Through this Privacy Policy, we would like to inform you about the types of data processed by AZZURO RENT d.o.o. and the purposes of this data processing. We would also like to inform you about important legal aspects of data protection, such as your rights.
I. Data controller
The party responsible for data processing (controller) is AZZURO RENT d.o.o. ul. Zadarska / via Zara 8, 52100 Pula / Croatia (hereinafter referred to as AZZURO BIKES).
II. Categories of personal data
The following categories of personal data may be processed in connection with the services we provide:
Basic data: This includes, for example, first name, surname, residential address (private and/or business);
Contact details: This includes, for example, the person’s telephone number, e-mail address (private and/or business), fax number, if applicable, and the content of the message (e.g. e-mails, letters, faxes);
Contract data: This includes, for example, rental information (category and type of equipment rented, date of collection and return, address where the rental equipment is collected and returned, extras/services ordered), rental contract number, booking number, identity document details, identification details of the rented e-bike and information on loyalty and partner programmes;
Financial data: credit card details and other data necessary for making online payments through the banking system;
Voluntarily provided data: This is data provided to us voluntarily, without our express request, containing information such as preferences regarding equipment and category of equipment rented;
Special categories of data: In the event of an accident, damage to equipped equipment or similar events, we process data on the course of events and the damage suffered. This data may be provided by customers, users or injured persons. Data processed in such circumstances may include health data such as injury data, blood alcohol levels, driving under the influence of intoxicating substances and the like;
Third party data: If you have provided us with personal data of third parties (e.g. family members, other users) as part of your equipment rental, then we also process this data;
Location data: Location data is data that we can process when our equipment is equipped with a telematics device.
III. Legal basis for data processing
Article 6(1)(a) GDPR of the General Data Protection Regulation (GDPR): According to this provision, the processing of data is lawful if consent has been given for its processing and to the extent of the consent given;
Article 6(1)(b) GDPR: According to this provision, the processing of personal data is lawful if such processing is necessary for the performance of a contract to which you are party or in order to take steps requested by you prior to entering into a contract;
Article 6(1)(c) GDPR: According to this provision, processing is lawful if such processing is necessary for the performance of a legal obligation to which AZZURO BIKES is subject;
Article 6(1)(f) GDPR: According to this provision, the processing of personal data is lawful insofar as such processing is necessary for the purposes of the legitimate interests of the controller, i.e. AZZURO BIKES or third parties;
Article 9(2)(f) GDPR: According to this provision, certain special categories of personal data may be processed if such processing is necessary for the establishment, exercise or defence of legal claims. These special categories of personal data include data on the health of data subjects.
IV. Purpose of data processing
1. Booking and rental of electric bicycles
a) Purpose of data processing
We process master data, contact data, contract data, financial data and any voluntarily provided data for the purpose of processing your booking and for the conclusion and performance of the rental contract.
In addition, we use master data, contact data and contract data for the purposes of customer relations, for example to process complaints or booking changes about which you contact us.
If you make a booking through travel agents, online travel agents or other intermediaries, your basic data, contact details, rental information and, where applicable, financial information, will be provided to us by our partners.
We also use the master data and contractual data for billing purposes (e.g. in connection with commissions and sales processing), for example with travel agencies, other intermediaries, and business partners. In order to be able to fulfil your booking request, we pass on your data to business partners if we do not have the desired type of e-bike available at the time.
In addition, we use your data to ensure your security and ours, for example to avoid non-payment and to prevent property crime (in particular fraud, theft and embezzlement).
Once both parties to the contract have fulfilled their obligations under the contract, the master data, financial data and contract data will be stored until the expiry of the statutory retention period or the statute of limitations for our claims.
b) Legal basis for the above processing
Article 6(1)(b) of the GDPR applies to the processing of data to the extent required for the processing of bookings, for the conclusion and performance of contracts and for customer relations purposes;
Article 6(1)(f) of the GDPR applies to the processing of data to the extent that it is required for the execution of settlementś with third parties, for the assertion of own claims and for the minimisation of risks and prevention of fraud;
Article 6(1)(c) of the GDPR applies to the processing of data to the extent required for the detection, prosecution and prevention of crime, for the issuing of an invoice, for the verification and storage of driving licence data, and for compliance with retention periods under commercial and tax law.
