Privacy Policy
General Provisions
This privacy policy (the “Privacy Policy”), together with the user agreement and terms and conditions (the “Agreement”), which can be accessed on Volti’s website at www.volti.app, outlines how Volti (Volti C.A) as the data controller, processes the personal data of its customers (“You”) when using the Services.
Unless otherwise stated in this Privacy Policy, the definitions used herein have the same meaning as in the Agreement. Questions concerning this Privacy Policy and the processing of your personal data by Volti can be addressed to or to Volti’s data protection officer at [email protected].
Collection, Purposes, and Use of Personal Data
Volti will collect personal data that You provide when creating an account in the Volti Application or that is generated when You use the Volti Application or Services. Volti processes your personal data as follows:
For the purpose of entering into, fulfilling, and managing our contractual relationship (including payment management) with You, we process the following personal data:
Location data (phone location and scooters/bicycles); Identification and contact data (for example, your full name, postal address, email address, and telephone number); Payment information (such as bank card information, billing history, payment history); Device identification; and Photos of scooters/bicycles that You upload in the Volti application. Our legal basis for processing your personal data for this purpose is to fulfill our contractual obligations in order to perform statistical analysis and data analysis to develop Services related to functionality, security, and methods, as well as to analyze markets and customers, we process the following personal data:
IP address;
Information about your device, such as brand, model, and operating system; Information about your use of the Volti Application and Services, such as the date, time, and duration of use. Survey data: responses to demographic and user experience questions. Our legal basis for processing your personal data for this purpose is our legitimate interest in being able to develop the Services and better understand markets and customers. For the purposes described above, we will perform our analysis from anonymized/aggregated data. However, the processing described above will be carried out within the process to anonymize or aggregate the data.
For conducting marketing campaigns and sending marketing materials, we may process the following personal data:
Contact data (such as name, email address, and telephone number) The legal basis on which we process your personal data for sending marketing materials via electronic means is your prior, explicit, and informed consent. However, we may also send you marketing materials via electronic means without your prior explicit and informed consent if you are an existing user or customer of Volti and the content of the marketing materials to be sent refers to Volti products or services similar to those already contracted by you. It is our legitimate interest to share marketing materials via electronic means with our existing users or customers who may be interested because they have contracted similar services or products.
When our processing is based on consent, you can withdraw it at any time using the unsubscribe link in our emails or by contacting us using the details stated in section 1.
For the purpose of segmenting and analyzing position data to provide personalized information based on your specific preferences and behavior patterns, we process the following personal data:
Position data
The legal basis for processing your personal data for this purpose is to fulfill Our contractual obligations to You, i.e., so that we can provide the Services.
For the purpose of providing loyalty credits for the use of a protective helmet, Volti will process your personal data when you send a photo of yourself with the helmet on while riding a Volti scooter. The personal data that will be processed for this purpose are:
The selfies that you send us
The legal basis for processing your personal data for this purpose is to satisfy our legitimate interest in being able to encourage our users to wear a protective helmet to increase safety when using Volti scooters.
For the purpose of improving the software that allows Volti to review the selfies provided subject to the above purpose, Volti will use the images you send to train and improve the software’s ability to react to protective helmets appearing in the images. The personal data that will be processed for this purpose are:
The selfies that you send us
The legal basis for processing your personal data for this purpose is to satisfy our legitimate interest in being able to continuously improve our services and ensure that the selfie service is as accurate as possible.
For the purpose of offering you the ability to detect and locate our nearest vehicles, and in order to detect any use that violates our User Agreement, we process the following data:
Location data when using the Volti App (mobile location)
The legal basis for processing your personal data is our legitimate interest in offering our services and ensuring that the service is used in accordance with our User Agreement.
In addition to the above, Volti may process your personal data (all categories of personal data described above) for the purpose of complying with laws and regulations or by court order (in which case the legal basis is a legal obligation or to protect the rights of Volti or third parties, for example, to defend, exercise or formulate claims (in which case the legal basis is Our legitimate interest in protecting the rights of Volti or third parties).
You are not obliged to provide us with your personal data; however, not doing so may mean that you cannot use our services.
Verification of Identity, Age, and Identity Document
Before using the Services for the first time in some countries, you may be asked to provide photos of your driving license or other identity document to: (1) verify and authenticate your identity, (2) verify your age, and (3) verify that your driving license/other identity document is valid. For the purpose of verifying and authenticating your identity, you may also be asked to send a selfie photo of your face. For this, we will use an automated process to compare the facial scanner data extracted from the photo of your driving license/other identity document with the facial scanner data extracted from the selfie photo you have submitted. The comparison is then used by automated means to determine whether it is You or not the person who appears in the photo of the driving license/other identity document.
In some countries, you will not be asked to authenticate your identity by sending a selfie photo of your face. In this case, we will not use the automated process described above.
The legal basis for verifying and authenticating your identity by facial scanning and comparison is your consent which you can withdraw at any time. Your consent is obtained in the Volti application before any facial scanning. Verification of your identity by other means than facial scanning and comparison, as well as verification of the validity of your driving license/identity document and your age are necessary for the conclusion of the User Agreement.
Transfer of Personal Data
Volti may transfer personal data to the following categories of recipients:
Cities, governmental authorities, and public transport operators. We share personal data with these recipients for the purpose of city planning, understanding mobility perspectives, including contacting individuals to request participation in surveys, integration into public transport operator applications, and travel planning applications. The data shared for these purposes are as follows:
Trip data: trip identification number; trip date; trip distance and duration
Scooter data: scooter identification number, scooter location at the start point, at the endpoint, and at various points during the trip
Survey data: responses to survey questions about user experience and demographic questions Researchers and third-party collaborators. We share personal data with such recipients for the purpose of developing the service and for understanding mobility.
