Privacy Policy - CoMotion

Privacy Policy

Last Updated 29th April 2024.

Introduction:

Comotion Mobility Solutions Ltd, T/A CoMotion (“COMOTION”,” Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the CoMotion mobile application (the “App”) or the CoMotion website (the “Site”).

Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in the App, on the Site, and in email, text, and other electronic communications sent through or in connection with the App and the Site. This policy DOES NOT apply to information that:

We collect offline or on any other Company apps or websites other than the Site, including websites you may access through the App or the Site.

You provide to or is collected by any third party. Our websites and apps, and these third parties may have their own privacy policies, which we encourage you to read before providing information on or through them. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App or access the Site.

By downloading, registering with, or using the App or by accessing the Site, you agree to this privacy policy. This policy may change from time to time. Your continued use of the App or access of the Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13:

The App and the Site is not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at info@comotion.ie

Information We Collect and How We Collect It:

We collect information from and about users of our App and our Site:

Directly from you when you provide it to us.

Automatically when you use the App or the Site.

Information You Provide to Us:

When you download, register with, or use the App or access the Site, we may ask you provide information:

By which you may be personally identified, such as name, postal address, email address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”).

That is about you but individually does not identify you.

This information includes:

Information that you provide by filling in forms in the App or on the Site. This includes information provided at the time of registering to use the App, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App or the Site.

Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

Your responses to surveys that we might ask you to complete for research purposes.

Details of transactions you carry out through the App or the Site and of the fulfilment of your orders. You may be required to provide financial information before placing an order through the App or the Site.

Your search queries on the App or the Site.

You may provide information to be published or displayed (” Posted”) on public areas of websites you access through the App or the Site (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Automatic Information Collection and Tracking:

When you download, access, and use the App or access the Site, it may use technology to automatically collect:

Usage Details:

When you access and use the App or the Site, we may automatically collect certain details of your access to and use of the App or the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App or the Site.

Device or Computer Information:

We may collect information about your mobile device or computer and internet connection, including the devices or computer’s unique device identifier, IP address, operating system, browser type, mobile or other network information, and the device’s telephone number.

Stored Information and Files:

The App and the Site also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

Location Information:

The App and the Site collect real-time information about the location of your device or computer.If you do not want us to collect this information do not download the App or delete it from your device and do not access the Site. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioural tracking).

Information Collection and Tracking Technologies:

The technologies we use for automatic information collection may include:

Cookies (or mobile cookies). A cookie is a small file placed on your smartphone or computer. It may be possible to refuse to accept mobile or other cookies by activating the appropriate setting on your smartphone or computer. However, if you select this setting, you may be unable to access certain parts of our App or Site.

Web Beacons. Pages of the App and our emails and our Site may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app or web site statistics (for example, recording the popularity of certain content and verifying system and server integrity).

Third-Party Information Collection:

When you use the App, the Site or their content, certain third parties may use automatic information collection technologies to collect information about you or your device or your computer. These third parties may include:

Advertisers, ad networks, and ad servers.

Analytics companies.

Your mobile device or computer manufacturer.

Your mobile or other network service provider.

System operators and other administrators of systems or services on the App or through the Site.

These third parties may use tracking technologies to collect information about you when you use the App or the Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioural) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, system setup or other targeted content, you should contact the responsible provider directly.

How We Use Your Information:

We use information that we collect about you or that you provide to us, including any personal information, to:

Provide you with the App, the Site and their contents, and any other information, products or services that you request from us. •Fulfil any other purpose for which you provide it. •Give you notices about your account or subscription, including expiration and renewal notices.

Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

Notify you when App updates are available, and of changes to any products or services we offer or provide though it or the Site. The usage information we collect helps us to improve our App and the Site and to deliver a better and more personalized experience by enabling us to:

Estimate our audience size and usage patterns. •Store information about your preferences, allowing us to customize our App and the Site according to your individual interests.

Speed up your searches.

Recognize you when you use the App or the Site.

We use location information we collect to provide services to you.

We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile.

We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information:

We may disclose aggregated information about our users, and information that does not identify any individual or device or computer, without restriction. In addition, we may disclose personal information that we collect, or you provide:

To our subsidiaries and affiliates.

To system operators and other administrators of systems or services on the App or through the Site.

To contractors, service providers, and other third parties we use to support our business.

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of CoMotion’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by CoMotion about our App or Site users is among the assets transferred.

To third parties to market their products or services to you if you have consented to these disclosures

To fulfil the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce our rights arising from any contracts entered into between you and us, including the EULA, the Terms and Conditions, and for billing and collection.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CoMotions, our customers or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information:

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App or the Site may then be inaccessible or not function properly.