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
To the extent that the processing is required to carry out analyses aimed at preventing damage to our company and our e-bikes, our legitimate interest lies in maintaining cost security and preventing economic disadvantages, such as situations arising from non-payment or loss of e-bikes.
d) Categories of recipients
For the purposes described above, in particular for the operation of the booking system used by AZZURO BIKES, we disclose your data to third parties with whom we have a business relationship and who are necessary for the implementation of the provisions of the rental agreement concluded with you. These include IT service providers, debt collection companies, legal, financial and archiving service providers and business partners.
As part of our fraud prevention measures, we also pass on personal data – in situations where third parties have been or are at risk of being defrauded – to such third parties who have been or are at risk of being defrauded.
2. Marketing and direct advertising
a) Purpose of data processing
We may process your master data, contact data and contract data in order to promote customer loyalty, implement loyalty and bonus programmes for customers and business partners, including the optimisation of offers to customers, market or opinion research and organise events for customers.
You may object at any time to the processing or use of your data for direct marketing purposes. Objections should be sent to: AZZURO RENT d.o.o. ul. Zadarska / via Zara 8, 52100 Pula / Croatia or by e-mail to: info@azzurobikes.com
b) Legal basis for processing
Article 6(1)(a) of the GDPR applies to the processing of data for the purposes of direct marketing measures which require express prior consent.
Article 6(1)(f) of the GDPR applies to the processing of data for direct marketing purposes, in forms that do not require express prior consent.
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
Our legitimate interest with regard to the use of your personal data for the application of direct marketing measures and listed marketing measures is that we want to persuade you to use our services and to promote an ongoing relationship with you.
d) Categories of recipients
For the purposes described above, we disclose your data to IT service providers, advertising partners and service providers for customer loyalty and bonus programmes.
3. Contractors and their representatives and designated contact persons
a) Purpose of data processing
If we conclude a cooperation agreement with you, we will process your data for the purpose of proper performance of the concluded agreement, as well as for the protection of claims arising in connection with its performance.
b) Legal basis for the above processing
Article 6(1)(b) and (f) of the GDPR concerns the verification of the above data in public registers, contacting on matters concerning the execution of the Contract;
Article 6(1l)(f) GDPR for the purpose of defending against or pursuing claims on the basis of a legitimate interest pursued by the controller;
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
Our legitimate interest in using your personal data to pursue any claims we may have against you consisting of our desire to prevent damage to our business.
d) Categories of recipients
For the purposes described above (in particular for the operation of the booking system used by AZZURO BIKES), we disclose your data to recipients with whom we have a business relationship for the purpose of fulfilling the terms of the cooperation agreement concluded with you. These include IT service providers, debt collection companies, legal, financial and archiving service providers, credit agencies and other business partners.
V. Damages, accidents, administrative offences
a) Purpose of data processing
If you find damage to our e-bike, if you or another person is responsible for such damage or if you or another person is involved in an accident with one of our vehicles, then we will process your basic data, contact data, contract data, financial data and, where applicable, health data for the following purposes:
- receiving and handling complaints;
- providing customer service in the event of damage;
- loss adjustment;
- handling of compensation arising from accidents (processing based on information provided by you and third parties, such as the police, downstream users, witnesses, etc.);
We also process your master data, contact data and contract data in order to comply with legal obligations (e.g. providing information to investigating authorities).
In the event of suspicion by the competent authorities that you have committed an administrative offence or a criminal offence with one of our e-bikes, we will process not only the master data stored by us and concerning you, but also the data provided to us by the competent authorities.
