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This Privacy Policy (“Privacy Policy”) explains how SIA Spaceship (“we”, “OX Drive”) processes your personal data, which we may collect, or you may provide to us when you visit our website, mobile application (“Mobile App”), use our short-term vehicle rent services (collectively “Services”).
We process personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (the General Data Protection Regulation) (“GDPR”) and other legal acts governing personal data protection (together – Personal Data Protection Laws) and this Privacy Policy.
The terms used in the Privacy Policy must be interpreted in accordance with the definitions set in GDPR and in our Terms and Conditions, unless otherwise provided in this Privacy Policy.
We may update the Privacy Policy from time to time, therefore we recommend that you review it periodically. We will inform you of any changes by posting the updated Privacy Policy on our website and Mobile App. In case of material changes, we will send you a notification via e-mail.
The controller for your personal data processing:
SIA Spaceship
Company registration number 40203300224,
Address: Raina iela 97 – 30, Jurmala, Latvia
Contact details: hello@oxdrive.lv, +371 20045699.
2.1 Installation of the Mobile App and selection of its settings
When you install our Mobile App, we may collect certain data, which is needed for the Mobile App to function properly. For this purpose, we will ask your permission to use the following device data:
the device’s operating system
the device model,
usage and performance data,
location,
other data, which may be required for the Mobile App to function properly.
We will process this information based on your agreement to our terms, when installing the Mobile App and your consent, which you provide when selecting its settings. You can withdraw this consent by changing the settings at any time.
2.2 Account creation in the Mobile App
When you create your account in our Mobile App and agree to our Terms and Conditions, we will collect the information needed for using our Services:
– Your full name and personal code
– Contact information (telephone number, e-mail address, address)
– Payment card information (card type, bank name, card number, validity period)
– the image of your driving licence’s both sides
– the data provided on the first side of your driver’s licence (name, personal identification number, date of birth, driving licence expiration date, the image of your face).
We will process this information based on the contractual arrangement concluded between you and OX Drive for the use of our Services as well as our legitimate interests to protect the company’s legal rights, assets and property, protect against harm and prevent fraud and/or criminal activities.
2.3 Verification of your identity and driving licence
To use our Services, we need to verify your identity and check the validity of your driving licence to ensure that you have the right to drive the vehicle, which you wish to rent. For this purpose we will process the following data:
– Your name
– Your personal ID number and other details contained in your driving licence,
– Picture of your face and your driving licence, which you will need to make with the Mobile App (we will compare the two pictures using automated means and algorithms, specifically designed and used for such purpose);
– The validity of the driving licence, which we will check in public registers.
We will process this information based on the contractual agreement concluded between you and OX Drive for the use of our Services, as well as our legitimate interests to protect the company’s legal rights and prevent fraud and/or criminal activities.
We have the right to perform periodical checks of your driving licence while you are using our Services, for example, if you have had a traffic accident. If we find that your driving licence is about to expire, we may contact you (by phone, e-mail, SMS or by push notifications) and notify you about the expiry of the driving licence.
2.4 Use of our Services and the Mobile App
We may collect certain data when you use our Services and/or the Mobile App to facilitate and monitor the use of our Services, for example, provide information on the nearby vehicles, ensure that you may reserve, unlock/lock the vehicle, provide data on your previous rides and reservations, etc. For this purpose we will use the following data:
– Your location, which we may receive from your device, if you have enabled this setting in the Mobile App and your device,
– Information on your previous reservations and rides,
– Your account data and information on use of our Services (vehicles you have used, date and time of use, places where the vehicle was taken and left, route of the vehicle, speed, battery and battery charging card usage, etc.).
We will process this information based on the contractual agreement concluded between you and OX Drive for the use of our Services, as well as our legitimate interests to monitor the use of our Services and improve its quality.
Please note that, if you have disabled the use of location settings on your device, some Mobile App features may not function, and you will not be able to use our Services.
