The purpose of this Privacy Policy is to inform you how we process your personal data which for us at Kleta is essential. We are transparent about what we do with your personal data, to help you to understand the implications of the way in which we use your data, and the rights you are entitled to in relation to your data:

  • We permanently make available for you all the information included in this Privacy Policy, that you can check when you consider appropriate, and in addition,
  • You will also find further information on how we use your data as you interact with us.

When we speak about our Platform, we refer, in general, to any of the channels or means, digital or in person, you may have used to interact with us. The main ones are:

  • Our website: www.kleta.es;
  • By phone, post mail or e-mail.

This policy does not apply to third-party websites, products or services, even if they link to our services or site, and you should consider the privacy practices of those third-parties carefully.

1. Who is responsible for processing your data?

KLETA MOBILITY, S.L.(“The Company”) whose registered office is located at Calle Calabria 199, Principal 4 (08029) Barcelona, Spain (hereinafter referred to as “KLETA” or “We”) is responsible for the processing and the protection of your personal data (i.e any information that would allow to identify you, either directly or indirectly) collected through this website.

The Company’s website within kleta.es domain may provide links to third-party sites. In order to use third-party content on our websites, you may need to accept their specific terms and conditions, including their cookie policies over which we have no control.

2. What personal data we collect?

Personal data is any information that relates to an identified or identifiable natural person.

1. Personal data that we collect about you

The personal data that you provide to us through our website and services will be apparent from the context in which you provide the data. In particular:

  • When you register for a Kleta account we collect your account log-in credentials.
  • When you fill-in our online form to contact our team, we collect your email and any other information you choose to include in the body of your email, message or responses.
  • When you use the services offered by Kleta, such as a subscription for the use of a bicycle and make payments, we will receive your transaction information. The financial information that we collect will include payment method information (such as credit or debit card), purchase amount and date of purchase.
  • If you are a Kleta User, you will provide your contact details, such as full name, postal address, telephone number and email address. As part of your business relationship with us, we may also receive personal information about you, such as your ID number, date of birth, location data for the Store Lock-Up and Pick-up service.
  • If you contact us by phone, we collect the phone number you use to call Kleta and additional information in order to verify your identity.
  • You may also choose to submit to us via other methods, including: (i) in response to marketing or other communications, (ii) through social media or online forums, (iii) through participation in an offer or promotion, (iv) in connection with an actual or potential business relationship with us, or (v) by giving us your business card or contact details at trade shows or other events.

2. Information that we collect automatically on our site

Our site uses cookies and other technologies to function effectively. These technologies record information about your use of our site, including:

  • Browse and device data, such as IP address, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language version of the site you are visiting;
  • Usage data, such as time spent on the site, page visited, links clicked, language preferences and the pages that led or referred you to our site. We use Google Analytics on our site to help us analyse your use of our sites and diagnose technical issues.

To know more about our cookies, please see our Cookies Policy.

3. How do we use your personal data?

3.1 Products and services

We rely upon a number of legal grounds to ensure that our use of your personal data is compliant with applicable law. We use your personal data to facilitate the business relationships we have with our users, to comply with our financial regulatory and other legal obligations, and to pursue our legitimate business interests. We also use your personal data to complete payment transactions and to provide payment-related services to our users.

Contractual and pre-contractual business relationships: we use personal data for the purpose of entering into business relationships with Kleta users, and to perform the contractual obligations under the terms and conditions that we have with Kleta users. Activities that we conduct in this context include: management of Kleta Checkout accounts, accounting, auditing and billing activities and processing of payments, communications regarding such payments and related customer service.

Legal and regulatory compliance: we use personal data to verify the identity of our users in order to comply with fraud monitoring, prevention and detection obligations, such as AML (Anti-Money Laundering) and KYC (Know Your Customer) obligations, and financial reporting obligations.

Legitimate business interests: we rely on our legitimate business interests to process personal data about you. The following list sets out the business purposes that we have identified as legitimate. In determining the content of this list, we balanced our interests against the legitimate interests and rights of the individuals whose personal data we process. We monitor, prevent and detect fraud and unauthorized payment transactions; mitigate financial loss, claims, liabilities or other harm to users and Kleta; respond to inquiries, send service notices and provide customer support; promote, analyse, modify and improve our products, systems and tools and develop new products and services; analyse and advertise our products and services and share personal data with third party service providers that provide services on our behalf and business partners with help up operate and improve our business.

3.2 Marketing and events-related communications

We send you email marketing communications about Kleta products and services, invite you to participate in our events or surveys, or otherwise communicate with you for marketing purposes, provided that we do so in accordance with the consent requirements that are imposed by applicable law. For example, when we collect your personal/business contact details through our participation at trade events, we may use the information to follow-up with you regarding an event, send you information that you have requested on our products and services and, with your permission, include you on our marketing information campaigns.

