European Regulation 2016/679 on the protection of natural persons with regard to the processing of their personal data (hereinafter GDPR) entered into force on May 25, 2018. Therefore, CICLO commits to protect individual confidentiality and personal data.
We undertook to observe the GDPR Regulation through dialogue and cooperation with our partners. Consequently, we created the following confidentiality Policy so as to inform on our practices in terms of collecting, using, storing, and disclosing the information that you may provide while you interact with us.
This confidentiality policy augments the CICLO Terms and Conditions. Before going over the Confidentiality policy, make sure you have read the CICLO Terms and Conditions. Any provision within such Terms and Conditions is hereinafter applicable with regard to the protection of personal data.
The present confidentiality policy applies to both the CICLO application, as well as to the CICLO web page.
CICLO is determined to observe the principles set-forth by the GDPR and, as such, personal data is:
CICLO collects the personal data of users, members, and visitors of the web page and those of clients/potential clients. When so commanded by the law, CICLO provides natural persons with an adequate notification on the data to be collected and the manner wherein they will be used.
We only collect personal data which are voluntarily provided by natural persons so that we may provide information, services, develop contractual relations, and promote our services. Additionally, we have to process certain personal data in order to be allowed to provide our services or to observe various legal obligations.
Processed data: identification data (name, first name(s)), telephone number, e-mail address, data pertaining to the bank card associated to the account, and geographical location.
In case of registration through a profile existing on another platform (e.g. Facebook), we will process the information from this profile, like the user name.
Furthermore, based on your freely given consent, CICLO may process cookie type files like:
- Preference cookies: allowing the web page to retain information which allow the page’s manner of operation like, the selected language.
- Statistic cookies: helps CICLO to understand the manner wherein users use the page and collect data, anonymously.
- Marketing cookies: are used to track visitors of the web page. The intention is to post relevant and interesting ads for each user and, as such, more valuable for third party editors and advertising agencies.
Data protection legislation allows for the collection and processing of data as long as there is a legal reason to do so. As mentioned above, CICLO processes personal data only in the following situations:
Intended persons may withdraw their consent at any time by contacting CICLO at the following e-mail address: firstname.lastname@example.org
Third parties providing personal data to CICLO are responsible with making sure that intended persons were informed on the provisions of the present confidentiality policy and that such intended person has given his/her consent for sharing the data.
CICLO might share personal data with third parties in order to observe legal obligations (for example, obligations regarding labour and fiscal legislation) or to execute contractual obligations (for example, in the event wherein we involve subcontractors in the provision of services).
Furthermore, CICLO might share personal data with the competent authorities/entities involved in such a procedure in view of recovering any prejudice caused by the users.
In terms of third parties, CICLO is responsible with making sure that, third parties processing data on behalf of CICLO provide sufficient guarantees to implement adequate technical and organizational measures and therefore the processing of personal data meets the requirements of the present regulations and ensures the protection of the intended person’s rights.
! Financial data necessary for the processing of payments are processed in safety conditions by: MobilePay.
CICLO stores data only throughout the period wherein the legal basis for data processing exists.
The data provided by users along with the opening of the account will be preserved for the period wherein the account is active respectively and, subsequently, for a period of 1 year. In the extent wherein, when the account is deactivated, the user has not paid all amounts due, the data may be subsequently preserved. After such period, the data will become anonymous and be kept for statistical purposes only.
Data regarding the geographical location and routes taken by users will be preserved for a period of 60 days after the completion of each ride.
Optionally, users may opt for data regarding routes taken to be preserved even after the 60 days term respectively, throughout the entire period wherein their account is active.
After such period, the data will become anonymous and be kept for statistical purposes only.
Personal data processed through by CICLO is stored in safety conditions in Firebase (Google). Firebase ensure the highest standard of data security.
Subject to certain legal conditions, as intended person, you have the following rights in terms of your personal data being processed:
Should you wish to exercise any of the above-mentioned rights, please contact us using the following contact details: email@example.com
CICLO is committed to implement technical and organizational measures so as to make sure the personal data processing meets the conditions set-forth by data protection legislation.
