This privacy policy (the ”Privacy Policy”), together with the user agreement and terms and conditions (the “Agreement”), available on the Zenway website www.zenway.app, describes how Zenway Mobility Ltd, a company registered in England and Wales with company number 14879692 and with its registered office at 128 City Road, London, EC1V 2NX, UNITED KINGDOM (”Zenway”, “We”, “Our“), as a data controller, process its customer’s (“You” in any form) personal data when using the Services, as defined in the Agreement.
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 Zenway’s processing of Your personal data can be sent to support@zenway.app.
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.
2.1 Personal data related to You (Our customers)
Zenway will collect personal data which You submit when creating an account in the Zenway App or which is created when You are using the Zenway App or the Services.
Zenway 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:
Our lawful basis for the processing of your personal data for this purpose is to fulfil our contractual obligations with You (Article 6(1)(b) GDPR).
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 and third parties described below process the following personal data:
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 (Article 6(1)(f) GDPR). Wherever possible, we anonymise or aggregate data processed for this purpose.
c) For the purposes of carrying out marketing campaigns we may process personal data including:
The lawful basis on which we process personal data for marketing purposes is either our legitimate interests in marketing our business (Article 6(1)(f) GDPR), or consent (Article 6(1)(a) GDPR) where we send marketing about third party products and services, as further described in section 6. 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.
d) 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:
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 (Article 6(1)(b) GDPR).
e) For the purposes of providing You with the ability to detect Our nearby vehicles and to enable Us to detect use of Our vehicles in breach of Our User Agreement, we process the following personal data:
Our lawful basis for the processing of your personal data for this purpose is our legitimate interest to provide you with services and to ensure use of our services in accordance with Our User Agreement (Article 6(1)(f) GDPR).
In addition to the above, Zenway may process personal data (all categories of personal data and categories of data subjects 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 (Article 6(1)(c) GDPR)) or to protect Zenway’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 Zenway’s or any third parties’ rights (Article 6(1)(f) GDPR)).
Zenway may transfer personal data to the following categories of recipients:
In some cases, Zenway may transfer your personal data outside the EU / EEA, mainly in cases where we use service providers that process personal data outside the EU / EEA. This will only be done after adequate protection measures have been taken by Zenway to ensure an adequate level of data protection, e.g. by including the European Commission’s standard contractual clauses for the transfer of personal data and, where necessary, by implementation of supplementary safeguarding measures. You can obtain further information regarding the protection measures taken when personal data is transferred outside the EU / EEA by contacting Us.
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 Zenway, is processed for as long as You are a customer of Zenway and have a Zenway 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.
We may send You marketing regarding Zenway’s Services as well as products and services offered by third parties. The marketing can be sent both by e-mail, push notifications and in-app. The purpose of sending 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 (Art. 6 (1) sentence 1 point (a) GDPR), which You may withdraw at any time. Where we process personal data for evaluating marketing campaigns the relevant lawful basis is Our legitimate interests (Article 6(1)(f), GDPR) 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 support@zenway.app.
You have certain rights in relation to Our processing of Your personal data. Your rights are the following:
a) 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.
b) 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.
c) Right to rectification. You have the right to request that incorrect or inadequate personal data about Your is updated or corrected.
d) 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.
e) Right to object. When Zenway is using legitimate interest (Article 6(1)(f) GDPR) 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.
f) 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 Zenway and not processed for any other purposes.
g) 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 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.
If You wish to exercise Your rights mentioned above under (a) – (g), please contact Us using the contact details below (Zenway will normally answer Your request within one month):
If You have any complaints regarding Our processing of Your personal data, You have the right to lodge a complaint to the Information Commissioner’s Office (ICO).
The technology used by Zenway, 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.
Zenway may change this Privacy Policy by publishing a new version of this Privacy Policy on the Website and in the Zenway 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.