Privacy Policy

Introduction

Welcome to the Pure E-Mobility GmbH Privacy Policy.

This Privacy Policy explains how Pure E-Mobility GmbH (referred to in this policy as “Pure Scooters”, “we” or “us”) will use your personal data through the course of providing our services and products to you and it informs you about your privacy rights and how the law protects you.

Your privacy is very important to us and we take responsibility for the personal data that we collect and hold about you. We'll protect your personal data and only use it for the purpose that we collected it for. We are committed to protecting your personal data and we will always treat your personal data in an appropriate manner and in accordance with relevant data protection laws.

The purpose of this Privacy Policy is to help you understand how we collect, use and protect your personal data so that you can decide if you feel comfortable with us processing it. Our Privacy Policy is provided in a layered format so you can click through to the specific areas, which are as follows:

  1. Important information and who we are
  2. What personal data we collect
  3. How we collect your personal data
  4. Use of your personal data
  5. Marketing
  6. Disclosures of personal data
  7. Transfer outside of the EEA
  8. Data Security
  9. Retention
  10. Your rights
  11. Cookies
  12. Google Enhanced Conversions

 

  1. Important information and who we are

Contact details of the controller

Pure E-Mobility GmbH is the controller of any personal data that is collected through our website and the provision of our products and services to you. We are responsible for the personal data that we collect about you.

If you have any questions regarding our use of your personal data or relating to this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details below:

By emailing: helpBE@purescooters.com

By telephone: +32 78 250 572

By post:
Pure E-Mobility GmbH
Paul-Lincke-Ufer 41,
10999 Berlin,
Germany

Lodging a complaint

If you have a complaint about the way we have used your personal data, you have the right to make a complaint to the Autorité de la protection des données - Gegevensbeschermingsautoriteit (APD-GBA), the Belgian regulator for data protection issues (https://www.autoriteprotectiondonnees.be/ - https://www.gegevensbeschermingsautoriteit.be/ ). We would however, appreciate the chance to deal with your concerns before you approach the (APD-GBA) so please contact us in the first instance using the contact details above.

 

Changes to our Privacy Policy

We will keep this Privacy Policy updated and keep you informed of any material changes to the way we process your personal data. We may update this Privacy Policy from time to time in order to reflect changes to our practices, or other operational, legal or regulatory means.

If changes are made to our Privacy Policy, we will update this page with the date that the Privacy Policy was implemented, so that you are aware of the information we collect and how it is used. Any revised Privacy Policy will take effect immediately and apply only to data collected after the new Privacy Policy comes into place. We encourage you to check this page before making a purchase to review any changes that might have been made.

This Privacy Policy was last updated on 1 October 2019 and historic versions can be obtained by contacting us using the contact details above.

Keeping us updated about you

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third party links

Our website may include links to third-party websites, plug-ins and other applications. Remember that when you leave our website, or are redirected to a third-parties website, we are not responsible for the privacy practices of these third-party websites or for how they collect, use or share your personal data. We encourage you to read the privacy policies of any third-party websites you visit.

 

  1. What personal data we collect

What is personal information?

Personal data means any information about an individual from which that person can be identified. This could include information such as your name, address, telephone number and card payment details. It does not include data where the identity has been removed (anonymous data).

We collect, use, store and transfer the following personal data about you:

- Identity Data includes your first name and last name.

- Contact Data includes your delivery address, billing address, email address and telephone numbers.

- Financial Data includes partial payment card details only.

- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from or through us.

- Technical Data includes internet protocol (IP) address (a public number unique to your device), your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.

- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and any survey responses.

- Usage Data includes information about how you use our website, our products and our services.

- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Privacy Policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you include any Special Categories of Personal Data when you use our website, or make contact with us through any means, it is your responsibility to make sure you are happy for us to use that personal data in accordance with this Privacy Policy. You should be aware that this personal data is more sensitive and is more heavily protected by data protection legislation, so you should avoid including this kind of data if possible.

Our website is not intended for individuals under 16 years old and we do not knowingly collect data relating to children.