2.5 Use of vehicles, video surveillance, photography and GPS tracking
To monitor our vehicles, ensure the provision of our Services and compliance with our Terms and Conditions (for example, make sure that the vehicles are used in accordance with our terms, they do not leave the designated geographical location, they are parked in the allowed areas, etc.) we have equipped our vehicles with an electronic GPS tracking system. This system records the location of the vehicle and its use (driving distance, speed, driving time, etc.). Therefore, when you use our Services and drive our vehicles, we will process the following data:
– Your location while you are driving our vehicle;
– Driving speed, travel time, distance;
Your driving habits (fast acceleration, sharp breaking, etc.). We will process this data based on our legitimate interests to protect our vehicles and our legal rights as well as ensure compliance with our Terms and Conditions for the use of our Services.
If during your use of the vehicle you have connected your device to the vehicle (for example, to use navigation or multimedia systems), your device’s data will be stored in the Vehicle, unless you remove them in accordance with the Vehicle manufacturer’s instructions. Please note that we do not process this data, nevertheless, it may be visible to any third party, which uses the vehicle after you. So, after the use of the vehicle we encourage you to remove the data of your device from the memory of the Vehicle. If you have failed to remove the data, we do not accept any liability in respect thereof.
Vehicles are by default equipped with video surveillance, which monitors the vehicle to ensure its safety and enable some of its features such as autopilot, traffic light and road sign recognition. This feature cannot be disabled or configured by us. During this surveillance, some of the data is stored in the vehicles’ drive, which is accessible to us and other drivers via the touchscreen. We may use video recordings, if required to prove and investigate any damage to the vehicle (collisions, traffic accidents, etc.). Please note that we do not have the technical authorization to remove the data after each use of the vehicle by a new user, therefore some of the video recordings of surroundings of the vehicle may be accessible to the next users of the vehicle. The recordings are stored for up to 60 days, depending on the capacity of the vehicle’s storage space.
During the provision of services, before or after the provision of services, the vehicle may be filmed or taken photos of, as a result of which your personal data may also be processed. Photo-fixation may be carried out in the form of photographs, screenshots or other technical solutions to ensure our legitimate interests, incl. evidence of possible violations of laws or Regulations, capture technical or visual condition of vehicles, use, parking, taking, returning and other facts and circumstances that are essential for the protection of our legitimate interests, compliance with laws and Regulations.
We will process this data based on our legitimate interests to protect our vehicles and our legal rights as well as ensure compliance with our Terms and Conditions for the use of our Services.
As the manufacturer of the vehicles, Tesla may also in exceptional cases have access to your data collected during video surveillance, nevertheless, the manufacturer does not receive any information on the user of the vehicles, therefore cannot link the data to your identity or user account. Please see more information on how Tesla processes personal data in this Privacy Policy.
2.6 Marketing and promotional activities
We may process certain personal data to inform you about our news, promotional activities and send you personalized offers from us and in cooperation with our partners, e. g., petrol stations, catering, vehicle maintenance, custodial service providers, etc. For this purpose we may use the following data:
– Your full name and personal code
– Your contact details (e-mail address, phone number),
– Your account information, for example, vehicle use data.
We may send such information using e-mails or push notifications only after obtaining your consent through the Mobile App. You have the right to withdraw your consent at any time by phone: +371 20045699; e-mail: hello@oxdrive.lv, by clicking on the link “Unsubscribe newsletter subscriptions” at any time or by unchecking the option to receive marketing messages in the Mobile App.
Please note that, if permitted by applicable law, based on our legitimate interests to carry out direct marketing activities, we may send general direct marketing messages of a general nature by e-mail or SMS to promote our Services or to ask your opinion about our Services. In addition, you can always give us permission to receive such messages as push notifications. You have the right to unsubscribe from such notifications at any time by telephone: +371 20045699; e-mail: hello@oxdrive.lv, by clicking on the link “Unsubscribe newsletter subscriptions” at any time, by replying to SMS with the word “STOP” or by unchecking the option to receive marketing messages in the Mobile App.
