Privacy Policy

For TUCYCLE your personal data and its protection are important.

TUCYCLE is committed to the use that makes of your personal information (“Personal Data”) and wants to guarantee its privacy. For this reason, below, you will find all the information you need to know about the use we make of it.

When using TUCYCLE we collect the necessary information so that we can provide you the car rental service without a driver in a modality (hereinafter, the “Service”), which we treat, in any case, with the utmost diligence and care.

Purpose and structure of our Privacy Policy

The purpose of our Privacy Policy is to explain in detail the treatment we do of the Personal Data that we obtain.

We want you to know and always have control over your personal data (“Personal Data”). For this, we put at your disposal this Privacy Policy (the “Privacy Policy”), in which you can consult in detail, but in an easy and transparent way, the characteristics of the use we make of your Data in order to provide our Service and for other purposes.

You can access this Privacy Policy at any time, as it is available to you in the “Privacy Policy” section of the TUCYCLE website https://tucycle.com (the “Website”) and the mobile application (the “Application”). On the Website, the “Legal Bases” section is at the bottom, while on the Application it is accessible from the menu you can display by tapping on the circle located at the top left of the screen. When we use the term “Platform”, we mean the Application.

In this way, throughout this document you will be able to consult: (i) who is responsible for the processing of your data; (ii) where we get them from; (iii) what use we make of them and (iv) how long we keep them, etc. You can consult additional information throughout the same document.

Responsible for the treatment of your info

The person responsible for the processing of User’s data is Tucycle Bike Sharing, S.L (TUCYCLE), with CIF number B52553385. TUCYCLE’s contact details are as follows:

• Postal address: C/Guillermo Marconi, 296; Polígono de Roces, 33212, Gijón.
• Email: info@tucycle.com

Where do we get your Personal Data from?

The Personal Data that TUCYCLE obtains can be provided by (i) the User himself when registering in the App and creating an account, (ii) from the App itself once the user has his account activated and uses the Service, and (iii) from third-party collaborating mobility companies.

The Personal Data of the interested party that we obtain will be processed for the purposes indicated in section 4 of this Privacy Policy.

• Personal data we process that comes from the User himself. We receive and store all the information that you provide us through your user account. The categories of data that are processed are the following:
  • Identification data (name, surname, ID or passport);
  • Phone;
  • Email address;
  • Driving license;
  • Economic data (credit card data).
  • “Selfie” photography for identity verification.

• Personal data that we process through the App when the User uses the Service. When TUCYCLE App is in use, and you are using one of our vehicles, we will automatically collect and store certain information about your use of TUCYCLE services, including the location of the vehicle, the location of the device, your IP address, a history of the journeys you make in our vehicles, the identification code that we will assign you internally, dates and times when you access the App or the hardware, software and internet browser you use, data about the operating system, as well as the version of the Application and the language settings.

In no case will TUCYCLE commercialize the collected data with third parties.

• Personal data from the aggregation service. If you are a user of the mobility aggregation service provided by Reby Rides, Sl, at the time you want to drive a TUCYCLE vehicle you will be informed that your data will be shared between Reby and TUCYCLE in order to carry out the trip, by virtue of the relationship that we maintain, being Reby Rides, SL our treatment manager. The sharing of this data is necessary to provide you with our services:

• • Name.
  • Surname.
  • Birth date.
  • Address.
  • Language.
  • E-mail.
  • The validation status of the DNI or Passport and the Driving License.

In the event that the DNI and/or Passport and Driving License documents are duly validated by Reby, they will also be communicated to TUCYCLE.

What do we use your Personal Data for?

In short, we use your data to (i) provide our Service; (ii) only if you wish, to send you TUCYCLE news and promotions based on your profile; to (iii) improve our Service; to (iv) prevent fraud and to (v) consult your opinion about TUCYCLE.

The Personal Data collected by TUCYCLE is used to manage and improve the provision of the Service.