 

  1. How we collect your personal data

We collect your personal data at different stages of your journey with us and what we do with it depends on the information collected. We collect information about you through the following:

Direct interactions – We will collect personal data directly from you when you give us your Identity, Contact, Financial, Transaction, Profile and Marketing Communications Data. This includes personal data provided when you:

- create an account on our website;

- submit information through the website;

- use the live chat function of our website;

- purchase a product or service from us;

- return a product or request a refund;

- attend events organised by us or on our behalf;

- request marketing or updates to be sent to you through subscription to our service;

- enter a competition, promotion or survey;

- give us feedback or make a complaint; or

- make contact with us by any other means including telephone, email and post in order to submit a query to us of any nature.

 

Automated technologies or interactions - As you interact with our website, we will automatically collect Usage Data about how you use our website and Technical Data about your devices, equipment, browsing actions and patterns when you visit our website. We use the following technologies to help us collect this personal data:

Technology

What are they and what do they do?

Cookies

These are data files downloaded onto your device (eg. Computer) when you access a website. It allows the website to recognise the device and store some information about your preferences and past actions. For more information on cookies, please see our cookies notice.

Log Files

These track actions occurring on the site and collects data such as your IP address, browser type, Internet Service Provider, referring/exit pages, and date/time stamps.

Web Beacons

Electronic files used to record information about how you browse the site

Tags

Pixels

 

Third parties – Some of the information we collect about you comes from third party sources such as:

- Analytics service providers – We will collect personal data about you through Google Analytics, which analyses Technical and Usage Data from your use of our website.

- Other sellers - We may also collect personal data about you from when you purchase one of our products or service through a third-party website. Please note that we will only collect and hold the personal data necessary to fulfil your order when you use a third-party website to purchase our products or services.

 

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with products or services). In this case, we may have to cancel your order or service you have requested but we will notify you if this is the case at the time.

 

  1. Use of your personal data

We collect your personal data at different stages of your journey with us and what we do with it depends on the information collected.

Lawful basis

Under data protection laws we are only permitted to use your personal data if we have a lawful basis for doing so as set out in the data protection laws. We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

- where we need to perform a contract with you;

- where we need to comply with a legal or regulatory obligation;

- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests; or

- with your consent (for example, in relation to sending marketing communications to you via email), which you have the right to withdraw at any time by contacting us using the contact details above.

-

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the lawful bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

Create an account – When you create an account via our website, we will use your personal data to register your account with us.

(a) Identity;

(b) Contact;

(c) Profile; and

(d) Marketing and Communications.

Performance of a contract with you.

Managing your account – We use your personal data to administer your account and to manage our relationship with you, including receiving and responding to your queries or requests via email, telephone, post or live chat.

(a) Identity;

(b) Contact;

(c) Profile;

(d) Marketing and Communications.

(a) Performance of a contract with you;

(b) Necessary for our legitimate interests (to keep our records updated and to develop our relationship with you in order to progress our business).

Purchases – We use your personal data when you purchase a product or service from us in order to manage payments, charges and fees and to recover money owed to us.

(a) Identity;

(b) Contact;

(c) Financial; and

(d) Transaction.

(a) Performance of a contract with you;

(b) Necessary to comply with a legal obligation; and

(c) Necessary for our legitimate interests (to recover debts due to us).

Delivering products– We use your personal data in order to process your order and facilitate delivery of the products or services you have ordered from us.

(a) Identity; and

(b) Contact.

(a) Performance of a contract with you;

(b) Necessary to comply with a legal obligation; and

(c) Necessary for our legitimate interests (to keep our records updated and to develop our relationship with you in order to progress our business).

Refunds/Returns/Recalls – We use your personal data when you choose to return a product or service to us and in order to manage the refund payments, including where we need to carry out a product recall.

(a) Identity;

(b) Contact;

(c) Financial; and

(d) Transaction.

(a) Performance of a contract with you;

(b) Necessary to comply with a legal obligation; and

(c) Necessary for our legitimate interests (to keep our records updated and to develop our relationship with you in order to progress our business).

Prize draws, competitions and events – We may use your personal data to invite you to partake in a prize draw, competition or to attend an event hosted by us or on our behalf.

