DriveNow carsharing

Privacy Policy

 

Privacy Notice

 

1. General information

This Privacy Notice contains information required by the EU General Data Protection Regulation (hereinafter the General Data Protection Regulation) and the national data protection law for a data subject, such as for the controller’s customer, employees and for the supervisory authority.

 

2. Controller and its contact information

OP Co-ride Oy

Postal address: PL 308, 00013 OP

Street address: Gebhardinaukio 1 00510 HELSINKI, Finland

The controller’s contact person: Lauri Tolvas

Email address: asiakaspalvelu@drive-now.fi

 

3. Data Protection Officer’s contact information

OP Financial Group’s Data Protection Officer

OP Financial Group

Postal address: P.O. Box 308, 00013 OP

Email: dataprotection@op.fi

 

4. Name of the personal data file and data subjects

OP Co-ride Ltd’s customer data file regarding DriveNow-Service

Data subjects consist of current and potential private and business customers

 

5. Purposes of personal data processing and legal basis for processing
1.1 Purposes of processing

The purposes of personal data use include:

- customer service and customer relationship management and development, including customer communications, customer events and newsletters
- production and delivery of services, and development and quality assurance of services
- business development
- monitoring and analysis of service use and customer segmentation, for example, in order for the controller to be able to offer personalised service content to the users
- opinion polls and market surveys
- organizing competitions and marketing lotteries
- direct marketing
- marketing and targeting of marketing
- fulfilling statutory obligations and any other official rules and regulations
- risk management
- ensuring the security of services and investigating abuses
- training purposes

 

Automated data processing

Processing of personal data within the scope of the data file includes profiling and automated decition-making. Profiling means automated processing of personal data where certain aspects relating to a natural person are evaluated by utilising this data. For example personal data maybe used for the creation of marketing target groups and for marketing products and services or for conducting marketing surveys. This is done using consent or legitimate interests. Personal data is also used for performing profiling to implement targeted marketing based on services data subject has used, and to create more personal and suitable services for customers by making recommendations and showing targeted content in the service.

Automated decision-making is involved when a decision is made automatically only in such a way that a person does not participate in making an individual decision and when such a decision has legal effects on the data subject and considerably affects the data subject in a similar manner. If automated decision-making is included in the product or service purchased by the data subject, this is informed upon purchase of the product or service. When the decision process is fully automated, the controller ensures that the data subject can submit the matter for manual processing and decision.

    1. Legal bases of processing

The table below describes the legal bases of processing personal data used by the data file and provides examples of processing performed on each basis.

Legal basis

Example

Contractual relationship or actions preceding the conclusion of a contract

Personal data is processed in the data file on a contractual basis to provide and delivery DriveNow-Service acquired by the data subject.

Consent

Location data is handled with data subjects consent.

Depending on customer’s phone model application also askes consent for push messages as well as using camera (iOS and Android) and photo files (Android), because the service requires taking photo from driver’s license.

Direct marketing through an electronic channel is based on the consent of the data subject.

Statutory obligation

OP Co-ride may use vehicle’s location data in case of an accident to alert help.

Legitimate interests of the controller or a third party

Direct marketing and business development are based on the legitimate interest. Electric marketing to business customers is based on the legitimate interest.

OP Co-ride may disclose information to the other personal data files of OP Financial Group entities on the basis of legitimate interests.

In most cases, OP Co-ride’s legitimate interests are based on the customer relationship or similar relationship between the OP Co-ride and the data subject. The controller ensures that the processing performed on this basis is proportionate to the data subject’s benefits and meets his/her reasonable expectations.

 

6. Categories of personal data

Category of personal data

Data content of the category

Basic information

Data subject’s first name and surname,

title, birthday, contact information (email, phone number, address, country)

 

Business customers contact person’s name, title and contact information

Customer relationship information

Information that uniquely identifies and classifies the customer, like that the data subject is business customer.

 

Credit card information, driving license information, information which city the customer has selected in the service and the information in the customer agreement between customer and OP Co-ride (classification and responsibility). This information is needed for contractual handling.

Consent

The consents given and withheld by the data subject concerning personal data processing, like for direct marketing.

Contract and product information

OP Co-ride’s/DriveNow’s and data subject’s contract information

Information on products and services acquired by the data subject

Customer activity data

Tasks and transactions related to the management of customer relationship, like for example renting and billing information.

 

Information concerning the vehicle reservation (date, time, address, license plate, duration).