At TUCYCLE we use the personal data that users give us for the following purposes:

• For the provision of the Service: TUCYCLE collects your personal data in order to provide, manage, administer and improve its Service. The provision of the Service includes the following issues:
  • Manage the creation of your user account and allow you to use or modify it. To enjoy the Service, you need to create an account and identify yourself as a user. You can modify the Personal Data that you have provided us at any time through the “My account” section included in the menu.
  • Verification of the identity of the person who created the account. In order to use our service, it will be necessary to provide, at the time of registration, a “Selfie” photograph in order to adequately validate the DNI/Passport and the Driving License and confirm the identity of the user.
  • Allow you to make reservations for vehicles without a driver.
  • Monitor the trips you make. For this, it is necessary that we access your location through the geopositioning systems of your mobile device.
  • Contact you to give you information regarding a trip in progress. These communications may be made by email, telephone or text messages. The form of communication chosen will depend on the reason for the communication.
  • Manage payments for your trips through the payment method that you have preset and selected. This functionality allows you not to have to include a means of payment every time you reserve a vehicle, but it also means that we can know your bank information. However, keep in mind that we will not use the data about your means of payment for any purpose other than the management of your payments or Allow you to consult a history of all the trips you have made. To do this, you simply have to access the “My trips” section included in the drop-down menu.
  • Provide you through the email address that you have provided us with the receipts or invoices corresponding to the trips you have made.
  • Offer you the best service and Through our Help Center we offer you assistance at any time for any doubts, comments, suggestions or incidents related to the Service that you want to raise with us. The aforementioned help can only be provided if we have your Personal Data.
  • Any other question related to the provision of the service.

• To create personal accounts and modify them: As we have already indicated, to use TUCYCLE, you must create an account. This account will allow you to consult your personal data, the promotions received, etc., as well as manage at any time the changes you wish to make regarding said data.
• To carry out Marketing actions: we love that you use our Service and that you enjoy all the news that TUCYCLE has available for you. Therefore, due to the contractual relationship that binds us, we will use your data to send you news and related products. Likewise, we will provide you with the relevant information so that you can enjoy, manage and benefit from the promotional activities that we develop (such as raffles, recommendation programs, contests, promotions …).

In any case, please bear in mind that you can unsubscribe from these communications at any time. In the latter case, you will only have to click on “Unsubscribe”.

• To improve our Service: TUCYCLE works permanently in the improvement of the Application and, for that reason, conducts tests, investigations, analytical studies and product development, which end up resulting in the improvement of the quality of the Service and user experience, but it can also be used to carry out tests. Such works often require the use of certain personal data, which allows us to optimize and customize our Service to suit your needs, making it easier and more functional.
• To prevent fraud: To prevent potential fraud against you and TUCYCLE, we have implemented measures that make our Platform a safe place. For example, we may ask you to validate your account by entering a code that you will receive by SMS and, in some cases, we will ask you to send us a photograph of your ID. Likewise, when we detect the existence of charges or irregular information, we will contact you to make sure everything is correct. In some cases, we will have to disclose information related to your trips to the issuing entities of your means of payment to resolve possible conflicts.
• To ask your opinion: It is very useful to know what your opinion is about TUCYCLE in order to make strategic decisions that make us a company aligned with the interests and concerns of our users. For this reason, in some moments we may ask you to respond to a simple survey to find out what your perception of TUCYCLE is. Keep in mind that we are interested in knowing the opinion of our users in a statistical way. For this reason, when we receive your opinion, we will proceed, in most cases, to anonymize it, that is, they cannot be traced to your user account. It is important to remember that, in this case, since it is anonymous information and has a purely statistical purpose, it is not considered personal and therefore does not fall within the scope of the data protection regulations.

Also, on other occasions, we may treat your responses in a pseudonymized manner, that is, they will only be associated with a code and never with your user account.

• For legal reasons: in certain cases, we may have to use your information in order to comply with legal or administrative requirements.

For how long?

We generally keep your data until you delete your user account or request the cancellation of your Personal Data.

