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TOPMOBILITY Ltd and its affiliates (Top Rent A Car, Low Cost Cars, Top Lease, TopImmo) are strongly committed to transparency and we want you ("you" or "your") to understand how we collect, use, share and protect your information. This Privacy Notice ("Privacy Notice") describes how Top Mobility processes information in connection with Top Mobility's websites and related mobile applications and services (collectively, the "Services") and when you interact with us in other respects. Where specifically stated, this policy also describes our data practices relating to logistics service providers or logistics service providers' personnel.
We reserve the right to change this Privacy Notice from time to time. We will inform you in advance of any material changes.
Types of information we collect
The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the information you provide to us, although if you choose not to provide certain information (such as account information), we will not be able to provide the Services. We use and disclose this information for the purposes described below. The types of information we collect include:
Account information such as your name, email address, phone number, date of birth, gender, address, and billing information such as your credit card information. In order to use certain products, we may also require you to provide photos of government-issued identification (such as a driver's license) from which we collect data, including identification number, date of birth, gender, city, and zip code. We also require government-issued identification and proof of low-income status to provide access to Top Mobility for verification purposes.
We collect and process location data when you register and use the Services. For example, in order to properly display Top Mobility vehicles near your location, we need to obtain and record the location of your device. Top Mobility also collects location data directly from Top Mobility vehicles, including when a Top Mobility user is driving them.
When you use certain products that require a government-issued driver's license, verification of age, or use of a helmet or other legally required protective equipment, we will ask you (and your passenger(s), if applicable) to take a selfie, which we retain.
If you link to, connect with, or log in to Top Mobility with a third party service (such as Facebook), the third party service may send us information, such as your profile information, from that service.
When you request customer service, support, or other assistance, you may choose to provide us with contact information to better respond to your requests, and we may retain information about your use of our support services.
Top Mobility and third parties (such as Facebook) collect information from your browser, computer or mobile device that provides us with technical data, such as your device's IP address and device token, when you access or use the Services. We use cookies and similar tracking technologies (such as pixels and tags) to provide our Services, including to protect the security of the Services, remember your settings, and collect analytics information about you. Third parties may use the technical information to provide measurement services and targeted advertisements. You can learn more about how we (and third parties) use cookies and similar technologies and how you can opt-out of information being used for advertising purposes.
We collect information that you share on the Services, such as when you participate in communities or other forums or comment on our social media accounts or blog entries.
We receive information about you when we use third party partners, for example marketing and advertising partners, such as social networks.
If you are a logistics service provider, we record the following types of information:
Information submitted as part of your application to engage with Top Mobility as a logistics service provider, such as contact and ID information;
business operations information, such as business license, tax registration, and insurance information; and
your bank account details.
If you are a staff member of a logistics service provider, we record the following types of additional information:
Contact information; and
details of the work you do, such as information about the vehicles you load and deploy and other services provided for Top Mobility.
How we use the information
We use your information, including information about your location, to:
confirm that your government issued driver's license (if provided) is valid, not currently linked to another Top Mobility account, and not expired;
confirm that you are old enough to use our products by verifying that your selfie matches your government-issued identification (e.g., driver's license), for example, using facial recognition technology;
monitoring, tracking and servicing Top Mobility vehicles, including when used by you; where applicable, this includes collecting images and/or video footage of your journey;
Confirm that drivers are wearing helmets and other legally required safety equipment where necessary;
to process payments, subscriptions or donations and any discounts or special offers such as free unlocks;
communicate with you about your account, interactions or transactions, including service-related communications, such as changes to our policies. As permitted by local law, we may also send you surveys or marketing messages on behalf of Top Mobility and/or third parties, including information about features and enhancements to our Services;
personalizing advertisements for you;
optimize, develop and improve our Services, including by creating and training machine learning models. For this purpose, we may use third-party analytics providers to understand how the Service is used to help us improve the Services;
where necessary, comply with our legal obligations, including to comply with regulatory or local legal requirements;
detect, investigate and prevent activities that violate Top Mobility's policies or terms, or are illegal, including incidents of traffic violations or accidents, which may include sharing information with government agencies such as law enforcement agencies and municipal authorities that may be located outside of the country in which you live; and
sharing and collaborating with third parties, such as universities, local government entities, and other third parties to build or improve transportation infrastructure, as described in the "Who Do We Share Your Information With?" section below.
