Privacy policy

We at Segem Micromobility AB respect your privacy and want you to feel safe when you entrust us with your personal data. The purpose of this privacy policy is to provide you with information on how we process and protect your personal data. This privacy policy describes what Personal Data we collect when you make a purchase from our webpage, use our electric scooters or smartphone application and for what purposes your personal data is processed.

In this Privacy Policy, the term "Processing" includes all activities involving your Personal Data including the collection, handling, storage, dissemination, retrieval, use, transfer and deletion or destruction of information.

"Applicable Data Protection Legislation" refers to the GDPR (EU General Data Protection Regulation No. 2016/679).

"Personal data" refers to all information relating to an identified or identifiable natural person ("registered").

1. Who is responsible for collecting and processing your personal data?

Segem Micromobility AB, org.nr 559278-5496 is the legal entity responsible for all collection and processing of your personal data in connection with our products and services, the application My Segem and our webpage www.segem.se and its affiliated sites.

2. Why do we process your personal data?

We process your personal data primarily in order to be able to fulfill our obligations towards you in the best possible way. We strive to not process more personal data than what is necessary for each purpose.

We may process your personal data for the following purposes:

1. a) To communicate with you in a personal way or inform you about our products or services.
2. b) To provide customer service, including service related to the purchase of products, fulfill warranty obligations and to handle any questions or complaints.
3. c) To provide our services and manage your My Segem account.
4. d) To enforce our legal obligations, resolve disputes or enforce our agreements;
5. e) For marketing purposes, including mail, email and sms / mms marketing (which you can choose to unsubscribe from via a link in each mail or email / text message); or
6. f) For other purposes specified at or around the time when the information is collected.

3. What personal data do we process?

We only process personal data when we have a legal basis to do so and only when it is necessary in order for us to fulfill our obligations towards you as a customer and user.

These are the types of personal data that we request, collect or that you provide us with:

Name, contact information and payment information: When you order an electric scooter from us, we ask for your name, email address, home and/or delivery address, phone number and payment information.

Position data: We will collect location data from your scooter and the phone on which you have installed the My Segem app. This data includes the GPS-position of your scooter and your phone, battery level, speed and travel direction as well as other external parameters such as the outside temperature.

Your communication: Information that you provide when you contact our customer service will be collected by us.

Your use of our website: When you visit our website we collect information about how you interact with our website or from the devices or computer you use to access the website in order to be able to improve your experience of visiting the website and to understand how our services are used. This may include click data (such as the type of computer and browser you use, the address of the website from which you are linked to our website), page views and IP addresses.

4. Legal basis for the processing of personal data

According to the EU General Data Protection Regulation 2016/679 ("GDPR"), all processing of personal data must be justified by a legal basis for processing. The processing of personal data can be justified by:

1. ● Consent – you have given us permission to process your personal data. (Article 6(1)(a) GDPR)
2. ● Contractual performance – the processing is necessary to establish a contract with you or to fulfil our contractual obligation (eg process your payments or deliver your order). (Article 6(1)(b) GDPR)
3. ● Compliance with a legal obligation - the processing is necessary for us to be able to comply with a relevant legal obligation. (Article 6(1)(c) GDPR); or
4. ● Legitimate interests - we have a legitimate commercial interest in the processing and this interest is not overridden by your interests and fundamental rights (Article 6(1)(f) GDPR).

5. Your rights

Segem will, at your request or on its own initiative, rectify, disassociate, delete or supplement information that is found to be incorrect, incomplete or misleading.

You are entitled to object to personal data processing performed on the legal basis of a balance of interest. If you object to such processing, we will only continue to process your personal data if there are legitimate reasons for treatment that weigh heavier than your interests.

If you do not want us to process your personal data for marketing purposes, you are always entitled to object to such processing by contacting us, see contact information below. Once we have received your objection, we will cease processing your personal data for such marketing purposes.