The period of conservation of your Personal Data depends on each of the purposes for which we use them. Next, we indicate how long or until what moment we will keep your data in relation to each of the purposes:

• Provide the Service

We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to process your Personal Data for this purpose. Please note that if there is any pending issue related to the Service, we will try to resolve it before you can unsubscribe.

• Carry out marketing actions

We will use your Personal Data until you ask us to stop, regardless of whether you continue to use our Service or have unsubscribed. Please note that you can ask us to stop sending you personalized news, offers and promotions at any time; You simply have to click on the link “Unsubscribe” contained in any of our communications.

• Improve our service

We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to process your Personal Data for this purpose.

• Prevent fraud

As in the previous case, we will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to process your Personal Data for this purpose.

• Ask your opinion about TUCYCLE

We will use your Personal Data until the entity that helps us carry out the statistical studies sends us the corresponding study.

When the times indicated in the previous table arrive, we will not directly delete your Personal Data; We will keep them duly blocked and protected during the time in which responsibilities derived from the treatment may arise or during the periods required by any applicable regulations.

During that time, your Personal Data will not be processed for any purpose other than meeting such possible responsibilities or complying with said legal obligations. Consequently, only the same members with special capacity of TUCYCLE and the members of the IT department will be able to access these responsibilities or legal obligations. Once these possible actions expire and the aforementioned legal obligations expire, we will proceed to permanently delete your Personal Data without further delay.

Why is it lawful for us to use them?

For many reasons. First of all, because we need to use them to execute the Terms and Conditions that you agree to with us when creating an account; otherwise, we will not be able to provide the Service to you. Second, we send you news and promotions about TUCYCLE or third parties only when you authorize us. Finally, we try to improve our Service, prevent fraud, and conduct market research because we believe that we have a legitimate interest in doing so and that they are also beneficial to you.

At TUCYCLE we only use your Personal Data in a lawful manner, as required by the applicable regulations on the matter. For this, we need to have a sufficient legal basis. Below we indicate what the legal basis is, that is, for what reason it is lawful, that we use your Personal Data for each of the purposes described in the previous section.

Provide the Service

Using your Personal Data is necessary to be able to execute the contract that binds us with you from the moment you accept our Terms and Conditions. Otherwise, you will not be able to enjoy the Service.

Carry out marketing actions

We will use your Personal Data to send you news, offers and promotions based on your profile only if you have given us your consent to do so. The communications that we send you may be made via email, SMS or even through push notifications, as long as you have the Application open. Remember that you can ask us at any time to stop sending you these personalized communications.

Improve our service

We consider that in TUCYCLE we have a legitimate interest to carry out tests, investigations and analytical studies that improve the quality of our Service, allow us to make it more functional and adapt it to your needs. In our opinion, this treatment also benefits you directly, since you will be able to enjoy a Service that more precisely solves your mobility needs.

Prevent fraud

We also understand that we at TUCYCLE have a legitimate interest in trying to prevent potential fraud related to the Service. This treatment is positive for TUCYCLE and also for you, since it will allow us to use procedures that try to avoid fraudulent use of the Service. For example, that a third party tries to use your bank details or charges are made not related to your trips, etc.

Ask your opinion about TUCYCLE

We believe that we have a legitimate interest to know the perception you have about TUCYCLE, since it will allow us to make strategic decisions that are adapted to the needs and concerns of all our users. Furthermore, we understand that the use of your Personal Data for this purpose is compatible with the provision of the Service.

Do we share your Personal Data with third parties?

Guaranteeing the privacy of our Users’ data is essential for us. In no case do we market with your personal data. However, certain personal data that has been provided to TUCYCLE may be transferred to third parties, to enable, facilitate and improve our services.

We do not carry out international data transfers. All the data that we maintain is stored on servers located within the European Economic Area, and that, therefore, guarantee the appropriate levels of protection according to the applicable regulations.

The User’s Personal Data may be transferred to the following recipients:

• Entities of the TuCycle Group or that may become members of the Group in the future (understood as a group of companies in accordance with the provisions of article 42 of the Commercial Code), or any third party that acquires all or a substantial part of the assets of TUCYCLE, mainly for management and administration purposes of the Group.

