1. WHEELY GROUP (“We” or “Us” or “Our”, depending on what makes the most sense) are committed to protecting and respecting your privacy.
A quick word about children
3. We recognise we have a special obligation to protect personal information obtained from children. We do not and will not knowingly collect information from any unsupervised child under the age of 13. In certain jurisdictions, prior written permission or other verifiable consent may be also required from a parent or guardian for children under 18 years of age.
The Data Controller
4. For the purpose of the Data Protection Act 1998 (the “Act”), the data controller is Wheely AG, Fraumünsterstrasse 9, CH-8001 Zürich, Switzerland.
Information we may collect from you
5. We respect your right to privacy and will only process personal information you provide to us in accordance with the Data Protection Act 1998, the Privacy and Electronic Communications (EC Directive) Regulations 2003 and other applicable privacy laws.
6. The kinds of data which we may process include:
- your name;
- your contact details (including email address and phone number);
- technical or other details about any device which you use to access the Services, including: Internet and/or network connection (including your IP address, Media Access Control (MAC); operating system, browser type or other software; hardware (including computer hardware or mobile model); mobile device details (including your mobile device type and number; mobile carrier details; and unique mobile device ID) or other technical details. This is statistical data about our users’ actions and patterns, and does not identify any individual;
- details of your use of our Services including, but not limited to, traffic data, location/geographical data, weblogs and other communication data and the resources that you access.
7. We may collect and process data about you through the following means:
- we may retain information that you provide by filling in information using the Wheely app. This includes information provided at the time of registering, subscribing or purchasing any of our Services, or requesting further services. We may also ask you for information when you report a problem with any of the Services;
- if you contact us, we may keep a record of that correspondence.
8. We may collect this data through any of our Services or third party services connected with them.
Where we store your personal information
10. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Services; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
Uses made of your information
11. We use information held about you in the following ways:
- to ensure that content from our Services is presented in the most effective manner for you and for your computer or other device from which you access the Services;
- to provide you with information, products or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes;
- too carry out our obligations arising from any contracts entered into between you and us;
- to allow you to participate in features of our Services, when you choose to do so;
- to notify you about changes to our Services.
If you are a new user, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
Disclosure of your information
12. We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006.
13. We may disclose your personal information to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets;
- if we or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets;
Third party sites
14. Our Services may, from time to time, contain links to and from the websites of our partners, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies, nor do we endorse such websites. Please check these policies before you submit any personal information to these websites.
15. You have the right to ask us not to process your personal information for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us at firstname.lastname@example.org. The Act gives you the right to access information held about you. Any access request may be subject to a fee of £10 to meet our costs in providing you with details of the information we hold about you.
16. You may also email us at email@example.com to request that we delete your personal information from our database. We will use commercially reasonable efforts to honour your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.