Zoomo Terms and Conditions

‍PRIVACY POLICY

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Voir la politique de confidentialité en français

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Welcome to Zoomo’ Privacy Notice. At Zoomo, we want you to know that we have your best interests at heart and in this Privacy Notice, we give you information on how we collect and process your Personal Data when you use our website or mobile applications, take part in any of our competitions, sign-up as a member with us, apply for a job with us, or are a service provider to us.

As data protection is really important to Zoomo, we may provide you with additional data privacy notices or information that is specific to your situation – and if we do, you need to read that additional information alongside this Privacy Notice (which is our key document and will always apply).

As Zoomo takes managing your Personal Data seriously, we have a team who are responsible for overseeing the management and security of your Personal Data as well as answering any questions that you have about this Privacy Notice. If you would like to get in touch with this team, please kindly contact privacy@ridezoomo.com.

We also need to let you know that if you have any concerns or if you’re not happy with our approach, you have the right to make a complaint at any time to your local data protection regulator. This Privacy Notice is kept under regular review and was last updated in June 2023.

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PERSONAL DATA

Personal Data, or personal information, means any information about an individual from which that person can be identified.

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A) Types of Personal Data

In general, we collect, use, store and transfer the different kinds of Personal Data we’ve grouped for you below:

• Identity Data includes first name, maiden name, last name, username or similar identifier, title, Social Security number, driver’s license number, state identification card number, passport number and date of birth.
• Contact Data includes billing address, email address, and mobile numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments from you and other details of products and services you have registered for with us.
• Technical Data includes internet protocol address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website. Where you are a member with us, it also includes data on your rides, such as the locations that you have travelled to and from with our bike, return time, mileage, accidents, etc., as our bikes are equipped with bike tracking and anti-theft technology that uses Global Positioning System (GPS), as well as devices that monitor the state of the bike and any accidents.
• Profile Data includes your username and password, agreements signed with you (such as our rental or rent-to-own agreements), interests, preferences, feedback, and survey responses.
• Usage Data includes information about how you use our website and services.
• Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences. We process your Personal Data to send you marketing communications via Email or SMS (or other digital mediums) about our products, services and upcoming events that might interest you.
• Aggregated Data includes location, statistical or demographic data that is compiled for any purpose. Aggregated Data could be derived from your Personal Data, but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Notice.

We do not collect any special categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data).

Our products and services are not intended for anyone under the age of 18 and therefore, we do not knowingly collect data relating to children.

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‍B) Our relationship with you

The Personal Data that we collect from you depends on our relationship with you. Below we’ve made a chart that explains the Personal Data that we collect, how we collect this data, and what our legal basis is for collecting it (as we will only collect and process your Personal Data when the law allows us to do so).

Please contact us on privacy@ridezoomo.com if you need details about the specific legal ground we are relying on to process your Personal Data where more than one ground has been set out in the table above.

It is important that the Personal Data we hold about you is accurate and current. Please keep us informed if your Personal Data changes during your relationship with us.

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‍C)  If you fail to provide Personal Data

Where we need to collect Personal Data by law or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods and/or services). In this case, we may have to cancel the goods and/or services you have with us – but we will notify you of this in advance.

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‍D) Change of purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.

If this does occur and you wish to get an explanation as to how the processing for a new purpose is compatible with the original purpose, please contact us on privacy@ridezoomo.com. If we need to use your Personal Data, however, for an entirely unrelated purpose, we will notify you, and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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‍DO WE DISCLOSE YOUR Personal Data TO OTHERS AND IF SO, WHO?

We may share your Personal Data with internal third-parties, such as other entities within our group, that are based outside of your country of residence.

We may also share your Personal Data with the following external third-parties for the reasons set out below:

• Potential and existing customer tracking and engagement providers – for us to be able to track our engagement with potential and existing customers as well as be able to communicate with them through different methods (such as online chat, text and telephone).
• ‍Telematics device and software providers – for us to be able to monitor bike data, riding behavior, and bike location.
• ‍Payment service providers – for us to process any payments made by our customers to us.
• ‍Insurers and claims processors – for us to deal with any accidents or bike issues that our customers face.
• ‍Bike servicing, maintenance, and repair organizations – for us to ensure that the bikes that our customers are driving are roadworthy.
• ‍Candidate tracking, assessment, and background screening organizations – for us to manage and evaluate candidates that are applying for vacancies with us and to confirm their details and credentials.
• Technology companies that provide us with desktop and cloud-based products – for us to conduct our business and back-up data (which may include your Personal Data) whilst you are reviewing our website, applying to be our customer, applying for a vacancy with us, or acting as one of our suppliers.
• Professional advisers such as law firms, banks, and accountancy firms – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your Personal Data).
• ‍Delivery Platform Partners – which we partner with to provide discounts and other special offers to eligible Zoomo Riders.
• ‍Regulators and other governmental authorities – which we need to engage with for the purposes of our business and may need to provide data (and this may include sharing your Personal Data).
• ‍New business/asset owners – Third-parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your Personal Data in the same way as set out in this Privacy Notice.

