Privacy Policy

Privacy Policy

1. General

This privacy policy (the ”Privacy Policy”), together with the user agreement and terms and conditions (the “Agreement”), available on Thtenn website www.Thtenn.com, describes how Thtenn (”Thtenn”, “We”, “Our“, “Us”), as a data controller, process our customer’s (“You”, “Your”) personal data when using the Services, as defined in the Agreement.

Unless otherwise stated in this Privacy Policy, the definitions used herein will have the same meaning as in the Agreement. Questions regarding this Privacy Policy and Thtenn’s processing of Your personal data can be sent to support@Thtenn.com or  Dataprotection@Thtenn.com

The Privacy Policy is intended to comply with our obligations to provide you with information about our processing of your personal information under applicable privacy laws. It explains how we collect, use and share personal information in the course of our business activities.

2. Collection, purpose and use of personal data

2.1 Your Personal data

We collect personal data which You submit when creating an account in the Thtenn App or when You are using the Thtenn App or the Services provided.

We process Your personal data for the purpose of:

1. Entering into, fulfilling and administering our contractual relationship (including handling payment) with You and to correspond with You in relation to the Services. We process the following personal data:

  • Location data (device location and location Vehicles);
  • Contact details (such as Your name, address, e-mail address and phone number);
  • Valid driver’s licence.
  • Payment information (such as bank card information, invoice history, payment history)
  • Your Device ID.
  • Photos of Vehicle which You upload in the Thtenn App; and
  • Evidence of your status, such as a copy of your HC2 / HC3 certificate, staff card, student campus card or other documentation that can prove your status.

2. Our lawful basis for processing your personal data is to fulfil our contractual obligations to You and to performing statistical data analyses in order to develop better Services in functionality, security and customer experience. This is also done in order to analyse the customer markets that we describe as:

  • IP address;
  • Information about Your device, such as make, model, and operating system;
  • Basic information about You and the service we offer including your age, Your post code and Your gender;
  • Information about how You use Thtenn App and the Services we provide including date, time and duration of your usage.
  • Survey data, especially how Your respond and interact with Thtenn App, Your experience and general demographic survey questions.
  • Location data (device location and location of Vehicles);
  • Gyroscope data and Accelerometer data from Your device.

3. Our lawful basis for processing your personal data is a legitimate interest of being able to develop our Services and to increase Our understanding of the customer markets. Wherever possible, we anonymise or aggregate data processed for carrying out marketing campaigns. We may process Your  contact details such as name, e-mail address and phone number for this purpose.

4. Our lawful basis for process personal data for marketing purposes is either for our legitimate interests in marketing our business or for Your consent where we send marketing information about third party products and services. You can withdraw from this consent at any time by unsubscribe to Our emails or by contacting us through Appaccounts@Thtenn.com We also process Your personal data for the purposes of segmenting and analysing position data in order to improve our services based on specific customer preferences and behavioural patterns, we process the following personal data:

5. The lawful basis for processing your personal data is to fulfil Our contractual obligations for You especially service delivery.

We also process Your photo data to provide Thtenn Points User ethical behaviour and safe riding.  We will process Your personal data when you submit a picture of yourself wearing a helmet when using Our Vehicle. The personal data that will be processed for this purpose a Selfie Photo that You submit to Us.

6. Our lawful basis for processing Your personal data is to satisfy Our legitimate interest in being able to encourage Our service users to observe safety measures by wearing helmets in order to facilitate their own safety when using Our vehicles.

We also process Your personal picture data to improve and enhance our system so that we able to review selfies and use the pictures that you submit in Our training programme and improve the software’s ability to react to helmets that appears in the pictures.

7. Our lawful basis for processing Your personal data is to satisfy Our legitimate interest in being able to continuously improve our services and to ensure that Our safe riding policy is as effective as possible. You are not obliged to provide us with your personal data, however, not doing so may mean that you are unable to use our services.