Location Information. You can choose whether or not to allow the App or the Site to collect and use real-time information about your device’s or computer’s location through the device’s or your other applicable privacy settings. If you block the use of location information, some parts of the App or the Site may then be inaccessible or not function properly.

Promotion by the Company. If you do not want us to use your email address or other contact information to promote our own or third parties’ products or services, you can always opt-out by logging into the App or your account on the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@comotion.ie.

Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@comotion.ie

Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can always opt-out by logging into the App or your account on the Site and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to info@comotion.ie. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
Accessing and Correcting Your Personal Information:

You can review and change your personal information by logging into the App or your account on the Site and visiting your account profile page.

If you delete your User Contributions from the App or the Site, copies of your User Contributions may remain viewable in cached and archived pages or might have been copied or stored by other App or Site users. Proper access and use of information provided on the App or the Site, including User Contributions, is governed by our Terms and Conditions.

Data Security:

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Any payment transactions will be encrypted.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App or the Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App or the Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

Changes to Our Privacy Policy: We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email to the email address specified in your account or an in-App or on-Site alert the first time you use the App or access the Site after we make the change.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

Contact Information: To ask questions or comment about this privacy policy and our privacy practices, contact us at info@comotion.ie.

PRIVACY POLICY – MOBILE APP SPECIFIC.

CoMotion collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

CoMotion Mobility Solutions Limited, T/A CoMotion, Unit 7, Northwest Business Park, Collooney, Co. Sligo, Ireland

Owner contact email: info@CoMotion.ie

Types of Data collected

Among the types of Personal Data that CoMotion collects, by itself or through third parties, there are: Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; payment data; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; NFC Reader permission ; Universally unique identifier (UUID); Crash information; phone number; email address; first name.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using CoMotion.
Unless specified otherwise, all Data requested by CoMotion is mandatory and failure to provide this Data may make it impossible for CoMotion to provide its services. In cases where CoMotion specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by CoMotion or by the owners of third-party services used by CoMotion serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published, or shared through CoMotion and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of CoMotion (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
processing is necessary for compliance with a legal obligation to which the Owner is subject.
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Hosting and backend infrastructure, Analytics, Platform services and hosting, Handling payments, Device permissions for Personal Data access, Managing contacts and sending messages, Infrastructure monitoring, Content performance and features testing (A/B testing) and Registration and authentication.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User’s specific device, CoMotion may request certain permissions that allow it to access the User’s device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.

Please note that the revoking of such permissions might impact the proper functioning of CoMotion.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by CoMotion.

Approximate location permission (continuous)

Used for accessing the User’s approximate device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User’s approximate device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for CoMotion to derive the approximate position of the User on a continuous basis.

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

NFC Reader permission

Allows CoMotion to read contact-less tags.

Precise location permission (continuous)

Used for accessing the User’s precise device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User’s precise device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for CoMotion to derive the exact position of the User on a continuous basis.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase (Google Ireland Limited)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google Ireland Limited.
In order to understand Google’s use of Data, consult Google’s partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.

CoMotion uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data processed: Application opens; Application updates; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.

Place of processing: Ireland – Privacy Policy.

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of CoMotion.

Firebase Remote Config (Google Ireland Limited)

Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Device permissions for Personal Data access

CoMotion requests certain permissions from Users that allow it to access the User’s device Data as described below.

Device permissions for Personal Data access (CoMotion)

CoMotion requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.

Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; NFC Reader permission; Precise location permission (continuous); Precise location permission (non-continuous).

Types of Data collected

If you link, connect, or login to CoMotion with a third-party service (Google ID, Apple ID and Facebook), the third-party service may send us information such as your profile information (e.g. e-mail) from that service.
The information CoMotion gets from such services depends on your settings and the third-party service’s privacy policy.

Handling payments

Unless otherwise specified, CoMotion processes any payments by credit card, bank transfer or other means via external payment service providers. In general, and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. CoMotion isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Payments processed via the Google Play Store (Google Ireland Limited)

CoMotion uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: payment data.

Place of processing: Ireland – Privacy Policy.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Google Pay (Google Ireland Limited)

Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Pricing Plan – Pay as you go

During the creation account process Users agreed to the “Pay as you go” pricing plan, containing the following prices, fees and/or taxes:
• (Optional) Booking – Creation: 0,50 €
• (Optional) Booking – No show: 1,00 €
• Trip – Ended next to vehicle sharing station: 1,00 €
• Trip – End outside vehicle sharing station area: 30,00 €
• Trip Duration – Cost per minute: 0,01 €
• Trip Start: 1,00 €
Prices on CoMotion are displayed:
– including all applicable fees, taxes and costs;

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable CoMotion to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of CoMotion.