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We require all third-parties to respect the security of your Personal Data and to treat it in accordance with the law. We do not allow our third-party service providers to use your Personal Data for their own purposes and only permit them to process your Personal Data for specified purposes and in accordance with our instructions, except for when such third-parties are regulators and other governmental organizations.

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EEA Residents Only: We share your Personal Data within the Zoomo group and with some of our third-party suppliers. This will involve transferring your data outside of the EEA. Whenever we transfer your Personal Data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your Personal Data to countries that have been deemed to provide an adequate level of protection for Personal Data by the European Commission. For further details, see European Commission: Adequacy of the protection of Personal Data in non-EU countries.
• Where we use certain service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of Personal Data to third countries.
• Where we use providers based in the U.S., we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to Personal Data shared between Europe and the U.S. For further details, see European Commission: EU-US Privacy Shield.

Please contact us on privacy@ridezoomo.com if you want further information on the specific mechanism used by us when transferring your Personal Data outside of the EEA.

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‍HOW LONG DO WE RETAIN YOUR DATA?

We will only retain your Personal Data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal Data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and sensitivity of the Personal Data; the potential risk of harm from unauthorized use or disclosure of your Personal Data; the purposes for which we process your Personal Data and whether we can achieve those purposes through other means; and the applicable legal, regulatory, tax, accounting or other requirements.

By law, we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for 6 years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see “What are your legal rights?” below for further information. In some circumstances, we will anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

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‍WHAT ARE YOUR LEGAL RIGHTS?

You have various rights under data protection laws in relation to your Personal Data. These rights are summarised for you below.

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Right to request access to your Personal Data (commonly known as a “data subject access request”)

You are entitled to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

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Right to request correction of the Personal Data that we hold about you

You are entitled to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

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Right to request erasure of your Personal Data

You may ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

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Right to object to the processing of your Personal Data

If we are relying on a legitimate interest (or those of a third-party) to process your Personal Data and you feel this impacts on your fundamental rights and freedoms due to your particular situation, you may object to our processing. You also have the right to object to our processing of your Personal Data for direct marketing purposes. In some circumstances, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

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Right to request the restriction of the processing of your Personal Data.

You may ask us to suspend the processing of your Personal Data in the following scenarios:

• If you want us to establish the data’s accuracy.
• Where our use of the data is unlawful, but you do not want us to erase it.
• Where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims
• You have objected to our use of your data, yet we need to verify whether we have legitimate grounds to use it which may override your objection.

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Right to request the transfer of your Personal Data to you or to a third-party

You may request that your Personal Data be provided to you, or a third-party you have chosen, in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

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Right to withdraw your consent at any time where we are relying on consent to process your Personal Data

This will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us on privacy@ridezoomo.com. You will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, we may charge a reasonable fee or, alternatively, refuse to comply with your request, if your request is clearly unfounded, repetitive or excessive.

We may require information from you to help us confirm your identity. This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within 1 month. It may take us longer than 1 month to respond to your request if it is particularly complex, or you have made multiple requests. We will keep you updated if this is the case.

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California Residents Only: California residents have additional rights to limit the sharing of Personal Data. You should read the “Important Privacy Choices for Consumers” notice which describes your right to control the sharing.

Vermont Residents Only: We will not disclose your personal information or financial information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures.

Connecticut Residents Only: Pursuant to Connecticut General Statutes Sec. Section 42-471, it is the policy of Zoomo to protect the privacy of your Personal Data by doing the following:

• safeguarding any data, computer files and documents containing your personal information from any misuse by third parties;
• destroying, erasing or making unreadable any data, computer files and documents containing your personal information prior to their disposal;
• protecting the confidentiality of your Social Security number and other personal information;
• prohibiting the unlawful disclosure of your Social Security number and other personal information;
• limiting and/or restricting the access to your Social Security number and other personal information to other third parties; and
• limiting the access of your Social Security number and other personal information only to our employees who need access to your personal information in order to allow us to provide legal services to you, limiting the access of these employees to the extent that it is needed, and otherwise imposing restrictions and reasonable safeguards on our employees to prevent them from accessing your personal information

In the event that there is ever a breach of security regarding your personal information, we intend to comply with applicable state and federal law requirements regarding the notification and disclosure to you and to the appropriate authorities of the circumstances surrounding the breach.