 

Information conserning the usage and reniting of the vehicle (pick-up and return, time and location, mileage and information on addiotional costs and services, and also time driving has took and how long vehicle is parked, and fuel refills and driving style)

Areas of interest

Information on the data subject’s areas of interest, that the data subject has informed to the service

Behavioural information (incl. information collected using cookies and other such technologies)

Tracking of the data subject’s online behaviour and use of services using, for example, cookies. The collected information may include a website browsed by the user, the device model, unique device and/or cookie ID, channel such as an application, mobile browser or Web browser, browser version, IP address, session ID, session time and duration, and the display resolution and operating system.

Recordings and content of messages

Recordings and messages in various formats, in which the data subject is a party, such as call recordings

Location data

Tracking the data subject’s location and information on the subject

Technical verification data

Identifier determined by a device or an application, with which the user of the device or application can be identified, using additional information if necessary

 

7. Recipients and recipient groups of personal data

7.1 Data recipients

Personal data may be disclosed to DriveNow GmbH & Co. KG to enable operations of the Drive Now-Service. DriveNow’s privacy policy can be found at: https://www.drive-now.com/de/en/privacy. DriveNow’s data protection officer’s contact information: privacy@drive-now.com.

Any personal data collected may be used within OP Financial Group as permitted by law. Within investment services, data may be disclosed, for example, to an entity within the Group that manages securities custody.

Personal data may be disclosed to authorities, including the Finnish Tax Administration or the Finnish Financial Supervisory Authority, only within the limits permitted by law. Annual notifications of the controller’s customers are sent to the tax administration.

When disclosing personal data included in the data file, the controller takes into account the requirements of mandatory legislation, including the controller’s confidentiality obligations.

7.2 Transfer of data to suppliers

The controller uses suppliers which process personal data for its account. The controller concludes appropriate agreements on personal data processing with such suppliers.

The suppliers provide the controller with information system services, among other things. Some of the controller’s suppliers are other OP Financial Group entities.

7.3 International transfers of data

The controller uses suppliers in personal data processing, and data will be transferred outside of the EU / EEA to a limited extent. The controller also discloses personal data outside of the EU / EEA.

Data is transferred outside of the EU / EEA using standard contractual clauses based on data protection legislation or using another transfer mechanism permitted by legislation that guarantee appropriate protection of personal data. A transfer mechanism used by the controller is the standard contractual clauses adopted by the EU Commission that can be found at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en

8. Personal data retention period or criteria for determining the period

The controller processes personal data during the validity of the contractual relationship / customer relationship. Once the contractual relationship / customer relationship has terminated, OP Co-ride will erase or anonymise the data after around four years in accordance with the erasure processes it follows.

If OP Co-ride determinates the contract in case of a bankruptcy or security related matter, OP Co-ride will erase or anonymise the data after around five years in accordance with the erasure processes it follows.

The controller processes potential customer personal data for no more than one year calculated from the date when the data subject through his/her active action last showed interest in the products or services of the controller.

After the contractual relationship has terminated, the controller may process the personal data for direct marketing purposes in accordance with applicable legislation.

The controller may be under an obligation to process some personal data in the data file for a period longer than stated above in order to comply with legislation or requirements set by the relevant authorities, such as capital adequacy regulation.

9. Personal data sources and updates

Personal data is collected primarily from the data subjects themselves. Personal data may also be collected when the data subject uses certain controller services , such as online services or mobile application.

Personal data can also be collected and updated within the limits permitted by law from the personal data files of third parties, such as:

- The Population Register Centre
- personal data files maintained by other authorities
- DriveNow GmbH & Co. KG.
- other customer data files of OP Financial Group entities

 

10. Data subject’s rights

Data subjects have the right to receive the controller’s confirmation of whether their personal data will be processed or not, or whether they have already been processed.

If the controller processes a data subject’s personal data, the data subject has the right to receive the information in this document and a copy of the personal data being processed or already processed.

The controller may charge a reasonable administrative fee for additional copies requested by the data subject. If the data subject submits a request electronically and has not requested any other form of delivery, the data will be delivered in a commonly used electronic format, provided that the data can be delivered in a secure manner.

The data subject also has the right to request the controller to rectify or erase their personal data and prohibit the processing of their personal data for direct marketing purposes.

After the application of the General Data Protection Regulation has begun, the data subject will, in certain cases, also have the right to request the controller to restrict the processing of their personal data or to otherwise oppose the processing. In addition, under the General Data Protection Regulation, the data subject may request that the data they have provided themselves be transferred in machine-readable format.

All of the above requests must be submitted to the abovementioned contact person of the controller.

If a data subject considers that his/her personal data is not processed legally, he/she has the right to file a complaint with the supervisory authority.

 

11. Right to cancel prior consent

If the controller processes the data subject’s personal data on the basis of consent, the data subject has the right to cancel such consent. The cancellation of consent does not affect the lawfulness of processing performed based on the consent prior to its cancellation. Such cancellation may, however, have an effect on the usability and functionalities of the service.