In addition, if you are a logistics service provider or a staff member of a logistics service provider, we use your information in order to: allow you to provide your services to us; have visibility and compensate you for the services you provide to Top Mobility; and track Top Mobility vehicles.
Who do we share your information with?
We share your information with:
Our service providers and partners: We share your information with our trusted service providers and partners who provide services to Top Mobility, such as hosting data and our infrastructure, providing identity verification services, processing payments and donations, maintaining and enhancing the Services, performing customer service, or providing marketing and advertising services. For example, we share information with credit card issuers to process your payments and refunds.
Collaborations with Third Parties: After removing certain identifiers, such as your name, phone number, and email address (if provided), and combining the resulting information with similar information from other users, Top Mobility may share your information, including individual travel records and travel location (trip) history, with third parties for research, business, or other purposes. For example, Top Mobility collaborates with universities to assist with research projects, such as understanding traffic and travel patterns in a city.
Governmental, Municipal, Regulatory, and Law Enforcement Agencies: We may share your information with governmental, municipal, regulatory, and law enforcement agencies to comply with federal, state, regulatory, or local laws, or as part of a legal process, to detect, investigate, prevent, and clarify fraud and other illegal activities, security or technical issues, or to prevent damage or harm to you, members of the public, our staff, other third party
Integrated Partners: We share your information with third party services that integrate or provide access to Top Mobility vehicles and/or the Services on their platforms or that make their products available on our Services.
Cities, Local Authorities and Public Transport Operators: We share your information with these recipients where necessary to comply with the terms of our license or where necessary to operate in a particular city or locality, or for the purposes of urban planning and understanding mobility data. This may include recipients contacting drivers to request participation in surveys and integration into public transport operators' apps and journey planning apps.
Top Mobility Affiliates: We may share your information with Top Mobility Affiliates to help provide, maintain and improve the Services.
Business Reorganization: We may also share your information as part of a sale, merger, change in control or business restructuring.
Advertising and Analytics
We permit others to provide analytics services and serve advertisements on our Services and on our behalf on the web and in mobile applications. These parties may use cookies, web beacons, device identifiers and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages in mobile applications, links clicked and conversion information. This information may be used by Top Mobility and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertisements and content targeted to your interests on our Services and other websites, measure the effectiveness of our advertising, and better understand your online activity.
When Top Mobility uses the Meta pixel (a type of cookie) to deliver advertising to you, Top Mobility and Meta Bulgaria are joint administrators for that processing. Top Mobility and Meta Bulgaria have entered into a Data Controller Addendum to separate their responsibilities under the General Data Protection Regulation (GDPR) in respect of this joint processing, for example, Top Mobility is responsible for providing this notice to you and Meta Bulgaria is responsible for managing your individual rights in relation to the joint processing.
We also work with third parties to serve you ads as part of custom campaigns on third party platforms (such as Facebook and Instagram). As part of these advertising campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be associated with a user account on these platforms to allow us to learn about your interests and show you advertising tailored to them. Note that third-party platforms may offer you choices about whether to see these types of personalized ads.
We do not submit your personal information to third parties for their direct marketing purposes.
Our legal basis for using your information
Top Mobility relies on multiple legal bases to collect, use, share and otherwise process your information for the purposes described in this Privacy Notice, including when:
is necessary to provide the Services and perform our obligations under our Terms. For example, we cannot provide the Services without obtaining and processing information about you and your location;
You have consented to us processing your information (in which case you may withdraw your consent at any time);
is necessary to comply with a legal obligation, including, for example, to respond to requests for information from government or law enforcement agencies, or to establish, exercise or defend legal claims;
is necessary to protect the vital interests of our users, logistics service providers and logistics service providers' personnel, staff and members of the public, both on and off the Services; and/or
the processing is necessary for Top Mobility's purposes or the legitimate interests of third parties, provided that we have aligned these with your fundamental rights and interests.