• Public Administrations, Courts and Tribunals: the personal information provided by the Users will be transferred to the aforementioned organizations provided that there is an applicable legal provision that obliges TUCYCLE to assist these entities, for their own purposes. We will also transfer the data provided by the Users when we consider that such action is reasonably necessary to comply with a judicial process; to answer any claim or legal demand; or to protect the rights of TUCYCLE or its customers and the general public.

• Suppliers that provide services to TUCYCLE: third-party companies that provide administrative, accounting, tax and marketing services and that have the status of data processors. In any case, the third parties with whom certain personal data of the User is shared will have previously accredited the adoption of adequate measures for the correct protection of these. These third party service providers will have access to personal information necessary to perform their functions, but may not use it for other purposes.

• Payment entities: User payments will be managed securely through the entity Stripe Spain, S.L., with address at Calle Zurbarán, 9 -LOC DR, >Madrid, CP 28010, Madrid, and CIF B88501820. In no case will they use the personal data of the Users for their own purposes or for purposes other than the payment management entrusted by TUCYCLE. We have a confidentiality agreement signed with this entity for this purpose.

• Traffic authorities for driver identification purposes in case of violation.

What are your rights?

As a TUCYCLE user, you have a series of rights so that you can decide and control at all times how we use your Personal Data. You can exercise these rights at any time and for free (unless your request is excessive or unfounded – it will be unfounded, for example, if you have just exercised the same right before TUCYCLE very recently; in which case we can reject your request or charge you, always notice, a canon). To exercise one of your rights, you simply have to do it through the Help Center in the Application. In order for us to meet your request, we need to make sure that it is really you, so you must provide us, if we request it, a copy of your identity document; We would also appreciate if you could indicate the right you wish to exercise. If your application does not meet the above requirements, we will ask you to correct it.

In particular, you have the following rights:

• Access. You can ask us to tell you whether or not we are using your Personal Data; If we are using them, we will also transfer additional information such as what personal data we have about you, what we are using them for, the entities with which we share them, the period during which we are going to keep your data or if we are carrying out profiles, among other issues.
• Rectification. You can ask us to modify some of the Personal Data we have about you so that it is accurate and up-to-date. In fact, keep in mind that you must keep the Personal Data that appears in your user account updated at all times. You can do it in the “My account” section accessible from the drop-down menu.
• Deletion. You can ask us to delete the Personal Data we have about you (i) when they are no longer necessary for the purpose for which we use them, (ii) when you withdraw your consent, in the event that we only treat them to develop purposes based on it.
• Limitation. You can ask us to temporarily restrict the use of your Personal Data (i) when you consider that your data is inaccurate, until we verify or update it (keep in mind that, in the meantime, you will not be able to enjoy the Service); (ii) when we no longer need them to carry out the purposes indicated in section 4 above but you prefer that we keep them so that you can exercise or defend yourself against claims and (iii) when you object to our use of your data for any of the purposes included in the second epigraph of section 4 of this Privacy Policy, while we assess whether the legitimate interest we have in TUCYCLE prevails over your right to oppose our use of them. You can request that we deliver directly to you or that we deliver to another entity, whenever technically possible, a structured file, commonly used and readable by a computer system, containing the Personal Data related to the trips you have made with the limit indicated in section 4 of this Policy, as well as any other information related to the provision of the Service.

• Claim. You can file a claim with the competent data protection control authority. In your case, the competent authorities are the following:

Spanish Agency for Data Protection.

• Opposition. You can oppose our use of your data for any of the purposes set out in the second epigraph of section 4 of this Privacy Policy. We especially want to remind you that you can ask us to stop analyzing your profile to send you promotional communications.

Will we modify this Policy?

It’s possible. Keep in mind that, if for any reason we decide to make any changes to our Privacy Policy, we will inform you promptly before the changes become applicable. In this way you will be able to know how we intend to use your Personal Data before we start to do so.