You are also entitled to request:

1. a. Access to your personal data: This means that you are entitled to request a registry outline of the personal data being processed about you. You are also entitled to receive a copy of the personal data being processed. You are entitled to once a calendar year, by written application, receive a transcript of what personal data is registered about you, the purpose of the processing and information about who we have disclosed your information to.
2. b. Correction of your personal data: We will correct any incorrect or incomplete information we have stored about you as soon as possible upon your request.
3. c. Deletion of your personal data: This means that you are entitled to request that your personal data be removed if it is no longer necessary for the purpose for which it was collected. However, this right is limited by the fact that there may be legal requirements preventing us from immediately deleting your personal data, for example, accounting and tax laws. In that case, we will stop processing your personal data for any purposes other than complying with applicable legislation.
4. d. Limitation of data processing: This means that your personal data may only be used for specific purposes that you have agreed to. For example, you may request a limitation when you consider your information to be incorrect and you have requested a correction according this Privacy Policy. Meanwhile, the accuracy of the data is investigated, the processing will be limited.
5. e. Data portability: This means that you have the right to, under certain conditions, extract and transfer your personal data in a structured, widely used, and machine-readable format to another data controller.

6. Our security measures

We want your personal data to remain as secure as reasonably possible and have established routines and working methods for your personal data to be handled in a secure manner. Therefore, only employees and persons within the organization who need access to the personal data in order to be able to perform their tasks have access to your personal data. We also make sure that all data that is transferred from the scooters to our servers via the mobile network is encrypted.

Furthermore, we are committed to developing, implementing, maintaining, monitoring and updating our routines for information security, but no such program is perfect. In other words, not all risks can be completely eliminated. You should be aware that data security incidents and crimes can occur due to vulnerability, criminal exploitation or other factors that cannot reasonably be prevented.

7. Transfer of personal data to third parties

We never sell or license your data to third parties.

We only disclose your personal data to third parties when it is necessary to fulfill our obligations to you as a customer. In cases where we disclose personal data to third parties, we ensure that the personal data is processed in a secure manner and in accordance with applicable legislation.

When you make a purchase, we share information with our payment solution provider. The information shared is name, credit card number, address, email address and telephone number. The payment provider (payment solution) that we use is Stripe Inc.

In order to deliver your orders and fulfill our agreement, we must also share relevant information with our logistics partners. The information we share is primarily your name and your delivery address, but your email address and / or mobile number may also be shared with the delivery company for notification purposes. Our primary logistic partner is LO Consulting AB. Sub-contractors may be used for last mile delivery to your local home adress."

These third parties have access only to information that is needed in order for them to carry out their support functions, and they may not use it for other purposes.

If necessary, we may also transfer your personal data to assist law enforcement agencies and the Police in its investigations, but only to the extent we are obligated to do so or have a legitimate interest in assisting the Police in its investigations.

8. Data storage

Your personal data is stored only as long as is necessary in order to fulfil the purposes for which the personal data was collected.

Location data which is generated from the use of the scooter and the My Segem app is stored for 30 days.

The personal data which is processed to enter into, perform or administer an agreement between you and Segem, is processed for as long as you are a customer and have a My Segem account. If your account is terminated, we will delete the personal data from your account, with the exception of personal data which needs to be stored by us due to legal requirements or to safeguard our legal interests.

All personal data that we process is stored on our own servers in a datacenter in Stockholm.

9. Cookies

At www.segem.city and its affiliated sites we use cookies.

We use cookies for statistical purposes and to give you the best possible customer experience. By changing the settings in your browser, you can refuse the website to use cookies. However, such settings may cause some features of the website to not work properly.

10. Policy changes

We reserve the right to make changes to this Privacy Policy from time to time. The current version of the policy is always available on our website and we encourage you to review this policy regularly. This policy was last amended on the 18th of January 2022.

11. Contact information

If you have any questions about our processing of your personal data, what information we have stored or if you would like to exercise any of your rights as stated above please contact: [email protected] or our data protection officer: Simon Krantz, [email protected]

Adress:

Segem Micromobility AB

Luntmakargatan 66

113 51 Stockholm

Sweden

If you have any complain about our processing of your personal data you can always contact the Swedish Authority for Privacy Protection (IMY), which is the supervisory authority.

Phone number: 08-657 61 00

E-mail: [email protected]