Urban Connect – Privacy Policy

Last updated at 22nd of March 2024

1. Introduction

Urban Connect (“we”, “us”, or “our”) is committed to protecting and respecting your privacy.

This Privacy Policy describes how we collect, use, and disclose your personal data in connection with our mobility app (the “App”) and any related services (collectively, the “Services”).

By using the App or any of our Services, you agree to the collection and processing of your personal data as described in this Privacy Policy and opt-in to our Services. If you do not agree to this Privacy Policy, please do not use the App or any of our Services.

2. Scope and Applicability

Urban Connect offers its services to the authorised users of our contractual partners (customers). The majority of these are employees (authorised users) of our corporate customers (contractual partners) or residents (authorised users) of property developments (contractual partners).

This Privacy Policy applies to all personal data we collect, process, and store when you use the App or any of our Services, for the use cases in which we are the Data Controller.

For the cases in which we are the Data Processer and the corporate client the Data Controller, a separate Data Processing Agreement may be in place with the client and this Privacy Policy may not apply, or only apply partially. If that is the case, it will be your employer wo should let you know how Urban Connect processes your data for that particular case.

The processing of all personal data for both cases is subject to the provisions of the Swiss Data Privacy Law and other applicable data protection laws.

You must be 18 years old or older to directly use Urban Connect mobile App. By downloading the Urban Connect App, you confirm that you are 18 years or older.

If you have any questions whether this privacy policy applies to you, please reach out to us.

3. Personal Data We Collect

We may collect and process the following personal data from you:

Account and Profile Information:
- When you create an account on the App, we collect your name, email address, password, phone number, and any other information you choose to provide.
- For car driving, we may need your address, driver license, birth date and other points.
- Purpose(s): to identify user, to provide him/her relevant usage information, to verify that he is entitled to the service, to contact him/her (See Section 6), to handle incidences with insurance (see Section 5.6)
Payment Information:
1. To process payments for the Services, we transfer your payment information, such as your credit card number, expiration date, and security code, directly to our Payment Processor.
  - Purpose: to charge you for the services incurred.
2. In relation to our Mobility Budget product, we store and process the use you make with the Mobility Card, including merchants and date of transaction.
  1. Purposes:
    1. generate anonymous statistics of what merchants are used when, so clients (your employer) get an understanding of the use made out of the product.
    2. Provide tax-relevant data and generate anonymous statistics of what merchants are used when, so clients (your employer) get an understanding of the use made out of the product
Location Data: To provide the Services, we may collect and process your device and vehicle location data (e.g., GPS coordinates).
- Purpose: to calculate the mileage of rides and vehicles, to locate lost vehicles.
The vehicle location and trajectory will not be linked to your user id, unless our Customer Support team has reasons to believe that this vehicle has been lost, stolen or damaged. In that case, we may benchmark the last coordinates of the vehicle with the last users, in order to try to find the vehicle.
Usage Data: We may collect information about your usage of the App and our Services, such as the transportation mode you use and your interaction with the App and the vehicle. This can also include driving speed and behavior.
- Purpose:
  - to internally gather insights of user behavior in order to:
    - identify technical issues on our platform.
    - to be able to support you in case of an incident during your booking.
  - to ensure that vehicles are used according to the Terms of Use and the Terms & Conditions
Additionally, some of our shared cars are equipped with recording camera for the outside environment. Our maintenance team disables the recording periodically, but we cannot guarantee that the previous user has not left the recording enabled.
- we ask you to take action as soon as you access the car to adjust it to your prefered settings.
- Urban Connect doesn’t download or process these recordings except in case of accident or infraction, and they are typically deleted after some hours by the OEM automatically.
Device and Technical Data: We may collect information about the device you use to access the App and our Services, such as your device’s unique identifier, operating system, browser type.
- Purpose: We collect these data to correlate issues that users are experiencing with specific application versions or specific mobile devices. We also collect it to give the best answer to user support issues without requesting every time the information.
Employer and Employee Information: If you use our Services as part of an employer-provided mobility budget, we may collect information about your employer and your employment, such as your job title, department, and the amount of your mobility budget.
- Purpose: to link you to the correct mobility budget group and its conditions,to generate user-anonymous usage statistics for our clients (employers).

We have proactively disabled the IP address collection in our crash reporting tools, as we believe we do not need it and we aim to collect the minimum info to give you the best support.

4. How We Use Your Personal Data

We use your personal data for the following purposes:

To provide the Services: we use your personal data to provide and improve the App and our Services, including booking shared e-bikes, e-cars, purchasing public transport tickets, and providing you with a mobility budget.
To communicate with you: We use your personal data to send you important notices, such as updates to our terms, conditions, and policies, or promotions, as well as to respond to your inquiries and provide customer support.
To process payments: We use your payment information to process transactions for the Services.
To personalize your experience: We may use your personal data to tailor the content and information we provide to you, such as recommendations, promotions, and special offers.
To analyze and improve the Services: We may use your personal data to analyze usage patterns and improve the performance, security, and functionality of the App and our Services.
To comply with legal obligations: We may use your personal data to comply with applicable laws, regulations, and legal processes.

