PRIVACY POLICY SEAT MÓTOSHARING
Date updated: 23/11/2023
By means of this Privacy Policy, we inform you about the collection,
processing and use of your personal data through the use of the motosharing
services offered by Connected Mobility Ventures, S.A., owner of the «SEAT
MÓ» brand.
01. Who is responsible for
the processing of your data?
• Identity: CONNECTED
MOBILITY VENTURES, S.A.U. with Tax Identification Code A67140582
• Address: Autovía A-2,
km. 585, Martorell, Barcelona (Spain)
• Mail: gdpr@seatmo.com
02. For what purpose do we process your data?
At SEAT MÓ we process the personal data you provide us with, as well as
all data collected through the purchase procedure, for the following main purposes:
– Create a user account
for you which will allow you to access the mobility services offered by SEAT
MÓ.
– Carry out the
necessary actions to proceed with the effective provision of the contracted
shared mobility services. You will be able to receive communications related to
your journeys and procedures, as well as receive the corresponding invoice.
– Geolocate the vehicle
of the assigned fleet in case it is necessary to ensure and confirm the proper
use of the service. Likewise, given that SEAT MÓ uses connected vehicles for
its services, any data obtained through its sensors will be processed in order
to guarantee the safety of the vehicle, as well as to guarantee the correct use
of the services contracted by users.
– To attend to your
queries and requests, as well as to resolve any possible incidents. In this
case, we may contact you to resolve your query through the same means by which
you have contacted us.
– In the event of damage
or claims on the vehicle, to take the corresponding actions in the event that
it is necessary to contact the insurance company of the vehicle used to manage
a claim or damage arising from your use of the service.
– Where appropriate,
manage the receipt of any fines or sanctions that may have been caused during
the use of the vehicles in the fleet of the service used so that they can be
sent and applied to the user who caused the event constituting the sanction or
fine. To this end, we will contact you to inform you of the penalties imposed
on vehicles owned by SEAT MÓ.
– Anonymise your data so
that they can be analyzed by SEAT MÓ in order to be able to adjust our products
to the needs of users or improve our procedure to improve the user experience.
– To carry out marketing
activities, which involves sending commercial information about the services
offered by SEAT MÓ by printed, electronic and telephone means such as SMS or,
among others.
– Send you notifications
that may be of interest to you for the operation of the application.
03. What categories of data
do we process?
Within the framework of the services offered by SEAT MÓ, we will process
the following categories of data:
• Identifying and
contact data relating to the owner of the service, such as, but not limited to:
name, surname, telephone number, postal address or email address.
• Data derived from the
use of the mobile application and your relationship with us, such as data
related to your driving habits.
• Management and payment
data.
• Likewise, criminal or
misdemeanour data may be processed if, during the use of one of our services,
an event occurs that results in a criminal offence or an administrative
sanction.
• Data related to the
vehicle used associated with a VIN number, or issued by the vehicle’s sensors,
such as the location of the vehicle, during the time of use, as well as its
parking place.
As part of the use of the App, SEAT MÓ uses technologies that are files
that store and retrieve information about the user’s navigation through the
App. In particular, the App uses analytical technologies that may be used by us
and third parties to verify the correct functioning of the App, as well as to
measure, understand and prepare analyses on its use. SEAT MÓ will use this
information to improve the App and the user experience. The app uses the
following types of technologies:
Technology: Mobile Core generic APIs SDK
Purpose: Analytical
Description: The SDK provides central, extension-independent APIs to
facilitate the tracking of user screen events, actions and PII data. Events
generated by these APIs are published in the SDK’s event centre and are
available for use by extensions. For example, when the Analytics extension is
installed, all user actions and application screen event data is sent to the
appropriate Analytics reporting endpoints.
Technology: Adobe Configuration Extensions SDK
Purpose: Analytical
Description: The configuration extension provides different APIs for
configuring SDK configuration settings
Technology: Adobe Identity SDK
Purpose: Analytical
Description: The identity framework allows your application to use
Experience Cloud ID (ECID). Use of ECID improves synchronization with Adobe and
other client identifiers.
Technology: Adobe Lifecycle SDK
Purpose: Analytical
Description: The Lifecycle extension allows you to access information
about application sessions, including device information, application
installation, application updates, session start and pause times, number of
application launches, and additional context data.
Technology: Adobe Signal SDK
Purpose: Analytical
Description:The Lifecycle extension allows you to access information
about application sessions, including device information, application
installation, application updates, session start and pause times, number of
application launches, and additional context data.
Technology: Adobe Profile SDK
Purpose: Analytical
Description: You can use the profile extension to store attributes about
your user on the client. This information can later be used to target and
personalize messages during online or offline scenarios, without having to
connect to a server for optimal performance. The profile extension manages the
client-side operation profile (CSOP) and provides a way to react to APIs,
update user profile attributes, and share user profile attributes with the rest
of the system as a generated event.
Technology: Adobe Target SDK
Purpose: Analytical
Description: You can use the profile extension to store attributes about
your user in the client. This information can later be used to target and
personalize messages during online or offline scenarios, without having to
connect to a server for optimal performance. The Profile extension manages the
client-side operation profile (CSOP) and provides a way to react to APIs,
update user profile attributes, and share user profile attributes with the rest
of the system as a generated event.
Technology: Adobe Analytics SDK
Purpose: Analytical
Description: The Analytics extension represents the Analytics SDK Adobe
Experience Platform that is required to send mobile interaction data from your
application to Adobe Analytics.