 

12. Organisation of protection of data file

The controller processes personal data securely in accordance with applicable laws. It has carefully assessed the risks that may be associated with the processing and taken the necessary measures to manage these risks. These security measures are continually updated in line with technological developments. The transmission of personal data between your computer or mobile device and our server is always encrypted (TLS procedure, Transport Layer Security).

The controller has protected the data appropriately in technical and organisational terms. The data file is protected using, for example, the following tools:

- Protection of equipment and data files
- Access control
- User identity verification
- Access rights
- Registration of usage events
- Processing guidelines and supervision

The controller also requires that its suppliers and other partners ensure appropriate protection of the personal data to be processed.

Service user will be send automated notice by email, if their DriveNow customer account is logged from new device. For this purpose and enhancing security device ID is stored.

 

13. Changes to the privacy notice

This privacy notice may be subject to change over time. We encourage you to regularly review the privacy notice for any changes. However, we will provide you with a corresponding notification in case of significant changes. This may involve e-mail notification if necessary. This privacy notice was last updated on November 19, 2018.

 

14. Other information

Registration process

Our website offers users the option to register by entering personal data. As part of this process, the data is entered into an input screen, transmitted to us, and saved. We do not share data with third parties. The following personal data is collected as part of this registration process: Name, address, date of birth, e-mail address, mobile phone number, payment data as well as a PIN selected by you, answer to security question, and a password. In addition, the following personal data is collected: IP address and Date and time of registration.

Driver’s license verification (DLCS)

You can perform the necessary verification of your driver’s license with DLCS Tool offered on our website for driver license verification. To this end, we use the data you specified as part of your registration as well as a copy of your driver license (front and back) for review by our staff. After the verification, the data that was processed for this purpose will be deleted.

Google Maps application

This website, as well as the DriveNow application, use Google Maps API applications. This enables us to display interactive maps directly on the website or on our app and enables you to conveniently use the map function. This application is essential for the functionality and complete provision of our content and services. You can view Google's Terms of Use here: https://policies.google.com/terms?hl=en. The additional terms of use for Google Maps/Google Earth can be found here https://www.google.com/intl/en-US_US/help/terms_maps.html. You can find Google's privacy policy here: https://policies.google.com/privacy?hl=en. We use Google Maps to determine the current location of our vehicles and to show you the nearest available vehicle. In addition, we use Google Maps to translate geo-positions into addresses and to show you the estimated walking distance to the selected vehicle. After your approval, we will use Google Maps to show your planned arrival location and the remaining arrival time for handover to a subsequent customer on our app. We do not share this information with Google. This data will only be transmitted to Google anonymously. It cannot, therefore, be traced back to you.

 

Cookies 

What are cookies?

Cookies are small text files that are stored on the user’s device. We use cookies to uniquely identify browsers and to verify browsers used by our website visitors. So, by using cookies we will know if the user has visited our website previously using his/her browser. Cookies can also be used for technical reasons to guarantee the website’s functionalities.

We use both session and persistent cookies. Session cookies exist only during a session, or a single visit. They are deleted automatically when the browser is closed.

Permanent cookies also exist only for a specified limited period: they will remain on the visitor’s device for a specified period after the expiry of the session unless the visitor deletes them before that. Cookies do not harm devices or files in any way.

A website visitor can disable the use of cookies for statistical purposes or for targeted advertising. If a visitor wants to disable cookies altogether, he/she can do it in the browser settings. Visitors can also disable cookies from the browser and disable targeted advertising and messages based on historical behavioural data.

What cookies and similar techniques does OP Co-Ride use?

We use different analytics services on our website, for example, to monitor the usage of our website and services, including the number of visitors, and to target advertising to users. By analysing our website usage and by using cookies, we aim to provide more personal services and to maintain and further develop our websites.

The analytics on this website use cookies. Cookies and analytics provide us with information, for example, on which pages visitors go to, what applications they use and how they navigate between pages. In order to develop our website, we collect data on, for example, what kind of website content is most efficient and functional. In order to develop our website, we collect data on, for example, what kind of website content is most efficient and functional. We can link data on the usage of services and websites to a customer.

Through the collected data on website usage, we can create target audiences and improve visitor experience by offering targeted content, such as advertising and messages relevant to website visitors.  We use analytics to create audiences for targeting purposes. These target audiences enable us to target advertising on third-party websites as well. That is why users may see OP advertising on third-party websites too. We may also create target audiences by using visitor data from other websites collected together with our partners. In such a case, we will ensure that our partner has the right to give us the data.

In the following, we describe processing procedures within the framework of using cookies in detail.  