We also process your master data, contact data, financial data, contract data and, where applicable, health data in order to maintain and pursue any claims that we may have against you, for example claims arising from non-payment or damage caused to our property.
b) Legal basis for processing
Article 6(1)(b) of the GDPR concerns the processing of data for the purpose of handling claims, providing services to customers in the event of damage and handling compensation arising from accidents;
Article 6(1)(b) of the GDPR relates to the processing of data to handle compensation arising from accidents;
Article 6(1)(f) of the GDPR concerns the processing of data for the purposes of settling claims, pursuing claims that may be made against you and handling claims relating to administrative offences;
Article 9(2)(f) of the GDPR concerns the processing of health data for the establishment, exercise or defence of legal claims;
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
Our legitimate interest in using your personal data for the purposes of settling claims and pursuing any claims that you may have against us lies in our desire to prevent damage to our company. We are furthermore obliged, in accordance with our contractual relationships with third parties (e.g. insurance companies), to process your data for the purpose of loss adjustment. Our legitimate interest in this regard is to ensure compliance with the contracts.
d) Categories of recipients
For the purposes described above (in particular for the operation of the booking system used by AZZURO BIKES), we disclose your data to recipients with whom we have a business relationship for the purpose of fulfilling the provisions of the contract concluded with you. These include IT service providers, call centres, debt collection companies, legal, financial and archiving service providers, credit agencies, agency partners and other business partners.
VI. Monitoring of electric bikes
a) Purpose of data processing
AZZURO BIKES electric bicycles may have so-called geolocation functions, which enable us to process location data as well as information on the status of the electric bicycle, such as the speed of the bicycle, the status of the drive unit sensors including the possibility of activating safety systems. This data is processed exclusively for the prevention of property crimes if the e-bike is not returned within the agreed rental period or is used outside the region agreed upon in the contract (as well as near the state border or in prohibited areas) and for the purpose of determining, verifying and investigating resulting damage and accidents.
b) Legal basis for processing
Article 6(1)(f) GDPR.
c) Legitimate interest insofar as Article 6(1)(f) of the GDPR applies to the processing in question
Our legitimate interest in using personal data to prevent property crime and to identify, verify and investigate damage and accidents is to protect our e-bike fleet and our contractual and non-contractual rights.
d) Categories of recipients
We work with geolocation providers to prevent property crime.
VII. Improving our processes and offerings
a) Purpose of data processing
We process your master data, contact data, contract data and any data you provide voluntarily in order to optimise our processes and offers. This includes, for example, collecting and evaluating rental reports, implementing capacity planning for service provision in order to improve e-bike allocation procedures, creating a data warehouse, analysing and removing sources of errors and conducting customer satisfaction surveys. We also process address data from third-party service providers in order to update our address database and to ensure that the master data used to support contracts is correct.
b) Legal basis for the above processing
Article 6(1)(a) of the General Data Protection Regulation (GDPR) applies where consent is required in order to implement measures to optimise processes and offers;
Article 6(1)(f) GDPR;
c) Legitimate interest insofar as Article 6(1)(f) of the GDPR applies to the processing in question
Our legitimate interest in using personal data to improve our services and customer care is that we want to offer the best possible service and significantly increase customer satisfaction.
d) Categories of recipients
For the purposes described above, we disclose your data to the following recipients: IT service providers, call centres, debt collection companies, business partners, agency partners and franchise partners.
VIII. Events organised by AZZURO BIKES
a) Purpose of data processing
We may also process master data and contact details in order to invite you to events taking place as part of our customer service and customer loyalty activities.
b) Legal basis for the above processing
Article 6(1)(b) of the GDPR concerns the processing of data for the purposes of customer acquisition, renewal of contractual relationships and business customer management;
Article 6(1)(c) GDPR applies to the processing of data to the extent required to comply with retention periods under commercial and tax law;
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
Our legitimate interest in using your personal data for customer service, customer loyalty. On the one hand, it is about offering the best service and sustainably improving customer satisfaction, and on the other hand, it is about fulfilling the social obligations to which we, as a large company, are bound.
d) Categories of recipients
For the purposes described above, we disclose our business customer contact data to the following recipients: IT and archiving service providers, call centres, event organisers.
