set out under section 149 of the Equalities Act 2010.
To summarise, the personal data that will be shared with the DfT include:
|User||Zwings User ID, full name, email address, phone number|
|User Trip||Zwings Trip ID, trip timestamp, trip distance and duration, trip area|
|Survey||Zwings ID, survey timestamp, questions and answers|
Other pseudonymised data which cannot be linked to individuals will also be shared, such as our vehicle IDs, our vehicle statuses and locations etc.
We may use your identity, contact, technical, usage, and Account to form a view on what we think you may want or need, or what may be of interest to you, including promotional offers and also informative messaging, for example, information relating to our company’s response during lockdown.
You may receive marketing communications from us if you have requested information from us or purchased services from us or if you provided us with your details when you entered a competition or registered for a promotion unless you have opted out of receiving that marketing.
- collect information that will help us understand visitors’ browsing habits on our website;
- compile statistical reports on website activity, e.g. number of visitors and the pages they visit;
- temporarily store any information which you may enter in tools, such as calculators or demonstrations on our website; and
- in some cases, remember information about you when you visit our site.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We limit access to your personal data to those Zwings employees, agents and contractors and other third parties who have a justified business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have procedures to deal with any personal data breach, suspected or actual, and will notify you and any applicable regulator of a breach where we are legally required to do so.
RETENTION OF YOUR PERSONAL DATA
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for. We apply the following criteria to determine data retention periods for your personal data:
- Retention in case of queries: we will retain your personal data as long as necessary to deal with your queries or for a sensible period in order for us to reply to your online query and then deal with queries you raise upon receipt;
- Retention in case of claims: we will retain your personal data for as long as you might legally bring claims against us; and
- Retention in accordance with legal and regulatory requirements: we will retain your personal data after your account, policy or service has been closed or has otherwise come to an end based on our legal and regulatory requirements.
YOUR RIGHTS UNDER DATA PROTECTION LAW
The Data Protection Act 2018 gives you the following rights:
- The right to be informed about our processing of your personal data;
- The right to have your personal data corrected if it’s inaccurate and to have incomplete personal data completed;
- The right to object to processing of your personal data;
- The right to restrict processing of your personal data;
- The right to have your personal data erased (the “right to be forgotten”);
- The right to request access to your personal data and information about how we process it;
- The right to move, copy or transfer your personal data (“data portability”); and
- Rights in relation to automated decision making including profiling.
You have the right to complain to the Information Commissioner’s Office. It has enforcement powers and can investigate compliance with data protection law: www.ico.org.uk.
If you wish to exercise any of the rights set out above, please contact us using the details provided above.