May 25, 2018
Scootaround understands that your privacy is important to you and that you care about how your information is used online. We value the privacy of everyone who visits Our Sites and will only collect and use information in ways that are useful to you and in a manner consistent with your rights and Our obligations under the law.
1. Definitions and Interpretations
In this Policy the following terms shall have the following meanings:
"Account" means an account required to access and/or use certain areas and features of Our Sites;
"Cookie" means a small text file placed on your computer or device by Our Sites when you visit certain parts of Our Sites and/or when you use certain features of Our Sites. Details of the Cookies used by Our Sites are set out in section 12, below;]
"Our Sites" means these websites, www.scootaround.com and shop.scootaround.com;
"Canada and EU Cookie Law" means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and]
"We/Us/Our" means Scootaround Inc., a limited company registered in Canada at the address 1345 Waverley St. Winnipeg, MB R3T 5Y7, and in the United States at the address 7703 Kingspointe Pkwy #400, Orlando, FL 32819.
2. Information About Us
2.1 Our Sites, scootaround.com and shop.scootaround.com, are owned and operated by Scootaround Inc., a limited company registered in Canada at the address 1345 Waverley St. Winnipeg, MB R3T 5Y7, and in the United States at the address 7703 Kingspointe Pkwy #400, Orlando, FL 32819.
2.2 We are a member of the American Rental Association
3. Scope - What Does This Policy Cover?
4. What Data Do We Collect?
4.2 Business/company name
4.3 Contact information such as email addresses and telephone numbers
4.4 Demographic information such as postal/zip code, preferences and interests
4.5 Credit card numbers
4.6 Height and weight (only if you are looking to book equipment)
4.7 IP address (automatically collected)
4.8 Web browser type and version (automatically collected)
4.9 Operating system (automatically collected)
4.10 A list of URLs starting with a referring site, your activity on Our Sites, and the site you exit to (automatically collected)
5. How Do We Use Your Data?
5.1 All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see section 6, below.
5.2 We use your data to provide the best possible personal transportation solutions and mobility equipment services to you. This includes:
5.2.1 Managing any accounts or rental/claim files you have with us
5.2.2 Managing your access to Our Sites
5.2.3 Personalising and tailoring your experience on Our Sites
5.2.4 Supplying Our personal transportation solution services to you
5.2.5 Personalising and tailoring Our personal transportation solutions and services for you
5.2.6 Responding to communications from you
5.2.7 Supplying you with email newsletters, promos, and updates that you have subscribed to (you may unsubscribe or opt-out at any time by clicking the “unsubscribe” link at the bottom of our emails)
5.2.8 Market research
5.2.9 Analysing your use of Our Sites and gathering feedback to enable Us to continually improve Our Sites and your user experience
5.3 In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the rental, repair, or other personal transportation services We can provide you without your consent for Us to be able to use such data.
5.4 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email, telephone, text message, and/or post with information, news and offers on Our personal transportation solution services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003, as amended in 2004, 2011 and 2015.
5.5 Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
a) you have given consent to the processing of your personal data for one or more specific purposes;
b) processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
c) processing is necessary for compliance with a legal obligation to which we are subject;
d) processing is necessary to protect the vital interests of you or of another natural person;
e) processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
f) processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. This is interests could include
6. How and Where Do We Store Your Data?
6.1 We only keep your data for as long as We need to in order to use it as described above in section 5, and/or for as long as We have your permission to keep it. We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. These policies are:
6.1.1 We keep your personal information for as long as you have an account with Us
6.1.2 We keep your personal information for as long is needed to provide you our services
6.1.3 We may retain your information because we have legal, auditing or account obligations, but you have the right to have this data deleted at any time
6.2 All of your data will be stored on Canadian servers outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Sites and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements.
6.2 Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Sites.
6.3 Steps We take to secure and protect your data include:
6.3.1 All data is secured over transmission with 256bit SSL encryption
6.3.2 Customer database is siloed and is only accessible to Scootaround staff who are granted specific security permissions
6.4 Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.