2.7 Processing of payments
To comply with our legal requirements, for example, for accounting, anti-money laundering, payment processing and maintaining other payment-related documentation, we process your data related to your payments and fulfilment of your financial obligations towards us. For this purpose we will process the following data:
– Your name and identification data (personal ID number),
– Contact information (phone number, e-mail address, address),
– Information on the payments you have made to us, and your bank account details.
We will process this information based on the contractual agreement concluded between you and OX Drive for the use of our Services and to comply with legal obligations applicable to us.
2.8 Credit risk check
In certain cases, for example, (i) if you are renting an exclusive vehicle or (ii) plan a trip abroad or (iii) plan to use the vehicle for an extended period of time, (iv) you request to defer the payment, (v) the travel price exceeds 250 euros, or (vi) if there are other serious circumstances which may cause any kind of risk, we may need to verify your ability to pay for our Services and assess your creditworthiness. In such a case, based on your consent, we may request data about you from the credit register to provide lawfully available data about you (including your credit rating, etc.) and to assess them for solvency, debt management and/or recovery purposes. For this purpose we will process the following data:
– Your name,
– Your identification details (personal ID number, date of birth, ID document data),
– Contact information (phone number, e-mail address, address),
– Financial data (e.g., information on your liabilities and income),
– Data on your fulfilment of obligations (e.g., information on your previous and current financial obligations, payment discipline, failures to pay, etc.).
We will request the data from a credit register based on your consent and following your identification.
We will carry out your creditworthiness check and perform risk assessment based on our legitimate interests to perform a risk assessment and avoid inability to recover our assets and income, avoid the possibility of debt and protect our legal interests.
2.9 Communication with you and customer support
To communicate with you, provide our customer service, consultations, inform about updates of our Terms and Conditions and prices, resolve any issues in relation to our Service, we may process your data that we already have and the data you provide to us during communication. If you contact our customer service by telephone, we will record the call to be able to duly process your request and monitor the quality of our customer service, as well as for the possible provision of evidence in cases of legal disputes or violations of law. For this purpose we will process:
– Your full name, personal code
– Your contact details (phone number, e-mail address)
– Your voice recording, if you have contacted us by telephone
– Any other information, which you have provided to us during the communication
We will process this data based on our legitimate interests to provide you with quality service and to solve any related problems as well as protect our interests in case of any disputes between us.
The information referred to above can also be sent as push notifications of the Mobile App. You can opt-out from Mobile App push notifications at any time by changing the settings of your device’s operating system.
2.10 Protection of our rights during disputes and providing information to state and government authorities
In case of an accident involving our vehicle, we will process certain data related to the accident to be able to compensate the damages to the persons involved in the accident jointly with our insurance companies and/or the persons involved in the accident. For this purpose we may share your personal data with our insurance companies. Additionally, in certain cases we may disclose your personal data to state and government authorities if we have received such a request and we are legally required to disclose the data. For this purpose we will process:
– Your identification data (e.g., name, surname, personal ID number and other identifiable information, driving licence),
– Information on how you have used our Service,
– Other information, which may be required for this data processing purpose.
We will process this data based on our legitimate interests to pursue and defend our legal rights, recover, and compensate any damages resulting from accidents involving our vehicles as well as to comply with legal obligations applicable to us, incl. provide information to public administration authorities.
2.11 Defending our legal interests, including debt collection and assignment
In certain cases, we may process your personal data to pursue and defend our legal interests, such as to prevent fraud or attempted fraud, recover funds, pursue debt recovery, assert, or cede debts, prove your consent or obligations, resolve any disputes and conflicts, raise and maintain legal claims.