The data we share for these purposes include the following:
Trip data: trip identification number; trip date; trip distance and duration
Scooter data: scooter identification number, scooter location at the start point, at the endpoint, and at various points during the trip
Survey data: responses to survey questions about user experience and demographic questions
IT service providers. The purpose of these transfers is to be able to offer you all the functions of the Services. Such service providers process your personal data as data processors on our behalf and for our account. We only provide personal data in the context of a legally permitted processing to service providers who have been carefully selected and contracted in writing. Service providers will only receive those personal data that they need to carry out their tasks.
Marketing partners. The purpose of these transfers is to conduct marketing campaigns and the legal basis is our legitimate interest in being able to conduct marketing campaigns so that our products and services reach a wider audience. Group companies The purpose of these transfers is internal administration and to provide you Our Services. The legal basis is our legitimate interest in being able to manage our business.
Insurance companies. The purpose of these transfers is to manage insurance claims and administer Our insurance policies. The legal basis is our legitimate interest in managing insurance claims and administering Our insurance policies continuously.
Courts and Counterparts in legal matters. The purpose of these transfers is to defend, exercise, and formulate claims. The legal basis is Our legitimate interest in defending, exercising, and formulating claims.
Regulators or governmental authorities: The purpose of this transfer is compliance with applicable legislation, regulations, and regulations as well as responding as appropriate to requests for information from regulatory bodies and other governmental bodies such as Public Administration. Law firms and other professional forms (including our auditors): The purpose of these transfers is to seek professional assistance from law firms or other professional services for the exercise and defense of our legal rights.
Law enforcement authorities, including the Police. The purpose of these transfers is to assist law enforcement authorities and the Police in their investigations, to the extent that we have an obligation to do so. The legal basis is to comply with legal obligations. Potential buyers and sellers. The purpose of these transfers is to share information with potential buyers and sellers in a business transaction (for example, a merger or acquisition) in which Volti participates.
Retention of Personal Data
Your personal data is retained only for as long as necessary to fulfill the purposes for which your personal data was collected; however, if personal data is processed based on your consent or Our legitimate interest, your withdrawal of consent or opposition will end the processing, without affecting the processing that has taken place up to that point and without affecting any legal obligation to process personal data. Personal data processed to enter into, execute, or manage a contract between You and Volti will be processed as long as You remain a Volti customer and maintain a Volti account. If your account is canceled, we will delete the personal data from your account, except for personal data that we must retain due to legal requirements or to safeguard our legal interests during the applicable limitation periods.
Marketing
We may send you marketing communications related to Volti Services as well as third-party services. Marketing communications may be sent by email, push notifications, and in the application itself. The purpose of sending you marketing communications is to inform you about our Services and relevant third-party offers. We may also process personal data for the purpose of evaluating a marketing campaign, which may include transferring some personal data, primarily email addresses, to relevant marketing campaign partners.
The legal basis for sending marketing communications by electronic means in connection with Our Services and those of third parties is your prior and informed consent, which you can withdraw at any time. We may also send you marketing materials via electronic means without your prior explicit and informed consent if you are an existing user or customer of Volti and the content of the marketing materials to be sent refers to Volti products or services similar to those already contracted by you. It is our legitimate interest to share marketing materials via electronic means with our existing users or customers who may be interested because they have contracted similar services or products.
When we process personal data to evaluate marketing campaigns, the relevant legal basis is our legitimate interests in analyzing the outcome of our marketing campaigns.
You may opt out of our marketing efforts at any time, either directly in the marketing message itself or by contacting us at [email protected].
Rights and Contact
You have certain rights in relation to our processing of your personal data. Your rights are as follows:
a) Right of access. You have the right to receive confirmation from us that we process your personal data, including the right to access your personal data and to receive an electronic copy. b) Right of erasure (“right to be forgotten”). In certain circumstances, for example, if you have objected to the processing and we do not have a compelling legitimate interest, you may request the erasure of your personal data. However, this does not apply if we have a legal obligation to process personal data or other legitimate purposes. c) Right to rectification. You have the right to request that incorrect or inadequate personal data about You be updated or corrected. d) Right to withdraw consent. To the extent that 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 Volti relies on its legitimate interest as a legal basis for processing, or if the processing refers to direct marketing communications, you have the right to object to the processing. In such a case, we may have the right to continue processing your personal data if we can demonstrate a compelling legitimate interest to continue the processing operation. f) Right to restriction of processing: In certain circumstances, you have the right to request that the processing of your personal data be restricted, so that personal data may only be stored by Volti and not processed for any other purpose. g) Right to data portability. If the processing is based on your consent and the personal data has been obtained directly from You, you have the right to request data portability, in which case you will have the right to receive your personal data in a commonly used, machine-readable format. Please contact Us using the contact details provided below:
Email [email protected]
Right to lodge a complaint
If you have any complaint regarding our processing of your personal data, you have the right to lodge a complaint with the relevant data protection authority in your country.
Security
The technology used by Volti, together with this Privacy Policy, is intended to protect your personal data against unauthorized access and use. We may update these actions as new technology becomes available.
Changes to the Privacy Policy
Volti may modify this Privacy Policy by posting a new version of it on the Website and in the Volti App. However, in case a modification is due to a change in our processing operations, we will notify you by sending an email with information about the change.