7. Do We Share Your Data?
7.1 We may share your data with other companies in Our group. This includes CareVacations USA.
7.2 We may contract with third parties to supply personal transportation solution services to you on Our behalf. These may include payment processing, delivery of equipment, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with:
a) Our trusted cruise line partners (identified on our website: Cruise Lines Partners);
b) Our trusted third-party vendors who provide us with equipment and repair services across the continent;
c) Hotels and casinos where we deliver rental equipment or provide equipment for rental onsite;
d) Airlines who contact us on behalf of their customers to facilitate rentals, repairs, or replacements of damaged mobility equipment;
e) Credit and debit card companies which facilitate your payments to us, and anti-fraud screening, which may need information about your method of payment and flight booking to process payment or ensure the security of your payment transaction;
f) Service providers we are using to run our business, such as agents who provide equipment rental and delivery services at ports across North America, and SEO and paid advertising specialists who assist our marketing team with running targeted marketing campaigns;
7.3 We may compile statistics about the use of Our Sites including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.
7.4 In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.
8. What Happens If Our Business Changes Hands?
8.2 In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes. However, you have the right to have your data deleted at any time.
9. How Can You Control Your Data?
9.1 When you submit information via Our Sites, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and/or when first providing us with your details online or over the phone).
9.2 You may also wish to sign up to one or more of the preference services operating in the United States or Canada or the EU: The National Do Not Call List (Canada), the Do Not Call Registry (USA), or The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”) (EU). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
10. Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
10.1 You may access certain areas of Our Sites without providing any data at all. However, to use all features and functions available on Our Sites you may be required to submit or allow for the collection of certain data.
10.3 You may withdraw your consent for Us to use your personal data as set out in section in 5 at any time by contacting Us using the details set out in section 15, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible personal transportation solution services to you.
11.How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at [email protected] , or using the contact details below in section 14.
12.What Cookies Do We Use and What For?
12.2 By using Our Sites you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. We use third party Cookies on Our Sites for advertising services, analytics tracking, and communicating with our customers. For more details, please refer to section 5, above, and to section 12.6 below. These Cookies are not integral to the functioning of Our Sites.
12.3 All Cookies used by and on Our Sites are used in accordance with current English and EU Cookie Law.
12.4 Before any Cookies are placed on your computer or device, subject to section 12.5 and section 12.8, you will be shown a pop-up message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Sites may not function fully or as intended.
12.5 Certain features of Our Site depend on Cookies to function. The US, Canada, and EU Cookie Law deems these Cookies to be “strictly necessary”. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 12.10, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
12.7 Our Sites uses analytics services provided by Google and Lucky Orange. Website analytics refers to a set of tools used to collect and analyze usage statistics, enabling Us to better understand how people use Our Sites. This, in turn, enables Us to improve Our Sites and the personal transportation solution services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Sites, it does enable Us to continually improve Our Sites, making it a better and more useful experience for you.
12.9 You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third-party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.
12.10 You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Sites more quickly and efficiently including, but not limited to, login and personalisation settings.
12.11 It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.
13.Summary of Your Rights under GDPR
Under the GDPR, you have:
13.1 the right to request access to, deletion of or correction of, your personal data held by Us;
13.2 the right to complain to a supervisory authority;
13.3 be informed of what data processing is taking place;
13.4 the right to restrict processing;
13.5 the right to data portability;
13.6 object to processing of your personal data;
13.7 rights with respect to automated decision-making and profiling (see section 14 below).
14.Automated Decision-Making and Profiling
14.1 In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.
14.2 The right described in section 14.1 does not apply in the following circumstances:
a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.
14.3 Where We use your personal data for profiling purposes, the following shall apply:
a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.
2.1 Our Sites, scootaround.com and shop.scootaround.com, are owned and operated by Scootaround Inc., a limited company registered in Canada at the address 1345 Waverley St. Winnipeg, MB R3T 5Y7, and in the United States at the address 7703 Kingspointe Pkwy #400, Orlando, FL 32819.2.2We are a member of the American Rental Association