Privacy Policy
Who Are We?
When we refer to ‘we’ (or ‘our’ or ‘us’), that means Zipp Mobility Limited. Zipp Mobility Limited is our legal company name but we are trading as Zipp Mobility. To keep things simple, we will use our trading name ‘Zipp Mobility’ throughout this Privacy Notice. Zipp Mobility is based in Ireland.
Privacy Notice Overview
This Privacy Notice describes how and why we, as Data Controller, might obtain, store and process your personal data when you use our services (‘the services’). ‘Personal data’ means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. We commit to processing your personal data fairly, lawfully, and transparently. Please do not hesitate to contact us if you have questions in addition to the information provided in this Privacy Notice at info@zippmobility.com.
The Personal Data We Collect
Depending on the type and level of engagement you have with us, we may collect the following categories of personal data:
- Identifying and Demographic Information: such as your full name, date of birth, email address and phone number (if provided)
- Purchase and Billing Information: such as purchase history, payment preferences, address, bank account details and billing address (if provided)
- Communications: such as a records of our interactions with you using one or multiple of the following; direct messages, emails, posts, phone conversations
- User Feedback: while using our services, occasionally you may be asked to provide feedback. Providing this feedback is entirely optional.
When you visit our website, we collect technical data such as:
- Usage data: (if permitted) we collect certain information related to your device. This can include your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, the website you visited before browsing our site, what pages your device visited, the time that your device visited our website, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, and general location information such as city, state or geographic area (for more information please see the ‘Our Use of Analytics’ and ‘Our Use of Cookies’ sections later in this policy)
Children
While our services are designed for a general audience, we will not knowingly collect any data from children under the age of 16 or sell products to children, without the consent of a parental guardian to do so. If you are under the age of 16 and we do have the consent of a parental guardian, you are not permitted to use or submit your data to the website.
How We Collect Your Data
We may collect your personal data in one of the following ways:
- When you provide information directly into our products and services
- When you visit our website
- When you express an interest to use our services
- When you contact us for service related queries
- When you engage with us on social media
- When you review our services
- When you interact with our website (see our Cookies Policy for more details)
- When you request a parking bay
- When you contact support
- When you submit a report to Zipp
We may also receive data about you from various third parties, including:
- Technical data from analytics providers. Please see further information in the section entitled ‘Our Use of Analytics’
- Technical data from our website and cookies providers. Please see further information in the section entitled ‘Our Use of Cookies’
- Contact and/or transactional data from our trusted third-party providers. Please see further information in the section entitled ‘How We Share Your Data’
How We Use Your Personal Data
We will only collect and process your personal data where we have a legal basis to do so. As a data controller, the legal basis for our collection and use of your personal data varies depending on the manner and purpose for which we collected it. We will only collect personal data from you when:
- We have your consent to do so, or
- We need your personal data to perform a contract with you, or
- We are pursuing our legitimate interests in a way that you might reasonably expect to be a part of running our business and that does not significantly impact your interests, rights, and freedoms. For example, communicating with you if we have a sufficient legal ground based on the e-marketing laws in your country
- We have a legal obligation to collect or disclose personal data from you (for example, in suspected instances of fraud we may need to give personal data to relevant government bodies).
Why We Process Your Personal Data
We process your personal data in order to fulfill any of the activities below:
- Providing, operating, and maintaining our services (Legal basis: Performance of a contract)
- Providing marketing communications to existing customers or subscribed users (Legal basis: Consent or Legitimate Interest)
- Processing and completing transactions, and sending related information, including transaction confirmations and invoices (Legal basis: Performance of a contract)
- Managing our customers’ use of our services, responding to enquiries and comments, and providing customer service and support (Legal basis: Performance of a contract or Legitimate Interest)
- Sending customers technical alerts, updates, security notifications, and administrative communications (Legal basis: Performance of a contract)
- Analytics to improve our website, products, services, and features for a better user experience. (Legal basis: Legitimate Interest or Consent – see the “Our Use of Analytics” section for more information)
- Investigating and preventing fraudulent activities, unauthorised access to our services, and other illegal activities (Legal basis: Legal Obligation)
How We Share Your Data
We sometimes share your personal data with our trusted categories of third parties we use to conduct our business. Our trusted categories of third parties include:
- Website provider
- Cloud service (SaaS) providers
- Professional services providers (e.g., our lawyers, accountants, and insurance providers)
- E-marketing providers
- AML Monitoring Partners
- Transport Departments
- Advertising providers
UK Department for Transport (DfT)
Some data pertaining to your use of e-scooters with any participating Operator of rental e-scooters in the UK, including Zipp Mobility will be shared securely with the UK Department for Transport (DfT) and DfT’s third party research contractors, Arup and NatCen Social Research, for the purpose of the e-scooter trials.