To this end, CICLO has implemented the following measures:
If you have any question, query, demand, or complaint regarding the manner wherein CICLO process personal data, you may contact us at: firstname.lastname@example.org .
In order for us to comply legal obligations undertaken with regard to data security and confidentiality, when you exercise one of your rights as intended person, it is possible for us to ask you to prove your identity and provide us with a copy of an identification document or any information required for verifying that such requests originate from a relevant intended person.
We will take into consideration and demands or complaints we receive and provide answers in compliance with the terms set-forth by the law. Should you be unsatisfied with our response or believe processing is achieved in breach of the applicable legislation, you may formulate a complaint with the Romanian data processing surveillance authority:
National Authority for the surveillance of Personal Data Processing, located at 28-39 Magheru Boulevard, Bucharest, Romania, telephone: 031 80 59 211 / 031 80 59 212.
We reserve the right to amend the CICLO Confidentiality Policy if necessary. In such cases, we will notify all users with regard to the new format of the confidentiality Policy.
The present format of the confidentiality policy was adopted on: 25.06.2020
We, SC CICLO MOBILITATE URBANA SRL, ensure data protection and respect your privacy. We collect, process and use your personal data only with your consent or if there is another legal basis for doing so in accordance with the GDPR; all in compliance with data protection regulations and civil law.
Personal data is only collected to the extent necessary to carry out and process our business relationship or that you have voluntarily provided to us.
Personal data is any data that contains data about personal or material circumstances, such as name, postal address, email address and telephone number.
2. Access and delete your data
At any time, you have the right to access your stored personal data, their origin and recipients, as well as the purpose of their processing. You also have the right to rectification, portability, objections, limitation of processing and blocking or delete any inaccurate or unlawfully processed data.
If there are changes to your personal data, please notify us accordingly.
You have the right to withdraw any consent given to the processing of your personal data at any time. Your request for access, erase, rectification, objection and/or portability, if it does not involve a disproportionate effort, may be addressed to the contacts listed in section 8 of this statement.
If you believe that our processing of your personal data infringes data protection legislation or that your data protection rights have been infringed in another way, you can notify us, or you have the right to lodge a complaint with the authority competent supervision.
3. Data Privacy
For the protection of your personal data, we take appropriate organizational and technical precautions. These precautions relate in particular to safeguards against unauthorized, unlawful and including accidental access, processing, loss, use and manipulation. Despite all efforts to maintain a high level of due diligence, it cannot be excluded that the information you make available to us via the Internet may be seen and used by third parties.
Please note, therefore, that we assume no liability for disclosure of information due to errors during data transmission not caused by us and/or unauthorized access by third parties (e.g. hacker attack on an e-mail account or telephone, interception of faxes).
4. Use of data
We will process the data you have provided for the purposes of providing services, marketing, to send newsletters and to contact you by mail and telephone, on paper and for purposes to which you have given your consent or which are regulated in accordance with the GDPR. Exempted from this is the use for statistical purposes, if the data made available was anonymous.
5. Transfer of data to third parties
In order to be able to complete your order, it may be necessary or required by law to transfer your data to third parties (for example, service providers we employ and to whom we provide data, etc.), courts or public authorities. The transfer of your data will be carried out exclusively in accordance with the GDPR, in particular for the completion of your order or based on your prior consent.
6. Reporting data incidents
It is our aim to ensure that data breaches are detected as soon as possible and that they will be reported, as appropriate, depending on the respective categories of data, to you or to the supervisory authority of the jurisdiction.
7. Data Storage
We will storage your data no longer than is necessary to fulfill our contractual or legal obligations and to defend against any liability claims.
8. Our contact details
If you have any questions or requests regarding the processing of your personal data, please contact:
Name: SC CICLO MOBILITATE URBANA SRL
Address: Prelungirea Craiovei, nr. 107, sat Geamana, Comuna Bradu, judetul Arges
Phone number: +40 371 900 191
Email address: email@example.com