Privacy Policy

Shared Mobility AS

Last revised: 29.11.2022

This statement (“Privacy Policy”) describes the types of personal data Shared Mobility may collect and process about you if you have opened an account with Shared Mobility, downloaded our mobile application (the “App”), use Shared Mobile Services (as defined in our Terms and Conditions) or requested information from us.

"You," "your," and "User" mean each and every person who accesses or uses our Site or any Service (as defined in the applicable Terms of Service). The words "Shared Mobility," “us,” and “we” mean Shared Mobility AS.

If you have any further questions after reading this statement, do not hesitate to contact us on gardermoen@ehiglobal.no.

Shared Mobility may change this Privacy Policy at any time by posting the revised Privacy Policy on this website and indicating the effective date of the revised Privacy Policy. You will be notified of any material changes to this Privacy Policy via email.

1         The data Shared Mobility collects

Shared Mobility is the controller of all of your personal data that Shared Mobility collect.

Shared Mobility collects your personal data when you use Shared Mobility’s App and/or Services, create a new account, and add or update information in your account.

Shared Mobility also collects personal data from other sources (such as hardware devices installed in the vehicles).

In connection with providing the Services, Shared Mobility processes information about its Users to pursue its legitimate interests, in order to fulfill the contract and administrate the customer relationship. The User personal data we collect is:

·       Name of the User

·       Copy of the User’s driver’s license

·       User address

·       IP address

·       Location Data (from the rented car)

·       Transaction information (amount due to Shared Mobility related to each car rental period)

2         Storage of personal data

Shared Mobility retains each data for the following period:

Shared Mobility will also delete all User data in the case that such User is inactive for three (3) years.

3         Purposes and legal basis for data collection and processing

Shared Mobility processes your personal data to pursue legitimate interest and in order to fulfil Shared Mobility contract with you and to provide you with the Services. This includes the following purposes:

·       Processing of data to collect information as to how the cars are being used, where and when they are picked up and returned by the User;

·       Processing of data to gather information properly and accurately about the use of the vehicles under the rental contract and the condition of the vehicle;

·       Processing of data to verify (i)  the User’s compliance with the terms of the acquired insurance (specifically if the vehicle is within the insured area); (ii) that the distance driven is within the contractual mileage limitations; and (iii) the return time and location (end of the rental period);

·       Provision of Services, especially to enable a cloud-based keyless entry technology to lock and unlock a vehicle’s doors and starts its engine with the User smart device;

·       Providing general customer support including the solution of problems with your account and/or the car, handle disputes, providing other services within the scope of customer service.

Even if Shared Mobility is collecting location data, Shared Mobility will never use any such with the purpose of  monitoring the individual Users’ live movements during the rental period, to control speeding or to detect breach of other traffic regulations.

Shared Mobility also processes your personal data in order to fulfil legal obligations to which Shared Mobility is subject. This includes the following purposes:

·       Complying with information requests from third parties based on any statutory information rights they have against Shared Mobility;

·       Ensuring the information security of the Services; and

·       Retention and storage of your personal data to comply with specific legal retention requirements.

4         Data Processors

Shared Mobility will use two separate suppliers to perform the services:

·       Continental Automotiv Benelux BV, Connected Car Solutions

·       Jumik bvba

The collection and processing of the location data will be performed by the suppliers defined above. Shared Mobility will not have access to the location data when linked to an individual User.

5         International Data Transfers

Shared Mobility stores and processes all your personal data within the European Economic Area. Shared Mobility may transfer personal data to the United States. If Shared Mobility transfers data to the United States. In that case, the personal data will be pseudonymized so that only location data is transferred, and it cannot be linked directly to you when located in the United States. You may request information on the legal ground for the transfer by contacting us.

6         Your rights as a data subject

6.1         Your rights

You have the right to request:

·       access your personal data that is being processed by us. You may request information on the purposes of the processing, the categories of personal data concerned, the envisaged period for which the personal data will be stored, any available information as to the personal data’s source, amongst others. Your right to access may be limited by national law;

·       rectification of inaccurate personal data concerning you. Considering the purposes of the processing, you have the right to have incomplete personal data completed, including by means of providing a supplementary statement correction of any errors in the personal data we have stored about you,

·       deletion of personal data concerning you, unless processing is necessary for exercising the right of freedom of expression and information, for compliance with a legal obligation, for reasons of public interest or for the establishment, exercise or defense of legal claims;

·       receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller ('right to data portability'); and

·       lodge a complaint with a supervisory authority.

Your personal data will be deleted when the data is no longer needed for the processing purposes specified in Section 2 above.

6.2         Exercising your rights

You can exercise your rights by emailing us at gardermoen@ehiglobal.no.

7         You may file a complaint

If you have any concerns about how we process your personal data, you are welcome to file a complaint to the Norwegian Data Protection Authority (Datatilsynet): https://www.datatilsynet.no/om-datatilsynet/kontakt-oss/hvordan-kan-jeg-klage-til-datatilsynet/ or the relevant data protection authority in your country.