Technology: Adobe Assurance SDK
Purpose: Analytical
Description: The Analytics extension represents the Adobe Experience
Platform Analytics SDK that is required to send mobile interaction data from
your application to Adobe Analytics.
You can obtain more information on the technologies and processing
carried out by the third parties identified above in these third-party
policies. Finally, we inform you that you can, at any time, allow, block or
delete these technologies installed on your terminal through the profile
section of the application.
04. What is the legitimacy
for the processing of your data?
With regard to the main purposes indicated, we inform you that, in
general, the legal basis for the processing of your data is the execution of
the service contracted in accordance with the General Terms and Conditions of
the MÓTOSHARING service accepted at the time of registration for the service.
Additionally, other legal bases may apply for the processing of your data as
provided for in the current data protection legislation; such as, for example:
i) legitimate interest,
in order to deal with your requests and incidents, to send you satisfaction
surveys, to geolocate vehicles for security purposes, and to anonymise your
data for statistical and analytical purposes;
ii) and compliance with a
legal obligation, in cases where it is necessary to process and communicate
possible traffic fines and/or accidents to the corresponding Companies or
Authorities;
iii) the public interest
in cases of fraud detection and prevention activities;
iv) and consent, in those
cases in which it specifically applies, for commercial purposes related to SEAT
MÓ services and products or other SEAT Group services and products.
Under no circumstances will automated decisions be taken that produce
legal effects on your person or that significantly affect you.
05. To which recipients will the data be communicated?
SEAT MÓ will only communicate your personal data to third parties in
compliance with the legal and/or administrative obligations that apply in each
case. It may also communicate your data to the corresponding insurance company
in order to be able to manage issues related to insurance due to the use of the
service, to the company managing the collection of the service that will
process your financial data in the event of non-payment or outstanding debts
or, where appropriate, to any body necessary for the recovery of the debt, both
communications being necessary for the development of the service.
It should be noted that, in order to be able to provide you with all our
services, we require the support of service providers. To this end, it will be
necessary for these third parties to access your personal data, always acting
in the name and on behalf of SEAT MÓ, following our instructions. Under no
circumstances will they have access to your personal data for their own
purposes.
06. Are your data transferred
outside the European Economic Area?
In general, your data will be processed within the European Economic
Area. However, some of our suppliers may process your data outside the European
Economic Area, such as, for example, Salesforce.com, Inc. which provides our
virtual infrastructure on a «cloud computing» model. This entity is
domiciled in the United States of America. SEAT MÓ regulates the relationship
with these suppliers in accordance with the applicable regulations in order to
guarantee and maintain an adequate level of protection in accordance with
European standards. Therefore, in the event that the country to which the data
is sent is not considered to have an adequate level, it will regulate the
relationship with the third party recipient by means of the corresponding
Standard Contractual Clauses adapted by the European Commission, the content of
which can be consulted here.
07. How long will we keep your
data?
SEAT MÓ will keep your personal data for as long as they are necessary
for the provision of the contracted services. Specifically, your personal data
will be kept for as long as the contractual relationship as a SEAT MÓ user is
in force and, after its termination, your data will be duly blocked for a
period of ten years.
In relation to personal data whose processing is legitimized by the
consent given, it will be kept until you revoke your consent and, in any case,
until you request its deletion.
In any case, as mentioned above, your personal data will be duly blocked
for the time necessary to comply with the legal obligations that in each case
correspond according to each type of data and purposes of processing and
conservation.
08. What are your rights as a data subject?
As the owner of the personal data, you may exercise the following rights
before SEAT MÓ:
• Access: you may obtain
confirmation as to whether SEAT MÓ processes your personal data, as well as
consult your personal data included in SEAT MÓ’s files.
• Rectification: you may
modify your personal data when they are inaccurate, as well as complete those
that are incomplete.
• Deletion: you may request
the deletion of your personal data when, among other reasons, the data are no
longer necessary for the purposes for which they were collected.
• Opposition: you may
request that your personal data not be processed. SEAT MÓ will cease to process
the data, except for compelling legitimate reasons, or the exercise or defence
of possible claims.
• Limitation of
processing: you may request the limitation of the processing of your data in
the following cases:
• As long as the
accuracy of your data is contested;
• When the processing is
considered unlawful, you may oppose the deletion of your data, and request the
limitation of its use;
• When SEAT MÓ does not
need to process your data, but you need them for the exercise or defense of
claims;
When you have objected to the
processing of your data for the performance of a public interest mission or for
the satisfaction of a legitimate interest, while it is being verified whether
the legitimate grounds for the processing outweigh yours.
• Portability: you may
receive, in electronic format, the personal data you have provided us with and
those that have been obtained from your contractual relationship with SEAT MÓ,
as well as to transmit them to another entity.
09. How can you exercise your rights?
You may exercise these rights by sending an e-mail to gdpr@seatmo.com or
by writing to CONNECTED MOBILITY VENTURES, S.A., SEAT Mó mobility services with
address at Autovía A-2, km. 585 Martorell (Barcelona) clearly indicating the
right you wish to exercise. The exercise of these rights is free of charge
unless the exercise of your rights is excessive or unfounded. If you consider
that SEAT MÓ has not processed your personal data in accordance with the
applicable regulations, you may lodge a complaint with the Spanish Data Protection
Agency via the website www.aepd.es.
10. Contact with the DPO
If you have any questions about data protection or wish to contact our
data protection officer («DPO»), you can contact him/her by sending
an email to dataprotection@seatmo.es.