If you fail to comply with your payment obligations set in Terms and Conditions of our Services and fail to pay your debt within 30 (thirty) calendar days from the date of receipt of the notice, we are entitled to pursue debt recovery, assert or cede your debt. For this purpose, we may process the following data:
– Your full name, personal code
– Your contact details (e-mail address, phone number, address)
– Personal ID number
– Data of your driving licence
– Information on your use of our Services and payments
– Other information, which may be required for this data processing purpose
We will process this data based on our legitimate interests to pursue and defend our legal rights, prevent fraud or attempted fraud, recover funds, pursue debt recovery, assert or cede debts, prove your consent or obligations, resolve any disputes and conflicts, and raise and maintain legal claims.
2.12 Analysis and improvement of the use of our Services and Mobile App
For analysis and advertising purposes, we use third-party cookies tools such as Google Firebase, Google Ads, and Facebook Ads, to enable ourselves to collect aggregated and depersonalized information about how people use the Mobile App, understand how we can improve and provide relevant non-personalized advertising of our services. If you disagree with the processing of data for the purposes described above, do not install the Mobile App on your device and do not select its settings. If you have already done this without reading this Privacy Policy available on Google Play and App Store platforms first, you should immediately delete the Mobile App from your device.
To improve and refine the quality of OX Drive vehicle rent and services, we may analyse non-personal, statistical data (such as Vehicle use date and time, the location where the vehicle was taken and left, the Vehicle route, speed, charging and charging card use, etc.) we have collected during your use of OX Drive vehicle rental and services via the Mobile App.
2.13 Information security and improvements
To monitor the use of our Services, as well as the operation of our information systems, including databases, website, Mobile App, we may process various technical data obtained from cookies, audit trails and other technical solutions.
For this purpose we may use the following data:
Your IP address,
Information on your device,
Type and version of your browser,
Time zone, various metadata, information on access and use of our website and Mobile App, data entry and other data used for this purpose.
Depending on how you use our Services, we may receive your data and share it with various third parties and service providers. If we will need to perform your credit risk check, we will request your data from credit bureaus, debt history databases and other cooperation partners, who can provide the required information. We may also access databases to verify the validity of your driving licence. Certain information, such as video surveillance of the vehicle, may be available to the manufacturer of the vehicles, nevertheless, the data is not linked or associated with you as the user, therefore does not allow your identification.
To provide our Services, we share your personal data with various third-party service providers and other recipients, for example:
– Service providers who ensure client identification tools, server co-location services as well as data and cyber security services, email and content delivery tools, postal, marketing, accounting, legal, audit, IT, web analytics, session recording, and online marketing services and other services that we may reasonably need;
– Public authorities and other government institutions, when required, as well as law enforcement authorities (for example, in cases involving a road traffic offence such as speeding, driving under influence), property theft or damage, etc), consultants, lawyers, sworn bailiffs, tax administration, debt collectors or other legal persons under assigned rights;
– In case of an accident involving the Vehicle, your data will be shared with insurance companies and, if necessary, to the other parties involved in the accident.
In certain situations, we have a legal obligation to share your information with third parties to comply with legal requirements or requests, as well as to protect our, or a third party’s legal interest. We will also disclose your information to third parties to the extent allowed by applicable law, including:
– To a prospective purchaser or purchaser within the customer database that acquires all or substantially all of us or our business;
– To a third party if we sell or buy any business or undergo a merger, in which case we may disclose your information to the prospective buyer of such business within the customer database;
– To a third party within the customer database if we partner with other companies or businesses, undergo a reorganization, bankruptcy, or liquidation, or otherwise undertake a business transaction or sell some or all our assets.
If any of our service providers will be located outside the EU/EEA, we will share your data in accordance with the requirements set in the applicable Personal Data Protection Law, including:
– by entering into EU Standard Contractual Clauses or by using other appropriate grounds for data transfer provided by applicable Personal Data Protection Law such as codes of conduct and certifications,
– cooperating with service providers located in the country, which offers an adequate level of data protection in accordance with the GDPR and Legal Acts on Personal Data Protection.
