Privacy Policy

August 13, 2020

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

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• We permanently make available to you all the information included in this Privacy Policy, which you can consult when you consider appropriate, and also,

• You will find more information about how we use your data when you interact with us.

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When we talk about our Platform, we are referring, in general, to any of the channels or media, digital or face-to-face, that you have used to interact with us. The main ones are:

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- Our website: www.kleta.es;

- By phone, postal mail or email;

- Through our social networks (Instagram, Facebook, etc.)

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This policy does not apply to third party websites, products or services, even if linked to our services or website, and you should therefore take into account the privacy policies of those third parties.

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1. Who is responsible for the processing of your data?

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KLETA MOBILITY, SL (“The Company”) with registered office at Calle Calabria 199, Principal 4 (08029) Barcelona, ​​Spain (hereinafter, “KLETA” or “We”) is responsible for the processing and protection of your personal data (that is, any information that allows you to be identified, either directly or indirectly) collected through this our Platform.

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

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2. What personal data do we collect?

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

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Personal data we collect about you

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The personal data that you provide us through our website and our services will be understood to be delivered with express consent from the moment that you yourself are the one who provides them. In particular:

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• When you register for a Kleta account, we collect your account login credentials.

• When you fill out our online form to contact our team, we collect your email address 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 we collect will include information about the payment method chosen (such as credit or debit card), the amount of the purchase, and the date of purchase.

• If you are a Kleta user, you will provide your contact information, 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 National Identity Document or Passport, date of birth and location data for the collection service.

• If you contact us by phone, we collect the phone number you use to call Kleta and additional information to verify your identity and fulfill your requests.

• If you communicate with us via our social media accounts (instagram and facebook) or share, like and follow us there, we collect your information (username and additional information) for marketing purposes.

• You may also choose to submit your submission to us through other methods, including: (i) in response to marketing or other communications, (ii) through social media (instagram and facebook) or online forums, (iii ) by participating in an offer or promotion, (iv) in connection with an existing or potential business relationship with us, or (v) by providing us with your business card or contact details at trade shows or other events.

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1. Information we automatically collect on our website

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

• Browser and device data: such as IP address, device type, Internet browser operating system and type, screen resolution, operating system name and version, device manufacturer and model, language version of the website you are visiting;

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Usage Data: such as time spent on the Website, page viewed, links clicked, language preferences, and pages that took or referred you to our Website. We use Google Analytics on our site to help us analyze your use of our website and diagnose technical problems.

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To learn more about our Cookies Policy, consult it here.

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3. How do we use your personal data?

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3.1 Products and services

We rely on a number of legal grounds to ensure that our use of your personal data complies 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.

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• Contractual and pre-contractual business relationships: We use personal data for the purpose of entering into business relationships with Kleta users and to fulfill contractual obligations under the terms and conditions we have with Kleta users. The activities we carry out in this context include: Kleta Checkout account administration, accounting, auditing, and billing and payment processing activities, communications about such payments, and 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 anti-money laundering and customer identification obligations (KYC - Know Your Customer), 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 balance our interests with the legitimate interests and rights of the people whose personal data we process: a) We monitor, prevent and detect fraud and unauthorized payment transactions; b) we mitigate financial losses, claims, liabilities or other damages to users and Kleta; c) respond to inquiries, d) send service notices and provide customer support; e) we promote, analyze, modify and improve our products, systems and tools and develop new products and services; f) we analyze and advertise our products and services and share personal data with third-party service providers who provide services on our behalf and business partners to help operate and improve our business.

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3.2 Marketing and event communications

We rely on you to send you email marketing communications about Kleta products and services, invite you to participate in our events or surveys, or contact you for marketing purposes, provided we do so in accordance with any express consent requirements imposed by the applicable regulations. For example, when we collect your personal and/or business contact information through our participation in events, we may use the information to follow up with you regarding our business, send you information you have requested about our products and services, and, with your permission, include you in our marketing information campaigns.

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3.3 Advertising

When you visit our Website, we may use your collected personal data to send you advertisements for Kleta's services. For example, when you visit our Website, we will use Cookies to identify your device and to serve you advertisements for our services. See our Cookie Policy for more information.

We do not use, share, rent or sell our users' personal data for advertising.

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4. Use by minors

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The Services are not directed to persons under the age of eighteen (18).

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We recommend that parents participate in their children's online activities to prevent Kleta from inadvertently processing their personal data.

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5. Service Providers

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

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If we are legally obliged or authorized to provide personal data to third parties to organizations that require it;