This data will enable DfT to understand the effects of e-scooters and to allow ministers to take an informed decision in the future about how they should be regulated to promote safe and sustainable travel. DfT’s privacy statement for e-scooter trials is available at: https://www.gov.uk/government/publications/dft-online-form-and-survey-privacy-notice/e-scooter-trials-privacy-statement
The data that will be shared includes:
1. Pseudonymised data: Details of the length, duration and location of trips. Please note neither DfT nor its research contactor will be able to attribute this data to any personally identifiable data.
2. Personal data: contact details (for the sole purpose of follow-up research); Month and day of the week, and a time band (i.e. a Wednesday in March, between 7-12am) for the trip; the duration and distance of the trip; and the area (the ONS Lower Super Output Area that corresponds to a trip’s start point). Operators will also share responses you may provide to questions asked after each trip.
DfT and Zipp Mobility take data protection extremely seriously and are ensuring the collection of this data is compliant with Data Protection Legislation. For more information about the standards you can expect when DfT asks for, or holds, your personal information, read DfT’s Personal information charter.
DfT is also preparing a separate survey that you may be asked to respond to as a participant in these rental e-scooter trials. The survey will ask for information about your gender, ethnicity, age and first-part post code to enable the DfT’s research contractor to assess the impact of e-scooter use on equality and opportunity, and to compare different experiences of e-scooter use according to those characteristics. Further details of this will be provided with the survey.
E-marketing Partners
As part of our e-marketing methods and on the basis of our legitimate business interests, we use some Google services and some Facebook products in accordance with the practices explained in the Google and Facebook terms and privacy notices. In order to protect your personal data by pseudonymising it, Google and Facebook ensure that a hashing algorithm is applied automatically at the point of sharing personal data with Google and Facebook. Please consult their relevant terms and privacy notices for further information and your options. If we can help you in any way please do not hesitate to contact us at info@zippmobility.com.
AML Monitoring Partners
As part of our fraud monitoring, detection and prevention methods and on the basis of our legitimate business interests, we use a third-party fraud monitoring, detection and prevention service provider for all website/online sales. As part of this service, we may share personal data that is required to make identity checks and personal data that we obtain from making identity checks (including data relating to your age, name and location), together with account information, with third party organisations (including law enforcement agencies), involved in fraud prevention and detection and credit risk reduction. Please note that these third parties may retain a record of the information that we provide to them for this purpose.
A full List of our Data Sub-Processors can be found in our Privacy Center on our website.
As part of fraud monitoring and prevention, we may be legally required to share your personal data with government bodies and law enforcement. Please note that these bodies may retain a record of the information that we provide to them for this purpose.
Sale or Merger
We may share your personal information as part of a merger or acquisition. If Zipp Mobility is involved in a merger, financing, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets, or in the event of a liquidation, insolvency, bankruptcy, or receivership, we may share your information with that company before and after the transaction closes. In such a case, unless otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer. You will be notified of any such changes in advance.
Marketing Preferences
We may send you direct marketing communications, product information and promotional offers:
- If you have consented to receiving such communications from us
- If we have an existing business relationship with you and can rely on your implied consent
- If you are from a country where the laws permit us to send you such communications based on our legitimate interests, if you have bought a product or service from us, and have not opted out of receiving communications from us (for example the EEA or UK)
- If you are from a country where the laws permit us to send you such communications
The marketing communications we send will be in relation to our own products or services, your personal data will not be used for third-party direct marketing unless separate explicit consent has been collected for that or you are from a country where the laws permit such processing.
You will always have full control of your marketing preferences. If you do not wish to continue receiving marketing information from us at any time:
- You can unsubscribe by using the unsubscribe directions or link included in marketing communication from us; or
- You may withdraw your consent by contacting us by e-mail at info@zippmobility.com