We store your data for as short a period of time as possible, but long enough to achieve the legitimate purpose for which the data was collected and processed.
We will process your personal data as long as:
– one of the above-mentioned legal basis for data processing exists and there is a purpose for your data processing, for example, the Service agreement you have entered into is in force or your consent to certain data processing is valid;
– we are required by applicable law to retain your personal data;
– there is a need to pursue our legitimate interests, for example, raise and maintain legal claims.
When these conditions end, we will delete or anonymize your data.
For example, data on your account and any associated payments, client management activities, debt recovery and fines will be retained for 5 years after the last transaction. This term may be prolonged, if the information will be required to protect our legitimate interests in case of any disputes or legal claims.
For the safety of our Vehicles, we will retain GPS data for 3 years as of the data of their recording.
Data processed for direct marketing purposes will be retained for 3 years or as long as your consent is valid. Recordings of our customer support telephone conversations will be stored for a period not exceeding years.
As a data subject, you have certain rights prescribed by Personal Data Protection Laws. These rights provide that you can:
– request access to your personal data and ask for details on its processing;
– correct incorrect or inaccurate data;
– ask to delete your data. Please note that we will not be able to delete data that we are required to process and retain in accordance with applicable law or that may be objectively necessary to achieve a legitimate goal, to defend our rights or bring a legal action if our rights have been infringed;
– object to the processing of your personal data, which is based on our legitimate interests. In case of such an objection, we will no longer process your personal data unless, we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims;
– request to receive your data to transfer it to another data controller, provided that this does not affect our legitimate interest in protecting our trade secrets or any other confidential information;
– withdraw your consent to the processing of data based on prior consent. Consent can be revoked by:
– using the unsubscribe option in our e-mail messages or SMS,
– sending an e-mail to hello@oxdrive.lv,
– calling our customer service centre +371 20045699.
Withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.
For the purposes of your personal data processing, we do not use automated decision-making processes, including profiling, which may produce legal effects on you or similarly significantly affect you. However, when processing your personal data for direct marketing purposes, we may assign you to a certain category of customers, to offer you more personalized Services, including discounts, promotions and other special offers.
To exercise your rights, you should contact us via e-mail hello@oxdrive.lv.We will process the request within 30 days and provide you with an answer. When we receive your request for the exercise of your rights, we will verify your identity, evaluate the request and execute it in accordance with the applicable legal norms. We will provide information free of charge, however, if your requests are manifestly unfounded or excessive, in particular, because of their repetitive character, we may charge a reasonable fee based on administrative costs or refuse to act on the request.
You have the right to lodge complaints in relation to our personal data processing activities by submitting such complaints to the Data State Protection Inspectorate of the Republic of Latvia https://www.dvi.gov.lv/en/.
We use appropriate technical and organisational measures to ensure personal data security, including protection of data against unauthorised processing and accidental loss, destruction or damage. These measures are selected taking account of the risks that may arise to you as the data subject’s rights and freedoms.
We strictly control access to personal data processed and provide it only to our employees who need such access to perform their work. Our employees and cooperation partners, who objectively who have access to personal data are acquainted with personal data protection requirements and ensure the confidentiality of your personal data.
We regularly monitor our systems for breaches or attacks. However, it should be noted that it is not always possible to ensure the complete security of information transmitted online, taking into account the limitations of technological capabilities or the dishonest actions of third parties. Accordingly, you transmit information on the Mobile App via the internet connection at your own choice and risk, especially if you use public (open) WIFI connections for internet connection and data transfer.
If you have any additional questions or comments, please contact us via e-mail hello@oxdrive.lv or by telephone +371 20045699.
SIA Spaceship
LV 40203300224
Sporta iela 2, k-1, Rīga, Latvia
Better than a horse