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NON-PERSONAL DATA

Personal Data does not include data where the identity has been removed (Non-Personal Data). Non-Personal Data includes any information that, by itself, cannot be directly associated with a specific person or entity. This Privacy Notice does not limit or restrict our ability to collect, use and share Non-Personal or Aggregated Data for various purposes where required or permitted by law.

If you are a member using our bikes, we may collect, use and share Non-Personal Data relating to your rides. Examples of this Non-Personal Data could include the location, speed and distance of your rides, along with other information about the quality of your ride, such as incident reports, battery level, alarm triggers etc. We may use this information for the purposes of improving your user experience and optimising efficiencies within our services.

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DATA SECURITY

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your Personal Data to necessary employees, contractors and other third-parties. These persons will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We also have procedures to deal with any suspected Personal Data breach and we will notify you, along with any relevant regulator, of any breach where we are legally required to do so.

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‍COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. By using our sites, we’re assuming that you’re happy with our use of cookies. If you have any questions about it, please get in touch with us at privacy@ridezoomo.com.

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‍THIRD-PARTY LINKS

Our websites and applications may include links to third-party websites, plug-ins, and applications. We also may display or implement third-party content in our website or applications (e.g. data, information, applications and other products or services). By clicking on those links or enabling those connections, this may allow third-parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites and applications, we encourage you to read the relevant privacy documentation for every website you visit.

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MARKETING

We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information or purchased services from us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your Personal Data with any third-party for marketing purposes.

You can ask us or third-parties to stop sending you marketing messages at any time by contacting us at privacy@ridezoomo.com and withdrawing your consent. Where you opt out of receiving these marketing messages, this will not apply to messages that we need to send you as a result of performing a contract that we have with you (e.g. we may be required to contact you about overdue payments).

We may collect and use your Mobile Number and SMS interactions between you and Zoomo for the following purposes:

• Appointment Reminders: to provide the service you have requested, such as sending you appointment reminders.
• Promotions: to communicate promotions applicable to your account and Region.
• Account Servicing: to communicate with you about your account or our services and allow you to use digital Zoomo products and services.

We will not share your SMS messages with third parties, except in the following circumstances:

With your explicit consent.

• To comply with legal requirements, such as a subpoena or court order.
• To protect the rights, property, or safety of our company, our users, or the public.

We will retain your SMS messages for as long as necessary to fulfill the purposes described above, or as required by law. You have the right to request access to, the rectification of, or deletion of your SMS messages at any time by contacting us at privacy@ridezoomo.com. Please note that certain SMS messages may be required to provide the requested service, and that we may be unable to delete those messages without also disabling the service.

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GDPR

What are your rights, and how can you exercise them?

In accordance with the General Data Protection Regulation (GDPR) and relevant privacy laws in our jurisdictions of operation, you, as a data subject, can exercise the following rights:

• Right of ACCESS: You can obtain information related to the processing of your Personal Data and a copy of such Personal Data. (Art. 15 GDPR)
• Right of RECTIFICATION: If you consider that your Personal Data is inaccurate or incomplete, you can request the Personal Data be modified. (Art. 16 GDPR)
• Right of ERASURE: You may require the deletion of your Personal Data, under certain circumstances. (Art. 17 GDPR)
• Right of PROCESSING LIMITATION: You can request the limitation of the processing of your Personal Data, under certain circumstances. The limitation is the marking of stored Personal Data in order to limit their processing in the future. (Art. 18 GDPR)
• Right of OBJECTION: You can object to one (or several) specific processing of your Personal Data, for reasons related to your particular situation. (Art. 21 GDPR)
• Right of PORTABILITY: Under certain circumstances, you have the right to recover the Personal Data you have given us or, when technically possible, to transmit the data to a third party with your authorization. (Art. 20 GDPR)
• Right of not being subject of automated individual decisions: This is to ensure that you are not subject to a decision based solely on the processing of your data, including profiling, that produces legal effects on you or significantly similarly affects you.(Art. 22 GDPR)

You also have the right to withdraw the provided declaration of consent regarding data protection at any time, with immediate effect. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

If more information is needed or in order to exercise the aforementioned rights, please contact us by email at privacy@ridezoomo.com or by postal mail at:

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Australia - Sydney
Unit 7, City Close Industrial Estate,
37-41 O’Riordan Street,
Alexandria, NSW 2015

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United Kingdom - London
Unit 1, Admiral Hyson Industrial Estate,
Hyson Road, London, SE16 3PA

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United States
252 W. 38th Street,
New York, NY 10018

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Please note that access can only be granted if you provide the following details in full: your first name and surname, your current and, if necessary, previous address, your date of birth, and your email address. This information is used exclusively for correlation purposes, ensuring that no unauthorised third party can obtain your Personal Data. Any product, operation, and/or contract numbers that we might have sent to you are also useful and helpful, but not necessary, in enabling us to identify the relevant data quicker.