Use of cookies 

Cookies are small text files that are stored on your hard drive by a web server. Cookies contain information that can later be read by a web server in the domain that issued the cookie to you. Cookies cannot run programs or deliver viruses to your computer. There is a distinction made between two different types of cookies. Session cookies are deleted as soon as you end the session. Temporary and permanent cookies are stored on the data carrier for a longer period or indefinitely. 

Data in the context of the use of cookies 

No personal data is stored in the cookies we use. The cookies we use are also not combined with personal data. In this respect, these cookies cannot be attributed to any particular person. When a cookie is activated, it only receives an identification number. Personal data such as name, IP address, etc. are not assigned to this identification number at any time. Using cookie technology, we only receive anonymous information, such as which pages of our website have been visited, etc. 

Use of session cookies 

Most of the cookies we use are so-called session cookies, which are necessary to keep your visit consistent, i.e. to ensure that, for example, no renewed login is required and that your preferences or other information already entered during the reservation request are retained during the session. In addition, we need session cookies to ensure that a specific offer that you have clicked on will be assigned to your request (e.g. for promotional offers). These session cookies are automatically deleted when the session ends. In addition, we use cookies when you visit the website subsequently to detect if you are particularly interested in certain offers, which allows us to display such targeted offers on the site. This assignment is only made using abstract criteria (e.g. "BMW") and not on a personal basis. These cookies have a lifetime of one year and are then automatically deleted. 

Onsite targeting 

Our website uses cookie technology to collect data to simplify our website. This tells us how the website is used and enables us to constantly optimise our offering. The following data is processed: 

- Search terms used  

- Frequency of page views 

- Use of website functions 

This data is used exclusively for anonymous evaluation of the use of the website and is never merged with the personal data stored by us. Using the information obtained through clickstream analysis, we make our website as attractive as possible in order to best meet our customers' needs. 

Re-marketing/re-targeting and web analysis 

We use so-called re-marketing/re-targeting to make online offers more relevant for Internet users and to consistently improve our promotional offers and marketing measures. This technology allows us to reach out to Internet users who have already shown interest in our website with DriveNow advertising via advertising banners or ads on the websites of our partners. To this end, the users’ stored surfing behaviour is analysed with an analytical tool on the basis of an algorithm. The display of our advertising on the websites of our partners relies on cookies and the analysis of usage behaviour on the website. The advertisement displays are completely anonymous. At no time are personal data saved or user profiles combined with personally identifiable data. For this purpose, we use cookies by the following third-party vendors:  

Criteo  

Criteo SA, 32 Rue Blanche, 75009 Paris, France: This product helps us, beyond the scope described above, to post our advertising in apps and e-mails to visitors who are interested in our products. We may share information such as technical identifiers from your registration information on our website or from our CRM system with reliable advertising partners. This allows for linking your devices and/or environments in order to offer you a seamless user experience with the devices and environments you typically use. For further details about these linking capabilities, please refer to the privacy policy of Criteo at: http://www.criteo.com/de/privacy 

Taboola  

Taboola Inc., 28 West 23rd Street 5th floor, New York, NY 10010, USA: This product lets us determine which services you use and which of our pages you visit. This utility supports you with the discovery of content on third-party websites. The cookie enables us to generate pseudonymous user profiles by collecting device-related data and log data. Tracking (i.e. the collection of data associated with website use generated by the cookie) can be deactivated at any time. For this purpose, please follow the instructions in this document: https://www.taboola.com/privacy-policy

Outbrain  

Outbrain UK Limited 39 W 13th Street, New York, NY 10011 USA: This (content discovery recommendation system) supports you with the discovery of content on third-party websites. Outbrain uses cookies that help to collect and save information about you and other users of the service. Data is collected and saved in anonymous form. Outbrain as the controller has compiled information on the collection and processing of usage and other data in its privacy statement: http://www.outbrain.de/legal/privacy-713/. Tracking (i.e. the collection of data associated with website use generated by the cookie) can be deactivated at any time. For this purpose, please follow the instructions in this document: http://www.outbrain.de/legal/privacy-713. 

Google Re-marketing 

Our website uses the re-marketing function of Google AdWords, a service provided by Google Inc.,1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. This technology enables us to place automatically generated, target-group-specific advertisements on our website after your visit. The ads are based on the products and services that you clicked on during your last visit to our website.  

Google uses cookies to generate interest-based advertisements. Google generally saves information such as your web request, IP address, browser type, browser language, and the date and time of your request. This information is used only for allocating the web browser to a specific computer. It cannot be used to identify a person.  

If you don’t wish to receive user-based advertising from Google, you can opt out of advertisements in the Google display settings. 