(a) Identity;

(b) Contact;

(c) Profile;

(d) Usage; and

(d) Marketing and Communications.

(a) Consent; and

(b) Necessary for our legitimate interests (to engage with you and to study how customers use our products/services, to develop them and grow our business).

Feedback - We will use your personal data to send you surveys and feedback forms in order to obtain feedback regarding our products and services;

(a) Identity;

(b) Contact;

(c) Profile;

(d) Usage; and

(e) Marketing and Communications.

Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business).

Research and Analysis – We will use your personal data to assess and analyse the effectiveness and performance of our products and services in order to improve and develop our business.

(a) Identity;

(b) Contact;

(c) Financial;

(d) Transaction;

(e) Profile;

(f) Technical; and

(g) Usage.

Necessary for our legitimate interests (to improve our services, to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

 

Administering and protecting our business - (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity;

(b) Contact;

(c) Profile;

(d) Technical; and

(e) Usage.

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and

(b) Necessary to comply with a legal obligation.

Promoting our business – We will use your personal data to make suggestions and recommendations to you about products or services that may be of interest to you.

(a) Identity;

(b) Contact;

(c) Marketing and Communications;

(d) Profile; and

(e) Aggregated Data.

(a) Consent; and

(b) Necessary for our legitimate interests (to develop and grow our business understanding of customers and to inform our marketing strategy).

 

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to obtain an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us using the contact details above.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Marketing

We will give you a choice regarding certain uses of your personal data, particularly in relation to receiving marketing materials. We allow you to positively opt-in to receiving marketing materials to keep you up to date with our latest offers. When you visit our website, or make a purchase, there is an option for you to positively opt-in.

When you opt-in to receiving marketing materials from us, we will use your Identity, Contact, Technical, Usage, Profile and Aggregated Data to provide you with details of products, services and offers that may be relevant for you.

You can choose to opt-out of direct marketing through your account settings, by clicking the ‘unsubscribe’ link from any email or contacting us using the contact details provided below. Please note that where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product or service purchase, warranties, registration or other communications that we need to send to you in relation to a service or product you have purchased from us.

When you see our adverts on other websites

We engage in online advertising to make it easy for you to find our site and keep you up to date with what we’re up to. You can opt-out of targeted advertising using the links below;

Facebook - https://www.facebook.com/settings/?tab=ads

Google - https://www.google.com/settings/ads/anonymous

Bing - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

  1. Disclosures of personal data

We will treat your personal data as confidential and will keep any personal data about you in accordance with the data protection laws. We do not, and will not, sell any of your personal data to any third parties. We may however, need to share your information with third parties who provide services to us which are necessary to deliver our services or products to you. These third parties include service providers such as IT maintenance, professional advisors, payment facilitators, website hosting, file hosting and system administration services.

The third parties we engage with work as we do and will only collect, use and disclose your personal data to the extent that it is necessary in order to deliver our service or product to you. We require all third parties to respect the security of your personal data and to treat it in accordance with the data protection laws. We do not allow our third party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

Where we use third parties to process your personal data on our behalf, we will always carry out checks to ensure that there are appropriate protections for safeguarding your personal data. We will also monitor the performance of these third parties (and their approved subcontractors) to ensure that your personal data remains secure.

We have outlined the key service providers (but not all of the service providers) we use to deliver our services and products to you below. We recommend that you read their Privacy Policies to help you understand how they process your personal data. These providers often use third party providers themselves; this allows us to work together to give you an exceptional shopping experience.

Key service providers

Hosting our online store

- Shopify - Our store is hosted on Shopify Inc. They provide us with the online e-commerce platform that allows us to sell our products and services to you. We recommend reading Shopify’s Terms of Service (https://www.shopify.com/legal/terms) and its Privacy Statement (https://www.shopify.com/legal/privacy).

