Updated version of 4/15/2020
Preserving your privacy is a priority. We describe through this charter how we collect, use and where appropriate, transfer or store personal information about our customers, in connection with the use of the SMART WHEELS application and associated services.
SMART WHEELS BV, located at Penstraat 21-A Curacao, is responsible for the use of personal data collected in the context of the services offered by the “SMART WHEELS’s” application.
What is personal data?
It designates any information enabling a natural person to be identified directly or indirectly. This is personal information (e.g. driver’s license number) that we collect in accordance with the principle of minimization, either when creating the SMART WHEELS user account and using our services, or as part of a vehicle rental.
What do we mean by data processing?
It is an operation or a set of operations carried out using automated or non-automated processes, and applied to personal data. For example the collection, recording, transfer or any form of use or manipulation of information concerning you.
1. What are the standards and fields of application?
This protection charter applies to all processing of personal data implemented under the responsibility of SMART WHEELS. In particular in the context of activities related to the use of SMART WHEELS or the services offered by SMART WHEELS.
This platform was developed taking into account rigorous functional and security requirements in alignment with the obligations of the general data protection regulations of May 25, 2018 and the Data Protection Act of June 6, 1978 in its latest version of June 2018.
2. How do we get your data?
We only collect and use your personal data if you are of legal age and if this information is essential for the proper functioning of the services you have subscribed to. Additional personal information may be provided to us by you or by a clearly identified and authorized partner, in order to improve your experience when using our services.
Data related to rental contracts
The proper functioning of the services relating to the rental of vehicles may lead our partners to send us information related to your reservation. In particular the Reservation number; the Date of the reservation; Rental Dates; the Price of the reservation; as well as the Options and details of the reservation.
Data related to our SMART WHEELS application
The use of the “SMART WHEELS” mobile application allows us to collect your data as soon as the user account is created, as well as information relating to the second driver if necessary.
We collect personal information from the Identity Card and the Driver’s License for the proper performance of the rental contract. This information is verified by our service provider Acuant to guarantee its validity, without ever being stored or transferred to any third party.
Subject to your consent, we can obtain your geolocation data from the “SMART WHEELS” application, which we collect only when recovering a vehicle at the start of the rental for security reasons.
We receive usage data for the SMART WHEELS app from the Apple Store on the iPhone or the Play Store on the Android. These data are necessary to improve your experience.
Data related to the use of the vehicle
When using the vehicle, we collect, via our service provider 2hire, vehicle geolocation information, as well as information on the use of the vehicle (opening doors, starting the engine, etc.) necessary for the proper functioning of our system, the safety of our vehicle fleet and the improvement of the quality of our services.
We may also collect this information, even if you are not registered on the mobile application, as provided for in the privacy policies of our car rental partners with whom you could have reserved your rental.
Data linked to the use of our website
We apply a policy of cookies and similar technologies in order to collect information about your device (computer, tablet, Smartphone, etc.) in order to facilitate the browsing experience and improve the service during your visit to the https website : / /www.SMARTWHEELSCURACAO.com.
We remind you that a cookie is a small data file that is transferred to your device to respond to several uses. For example, to recognize your browser, the language of your system, to keep your preferences … We use so-called “persistent” cookies which remain on your device for 30 days after visiting our website.
3. What do we use your data for?
Your data is used securely and transparently for the production of the services we provide to you. This is valid both for the stages before, during and after the vehicle rental period involving legal administrative procedures necessary for the vehicle rental contract.
We need your data for the following purposes:
- Validate the creation of the SMART WHEELS account on the mobile application which allows you to check the documents necessary for the rental of the vehicle.
- The geolocation of vehicles is necessary to find the rented vehicle via the SMART WHEELS application and guarantee the security of our operations
- Manage incidents during the rental period to improve the services provided to customers.
- Execute the legal, regulatory and administrative provisions in force (if applicable).
- Recognition of your preferred language thanks to cookies called “language cookies” or an analysis of the performance, operation and efficiency of the service by “cookie analytics”.
- Carry out statistics or other research and development analyzes in order to develop new (personalized) services and improve the user experience.
Data is exchanged with partners or service providers
The operations involved in the services provided by the SMART WHEELS platform require links with clearly identified external entities. Rightly we may be required to provide information about you to our suppliers for the performance of our services.
This may include, for example, payment management or background check organizations; Cloud hosts such as Microsoft AZURE and OVH; data analysis providers; entities that help SMART WHEELS improve the security of its applications; partners managing a fleet of vehicles using SMART WHEELS services.
Anonymized data will potentially be shared with insurance and finance partners; vehicle solution providers or third party vehicle suppliers.
4. How is your data secure?
Our platform is entirely housed in the Cloud. Consequently, it benefits from the already proven security measures, implemented by our hosts and cloud service providers, namely OVH and Azure, which are each leader in their field and comply with GDPR obligations.