IX. Cookies
a) Purpose of data processing
Our websites use cookies. Cookies are small text files that are copied from a web server to your hard drive. Cookies contain information that can later be read by a web server in the domain within which the cookie was assigned. Cookies cannot run any programmes or infect your computer with viruses. The cookies we use do not contain or are not linked to personal data. Information on cookies and their deactivation can be found in the cookie banner available on the website.
b) Legal basis for the above processing
The legal basis for this processing is found in Article 6(1)(f) of the GDPR, insofar as personal data is processed.
c) Legitimate interest insofar as Article 6(1)(f) GDPR applies to the processing in question
Our legitimate interest in processing your personal data via our website lies in our desire to optimise our online offering, thereby offering our customers the best possible service and increasing customer satisfaction.
X. Transfers of data to third countries
Please be advised that when you use our services to book electric bikes, we do not pass on your data to third countries.
We would like to inform you that we use ICT providers located in the European Economic Area.
XI. Retention period
AZZURO BIKES retains personal data until it is no longer needed in connection with the purposes for which it was collected. We carry out the deletion procedure once a year. Where we are legally obliged to store personal data, we keep your personal data for the retention period specified by law and no longer than the period of limitation according to Croatian law.
XII. Regulatory rights
1. Your rights under Articles 15 – 18 and 20 of the GDPR
You have the right to obtain, at reasonable intervals, information about the personal data stored (Article 15 of the GDPR). The information to which you are entitled includes information about whether our company stores personal data concerning you, the categories of personal data in question and the purposes of the processing. Upon request, AZZURO BIKES will provide you with a copy of the personal data processed. You are also entitled to obtain from AZZURO BIKES the rectification of inaccurate personal data concerning you (Article 16 of the GDPR). You are further entitled to obtain from AZZURO BIKES the erasure of personal data concerning you (Article 17 GDPR).
We are obliged to erase personal data in certain circumstances, including where the personal data is no longer necessary in relation to the purposes for which it was collected or was otherwise processed, where the consent on which the processing is based is withdrawn, and if the personal data has been unlawfully processed.
In certain circumstances, you have the right to request the restriction of the processing of your personal data (Article 18 GDPR). This includes circumstances where you question the accuracy of your personal data, following which we need to verify its accuracy. In such cases, we must refrain from further processing of your personal data, except for storage, until the issue is clarified.
You have the right to receive, in a machine-readable format, the data you have provided to us on the basis of the consent you have given or the contract you have concluded with us, or to have this data sent, also in a machine-readable format, to a third party of your choice (right to data portability, Article 20 GDPR).
2. No contractual or legal obligation to provide data/consequences for not providing data
You are not contractually or legally obliged to provide us with your personal data. However, it should be noted that it is not possible to enter into a rental agreement with us or use any other services we provide if we cannot collect and process your data in accordance with the requirements listed in the above sections.
3. Right to object in accordance with Article 21 GDPR
If the processing of your data by AZZURO BIKES is necessary for the legitimate interests of our company, you have the right to object to the processing of your data at any time for reasons relating to your specific situation. AZZURO BIKES will then terminate the processing, unless we can provide compelling legitimate grounds for such processing that supersede the grounds for termination of processing.
You can restrict the processing of your personal data for direct marketing purposes at any time and without any restrictions.
4. Right to withdraw consent at any time
If the processing of your data at AZZURO BIKES is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of your consent does not affect the lawfulness of the processing between the time you gave your consent and the time you withdrew it.
5. Right of complaint
You have the right to lodge a complaint with the supervisory authority in accordance with Article 77 of the GDPR.
Agencija za zaštitu osobnih podataka
Selska cesta 136
10 000 Zagreb / Croatia
e-mail: azop@azop.hr
Last updated 24.04.2024
