Privacy Policy
1. General
This privacy policy (the ”Privacy Policy”), together with the user agreement and terms and conditions (the “Agreement”), available on the Wer2 website www.wer2.com, describes how Wer Two Scooter Rental (”Wer2”, “We”, “Our“), as a data controller, process its customer’s (“You”) personal data when using the Services.
Unless otherwise stated in this Privacy Policy, the definitions used herein will have the same meaning as in the Agreement. Questions regarding this Privacy Policy and Wer2’s processing of Your personal data can be sent to contact@wer2.com
The Privacy Policy is intended to comply with our obligations to provide you with information about our processing of your personal information under applicable privacy laws. It explains how we collect, use and share personal information in the course of our business activities.
2. Collection, purpose and use of personal data
Wer2 will collect personal data which You submit when creating an account in the Wer2 App or which is created when You are using the Wer2 App or the Services.
Wer2 processes Your personal data for the following purposes:
a) For the purposes of entering into, fulfilling and administering our contractual relationship (including handling payment) with You and to correspond with You in relation to the Services, we process the following personal data:
Location data (phone location and location of Scooters);
Contact details (such as name, address, e-mail address and phone number);
Whether or not a user has a valid driver’s license
Payment information (such as bank card information, invoice history, payment history)
Device ID of your mobile phone; and
Photos of scooters which You upload in the Wer2 App.
Our lawful basis for the processing of your personal data for this purpose is to fulfil our contractual obligations with You.
b) For the purposes of performing statistical analyses, to analyze data in order to develop the Services regarding functionality, security and methods, and to analyze markets and customers, we process the following personal data:
IP address;
Information about Your device, such as make, model, and operating system; and
Information about Your use of the Wer2 App and the Services, for example, the date, time and duration of your usage.
Our lawful basis for the processing of your personal data for this purpose is our legitimate interest to be able to develop the Services and to increase Our understanding of the markets and customers. Wherever possible, we anonymise or aggregate data processed for this purpose.
c) For the purposes of segmenting and analyzing position data in order to provide custom information based on Your specific preferences and behavior patterns, we process the following personal data:
Position data
The lawful basis for the processing of your personal data for this purpose is to fulfil Our contractual obligations with You, i.e. in order for Us to provide the Services.
In addition to the above, Wer2 may process Your personal data (all categories of personal data as described above) in order to comply with laws and regulations or by court order (in which case the lawful basis is a legal obligation or to protect Wer2’s or any third parties’ rights, e.g. defending, exercising or establishing legal claims (in which case the lawful basis is Our legitimate interest in protecting Wer2’s or any third parties’ rights.
d) For the purposes of complying with any legal or regulatory requirements that we may have, we may process any of your personal data.
e) For the purposes of carrying out marketing campaigns we may process personal data including:
Contact details (such as name, e-mail address and phone number)
The lawful basis on which we process personal data for marketing purposes is either our legitimate interests in marketing our business, or consent where we send marketing about third party products and services, as further described in section 5. Where our processing is based on consent you can withdraw this at any time by using the unsubscribe link in our emails or by contacting us using the details given in section 1.
You are not obliged to provide us with your personal data, however, not doing so may mean that you are unable to use our services.
3. Transfer of personal data
Wer2 will transfer personal data to the following categories of recipients:
Cities, government authorities including the Department for Transport
and public transport operators. We share personal data with these recipients for the purposes of city planning, understanding mobility insights including contacting individuals to request participation in surveys, integration into public transport operators apps and journey planning apps. The data shared for these purposes includes the following:
User data: Wer2 user identifier; name. email address; phone number
Trip data: trip ID number; date of trip; distance and duration of trip
Scooter data: location of scooter at start point, end point and various points during a trip
Survey data: responses to user experience and demographic survey questions
IT service providers. The purpose for these transfers is to be able to offer to You all of the functions of the Services. Such service providers process Your personal data in the capacity as data processors upon Our commissioning and on Our behalf. We only provide personal data in the context of legally permissible processing, to service providers that have been carefully selected and commissioned in writing. The service providers will receive only such personal data which is required for them to perform their tasks.
Marketing partners. We share personal data with third party service providers which help us with our marketing. The purpose for these transfers is to perform marketing campaigns and the lawful basis is our legitimate interest to be able to perform marketing campaigns.
Group companies. The purpose for these transfers is internal administration and to provide Our Services to You. The lawful basis is our legitimate interest in being able to administer our business and thereby provide Our Services.