Further information about Google’s use of cookies can be found in the Google privacy statement at the following link: https://www.google.de/intl/de/policies/privacy/

Google AdWords & conversion tracking 

We place Google AdWords advertisements to draw attention to our products. In the scope of this activity, we use Google conversion tracking, a service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. These advertisements are displayed when users enter search queries on the websites of the Google advertising network. We have the option to combine our advertisements with certain search terms. We use cookies to place advertisements based on the prior visits of a user on our website.  

When a user clicks on an advertisement, Google saves a cookie in the user’s computer. Further information on the associated cookie technology can also be found in Google’s information on website statistics and privacy regulations. 

With the help of this technology, Google and we as a customer are notified when a user clicks on an advertisement and is redirected to our webpages. The information obtained in this context is exclusively used for the statistical analysis of advertising optimisation. We do not receive any information that personally identifies visitors. The statistics provided to us by Google include the total number of users who clicked on one of our ads and, if applicable, whether they were redirected to a page of our website that includes a conversion tag. These statistics enable us to understand which search terms led to the most frequent clicks on our ads and which advertisements resulted in a user filling out the contact form. 

You can take steps to prevent the storage of the cookies required for these technologies, for example in your browser settings. In this case, your visit will not be reflected in user statistics. 

You also have the option to select the types of Google ads in the display setting or to deactivate interest-based ads in the Google website. As an alternative, you can opt out of the use of cookies by third parties by visiting the Opt-Out help site of the Network Advertising Initiative. For more details, visit: http://www.networkadvertising.org/choices/ and http://www.youronlinechoices.com/ 

However, our company and Google will continue to receive statistical information about the number of users who visited this website and when. If you do not wish to be included in these statistics, you can prevent inclusion with the help of additional browser programs (e.g. the Ghostery add-on). 

Bing Ads 

This website uses Bing Ads, a program by Microsoft Corporation, Microsoft Way Redmond, WA 98052-7329, USA, which uses so-called universal event tracking (UET) for re-marketing and conversion tracking. This service saves a cookie in the website visitor’s computer if our website was found through the Bing or Yahoo search engines. Data is collected and saved in anonymous form. Based on the use of the re-marketing function, custom-tailored offers will be displayed to the user during subsequent searches in one of the above-listed search engines. You can access the Microsoft privacy statement on the handling of collected data at the following link: https://privacy.microsoft.com/de-de/privacystatement/. You can opt out of Bing Ads at any time. The corresponding instructions can be found here: http://choice.microsoft.com/de-DE/opt-out

Google Analytics  

This website uses Google Analytics, a web analysis service provided by Google Inc. ("Google"). Google Analytics uses "cookies", text files that are stored on your computer and which enable analysis of your use of the website. The information on your use of this website generated by the cookie (including your IP address) will be transferred to and stored on a Google server in the USA. However, if IP anonymisation is enabled on this website, your IP address will first be abbreviated by Google within the member states of the European Union or other parties to the agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the US and shortened there. 

Google will use this information for the purpose of evaluating your use of the website, compiling reports about website activities for website operators and to provide other services related to website and internet use, in particular functions for Google Analytics reports on performance according to demographic characteristics and interests. Google Analytics Demographics and Interest Reporting allows us to use data from Google's interest-based advertising and/or data from third parties about our advertising audience (e.g. age, gender and interests) in conjunction with Google Analytics for targeted and optimised advertising activities, strategies and content of our website. 

Google may also transfer this information to third parties as required by law or if said third parties process this data on behalf of Google. In any event, Google will not associate your IP address with other data held by Google. 

You can prevent these cookies being stored by selecting the appropriate settings in your browser; however, we wish to point out that doing so may mean you will not be able to enjoy the full functionality of this website. You can also prevent the data generated by cookies about your use of the website (incl. your IP address) being passed to Google and the processing of this data by Google, by downloading and installing the browser plugin available under the following link: https://tools.google.com/dlpage/gaoptout?hl=en

This website uses Google Analytics with the extension "anonymizeIp()". As a result, IP addresses are further processed in abbreviated form, so that a connection to a particular individual can be ruled out. If the data collected about you is personal in nature, it will be excluded immediately, and the personal data will be deleted immediately. 

We use Google Analytics to analyse and regularly improve the use of our website. We can improve our offering and make it more interesting for you as a user with the statistics gained. For the exceptional cases in which personal data is transferred to the USA, Google has submitted itself to the EU-US Privacy Shield, https://www.privacyshield.gov/EU-US-Framework.  

