With the advent of the General Data Protection Regulation (GDPR), new rules apply to the processing of personal data. In this Privacy Statement, we explain your rights and obligations when you provide us with personal data. Mobilock is responsible for the processing of personal data.
All data and/or personal data collected by MobiLock BV (‘Mobilock’) through website use (Cookies), application forms, emails, letters, telephone calls, via the Mobilock app, via social media, such as Facebook, Twitter and personal data obtained voluntarily in other ways, have been obtained because you either gave your unambiguous consent or because there is a legal basis for registering data (yours and otherwise).
What does Mobilock use your personal data for?
- To be able to perform agreements, for example when purchasing our products and subscriptions.
- In order to be able to respond to your questions, suggestions, or complaints.
- If you have indicated that you would like to receive our newsletter.
- If you have agreed to the sending of personalised and targeted marketing communications through the Mobilock App.
What data does Mobilock record?
- Name, address, town/city, phone number, email address
- Date of birth
- Respondent number
- Client number, card number, form number
- Subscription/product type, date of commencement, recruitment channel, duplicate history.
- Complaint details, refund.
- Transaction data on bicycle use, including check-in and check-out data
- Data relating to current/completed transactions and additional data such as navigation data, requested publications/brochures
- Details from direct contact
- Financial details, bank/giro account number, payment method, payments made
- Employer contact details (if you have a subscription through your employer)
- Account number, payment method and debtor details
- Data relating to the use of the Mobilock App
When does Mobilock use your data?
We use your data to establish and maintain a relationship with you. This can be done in many ways:
- If you have created an account and to give you access to our services.
- If you have purchased a subscription and to be able to perform this agreement.
- To be able to answer and/or handle your questions, suggestions, complaints and refund requests as well as possible.
- To inform you about new Mobilock products and services.
- To be able to make commercial offers.
- For market research, management information, product and service development and determining general strategy.
- For the usual financial activities when selling products/services (invoicing, collection, crediting, claiming through third parties, internal management).
- Data processing for direct marketing purposes aimed at establishing and/or maintaining a direct relationship between Mobilock’s activities (possibly with cooperating partners for joint offers) and users and former users of the Mobilock system and respondents. This includes determining transactions and interests obtained directly from users and former users of the Mobilock system and respondents.
- For maintaining contacts with debtors and processing the data of users and former users of the Mobilock system in order to be able to communicate in the context of the operation of and the making of payments in connection with a loyalty programme.
- In dealing with disputes and carrying out audits; carrying out or applying other laws.
- When carrying out debtor audits for order processing and sales support.
- In the responsible pursuit of Mobilock’s business objectives.
Accessing data (‘Right of access’)
If you want to know which of your data we process, you can always request an overview from us. In this overview you can see which of your personal data we process, what we use it for and the retention period. You can request this overview of your processed personal data by submitting a written request to this effect. In order to ensure that Mobilock provides the personal data to the correct person, we ask you to send us a copy of your passport or ID card. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond to your request for access within 20 working days.
Changing or supplementing data (‘Right to rectification’)
Should it appear that the personal data of yours we use is incorrect, you can submit a written request for rectification in which you inform us which data is are incorrect. In order to ensure that Mobilock provides the personal data to the correct person, we request that you also send a copy of your passport or ID card. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond respond to your request for rectification within 20 working days. The email newsletter and other mailings you receive from Mobilock contain a link allowing you to unsubscribe from Mobilock’s email communication.
Erasing your personal data (‘Right to erasure’, also known as the ‘Right to be forgotten’)
Under certain circumstances, it is possible to have your personal data removed from our systems. You can notify us of your right to erasure by submitting a written request to that effect. Please note that we will no longer be able to supply you with our products and services in this case. To ensure that Mobilock erases or provides the personal data of the right person, we ask that you also send us a copy of your passport or ID card. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond to your request for erasure within 20 working days.
Objecting to the processing of your data (‘Right to object’)
You may wish for us to stop processing your personal data, for example due to personal circumstances. If so, you have the option of asking us to do so. You can do this via a written request. After evaluation, we will let you know if and to what extent we can meet your request. In order to ensure that Mobilock provides the personal data to the correct person, we request that you also send a copy of your passport or ID card. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond respond to your objection to processing within 20 working days.
Temporarily stop processing of your personal data (‘Right to restrict processing’)
If you would like to temporarily interrupt (stop) the processing of your personal data, you can indicate this by means of a written request. In addition, we ask that you explain why you want to temporarily suspend the processing. In order to ensure that Mobilock temporarily suspends the processing of the personal data of the right person, we request that you also enclose a copy of your passport or ID in addition to the request for temporary suspension of the processing. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond to your request to temporarily suspend the processing of your data within 20 working days.
Transferring your data (‘Right to data portability’)
If you would like to transfer your data (also referred to as ‘data portability’), you can receive a copy from us specifying the data we hold of yours. We can also transfer this data to third parties for you. You can indicate this by submitting a written request to this effect.
In order to ensure that Mobilock provides the personal data to the right person, we request that you also enclose a copy of your passport or ID in addition to the data portability request. Make sure to shield off your Citizen Service Number (BSN) and passport photo. We will respond to your request regarding data portability within 20 working days.
Provision of personal data to third parties
We use third parties to perform our services and other activities. This could include IT companies, external customer service providers, marketing services (apps), customer satisfaction surveys, cooperation with insurance companies in the event of loss or damage, regulators, tax authorities and investigation agencies, collection agencies, and analysis services with regard to the use of our websites (Google Analytics). If external organisations process personal data on Mobilock’s behalf, we have made agreements with these parties regarding processing, purposes, security, etc. These agreements are laid down in a data processing agreement.
With regard to the processing of your personal data, you can contact us if you:
- Have any questions, comments or complaints about the use of your personal data.
Want Mobilock to delete your personal information because you no longer want to use our services. Mobilock has appointed a Data Protection Officer to monitor compliance with the GDPR within Mobilock. You can contact us in writing about this. We will respond within 20 working days.
If you feel that Mobilock has not acted correctly in response to your comment or complaint, you can report this to the Dutch Data Protection Authority (Dutch DPA) via www.autoriteitpersoonsgegevens.nl.
Laws and regulations
Mobilock is subject to various legal obligations. For example, we process Personal Data such as your name and address details or transaction details. The Basis used for this purpose is: implementing a statutory obligation. This could involve tax legislation, for example.
Data can also be requested by the Police, or the Ministry of Justice (investigative bodies). We are legally obliged to cooperate with these requests.
We try to ensure that the processing of personal data takes place as much as possible within the European Economic Area. However, this does not always work. For example, many people use Facebook, Google and WhatsApp. If data is nevertheless shared with organisations outside the EU, they are located in a country that is sufficiently secure. The European Commission has drawn up a list for this purpose. If we have personal data processed by others (for example, IT companies and internal and/or external Customer Service, then explicit further agreements have been made about the processing of personal data, which are laid down in Data Processing Agreements.
The retention periods for some data are laid down by law. If this is the case, the data will be retained for these periods.
Mobilock complies at all times with applicable laws and regulations.