Electra may make amendments to this Policy at any time by posting the Policy on its website at https://www.electra.ky/privacy-policy/. By continuing to use any of our services, you acknowledge to have read and understand the information practices described in this Policy. If you do not want information about you to be used in the manner set forth in this Policy, the services may not be available to you.
If you have any questions about our Policy, please contact Electra at firstname.lastname@example.org.
This Policy is incorporated into and subject to Electra’s Terms and Conditions and Rider Agreement (the Terms).
What personal data we might collect
In using any of the services, we may collect the following types of personal data for different reasons:
Contact information: Information such as your name, email address, phone number and address.
Payment data: Data necessary for us to process payments and other such relevant billing details.
Device information: your phone number, Unique Device Identifier or other device information that uniquely identifies individual smartphones or mobile devices.
Location Information: Electra offers features designed to help you use the Services, such as to locate vehicles available through the network, including, in whole or in part, based on your location. You will be given the opportunity to opt-in to location-based services, normally through an opt-in screen on the Electra Mobility App. If you choose to enable location-based services, we may collect your location based on information provided by you or your mobile device, including, if available, GPS, IP address or cell tower information. If you do not opt-in to location-based services, you may not have access to the features necessary to use the services. Electra may also collect different types of information about your location, including general information (e.g., IP address, postal code).
Social media and promotions: If you provide such information in connection with creating a profile or group (such as in social media), leaving comments, posting content, sending an email or message to another user or participating in any features of the services. In addition, from time to time we may collect other personal information you provide in connection with your participation in promotional offers and other activities on the Services.
Preferences: Information about your preferences as it relates to the services.
Platform information: Your password and other related log-in details for platforms related to Electra.
Automatically Collected Information. We also collect information through automated and technical means as you use the services.
Other information: Personal Information also includes information about an individual’s activities, such as information about ride activity, which includes data such as geographic area (including location), and preferences, when any of this information is linked to a particular individual. For purposes of this Policy, Electra collects personal information which is reasonably necessary to operate our personal mobility transportation services, among other things. Electra does not collect Personal Information related to race, gender, national origin or sexual determination except for survey data you provide to us on a voluntary basis or data we collect as required by applicable law. In the event of such survey, User is under no requirement to provide any of the requested information.
Aggregated data: Aggregated data is information collected that is subsequently combined and used in aggregate, non personally identifiable form. We may use aggregated data for a number of purposes, including analysis of the usage of the Services, and interests and behavior and to develop new and improved products, services, and marketing strategies and research.
How we use your personal data
In general, we use the information we collect to provide our services, process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the services, and for the purpose for which the information was provided. For example, we may, among other purposes, use the information we collect:
- to send you a welcoming email and to contact you about your use of the services, to provide other services, products or information you request and to complete any transactions in connection therewith;
- to enable your use of the services, including to locate vehicles and to determine your service eligibility and credit-worthiness, access your driving safety records, and obtain insurance;
- to respond to your emails, submissions, comments, requests or complaints;
- to enable us to develop, customize and improve the services and marketing;
- to personalize the services and communications to you based on your preferences;
- to provide you with information about other events, promotions, products or services we think will be of interest to you;
- to match personal data collected here with data about you that we collect through other sources;
- for the specific purpose for which the information was provided;
- to conduct an aggregate analysis of the performance of the services;
- for security of the services;
- for legal compliance;
- to protect Electra and others; and
- to enforce our Terms or this Policy.
Personal data we receive from you about others
Electra may offer an invitation service to tell a friend about the Services. If you choose to use our invitation service to tell a friend about the Services, we may ask you for information needed to send the invitation, such as your friend’s email address. We may also offer you the opportunity to invite your friend via third party services such as Facebook or Twitter. We will automatically send your friend a one-time email inviting him or her to try the Service. By providing email addresses of non-Users, you represent that you have the right to do so and that such information may also be provided to the third party service that you have designated to contact the non-User. We store and use this information to send this invitation, to register a friend if your invitation is accepted, and to track the success of our invitation service.
How we might share your personal data
We may share certain information to with companies that provide services to us, including outside contractors or agents who help us manage our information activities (for example, for payment processing, insurance, services to search driving records, data storage, customer service, email delivery, and to assist us in our marketing efforts). We limit the personal information that is provided to these service providers to that which is reasonably necessary to provide us with a specific business service and not for any other purpose.
We may disclose personal data to any of Electra’s affiliate entities, which includes any subsidiaries, parents and any entities owned (in whole or in part) by the shareholders of Electra.
How we keep your personal data safe
We take appropriate technical and organisational measures to keep your personal data confidential and secure, in accordance with our internal policies and procedures regarding storage of, access to and disclosure of personal data. We may keep your personal data in our electronic systems, in the systems of our contractors, or in paper files.
How long we keep your personal data
We delete your personal data once it is no longer reasonably necessary for us to keep it for the services, for the purposes set out above, or, where we have relied on your consent to keep your personal data, once you withdraw your consent for us to do so, and we are not otherwise legally permitted or required to keep the data. Importantly, Electra will keep your personal data as necessary for the purposes of defending or making legal claims until the end of the period during which we may retain the data and otherwise until the settlement of any such claims, as relevant.
Subject to certain conditions under applicable legislation, you have the right to:
- request a copy of the personal data which we hold about you;
- have any inaccurate data we hold about you corrected;
- object or restrict our use of your personal data; or
- submit a complaint if you have concerns about the way in which we are handling your data.
To do any of the above, please contact Electra at email@example.com. To enable us to process your request, we may require that you provide us with proof of your identity, such as by providing us with a copy of a valid form of identification – this is to ensure that we appropriately protect the personal data we hold from unauthorised access requests and comply with our security obligations.
We may charge you a reasonable administrative fee for any unreasonable or excessive requests we may receive, and for any additional copies of the data you may request.
In relation to complaints, we will promptly respond to your requests and complaints. In the event that you are unhappy with our response, you may submit a complaint to the relevant privacy regulator. We can provide you with the details of the relevant regulator upon request.
Last updated 17 April 2021