1. General

This privacy policy (the ”Privacy Policy”), together with the Terms of Service & Rental Agreement (the “Agreement”), available on the Hubb website www.hubbscooters.com, describes how Rozafa AB doing business as Hubb, Hubb Scooters, or the applicable subsidiary providing the services, a Swedish company, org.nr:559208-7463 and with its seat at c/o Hubb Scooters Box 2013 445 02 surte Västra Götalands län, Sweden(”Hubb”, “We”, “Our“), as a data controller, process its customer’s (“You”) personal information when using the Services.

Unless otherwise stated in this Privacy Policy, the definitions used will have the same meaning as in the Agreement. Questions regarding this Privacy Policy and Hubb’s processing of Your personal information can be sent to [email protected] or to Hubb’s data protection officer:

Rozafa AB

Data protection officer: Kushtrim Nura, Email: [email protected]

Postal address: c/o Hubb Scooters BOX 2013 445 02 Surte Västra Götalands län, Sweden

This Privacy Policy is intended to help us fulfill our obligation to provide you with information about our processing of your personal data in accordance with applicable data protection laws. It explains how we collect, use and share your personal information as part of our business activities.

2. Gathering, purpose and use of personal information

Hubb collects personal information that you provide when you create an account using the Hubb application or when you use the Hubb application or Hubb services.

Hubb processes Your personal information for the following purposes:

a)To enter into, execute and manage our contractual relationship with you (including payment processing) and to respond to you in connection with our services. We process the following personal data:

  • The ID of a user's mobile device;
  • If a user has,or does not have a valid driver’s licence and the expiry date of that user’s licence if they do have one;
  • Contact details (name, address, e-mail address and cell phone number);
  • Location information (location of mobile device and Scooter location);
  • Payment information (credit or debit card information,payment history);
  • (If you are a key employee, low income user or scholar claiming a discounted rate) proof of
    your status (such as a staff card or student campus card); and
  • Images of scooters uploaded using the Hubb App.

Our legal reason for processing your personal data for this purpose is to fulfil our contractual obligations towards you (Article 6(1)(b) GDPR).

b) To segment and analyze location information to provide customized information based on your specific preferences and behavioral patterns, we process the following personal information:

  • Position information

The lawful basis for processing your personal information for this purpose is the fulfilment of our contractual commitments towards you, i.e. in order for Us to deliver our Services (Article 6 (1) (b) GDPR).

In addition, Hubb may process your personal information(in all of the above categories) to comply with laws, regulations or court orders (in which case the lawful basis is a legal obligation (Article 6(1)(c) GDPR) or to protect the rights of Hubb or any third parties, e.g. defending, exercising or establishing legal claims (in which case the lawful basis is Our legitimate interest in protecting thr rights of Hubb or any third parties (Article 6(1)(f) GDPR)).

c) We and the third parties below process the following personal information for the purposes of statistical analysis, data analysis to develop the services regarding functions, security and methods, and market and customer analysis.

  • Details of the use of the Hubb App and Hubb Services (for example, date, time and duration of usage of the Hubb app and services).
  • Mobile device information, such as make, model, and operating system;
  • User details such as that described in (a) and age group, gender, first part of post code; and
  • IP address.

Our legitimate basis for processing your personal information for this purpose is our legitimate interest in developing the service and in better understanding the market and our customers (Article 6(1)(f) GDPR). Wherever possible, the information processed for this purpose is made anonymous or aggregated.

d) For the purpose of conducting marketing campaigns, we may process personal information including:

  • Contact details (such as name, e-mail address and cell phone number)

Our legitimate reasons for processing personal data for marketing purposes are legitimate interests in the marketing of our company (Article 6(1)(f) GDPR) or consent in the marketing of products or services of a third party(Article 6(1)(a) GDPR), as further explained in Section 5 .  Because our processing is based on consent, you can revoke your consent at any time by using the link contained in our e-mail to unsubscribe or by contacting us using the details given in section 1.

e) We may process your personal information for the purpose of meeting our legal or regulatory requirements.

You are under no obligation to provide us with personal information, but failure to do so may mean that you cannot use our services.

3. Transfer of personal information

Hubb will transfer personal information to the following categories of recipients:

