MONIMOTO, UAB
PERSONAL DATA PROTECTION POLICY

Date last updated: October 13, 2022

Monimoto, UAB (or ‘Company’ or ‘we’) protects your information and your privacy. We follow the requirements of the so-called European Union General Data Protection Regulation (GDPR) and other applicable laws while collecting, using and storing information about you.

Privacy policy

  • 1. Why should I read this policy?

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    This policy will answer the most important questions you may have on how we collect, use and store information about you. This is important to you – please read this policy carefully. This policy may be amended from time to time. Please visit the Company’s website www.cyclooptracker.com, where you will find the latest version of this policy.

  • 2. Who is responsible for protecting my information?

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    Monimoto, UAB
    Registration number: 304932414
    Address is: Sauletekio al. 15-1, LT-10224, Vilnius, Lithuania
    E-mail address: support@cyclooptracker.com

  • 3. How do we collect your data?

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    Depending on the nature of our cooperation, we process the following personal data:

    • Received directly from the data subject (you), for example when you make a purchase, send us inquiries, share your experience, or send us your CV to apply for a vacancy.
    • Generated when you use our services, for example when you visit our website.
  • 4. For what purpose and what personal data do we process?

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    4.1. To process your orders, receive payments and deliver purchased goods

    • When is this relevant for me?

    When you purchase our products or order a SIM card subscription

    • What information do you collect about me?

    Full name, address, phone number, country, postcode, company name (when applicable), VAT number, expiration date, security code, credit card type

    • Legal basis for processing

    Contract
    (Art. 6 (1) (b) of GDPR).

    • Data retention period

    10 years

      4.2. To provide you with GPS tracking service

      • When is this relevant for me?

      When you use our GPS tracking device via mobile app or web console

      • What information do you collect about me?

      User phone number, motorcycle photo and number plate (when applicable), tracking device’s coordinates received from Global Navigation Satellite System (GNSS) or wi-fi positioning system (WPS) providers or from mobile network Cells (Cell ID), date and time, movement speed, temperature, device SIM card, device SIM card number, subscription start/end date

      • Legal basis for processing

      Contract (Art. 6 (1) (b) of GDPR).

      • Data retention period

      Until the user deletes his /her account or 6 months whichever is shorter.

      4.3. To ensure our website/app security

      • When is this relevant for me?

      When you use our website/app

      • What information do you collect about me?

      IP address, user display information (color depth, aspect ratio, resolution, primary and secondary screens), browser information (browser time zone, browser storage capabilities (local storage support, etc.), browser canvas capabilities, browser fonts, used browser, browser language), user device information (CPU class, OS or platform, touch support), type of information banners shown to user, country, preferred language, outlinks, referrers, page and website speed, accessed content on website and URL’s, time and date the content on website was accessed, manufacturer and device type (only by app), cookie ID)

      • Legal basis for processing

      Legitimate interest (security and website support)(Art. 6 (1) (f) of GDPR)

      • Data retention period

      24 months

      4.4. To provide you with customer support

      • When is this relevant for me?

      When you submit an inquiry to our customer support

      • What information do you collect about me?

      Date and time of the inquiry / message, messages, submitted files, name (if provided), e-mail address, phone number, model of device from which the request is sent, approximate location of the device, user agent (browser), IP address, feedback text

      • Legal basis for processing

      Consent (Art. 6 (1) (a) of GDPR)

      • Data retention period

      36 months

      4.5. To send you marketing e-mails

      • When is this relevant for me?

      When you purchase our products or give your consent to receive e-mails

      • What information do you collect about me?

      Full name, e-mail, order history

      • Legal basis for processing

      Consent, Legitimate interest (direct marketing) (Art. 6 (1)(f) of GDPR) , Customer relationship (Art. 6 (1)(a) of GDPR; (Art. 81(2) of Electronic Communications Law of Lithuania)

      • Data retention period

      36 months if you purchase our products; 10 years after you give your consent, unless you withdraw your consent earlier

      4.6. To manage our social media profiles

      • When is this relevant for me?

      If you interact with our social media profiles (e.g. send a message, follow our profiles, share a post, react to a post)

      • What information do you collect about me?

      Name and surname, message, time, and date the message was received, content of the message, message attachments, response to the message, time of response to the message, information about our rating, comments on a post, post shares, information about post reactions

      • Where do you collect the information from?

      From yourself , LinkedIn Ireland, Facebook Inc, Google Ireland Ltd

      • Legal basis for processing

      Consent (Art. 6 (1) (a) of GDPR)

      • Data retention period

      10 years

      4.7. To carry out the selection of potential employees

      • When is this relevant for me?

      When you apply for a job at Monimoto

      • What information do you collect about me?

      Full name, e-mail, phone number, CV, work experience, other information you provide us with

      • Legal basis for processing

      Consent (Art. 6 (1) (f) of GDPR)

      • Data retention period

      2 years

      4.8. To fulfill statutory accounting requirements

      • When is this relevant for me?

      When you purchase our products or order our services

      • What information do you collect about me?