We also process Your location data to provide You with the ability to detect Our nearby vehicles and to enable Us to detect the use of Our vehicles in breach of Our User Agreement, we process the following personal

8. Our lawful basis for processing your personal data is to provide You with Our services and to ensure the use of our services is in accordance with Our User Agreement, terms and condition.

We also use Your processed data in recorded image data and location data to develop and improve Our technology and machine learning software for detecting how customers use Our Services in order to improve traffic safety (including functionality for accident detection/prevention and pavement detection).

We process Your account data, use data and payment data for the purpose of applying individual discounts in to encourage users to use Our Services and to developing and improving Our technology and machine learning software.

2.2 General Public data

 Our lawful basis for processing recorded image data and location data is also to improve our technology and machine learning software for detecting how You use Our services in order to improve traffic safety including functionality for accident report, prevention and safety measures.

2.3 Personal data subjects

Our lawful basis for processing Your personal data is to comply with laws and regulations or court order or to protect Our rights and third parties’ rights.

3. Verification of identity, age and identity document

You are required to submit photos of Your driver’s license/other identity document in order to: (i) verify and authenticate Your identity, (ii) verify Your age, and (iii) verify that Your driver’s license/other identity document is valid. The purpose of verifying and authenticating Your identity may also affect Your submission of selfie photo of your face in order to verify Our customers’ identity through facial scan data extracted from selfie photos You have submitted to determine whether You are the legitimate account user as displayed in Your driver’s licence and other identification documents provided.

Our lawful basis for processing Your photo data and identity documents is to verifying and authenticating Your identity by facial scanning and compare with Your scanned identity with Your consent. You may withdraw at any time, however, Your withdrawal may restrict Your access to Our services. Your consent for photo data is obtained in the Thtenn App prior to any facial scanning. Verification of Your identity is done by no other means other means than facial scanning and comparison, and verification of the validity of Your driver’s license/identity document and Your age is required to complete the User Agreement.

4. Transfer of personal data

We may transfer personal data to government authorities, local council, department of transportation and public transport operators for compliance purposes.: We may also share personal data with these recipients for the purposes of city planning and mobility insights including surveys, public service integration, journey planning systems. The data shared for these purposes are user data, vehicle data, journey data and survey data. We may also share user data with Third-party researchers and collaborators for the purposes of service development and mobility insights. The data we may share for these purposes include Journey data, vehicle data, survey data, location data, gyroscope data and accelerometer data. We share user data with Our IT service providers in order to offer all the functions of Our services. IT services providers process Your data upon Our commissioning and on Our behalf.  We only provide personal data in the context of legally permissible processing to IT service providers that have been carefully selected and commissioned in writing. The IT service providers will only receive data which is required for them to perform their tasks. We share personal data with marketing partners to help us with our marketing strategies. The purpose for these transfers is only to perform marketing campaigns. We share user data with Our group companies for internal administration and to deliver Our Services to You. Our lawful basis for sharing user data is to be able to administer our business and deliver Our Services. We share user data with Our Insurance companies in order to manage insurance claims and administer Our insurance policies. We share user data with Courts and counter parties in legal matter in order to defend, exercise and establish legal claims when necessary. We share user data with regulators to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies. We share user data with solicitors, auditors and other professional services firms to comply with regulations, exercise and establish legal representation when necessary. share user data with law enforcement agencies including the Police in order to assist law enforcement agencies and the Police in its investigations only the extent we are obligated to do so. The lawful basis for sharing is to comply with Our legal obligations. We may also under some circumstances have a legitimate interest in assisting the Police in its investigations even if We do not have a legal obligation to do so. In this case, We may transfer personal data to the Police on the basis of assisting the Police and also the Police’s legitimate interest in law enforcement. We may share user data with potential buyers and seller for the purpose of business transaction including merger and acquisition. Our lawful basis for sharing user data with potential buyers and seller is to carry through an acquisition or merger. We may share user data with third-party entities whom we are legally obligated to share information. In this case, Our lawful basis is to comply with Our legal obligations. In some cases, We may transfer personal data outside the EU / EEA, mainly in cases where we use service providers that process personal data outside the EU / EEA. This will only be done after adequate protection measures have been taken by Us to ensure an adequate level of data protection, e.g. by including the European Commission’s standard contractual clauses for the transfer of personal data and, where necessary, by implementation of supplementary safeguarding measures for data protection. You can obtain further information regarding the protection measures taken when personal data is transferred outside the EU / EEA by contacting Us on Enquiries@Thtenn.com