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Microsoft Azure (Microsoft Corporation)

Microsoft Azure is a hosting service provided by Microsoft Corporation.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Germany – Privacy Policy.

Google BigQuery (Google Ireland Limited)

Google BigQuery is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Firebase Cloud Functions (Google Ireland Limited)

Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Firebase Cloud Firestore (Google Ireland Limited)

Firebase Cloud Firestore is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Infrastructure monitoring

This type of service allows CoMotion to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of CoMotion.

Firebase Performance Monitoring (Google Ireland Limited)

Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Crashlytics (Google Ireland Limited)

Crashlytics is a monitoring service provided by Google Ireland Limited.

Personal Data processed: Crash information; device information; Universally unique identifier (UUID).

Place of processing: Ireland – Privacy Policy.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Firebase Cloud Messaging (Google Ireland Limited)

Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Twilio (Twilio, Inc.)

Twilio is a phone numbers management and communication service provided by Twilio, Inc.

Personal Data processed: phone number.

Place of processing: United States – Privacy Policy.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: email address; first name.

Place of processing: United States – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of CoMotion, therefore allowing the provision of CoMotion from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Google Play Store (Google Ireland Limited)

CoMotion is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

Users may opt-out of these analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Apple App Store (Apple Inc.)

CoMotion is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of CoMotion. Much of this information is processed on an opt-in basis.

Users may opt-out of these analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow CoMotion to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, CoMotion will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Creation of User account with Google ID and Apple ID

If the User links, connects, or logins to CoMotion with Google ID or Apple ID and or if the User modifies his/her Google ID or Apple ID e-mail, that such e-mail will shall be automatically changed updated accordingly on CoMotion User’s account too

Further information about the processing of Personal Data

Push notifications

CoMotion may send push notifications to the User to achieve the purposes outlined in this privacy policy.

Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for CoMotion, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of CoMotion.

Selling goods and services online

The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by CoMotion depends on the payment system used.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of CoMotion or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, CoMotion may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, CoMotion and any third-party services may collect files that record interaction with CoMotion (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

CoMotion does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within CoMotion and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through CoMotion (or third-party services employed in CoMotion), which can include: the IP addresses or domain names of the computers utilized by the Users who use CoMotion, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using CoMotion who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of CoMotion. The Data Controller, unless otherwise specified, is the Owner of CoMotion.

CoMotion (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by CoMotion as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to CoMotion, if not stated otherwise within this document.

Latest update: 29th April 2024

Privacy Policy (Updated 30.05.2022):

Introduction:

Our practices for collecting, using, maintaining, protecting, and disclosing that information.

We collect offline or on any other Company apps or websites other than the Site, including websites you may access through the App or the Site.

Children Under the Age of 13:

Information We Collect and How We Collect It:

We collect information from and about users of our App and our Site:

Directly from you when you provide it to us.

Automatically when you use the App or the Site.

Information You Provide to Us:

When you download, register with, or use the App or access the Site, we may ask you provide information:

That is about you but individually does not identify you.

This information includes:

Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.

Your responses to surveys that we might ask you to complete for research purposes.

Your search queries on the App or the Site.

Automatic Information Collection and Tracking:

When you download, access, and use the App or access the Site, it may use technology to automatically collect:

Usage Details:

Device or Computer Information:

Stored Information and Files:

Location Information:

Information Collection and Tracking Technologies:

The technologies we use for automatic information collection may include:

Third-Party Information Collection:

Advertisers, ad networks, and ad servers.

Analytics companies.

Your mobile device or computer manufacturer.

Your mobile or other network service provider.

System operators and other administrators of systems or services on the App or through the Site.

How We Use Your Information:

We use information that we collect about you or that you provide to us, including any personal information, to:

Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

Estimate our audience size and usage patterns. •Store information about your preferences, allowing us to customize our App and the Site according to your individual interests.

Speed up your searches.

Recognize you when you use the App or the Site.

We use location information we collect to provide services to you.

Disclosure of Your Information:

To our subsidiaries and affiliates.

To system operators and other administrators of systems or services on the App or through the Site.

To contractors, service providers, and other third parties we use to support our business.

To third parties to market their products or services to you if you have consented to these disclosures

To fulfil the purpose for which you provide it.

For any other purpose disclosed by us when you provide the information.

With your consent.

To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

To enforce our rights arising from any contracts entered into between you and us, including the EULA, the Terms and Conditions, and for billing and collection.

If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of CoMotions, our customers or others.

Your Choices About Our Collection, Use, and Disclosure of Your Information:

You can review and change your personal information by logging into the App or your account on the Site and visiting your account profile page.