      Full name, address, VAT identification number (where applicable), value and description of supplied goods and/or services

    • Legal basis for processing

    Legal obligation (Art. 6 (1) (c) of GDPR)

    • Data retention period

    10 years

    4.9. To fulfill other statutory requirements and defend the rights and interests of Monimoto

    • When is this relevant for me?

    In case there is present or potential dispute with Monimoto or we otherwise need to defend, enforce, exercise and uphold our rights or we are statutorily required to provide data

    • What information do you collect about me?

    All the afore-mentioned information, accounting and legal case files, legal documents, other information you provide us with

    • Where do you collect the information from?

    From afore-mentioned sources

    • Legal basis for processing

    Legitimate interest (protection of the rights and interests of Monimoto) (Art. 6 (1) (f) of GDPR).

    • Data retention period

    3 years following the moment we became aware of the afore-mentioned circumstances of termination of legal proceedings, if any

  • 5. Which information I must provide you with and why?

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    You are required to provide the information detailed under Sections 4.1 and 4.2 above as it is necessary to enter into a contract with you. Also, we are statutorily required to process the information detailed under Section 4.8 above. If you do not provide this information, you will not be able to purchase and receive our products, additionally, we may not be able to provide you with our services, handle your queries, requests, or complaints.

  • 6. Who do you share my data with?

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    Monimoto only shares data when necessary and only to those subjects who ensure an adequate level of data protection. Please note that in limited cases of data transfers to countries outside the EEA, we use EU Standard Contractual Clauses for the transfer of personal data as approved by the European Commission (link).

    6.1. Analytics

    Monimoto uses third-party web analytics services on our website, such as Google Analytics. These analytics services may collect information about your activities on our sites to help us analyse how visitors use our website, improve usability and customer experience. Google Analytics or other tools which we use may record clicks, mouse movements and scrolling activity, other activities that you voluntarily complete on our Sites. You can learn more about the data collected by Google’s tools here. Also, you can opt-out of Google Analytics by installing Google’s browser add-on.

    6.2. Email communication

    We use Omnisend and Mailchimp mailing systems for our email marketing. Whenever you subscribe to our newsletter, the information is stored in Omnisend or Mailchimp servers in the United States, so your information may be transferred to, stored, or processed in the United States (see also section 4 of this Privacy Policy).

    With the assistance of the Omnisend and Mailchimp cookies, we can analyse the performance of our newsletter campaigns. Omnisend and Mailchimp will capture data about your interactions with our emails, such as which links you click within an email. It does by automatically placing single-pixel gifs, also known as web beacons, in every email. For more detailed information please read Omnisend (link) and Mailchimp (link) cookie statements.

    6.3. Subcontractors

    Monimoto shares your personal data with other partners when services are provided by partners authorized by Monimoto. For example, before sending your order from Monimoto, we must share your information with our logistics provider to arrange shipment.

    Your personal data may also in some cases be shared with various types of professionals providing services to us, such as electronic communication service providers, email and cloud hosting service providers, customer support service providers, auditors, lawyers, financial consultants, social media service providers, GPS tracking service providers and other.

    6.4. Corporate transactions

    If we are participating in a corporate transaction such an acquisition or a sale or are otherwise involved in any capacity in any such transaction, your personal data may be shared with entities involved in the transaction, including sellers, buyers, or other investors, as well as consultants related to the relevant transactions.

    6.5. For legal reasons

    To defend our rights and interests and/or meet the requirements of the law we may (in cases necessary) share your data with attorney’s, notaries, bailiffs, public authorities, courts, legal officers, government entities, law enforcement agencies etc.

  • 7. What statutory rights do I have regarding my data?

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    In accordance with the provisions of the GDPR, you, as a data subject, can exercise the following rights:

    • The right of access to personal data: request information on whether your personal data is being processed, and if personal data is being processed, you have the right to access your personal data.
    • The right to rectify personal data: submit a request to correct your personal data if you find that the personal data we process is incorrect, incomplete or inaccurate.
      The right to data erasure (the right to be “forgotten”) – request the deletion of your personal data if you believe that your data has been processed illegally or fraudulently.
    • The right to restrict data processing: request to restrict (suspend) the processing of your personal data, except for the storage – in case, for example, you request the rectification of your personal data (while the accuracy of personal data is checked and/or corrected), when the personal data is processed unlawfully and you do not consent to the erasure of the data, you have expressed your consent to the processing of your personal data, etc.
    • The right to data portability: submit a request to transfer your personal data, which is processed by automated means, to you and/or another data controller in a systematic, commonly used, and computer-readable format.
    • The right to object data processing: to object to the processing of personal data where the processing is carried out on a legal basis or on a legal basis in the public interest.
    • The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her
    • The right to withdraw the consent given to us at any time, with regard to the processing of personal data, for example, for direct marketing.

    Regardless of any other legal remedy, you also have the right at any time to submit a complaint to the supervisory authorities.

  • 8. Do you engage in automated individual decision-making, including profiling?

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    No, we do not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you.

  • 9. How can I contact your DPO?

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    If you have any questions, comments, or complaints regarding how we collect, use and store information about you, Monimoto has a Data Protection Officer to help you. If you need his / her help, please send an e-mail to dpo@monimoto.com.

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