3.2 Advertising

When you visit our site, we may use personal data collected from you and your device to target advertisements for Kleta services to you on our site, where allowed by applicable law. For example, when you visit our site, we will use cookies to identify your device and direct ads for our services to you. Please see our Cookie Policy for more information.

We do not use, share, rent or sell the personal data of our users for interest-based advertising.

4. Use by Minors

The services are not directed to individuals under the age of eighteen (18), and we request that they not provide personal data through the services.

We recommend parents be involved in their children’s (online) activities, in order to prevent Kleta from unintentionally processing their personal data.

5. Service providers

Kleta share personal data with a limited number of our service providers in certain cases for the reasons explained below:

  • if we are legally obligated or authorized to provide personal data to third parties;
  • if we suspect a violation of the rights of third parties, criminal acts, or misuse, we may provide personal data to third parties who have a justified interest, or to bodies that serve the general interest. These may include enforcement authorities, such as the Public Prosecutor’s Office or supervisory bodies;
  • Kleta may also share your data with third parties in the context of implementing an agreement with you, or due to justified business interests such as maintaining a central administration or customer service unit, or analyzing our services provided to you;
  • for business purposes, such as the sale of business activities or shares or a reorganization;

Kleta also utilizes the services of third parties that act as ‘processors’, such as hosting and service providers and research bureaus that conduct market research or customer satisfaction surveys. If these third parties are indicated as ‘processors’ in accordance with applicable data protection law, then Kleta will make written agreements with these parties. These services providers will only process personal data in accordance with the instructions and guidance provided by Kleta.

Personal data sent to a recipient abroad will only be sent to a recipient in a country that the European Commission has determined offers a suitable level of protection for personal data. If personal data are sent to a recipient in a country that does not offer suitable protection for personal data, then Kleta will ensure that the legally required guarantees are implemented.

6. Security and Retention

We make reasonable efforts to ensure a level of security appropriate to the risk associated with the processing of personal data. We maintain organizational, technical and administrative measures designed to protect personal data within our company against unauthorized access, destruction, loss, alteration or misuse. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please contact us immediately.

We retain your personal data for as long as necessary or permitted within the limitations of the purposes listed in this Privacy Policy and in accordance with applicable legislation. The criteria used to determine this storage period include:

  • The duration of the period in which we have a current relationship with you and provide services to you (for example: as long as you have an account with us or continue to utilize our services);
  • Whether we are subject to a legal obligation, such as special laws that require us to store our transactions for a specific period before deleting them; or
  • Whether storage is desirable due to our legal position with regard to issues such as expiration terms, disputes or investigations by law enforcement bodies.

7. Your rights and choices

You have choices regarding our use and disclosure of you personal data:

  • Opting out of receiving electronic communications from us: if you no longer want to receive marketing-related emails from us, you may opt-out via the unsubscribe link included in such emails. We will try to comply with your request as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages that are required to provide you with our services.
  • How you can see or change your account personal data: if you would like to review, correct, or update personal data that you have previously disclosed to us, you may do so by signing in to your Kleta account or by contacting us.
  • Your data protection rights: You have the right to know which of your personal data we process and to whom we have provided your data. If you have granted permission for the processing of your personal data, you also have the right to revoke that permission.

If you would like to view, correct, edit, limit, delete any of your personal data processed by us, or object to the processing of your personal data or direct marketing activities, or if you would like to receive an electronic copy of your personal data to send it on to another company (inasmuch as the applicable legislation permits you to transfer such data), please feel free to contact Kleta. Please describe which personal data your request concerns as clearly as possible. We will reply to your request as quickly as possible, and no later than the legally stipulated reply period.

Finally, you also have the right to submit a complaint to the Personal Data Protection Authority of Spain. You may only exercise your rights within the limits granted by law. In order to ensure that you have submitted the request yourself, we may ask that you include proof of your identification along with your request. We will only ask this if necessary to identify you, and we ask that you also make the passport photo unreadable, the machine-readable zone (the row of numbers at the bottom of the passport), the passport number and your Citizen Service Number (CSN). We will destroy the copy of your proof of identification immediately after we have determined your identity.

8. Links to other websites

We may provide the ability to connect to other websites from our site. These websites may operate independently from us and may have their own privacy notices or policies, which we strongly suggest you to review.

If any linked website is not owned or controlled by us, we are not responsible for its content, any use of the website or the privacy practices of the operator of the website.

9. Contact

If you have any questions and/or comments regarding this Privacy Statement, please contact us via: info@kleta.es.

10. Updates to this Privacy Policy and Notifications

We may change this Privacy Policy from time to time to reflect new services, changes in our personal data practices or relevant laws. The “last update” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised. Any changes are effective when we post the revised Privacy Policy on the services.

We may provide you with disclosures and alerts regarding the Privacy Policy or Personal data collected by posting them on our website and, if you are a user, by contacting you through your email address.

www.kleta.es

August 2020

Barcelona