5. Storage of personal data

Your personal data is stored only as long as is Legally required and in order to fulfil the purposes for which Your personal data was collected, however, if  You consent to Your personal data being processed upon Your account activation or Our legal obligation, Your withdrawal of the consent or valid objection will put an end to the processing, without affecting any processing that happened until then and without affecting any legal obligation to process personal data. The personal data which is processed to enter into, perform or administer an agreement between You and Us, is processed for as long as You are Our customer and have a Thtenn App account. If Your account is terminated, We will delete the personal data from Your account, with the exception of personal data which needs to be stored by Us due to legal requirements or to safeguard Our legal obligations.

6. Marketing

We may send You marketing information regarding Our Services as well as products and services offered by third parties. The marketing can be sent both by e-mail, Website, push notifications and in-app. The purpose of sending marketing is to inform You about Our Services and relevant offers from third-parties. We may also process personal data for the purpose of evaluating a marketing campaign which may include that We will transfer some personal data, mainly e-mail addresses, to the relevant marketing campaign partners.

The lawful basis for sending marketing information regarding Our Services and those of third parties is your consent which You may withdraw/ opt out at any time. Where we process personal data for evaluating marketing campaigns, the relevant lawful basis is Our legitimate obligation to analyse the result of Our marketing campaigns.

You may always opt out from Our marketing efforts, either directly in the actual marketing message or by contacting Us at support@Thtenn.com.

7. Rights and contact

You have the right to receive confirmation from Us that we process Your personal data, including a right to access Your personal data and receiving a copy of Your personal data.

You have the right to object to the processing of Your personal data by requesting for Your personal data to be erased from Our system at which we will totally erase Your account. However, We may process user data to comply with regulations, rules and legal obligations.

You have the right to request that incorrect or inadequate personal data about Your is updated or corrected and with Your obligation to update Your information and consent to update Our system, this may be carried out to meet the standards of data protection.

As the processing of Your personal data is based on Your consent, You have the right to withdraw Your consent at any time.

You have the right to object to the processing of Your personal data for marketing purposes. However, we may be entitled to continue processing Your personal data  for compliance and legal obligation purposes.

You have the right to request that the processing of Your personal data is restricted, so that the personal data only may be stored by Us and not processed for any other purposes.

As Your personal data processing is is only performed based on Your consent or a contract and the personal data has been obtained directly from You, You have the right to request data portability, and you are entitled to receive Your personal data on a commonly used machine-readable format.

If you wish to exercise Your right in any case, please use contact us at Appaccounts@Thtenn.com or Support@thtenn.com and we will endeavour to respond within 5 working days

 

You have right to any complaints regarding Our user data processing procedure and You can lodge Your complaints to Us at Complaints@Thtenn.com and we will endeavour to respond to Your complaints within 5 working days.

If You are not satisfied with Our response, You may also contact the Information Commissioner’s Office (ICO) directly.

8. Security

We aim to protect all user personal data from unauthorized access and unauthorized use by technical, physical and organisational measures to ensure a level of security is appropriate to the risk. we maintain a security policy and store all user data on our secure servers. We may update these actions as new technology becomes available.

9. Changes to the Privacy Policy

We may change Our Privacy Policy by publishing a new version of this Privacy Policy on the Website and in the Thtenn App. However, in case a change is due, We will notify all users of the changes in Our processing operations. We will do this by sending You an e-mail with information about the change and update the App for your consent.