  • IT service providers. The purpose of these transfers is to enable us to provide you with all the features of the Service. We commission these service providers to process your personal information as data processors on our behalf. We will only transfer personal data to carefully selected service providers who have been outsourced in writing, within the scope of processing permitted by law. Service providers will only receive personal information that is necessary to fulfill their tasks.
  • Cities, government authorities, including the Department for Transport and public transport operators. We pass on personal information to these recipients in order to gain insights into urban planning and mobility. This includes contacting individuals to encourage them to participate in surveys and integrate them into public transport operator apps and travel planning apps. The information shared for these purposes includes the following:
    • Trip details: trip ID number; date of trip; distance and duration of trip
    • User details: Hubb user identifier; name, email address; cell phone number; age group; first part of postal code; gender.
    • Survey details: responses to user experience and demographic survey questions
    • Scooter details:Location of the scooter at the beginning, at the end and at any other point
  • Solicitors and other professional services firms (including our auditors).
  • Insurance companies. The purpose of these transfers is to process claims and manage our insurance policies. The legitimate basis is our legitimate interest in the processing of claims and the ongoing administration of our insurance policies (Article 6(1)(f) GDPR).
  • Marketing partners. We share personal information with third parties who assist us in our marketing efforts. The purpose of these transfers is to conduct marketing campaigns, and the legitimate basis for these transfers is our legitimate interest in being able to conduct marketing campaigns (Article 6(1)(f) GDPR).
  • Group companies. The purpose of these transfers is to provide you with internal control and our services. The legitimate basis is our legitimate interest in being able to conduct our business and thereby offer you our services (Article 6(1)(f) GDPR).
  • Courts and counter parties. The purpose of these transfers is to defend, enforce and establish legal claims (or if we are subject to bankruptcy). The legitimate basis is our legitimate interest in defending, enforcing and substantiating legal claims. (Article 6(1)(f) GDPR).
  • Potential buyers and seller. The purpose of these transfers is to exchange information with potential buyers and sellers in business transactions in which Hubb is involved (such as mergers and acquisitions). The legitimate basis is our legitimate interest in completing an acquisition or merger (Article 6(1)(f) GDPR);
  • Regulators: to comply with all applicable laws, regulations and rules and requirements of law enforcement regulatory and other government agencies.;
  • Law enforcement agencies, including the Police.The purpose of these transfers is to cooperate with law enforcement agencies and police investigations, insofar as we are obliged to do so. The lawful basis is the compliance with our legal obligations (Article 6(1)(c) GDPR). Under certain circumstances, there may be a legitimate interest to assist police investigations, even if we are not legally obliged to do so. In such cases, we may provide personal information to the police based on our legitimate interest in supporting the police and their (as third parties) legitimate law enforcement interests (Article 6.1(f) GDPR).

If Hubb transfers your personal data to countries outside the EU/EEA, it will only do so after security measures have been taken to ensure an adequate level of data protection, e.g. by entering into EU standard contractual clauses for the transfer of personal data. You can contact us for more information about the protection of your personal data when transferred outside the EEA by contacting us at the contact details provided in Section 1 of this Policy above.

4. Marketing

We may send you marketing about Hubb's services and marketing about products and services offered by third parties. Marketing can be via email, push notifications and in-app notifications. The purpose of sending marketing information is to inform you about relevant offers of our services and third parties. We may also process personal data for the purpose of evaluating our marketing campaigns, which primarily involves the transmission of personal data, such as e-mail addresses, to our partners in the relevant marketing campaigns.

The lawful basis for sending marketing via our services and the services of third parties is your consent (Article 6(1)(a) GDPR), which you can revoke at any time. If we process your personal data in order to evaluate our marketing campaigns, the relevant legal basis is our legitimate interest in the analysis of the results of our marketing campaigns (Article 6(1)(f ), GDPR).

You may always opt out from Our marketing efforts, either directly in the actual marketing message or by contacting Us at [email protected].

5. Storage of personal information

Your personal data will be kept only as long as necessary to achieve the purpose for which it was collected. However, if your personal data is processed with your consent or for our legitimate interests, the processing will be terminated with the withdrawal of your consent or a valid objection, which will not affect the processing carried out up to that point and won't affect any legal commitment to process personal information. Personal data processed for the purpose of entering into, performing or managing a contract between you and Hubb will be processed for as long as you are a customer of Hubb and have an account with Hubb. If your account is terminated, we will delete your personal data from your account, except for personal data that we are required to retain by law or to protect our legal interests.

6. Rights and contact

You retain certain rights in relation to the processing of your personal data by us. Your rights are as follows:

  • Right to rectification. You have the right to request that your personal data be updated or corrected if it is inaccurate or insufficient.
  • Right to restriction. Under certain circumstances, you have the right to request that your personal data be limited in its processing and stored only by Hubb and not processed for other purposes.
  • Right to access. You have the right to obtain confirmation of our processing of your personal data, including the right to access your personal data from us and to receive an electronic copy of your personal data.
  • Right to withdraw consent. If the processing of your personal data is based on your consent, you have the right to revoke your consent at any time.
  • Right to data portability.If the processing is based on your consent (Article 6(1)(a) GDPR) or a contract (Article 6(1)(b) GDPR) and the personal data is collected directly from you, you have the right to request the transferability of the data.
  • Right to erasure (“right to be forgotten”). Under certain circumstances, e.g. if you object to the processing and we have no compelling legitimate interest, you can request the deletion of your personal data. However, this does not apply if we are legally obliged to process your personal data or if we have another legitimate purpose for which your personal data is processed.
  • Right to object. If Hubb invokes a legitimate interest (Article 6(1)(f) GDPR) as a legitimate basis for the processing or if the processing relates to direct marketing, you have the right to object to the processing. In this case, you may have the right to continue the processing of your personal data if you can demonstrate a compelling legitimate interest in continuing the processing.

Please contact Us using the contact details below if You wish to exercise any of Your rights mentioned above. Hubb will normally answer Your request within one month.

You may contact Us at: [email protected], or by sending mail to Rozafa AB, c/o Hubb Scooters BOX 2013 445 02 Surte Västra Götalands län, Sweden

7. Right to file complaints

If you have a complaint about the processing of your personal data, you have the right to file a complaint with the competent data protection authority in Sweden (the Swedish Data Protection Agency).

8. Security

The technology used by Hubb, together with this Privacy Policy, is designed to help protect your personal information from unauthorized access and use by implementing appropriate technical, physical and organizational measures to provide a level of security appropriate to the risks involved. Among other measures, we maintain a security policy and store all of your personal information on our secure servers. We may update these measures as new technologies become available.

9. Changes to the Privacy Policy

Hubb may change this Privacy Policy by posting a new version of this Privacy Policy on the website and the Hubb app. However, if the change is due to a change in our processing practices, we will notify you by e-mail and with details of the change.