  Third party information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001. Usage conditions: https://www.google.com/analytics/terms/gb.html, Overview of data protection: https://support.google.com/analytics/answer/6004245?hl=en, as well as the privacy policy: https://policies.google.com/privacy?hl=en

  This website also uses Google Analytics for a device-independent analysis of visitor flows, which is carried out via a user ID. You can disable cross-device analysis of your usage in your Google Account under "My information", "Personal information" 

Google Tag Manager 

This website uses Google Tag Manager, which is operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Google Tag Manager is used to manage website tags. Google Tag Manager is a cookie-free domain; it does not collect personal data. However, the application initiates other tags, which may collect personal data, although Google Tag Manager does not access this data. Any opt-out established at the domain or cookie level will apply to all tracking tags that were implemented with Google Tag Manager. Further information on Google Tag Manager can be found at http://www.google.de/tagmanager/use-policy.html

adjust.io 

This website also uses the “adjust.io” analytical technology of adeven GmbH, Saarbrücker Str. 37a, 10405 Berlin, (“adeven”). adeven uses IP and Mac addresses of users for its analysis, which are exclusively used anonymously. No conclusions about individuals can be drawn. The information collected through this tool is exclusively used to analyse the function and usage of the website by generating anonymous evaluations and charts on the number of visits, number of pages accessed by each user etc. The analyses are exclusively used for the purposes of our own market research and the optimisation and user-friendly design of our website. By using this website for analytical purposes, you consent to the processing of anonymous data in the manner and for the purposes set out above. You can opt out of the collection and storage of data at any time with future effect by sending an e-mail to optout@adjust.io. 

adjust.io App

App performance tracking: Our mobile apps use the app performance and analysis technology “adjust”, a service provided by adjust GmbH ("Adjust"). When you launch the DriveNow app, “adjust” collects install and event data our iOS and Android mobile apps in order to help us understand how our users are interacting with our apps and to optimize and analyze mobile ad campaigns. For such analysis, “adjust” uses your IDFA or Google Play Services ID, and your anonymized (hashed) IP- and MAC address. The hashes used are one-way hashes and it is not possible to identify you or your mobile device individually. The legal basis for the processing is based on Art. 6 para. 1 f) GDPR. The legitimate interest lies in the analysis and improvement of our mobile advertising campaigns. Your data will (not) be transferred transnationally.
You can opt out of the collection and storage of data at any time with future effect by sending an e-mail to optout@adjust.io.

DoubleClick  

Our website uses DoubleClick by Google Inc. via Trakken Web Services GmbH, Zirkusweg 1, 20359 Hamburg, Germany to present you with relevant advertisements. When you open a website and see a display of an advertisement placed via websites of the Google advertising network or click on it, a DoubleClick cookie may be stored in your browser. The DoubleClick cookie identifier allocated to your browser is the same cookie that is used when you visit websites, in which advertising programs by DoubleClick are applied. This cookie allocated to your browser contains a pseudonymous identification number (ID) and can check which ads were displayed in your browser and how many ads have been viewed. These cookies do not contain any personal information. In connection with our re-marketing measures, we may show you advertisements tailored to your preferences on the basis of this information. Re-marketing collects and saves information about your surfing habits in anonymous form for marketing purposes. 

DoubleClick only allows Google and its partners to place advertisements on the basis of prior visits to our website or other websites. Google transmits the information generated by cookies to a server in the United States for analytical purposes and saves it there.  

Google observes the data protection provisions of the U.S. Privacy Shield Agreement and is registered with the U.S. Department of Commerce Privacy Shield Program> For further information, see: 

https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI 

The transmission complies with legal requirements or occurs within the scope of order processing. Under no circumstances will Google combine your data with other data collected by Google. By using this website, you consent to the processing of data collected about you by Google in the manner of data processing and for the purposes set out above. You can prevent the storage of cookies by selecting the corresponding settings in your browser; however, you may not be able to fully use some of the features of our website in this case.  

Information about data protection at DoubleClick can be found at: 

http://www.google.de/policies/technologies/ads/ 

In addition, you can opt out of the transmission of data generated by cookies, which refer to your use of websites to Google as well as the processing of this data by Google by downloading and installing the browser plug-in available at: 

Visual website optimizer (VWO)

Wingify Software Private Limited, Antriksh Apartments, Sector-14, Rohini, Delhi-110085, India: This enables us to analyse the behaviour of users on our website and the interaction with them, create versions of certain pages and test them by making them available to users selected at random or determined by target groups. For this purpose, VWO is capable, among other things, of recording the mouse movement of users and their interaction with boxes on our website in anonymised form. The anonymity of the users is guaranteed by the fact that no personal data, such as IP addresses, names or entries using the keyboard are recorded. VWO uses cookies to conduct tests and reproduce user behaviour. Further information about the use of cookies by VWO is available at https://vwo.com/knowledge/what-are-the-cookies-stored-by-vwo/. Information about the general function of VWO is available at https://vwo.com/privacy-policy/.
If you wish to be excluded from VWO analysis and test methods, you can arrange this at https://vwo.com/opt-out/.