5. Disclosure of Your Personal Data

We may share your personal data with third parties in the following circumstances:

Service Providers: We may engage third-party service providers to perform services on our behalf, such as payment processing, customer support, and analytics. These providers will have access to your personal data only to the extent necessary to perform their services.
- Our data processing partners are located in the following countries in Switzerland, EU/EEA, United States and Serbia. For example, we currently collaborate with IT service providers who are headquartered in the United States and who may process Personal Data such as for time billing purposes.
- If and to the extent your Personal Data is transferred to and/or stored at a destination outside of Switzerland/EU/EEA, we will take all steps reasonably necessary to ensure that your data is treated securely. To the extent that these countries are outside the EEA and the EU has not adopted an adequacy decision for these countries, we have made appropriate arrangements to ensure an adequate level of data protection for any data transfers. These include, for example, the EU’s standard contractual clauses. In these cases, however, it is possible and there is a risk that authorities in the respective third country (e.g., intelligence services) may gain access to the transferred data and that the enforcement of your data subject rights cannot be guaranteed.
Business Transfers: If we are involved in a merger, acquisition, or other business transaction, your personal data may be transferred to the new owner or partner as part of the transaction, subject to the terms of this Privacy Policy.
Legal Compliance: We may disclose your personal data if required to do so by law, regulation, or legal process, or if we believe that such disclosure is necessary to protect the rights, property, or safety of Urban Connect, our users, or the public.
With Your Consent: We may share your personal data with other third parties with your explicit consent, which you may revoke at any time.
With your Employer/Organization:We may share personal data with our client (your employer) or the organization whose fleet you use in the event of:
- a violation of the Terms & Conditions of use of the Urban Connect mobility fleet at your employer or organization,
- an incident or accident related to the use of the mobility fleet. Some examples are that you lost your vehicle, you had an accident, you continuously park the vehicle in unauthorized areas etc.
- a validation is needed with your employer/organization. Examples:
  - to define if you have access right to the service (e.g. are you still employed at the employer, or are you still a resident of the real estate complex? )
  - to understand what kind of Mobility Budget or Parking group you should belong to.
- usage of vehicles reported as business / work related use.
Also, our Point of Contact (POC) at your employer (typically an HR, Mobility or Facility Manager, or combinations of them), has the following visibility in the Client Portal:
- Vehicle trips and reservations: e-mail address, time of start and end, location of start and end, car model
  - Purpose: our POC often needs to create reservations for particular users.
- Mobility Budget:
  - if your employer participates in our mobility budget program, the POC can see and define to what mobility budget group your corporate e-mail belongs to, the periodical distributions you receive, your current mobility budget balance, your telephone linked to your UC account, and the language you use.
    - Purpose: POC manage themselves the Mobility Budget product.
  - in case of a suspicious of fraudulent use of the mobility card, we may let your employer know the merchants used by the suspected users.
Insurance companiesThe purpose for these transfers is to handle insurance claims.

Urban Connect is proud to share, that we do not sell data to third parties and that we do not use user data for targeted third-party advertisement.

6. When Do We Contact You?

We may contact you directly to:

support you if we suspect you have a problem with a booking if you exceed the maximum booking time.
update you about relevant application and platform updates that affect the service, such as increase of fleet, price changes, or particular promotions that may have an impact for you.
update you about changes to the Privacy Policy
ask you for your voluntary feedback about the product, service and your behavior. This will be particularly the case for participants of pilots, which will be notified about this in the frame of the pilot.

We will offer you the option to unsubscribe from the communications (opt out).

7. Data Retention

We retain your personal data for as long as necessary to fulfill the purposes for which it was collected, including any legal, accounting, or reporting requirements. When we no longer need your personal data, we will delete or anonymize it in accordance with applicable laws and regulations.
This translates as it follows:
- When your employer / fleet organization stops the service, we aim at erasing the data within the next 6 months, once it is clear that the service will not be re-continued
- When you are inactive for 2 years, your account gets irreversibly anonymized, despite your employer may still have a fleet with Urban Connect.
- When you request to delete your data, we wait until certain business conditions are met (example: ensure that no traffic tickets are received, or that no legal obligations can be broken), to execute your request.

8. Data Security

We implement appropriate technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction. These measures include encryption, secure servers, and access controls. However, no method of transmission or storage is 100% secure, and we cannot guarantee the absolute security of your personal data. For further information, you may consult our data breach policy.

9. Your Rights and Choices

You have certain rights concerning your personal data:

Access: You have the right to request access to your personal data and receive a copy of the data we hold about you.
Rectification: You have the right to request that we correct any inaccuracies or incomplete information in your personal data.
Erasure: You have the right to request the deletion of your personal data, subject to certain conditions. By deleting your account, you choose to opt-out from the Services.
Restriction of Processing: You have the right to request that we restrict the processing of your personal data in certain circumstances.
Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller.
Objection: You have the right to object to the processing of your personal data for direct marketing purposes or when processing is based on our legitimate interests.
Withdraw Consent: If we process your personal data based on your consent, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us using the contact information provided below.

10. Special Mobility Budget Survey Related Guidelines

In case you participate on a mobility budget, we may ask you to paticipate on a survey. The following additional data guidelines apply to the mobility budget surveys:

We will exclusively use the data of the survey to derive consolidated, anonymized reports of how the usage of the mobility budget has changed compared to the previous mobility habits.
We will NOT use the information provided in the survey to check if you use the mobility budget according to the Terms & Conditions, or to monitor any other fraud.

The objective of the survey is to assess the impact of the mobility budget on commuting behaviors. Based on the results, your employer will decide whether to continue and expand the mobility budget or not.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, the App, or our Services. We will notify you of any material changes by posting the updated Privacy Policy on our App or website. We encourage you to periodically review this Privacy Policy to stay informed about our privacy practices.

12. Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:

Urban Connect
Hardstrasse 201
8005 Zürich
Switzerland
Email: privacy@urban-connect.ch

If you believe that we have not adequately addressed your privacy concerns or if you wish to file a complaint, you have the right to contact your local data protection authority.