Processing payments

- Shopify – Where you choose a direct payment gateway to complete your purchase, then Shopify will store your credit card data and purchase transaction data only for as long as is necessary to complete the purchase transaction (see Terms and Privacy Statement above for further detail);

- Klarna's - Where you choose to use Klarna’s payments options, we pass some of your information onto them so that they can assess whether you qualify for their payment options and tailor the payment options for you. We recommend reading Klarna’s Privacy Policy (https://www.klarna.com/uk/privacy-policy/).

Customer Relationship Management

- Front - We use Front to manage all customer queries that we receive. Your query will be stored on this system for our records in accordance with our retention policy and only for as long as it is necessary. We recommend reading Front’s Privacy Policy (https://frontapp.com/privacy-policy).

Delivery Management

- DPD, Logvad, PVS and BPost - We use these providers to help us get your scooter, and other purchases, to you. We pass on some of your order information so that they can do this. We recommend reading their relevant Privacy Policy’s (https://www.tnt.com/express/en_gb/site/privacy-policy.html) (https://www.whistl.co.uk/privacy).

 

Phone System Management

- Ring Central - Our phone system is run using Ring Central. We record all inbound and some outbound calls, the system will automatically notify you when your call is/is not being recorded. Recordings are kept by Ring Central for 90 days before being transferred to our server. We recommend reading Ring Centrals Privacy Policy for more information (https://www.ringcentral.co.uk/legal/privacy-notice.html).

 

We will not usually disclose your personal data other than as set out above. However, there may be circumstances where we need to share personal data other than as anticipated above. These include:

- Where we are legally required to disclose the information, for example because a court orders us to do so;

- Where the disclosure of the personal data is required for the purposes of the prevention and detection of crime. This includes sharing the personal data with tax authorities and law enforcement agencies;

- Where we need to disclose the personal data for the purpose of or in connection with any legal proceedings, or for the purpose of obtaining legal advice, or the disclosure is otherwise necessary for the purposes of establishing, exercising or defending legal rights;

- Where disclosure is necessary to protect your vital interests (for example if you are unwell at one of our stores, we may need to seek medical assistance); and

- Where we may share your personal data with third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets if we reorganise our business. Alternatively, we may seek to acquire other businesses or merge with them.

 

  1. Transfer outside of the EEA

We may need to transfer your personal data outside of the European Economic Area (EEA) in order to provide you with the services and products you require.

In the event that personal data is transferred to countries outside of the EEA, those countries may not offer an equivalent level of protection for personal data to the laws in the UK. If we disclose your personal data to a third party which is outside the EEA, we will not do so until we have taken steps to ensure that appropriate safeguards are put in place and your personal data is afforded similar levels of protection as that required from us by data protection laws in the UK.

Where we transfer your personal data out of the EEA, we will ensure that a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.

- We will use specific contracts approved by the European Commission which give personal data the same protection it has in Europe; or

- Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal information shared between the Europe and the US.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data Security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.

Generally we will keep your personal data for as long as you have an account with us and for a period of 5 years following closure of your account or from the date of your last order where you do not hold an account with us. However, where we have a statutory obligation to keep the personal data for a longer period or where we may need to keep your personal data for a longer period in case of a legal claim or dealing with ongoing queries or complaints, then the retention period may be longer.

  1. Your rights

You have a number of rights in relation to your personal data. You have the right within certain legal parameters, to:

- Be informed about how we use your personal data (which we do in this Privacy Policy);

- Obtain access to your personal data that we hold;

- Request that your personal data is corrected if you believe it is incorrect, incomplete or inaccurate;

- Ask us to erase your personal data in certain circumstances;

- Ask us to restrict our information processing activities in certain circumstances;

- Ask us to transfer or port elements of your personal data to you or another service provider in a commonly used electronic format;

- Object to our processing of your personal data;

- Not be subject to automated decisions about you and to request human intervention; and

- Withdraw consent where we are relying on consent to process your personal data (for example, in relation to our marketing materials).

If you would like to exercise any of the rights set out above, please contact us using the contact details above.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

  1. Cookies

We use cookies on our website. You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly

For more information about the cookies we use, please see our Cookies notice.

  1. Google Enhanced Conversions

We use this technology on our website to send hashed first party personal data to Google, this helps support our ad measurement. To find out more about Enhanced Conversions, click here.