Data protection
[Effective Prior to February 1, 2020]
LMTS Holding S.C.A., a partnership limited by shares (société en commandite par actions) existing under the laws of the Grand Duchy of Luxembourg, having its registered office at 7 rue Robert-Stümper, L-2557 Luxembourg, Grand Duchy of Luxembourg, registered with the Luxembourg Trade and Companies’ Register under number B226854 (hereinafter the “Company”)
Data protection policy (hereafter, the “Privacy Policy”)
1. What is the scope of this document?
We have defined this Privacy Policy to explain and describe the personal data we collect and for what purposes, as well as your privacy rights and the way you can exercise them.
This Privacy Policy applies to our use of personal data collected by us or provided by you in relation to your use of our website (circ.com), hereafter, the “Website”) and/or the use of our mobile application (hereafter, the “App”).
This Privacy Policy does not apply to our use of personal data about (i) individuals employed by the Company and acting in the course of their employment or (ii) third parties providing services to the Company and accessing our Website and/or our App in connection with the provision of such services.
We may revise this Privacy Policy from time to time to keep it in line with changes in our business, services or applicable law, such as (but not limited to) the EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereafter, the “General Data Protection Regulation”) and/or the Luxembourg Law of 1 August 2018 on the organisation of the National Data Protection Commission and/or the Swiss Federal Act on Data Protection of 19 June 1992 and the general data protection framework. All changes to this Privacy Policy will be published on our Website and App. In case of substantial changes, we will also notify our users by email or other means.
2. Which types of personal data is collected about me?
We collect and processes two types of personal data:
(i) The personal data that you communicate to us. We collect and process all personal data that you choose to communicate to us when you register to use our services, such as:
your name;
your mobile number;
your date of birth;
your address;
your registration and log in details;
and your email address.
The personal data that our systems collect
(ii) We also collect and process certain types of information automatically, whenever you interact with us in order to allow you to use our services (for example, tracking the location of your device during use to validate your right to rent a scooter) or improve your experience on our Website and/or App. When you visit our Website and/or App, cookies may be installed on your browser software to obtain certain usage data when your web browser accesses our Website and/or App. We will also obtain certain usage data as other content served by and on behalf of the Company on other websites.
Those usage data are the following: the Internet Protocol (IP) address used to connect your computer or mobile device to the Internet; the location of your computer or mobile device during the use of our Website or App;
language settings;
time zone;
interface controls;
system information;
and version used.
we will also collect a copy of your ID in order to process requests addressed to us regarding your privacy rights in accordance with point 8 below.
3. For what purposes will my personal data be collected and processed?
We collect and process personal data when it is necessary for operating, providing or improving our services offered to our users. In particular, we collect and process personal data in order to prepare, execute and terminate your subscription to our services; improve your experience on our Website and App; handle your requests about our services, to send newsletters and/or marketing emails, to inform you about our services, to ask feedback about our services or inform you of changes and improvements of our services; verify that your usage of our services does not infringe our Terms and Conditions or any laws or regulations; and follow up on your job application submitted online via our website.
We will always ask for your prior consent before processing your personal data for any other purpose. You will give your consent by taking a positive action (such as ticking a box) and will be free to withdraw your consent at any time.
4. Who are the recipients of the personal data collected about me? Is this data shared with third parties?
Unless legally required or permitted, the Company does not share your personal data except with specified and authorised recipients, i.e. its affiliate companies and service providers that are either subject to this Privacy Policy or follow privacy rules at least as protective as those stated therein.
When we transfer personal data to an authorised recipient that is registered outside the European Economic Area, we will ensure that such data is transferred in accordance with this Privacy Policy and that the transfer is made in accordance with the General Regulation on Data Protection.
If one or some or your personal data might be shared to third parties other than specified above, you will receive notice and will have the choice not to allow your data to be shared.
5. How long is my personal data kept?
The Company only keeps personal data for the time strictly necessary in order to enable the use of our services and/or to fulfil the purposes identified above, and/or to comply with any legal or regulatory obligations.
If you have questions regarding the specific period of storage of your personal data, please contact us by email at (gdpr@circ.com).
6. Is my personal data safe with you?
Your personal data is stored securely in accordance with the principles set out in General Data Protection Regulation. The Company uses physical, administrative and software-based security safeguards to provide reasonable protection for your personal data. All electronic copies are encrypted and protected by firewall and information access authorisation controls.
7. Who is responsible for processing personal data?
The controller of personal data is LMTS Holding S.C.A, having its registered office at 7 rue Robert-Stümper, L-2557 Luxembourg, registered with the Trade and Commercial Register of Luxembourg under number B 226.854.
If you have any question on our Privacy Policy or on our privacy practices that are not addressed in this Privacy Policy, please contact us by email (gdpr@circ.com) or by mail (LMTS Holding S.C.A., 7 rue Robert-Stümper, L-2557 Luxembourg).
8. What are my rights regarding my personal data?
Subject to limitations set out under European law, Luxembourg law, Swiss law and any other applicable law, you have the right of access, rectification, restriction, opposition, erasure and data portability.
These rights may be exercised by contacting us via email (gdpr@circ.com) or by mail (LMTS Holding S.C.A., 7 rue Robert-Stümper, L-2557 Luxembourg), together with a signed copy of your ID.
If you are not satisfied by the way we address your privacy concerns, you may also file a complaint with the CNPD (Commission nationale pour la protection des données), the Luxembourg supervisory authority for data protection or with the national supervisory authority for data protection in your country of residence.