Opting out of cookie storage 

You have the option to accept or reject cookies. Most web browsers automatically accept cookies, but browser settings usually allow for rejecting cookies. If cookies are rejected, some features of the website may no longer be usable. If cookies are accepted, the accepted cookies may be deleted at a later point. When you delete cookies, all settings that are controlled by these cookies, including advertising preferences, will be deleted and may not be restored. Furthermore, please refer to the above-mentioned special opt-outs. 

Detailed additional information on this topic can be found at the following websites: youronlinechoices, Network Advertising Initiative and/or Digital Advertising Alliance. These websites also contain details about deleting cookies from your device. 

Legal basis  

The above-mentioned data processing activities and the associated purposes are our legitimate interest, on the legal basis of Art. 6 (1), lit. f, GDPR. 

 

Facebook 

This website uses some technologies provided by Facebook, Inc, 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). These technologies are explained in more detail below.  

Facebook Connect 

If a so-called "Facebook Connect Button" is placed on this website, you can log in to our website with your Facebook user data. In addition, Facebook Connect can automatically include information about your activities on our website in your Facebook profile. In this respect, when you activate the button, you will be given both the opportunity to expressly consent to access your Facebook user data and to publish information and activities in your Facebook profile. The use of further data (e.g. contact via your email address) only takes place with prior express consent. Please note that Facebook receives information about the application or website via Facebook Connect, including what you are doing. To personalise the connection process, Facebook may in some cases receive a limited amount of information prior to authorising the application or website. The purpose and scope of the data collection and the further processing and use of the data by Facebook as well as your rights in this regard and settings options for the protection of your privacy can be found in the privacy policy at: http://www.facebook.com/policy.php 
 

Facebook Custom Audience 

Within our Internet presence we use the "Facebook pixel" from Facebook Inc. 1601 S. California Ave, Palo Alto, CA 94304, USA ("Facebook"). This allows users' behaviour to be tracked after they have seen or clicked on a Facebook ad. This process is used to evaluate the effectiveness of Facebook advertisements for statistical and market research purposes and can help to optimise advertising measures. 

The data collected is anonymous to us, so it does not give us any indication of the identity of the users. However, Facebook stores and processes the data so that a connection to the respective user profile is possible and Facebook can use the data for its own advertising purposes in accordance with the Facebook data usage guidelines. You can enable Facebook as well as its partners to connect advertising ads to Facebook and including on external websites. A cookie can also be stored on your computer for these purposes. In order to reject the use of cookies on your computer in general, you can set your internet browser so that cookies can no longer be stored on your computer in the future or cookies that have already been stored will be deleted. However, disabling all cookies can result in some functions on our internet pages no longer being executed.  

You can disable the use of cookies by Facebook through a program we have developed specifically for this case (web-based opt-out procedure). For this you only need click on the following link

Legal basis 

Our legitimate interest lies in the aforementioned data processing processes and the purposes pursued with them. For this purpose, Art. 6 para. 1 lit. f GDPR provides the legal basis. 

 

Product and advertising e-mails 

The section below explains our data processing for the purpose of product information and advertising.  

Product recommendation e-mails 

We want to provide our customers with regular product recommendation e-mails. For this purpose, we use the e-mail address you specified as part of registration, your name and your date of birth. Our product recommendation e-mails are intended to inform you about products we offer, in which you may be interested on the basis of your most recent lease. In addition, we want to send you our confirmation notification regarding your registration and helpful product use instructions. You will receive these e-mails regardless of your subscription to our newsletter. Furthermore, we will use your data for the following purposes: Measures for the further development of services and products, reporting on the success of the utilised measures in the course of time, testing and optimisation of procedures for requirement analysis, benchmarking, and enrichment of our data, e.g. from publicly available sources or internal market research. We do not share data with third parties. Your data will be stored as long as we maintain a business relationship with you and you have not objected to this data processing. You have the right to object to this data processing, which is based on Art. 6 (1), lit. f, GDPR, at any time, either as a whole or for specific measures. In this case, we will no longer process your data. You may send your objection via e-mail to service@drive-now.com or via regular mail by writing to DriveNow GmbH & Co. KG, Seidlstraße 26, 80335 Munich, Germany. There is also an unsubscribe link in all notifications, which will be considered an objection if activated.   

Legal basis  

The legal basis for the processing of data after registration for the newsletter by the user is, with the user's consent, Art. 6 para. 1 lit. a GDPR. 