We organize the security of data processing flows through technical and physical measures in the area of cyber security. Information access control devices, firewalls and data encryption techniques have been implemented.
5. What are your rights?
In the event of a request for access to your information by exercising the “access right”, it is our responsibility to inform you about the purposes of our processing, the different data in our possession, their sources, potential recipients, etc.
The right of rectification allows you to obtain a modification of information concerning you on simple request.
You have the option to request that SMART WHEELS delete all information relating to your person by exercising the “right to erasure” also known as the “right to be forgotten”. In this case we will have to erase your data as soon as possible without failing to inform our partners at the same time about your request so that they too apply it.
Thanks to the “right of opposition” you can object on request until the final cessation of operations that we carry out on your data. We will apply your will without delay, provided that your request does not lead SMART WHEELS to posture in violation of its own obligations with regard to the regulations in force.
The “right to portability” allows you, on simple written request, to receive your data in our possession and in an exploitable format (Example CSV).
If you wish to reduce, for example, the scope of exploitation or certain categories of your data, you can exercise the “right to limit processing”. Once your request is taken into account at SMART WHEELS, we require the alignment of our partners and suppliers with regard to this action.
6. How can you exercise your rights?
You can exercise your rights by contacting us via the contact form available on the application interface, or by writing to the DPO (data protection officer) via the contact form (helpdesk.SMART WHEELS.com).
In order to allow your request to be taken care of, it is imperative that you are connected to the application or to SMART WHEELS online support (helpdesk.SMART WHEELS.com) to validate your identity. In addition, your message must contain the following information: the nature of the request; the scope concerned; the type of data concerned, your telephone number known to us.
Alternatively, the DPO can also be contacted by email at firstname.lastname@example.org . Only complete requests will be taken into account. A complete request must contain the nature of the request, scope concerned; the type of data concerned, an identity document and your telephone number.
You have the possibility to enter the CNIL
Furthermore, without prejudice to any other administrative or jurisdictional remedy, you have the right to lodge a complaint with the National Commission for Information Technology and Liberties (CNIL), if you consider that the processing applied to your data constitutes a violation of the regulations or a deprivation of your rights and freedoms.
7. What are our obligations?
Obligation to inform and educate our partners
We are committed to informing you about all of our activities concerning your data, as well as possible developments that our platform would experience. We do what is necessary to facilitate the exercise of your rights by implementing Accessible and fast communication channels. We respond to your requests within the deadlines in force.
Our compliance ecosystem protects your data
We educate our partners and service providers to take into account regulatory requirements in order to guarantee the overall protection of the personal data entrusted to them. A compliance charter is submitted to subcontractors and contractual clauses integrating data protection are adopted.
SMART WHEELS does not transfer personal data to a third country or to another international organization outside the EU.
Notify in case of data breach
In case of personal data breach, SMART WHEELS undertakes to notify the competent supervisory authority (CNIL) at the latest 72 hours after having read it in accordance with Article 33 of the EU 2016 regulations / 679 . When a personal data breach is likely to create a high risk for the rights and freedoms of a person, SMART WHEELS undertakes to inform the data subject of the said breach as soon as possible and in accordance with Article 34 of EU regulation 2016/679 .
We ask for your consent for specific treatments
Information, for example from geolocation or cookies, is only collected if you have given your consent. You have the possibility to withdraw it freely at any time; but in this case we do not fail to inform you about the risks of deterioration in the quality of the services provided.
For example, you can deactivate the geolocation of the SMART WHEELS Access application on your mobile at any time via the settings on your phone. You will understand that without the geolocation function of the smartphone, we cannot direct you to the location of the vehicle you want to recover.
We give you the opportunity to choose cookies.
As a user of SMART WHEELS services, you are free to authorize or refuse the recording of cookies in your terminal with the appropriate settings in your browser. On this point, SMART WHEELS invites you to consult the advice for using these parameters, depending on the browser used, available on the page of the CNIL website: http://www.cnil.fr/vos-libertes/vos-traces / cookies / .
The configuration of each browser is specific to its design; it is found in the help menu which allows you to know how to modify the choices regarding cookies. The user can manage cookies according to the browsers used:
We have defined the shelf life
Your data is collected to serve only the purposes expressed in the subscribed service contracts. We systematically delete information about you as soon as it is no longer useful, in particular when the user account is closed.
8. Changes to this policy
SMART WHEELS reserves the right to modify and update this policy at any time and without notice, in particular if new functionalities, new services or new partnerships enrich SMART WHEELS’ offers or if we introduce modifications following recommendations carried out by the supervisory authorities.
In this case, the new version will be published on our Website and our application. The changes made are binding on you and you are therefore required to refer to them each time you log in to be aware of the provisions in force which you must comply with. Notification of these changes implies acceptance of the charter, unless otherwise stated by you via our help center / helpdesk.