Courts and counter parties. The purpose for these transfers is to defend, exercise and establish legal claims (or if we are subject to a case of bankruptcy). The lawful basis is Our legitimate interest to defend, exercise and establish legal claims.
Regulators: to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
Solicitors and other professional services firms (including our auditors).
Law enforcement agencies, including the Police. The purpose for these transfers is to assist law enforcement agencies and the Police in its investigations, to the extent we are obligated to do so. The lawful basis is to comply with legal obligations. We may also under some circumstances have a legitimate interest in assisting the Police in its investigations even if We do not have a legal obligation to do so. In these cases We may transfer personal data to the Police on the basis of Our legitimate interest in assisting the Police and also the Police’s (in its capacity as a third party) legitimate interest in law enforcement.
Potential buyers and seller. The purpose for these transfers is to share information with potential buyers and sellers in a business transaction (e.g. a merger or acquisition) involving Wer2. The lawful basis is our legitimate interest to carry through an acquisition or merger;
4. Storage of personal data
Your personal data is stored only as long as is necessary in order to fulfil the purposes for which Your personal data was collected, however, if personal data is processed on account of Your consent or Our legitimate interest, Your withdrawal of the consent or valid objection will put an end to the processing, without affecting any processing that happened until then and without affecting any legal obligation to process personal data. The personal data which is processed to enter into, perform or administer an agreement between You and Wer2, is processed for as long as You are a customer of Wer2 and have a Wer2 account. If Your account is terminated, We will delete the personal data from Your account, with the exception of personal data which needs to be stored by Us due to legal requirements or to safeguard Our legal interests.
5. Marketing
We may send You marketing regarding Wer2’s Services as well as about products and services offered by third parties. The marketing can be sent both by e-mail, push notifications and in-app. The purpose to send marketing is to inform You about Our Services and relevant offers from third-parties. We may also process personal data for the purpose of evaluating a marketing campaign which may include that We will transfer some personal data, mainly e-mail addresses, to the relevant marketing campaign partners.
The lawful basis for sending marketing regarding Our Services and those of third parties is your consent, which You may withdraw at any time. Where we process personal data for evaluating marketing campaigns the relevant lawful basis is Our legitimate interests to analyze the result of Our marketing campaigns.
You may always opt out from Our marketing efforts, either directly in the actual marketing message or by contacting Us at contact@wer2.com.
6. Rights and contact
You have certain rights in relation to Our processing of Your personal data. Your rights are the following:
Right to access. You have the right to receive confirmation from Us that we process Your personal data, including a right to access Your personal data and receiving an electronic copy of Your personal data.
Right to rectification. You have the right to request that incorrect or inadequate personal data about Your is updated or corrected.
Right to withdraw consent. To the extent the processing of Your personal data is based on Your consent, You have the right to withdraw Your consent at any time.
Right to object. When Wer2 is using legitimate interest as lawful basis for the processing, or if the processing concerns direct marketing, You have the right to object to the processing. In such case, we may be entitled to continue to process Your personal data if we can demonstrate a compelling legitimate interest to continue the processing operation.
Right to erasure (“right to be forgotten”). Under certain circumstances, e.g. if you have objected to the processing and We do not have a compelling legitimate interest, You can request that Your personal data is erased. This does not, however, apply if we have a legal obligation to process the personal data or other legitimate purposes for which Your personal data is processed.
Right to restriction. Under certain circumstances, You have the right to request that the processing of Your personal data is restricted, so that the personal data only may be stored by Wer2 and not processed for any other purposes.
Right to data portability. If the processing is based on Your consent or a contract and the personal data has been obtained directly from You, You are entitled to request data portability, in which case you are entitled to receive Your personal data on a commonly used machine-readable format.
Please contact Us using the contact details below if You wish to exercise any of Your rights mentioned above. Wer2 will normally answer Your request within one month.
You may contact Us at: contact@wer2.com
7. Right to lodge complaints
If You have any complaints regarding Our processing of Your personal data, You have the right to lodge a complaint to the relevant data protection authority in Your country.
8. Security
The technology used by Wer2, together with this Privacy Policy, aims to protect Your personal data from unauthorized access and unauthorized use by using appropriate technical, physical and organisational measures to ensure a level of security appropriate to the risk. For example, amongst other measures, we maintain a security policy and store all of your personal information on our secure servers. We may update these actions as new technology becomes available.
9. Changes to the Privacy Policy
Wer2 may change this Privacy Policy by publishing a new version of this Privacy Policy on the Website and in the Wer2 App. However, in case a change is due to any changes in Our processing operations, We will notify You by sending You an e-mail with information about the change.