Personalised advertising and/or offer e-mails 

We want to regularly send interest-based customised advertisements and/special offers for DriveNow to our customers via e-mail. Special offers also include our DriveNow packages with special cooperation partners, which you can view at: https://www.drive-now.com/de/de/now/partners

Our goal is to continually improve our DriveNow customer experience and to make it more user-friendly. For the purpose of sending you such advertisements, we will use the e-mail address you specified as part of registration, your name and your date of birth. In order to send you interest-based advertising, we will use automatically generated information transmitted by your computer such as delivery and read receipts for messages, information on your device, your browser, your activities in our website, including the length of your visit on our website and your lease transactions. We will process this information in pseudonymised form. This ensures that our customers exclusively receive e-mail messages that match their interests relating to the advertising and/or special offers of DriveNow. You will receive these notifications regardless of your subscription to our newsletter. We do not share data with third parties. Your data will be stored as long as we maintain a business relationship with you and you have not objected to this data processing. You have the right to object to this data processing, which is based on Art. 6 (1), lit. f, GDPR, at any time, either as a whole or for specific measures. In this case, we will no longer process your personal data. You may send your objection via e-mail to service@drive-now.com or via regular mail by writing to DriveNow GmbH & Co. KG, Seidlstraße 26, 80335 Munich, Germany. There is also an unsubscribe link in all notifications, which will be considered an objection if activated. 

Legal basis 

The above-mentioned data processing and the associated purposes are part of our legitimate interest on the legal basis of Art. 6 (1), lit. f, GDPR. 

Newsletter  

We would like to regularly provide interested parties and our customers with advertisements about our products and services about the following products and product categories of our contract partners via e-mail, text message and push. For this purpose, we will use the e-mail address you specified as part of registration, your mobile phone number and your name.  Your data will be exclusively used for distributing our newsletter. The identification of your e-mail address and your mobile phone number takes place in a double-opt in process. That means you will receive a separate confirmation e-mail and a 4-digit code via text message after processing your data. You will only start to receive promotional e-mails after clicking on the link included in the e-mail and entering the code contained in the text message. In addition, we will store your IP address and time of registration and confirmation in each case. The purpose of this procedure is to prove your registration and to investigate any possible misuse of your personal data. We do not share data with third parties. Your data will be stored until you withdraw your consent. You have the right to withdraw your consent to this data processing, which is based on Art. 6 (1), lit. a, GDPR, at any time without citing any reasons. In this case, we will no longer process your personal data. You may send your notice to withdraw consent via e-mail to service@drive-now.com or via regular mail by writing to DriveNow GmbH & Co. KG, Seidlstraße 26, 80335 Munich, Germany. There is also an unsubscribe link in all e-mails, which will be considered withdrawal of consent if confirmed. 

Legal basis  

The legal basis for above-described data processing and the associated purposes is Art. 6 (1), lit. a, GDPR. 

Advertising by BMW 

On our website it is possible to obtain information about current products and services available from the BMW Group, Bayerische Motoren Werke Aktiengesellschaft (BMW), Petuelring 130, 80788 Munich (BMW). This is done on the basis of your consent. When you log in to the shipment section for customer care and to selected publicity communications and for market research, the data from the entry mask is sent to us and we then forward this information to BMW.

BMW AG is also authorised to share this data with certain subsidiaries (BMW M GmbH, Daimlerstr. 19, 85748 Garching-Hochbrück) as well as individual contract dealers and workshops (preferred partners, companies where you bought vehicles or used service or consulting offers, or your regional partners), who may use your data for the above-listed purposes and are authorised to contact you in this regard. Updates may be shared among the above-listed companies. 

For this purpose, we collect your e-mail address and your mobile phone number. The identification of your e-mail address and your mobile phone number takes place in a double-opt in process. That means you will receive a separate confirmation e-mail and a 4-digit code via text message after processing your data. You will only start to receive promotional e-mails after clicking on the link included in the e-mail and entering the code contained in the text message. You will begin to receive advertising e-mails once you click on the link included in the message. In addition, we will store your corresponding IP addresses and times of registration and confirmation in each case. The purpose of this procedure is to prove your registration and to investigate any possible misuse of your personal data. 

To unsubscribe, you can either send an e-mail to servicedatenschutz@drive-now.com at any time without citing any reasons or unsubscribe via the link at the bottom of any newsletter. You can also cancel your subscription by contacting the BMW Customer Service by phone at: +49 89 1250-16000 or by e-mail at: kundenbetreuung@bmw.de 

Legal basis  

The legal basis for processing data after a user’s subscription to the newsletter, in the presence of the user’s consent, is Art. 6 (1), lit. a, GDPR.