Data Security:

Contact Information: To ask questions or comment about this privacy policy and our privacy practices, contact us at info@comotion.ie.

PRIVACY POLICY – MOBILE APP SPECIFIC.

CoMotion collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

CoMotion Mobility Solutions Limited, T/A CoMotion, Unit 8A, Northwest Business Park, Collooney, Co. Sligo, Ireland

Owner contact email: info@CoMotion.ie

Types of Data collected

Users are responsible for any third-party Personal Data obtained, published, or shared through CoMotion and confirm that they have the third party’s consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law.
provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
processing is necessary for compliance with a legal obligation to which the Owner is subject.
processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The purposes of processing

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Device permissions for Personal Data access

Depending on the User’s specific device, CoMotion may request certain permissions that allow it to access the User’s device Data as described below.

Please note that the revoking of such permissions might impact the proper functioning of CoMotion.

If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by CoMotion.

Approximate location permission (continuous)

Used for accessing the User’s approximate device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

NFC Reader permission

Allows CoMotion to read contact-less tags.

Precise location permission (continuous)

Used for accessing the User’s precise device location. CoMotion may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics for Firebase (Google Ireland Limited)

CoMotion uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Place of processing: Ireland – Privacy Policy.

Content performance and features testing (A/B testing)

Firebase Remote Config (Google Ireland Limited)

Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Device permissions for Personal Data access

CoMotion requests certain permissions from Users that allow it to access the User’s device Data as described below.

Device permissions for Personal Data access (CoMotion)

CoMotion requests certain permissions from Users that allow it to access the User’s device Data as summarized here and described within this document.

Types of Data collected

Handling payments

Payments processed via the Google Play Store (Google Ireland Limited)

CoMotion uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.

Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data processed: payment data.

Place of processing: Ireland – Privacy Policy.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Stripe (Stripe Inc)

Stripe is a payment service provided by Stripe Inc.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Google Pay (Google Ireland Limited)

Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Pricing Plan – Pay as you go

During the creation account process Users agreed to the “Pay as you go” pricing plan, containing the following prices, fees and/or taxes:
• (Optional) Booking – Creation: 0,50 €
• (Optional) Booking – No show: 1,00 €
• Trip – Ended next to vehicle sharing station: 1,00 €
• Trip – End outside vehicle sharing station area: 30,00 €
• Trip Duration – Cost per minute: 0,15 €
• Trip Start: 1,00 €
Prices on CoMotion are displayed:
– including all applicable fees, taxes and costs;

Hosting and backend infrastructure

Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Microsoft Azure (Microsoft Corporation)

Microsoft Azure is a hosting service provided by Microsoft Corporation.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Germany – Privacy Policy.

Google BigQuery (Google Ireland Limited)

Google BigQuery is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Firebase Cloud Functions (Google Ireland Limited)

Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Firebase Cloud Firestore (Google Ireland Limited)

Firebase Cloud Firestore is a hosting and backend service provided by Google Ireland Limited.

Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Infrastructure monitoring

Firebase Performance Monitoring (Google Ireland Limited)

Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Crashlytics (Google Ireland Limited)

Crashlytics is a monitoring service provided by Google Ireland Limited.

Personal Data processed: Crash information; device information; Universally unique identifier (UUID).

Place of processing: Ireland – Privacy Policy.

Managing contacts and sending messages

Firebase Cloud Messaging (Google Ireland Limited)

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

Twilio (Twilio, Inc.)

Twilio is a phone numbers management and communication service provided by Twilio, Inc.

Personal Data processed: phone number.

Place of processing: United States – Privacy Policy.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: email address; first name.

Place of processing: United States – Privacy Policy.

Platform services and hosting

Google Play Store (Google Ireland Limited)

CoMotion is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.

By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.

Users may opt-out of these analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: Ireland – Privacy Policy.

Apple App Store (Apple Inc.)

CoMotion is distributed on Apple’s App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

Users may opt-out of these analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data processed: Usage Data.

Place of processing: United States – Privacy Policy.

Registration and authentication

Creation of User account with Google ID and Apple ID

Further information about the processing of Personal Data

Push notifications

CoMotion may send push notifications to the User to achieve the purposes outlined in this privacy policy.

Selling goods and services online

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

How to exercise these rights

Additional information about Data collection and processing

Legal action

Additional information about User’s Personal Data

System logs and maintenance

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

CoMotion does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honour the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Usage Data

User

The individual using CoMotion who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

CoMotion (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by CoMotion as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to CoMotion, if not stated otherwise within this document.

Latest update: 30^th May 2022