How we transmit your information
Because we offer our Services in many locations worldwide, we may transfer your information to or from those locations for the purposes of providing the Services to you.
For residents of the European Economic Area ("EEA"), Switzerland or the United Kingdom: please note that some countries outside the EEA, Switzerland or the United Kingdom may not offer the same level of data protection as your country. Where the European Commission has confirmed that a country provides an adequate level of data protection, Top Mobility may rely on the Commission's decision on the adequate level of data protection, as the case may be, to transfer data.
Top Mobility also relies on Standard Contractual Clauses approved by the European Commission or other appropriate mechanism(s) to transfer data from the EEA, Switzerland, and the United Kingdom to the United States and other countries outside the country in which you reside.
In certain limited circumstances, we may use derogations where it is appropriate to process personal data and there are no other applicable data transfer mechanisms.
How long we keep the information
We retain your information for as long as reasonably necessary to provide you with the Services or until your account is deleted, whichever is longer, subject to such longer period as may be required by applicable law or communicated to you. For example:
We retain account information, such as your email address and your date of birth, for the duration of the account. Certain information regarding transactions on an account is retained for 7 years in accordance with Top Mobility's accounting obligations;
We retain information related to customer support inquiries for the life of the account.
When you delete your account, it may take us additional time to completely delete your information from our databases and system log files. We may also retain information from deleted accounts to prevent fraud, collect fees, enforce the User Agreement to comply with our legal obligations, or enforce our legal rights.
In addition, if you are a logistics service provider or a member of the logistics service provider's staff, Lime retains certain information as necessary to comply with our legal obligations. For example, Top Mobility may retain some of your information to comply with applicable tax, legal, reporting and auditing obligations and other requirements in the countries in which we operate.
Your rights
Depending on where you live, you may have a number of rights in relation to your information, including:
Right to object (marketing) - You have the right to object to the processing of data for direct marketing purposes at any time.
Right to object (legitimate interest) - Where we process your information on the basis of legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is necessary for legal reasons, we will stop processing your information when you object.
Right of access - You can access much of the information by logging into your account. You can also request a copy of the information we hold about you and information explaining how the information is used.
Right of correction - You have the right to ask us to correct inaccurate information about you. You may be able to edit this information in the Top Mobility app settings.
Right to erasure - You have the right to ask us to delete your information.
Right to restrict processing - You have the right in certain cases to temporarily restrict our processing of your information, provided there are valid grounds for doing so.
Right to data portability - You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another data controller.
Right to withdraw consent - Where you have previously given your consent, for example for us to send you direct marketing, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of the processing based on the consent before its withdrawal. In addition, even in the event of withdrawal, we may continue to use your information as permitted or required by law.
Please contact us as set out in the section below "Who is responsible for my information?" if you wish to exercise any of these rights or if you have concerns about the way we process your information. For security reasons, we may require you to complete certain steps to confirm that you have the relevant Top Mobility account. For example, we may require that you have a confirmed email associated with your Top Mobility account and contact us using the confirmed email associated with your Top Mobility account. You also have the right to file a complaint with your local data protection supervisory authority. You can view a list of EU supervisory authorities here.
Your Choices and How You Can Manage Your Information: We believe you should have choices about the collection, use and sharing of your information. If you do not want Top Mobility to collect your information, please do not use the Services.
Emails and Other Communications: If you would like to change the types of communications you receive from us, including opting out of promotional communications from us, you may do so at any time by updating the communication preferences set forth in your account profile. If you opt-out of receiving promotional communications from us, we may continue to send non-promotional communications and other information regarding your use of the Service.
Accessing and Managing Your Information: If you have an account with Top Mobility, you may view, change or delete your information by logging into your account and editing your user profile. You can change your mobile phone number or email address using our in-app change feature. You can delete your Lime account at any time by selecting "Delete Your Account" from the settings screen in the app, by sending us a request at office@topmobility.bg, or by using the "Send Request" feature in the app. If you are a logistics service provider or logistics service provider staff member and wish to delete your account, please email office@topmobility.bg