Privacy policy

As part of its activities, Hooba collects and processes personal data.

This notice aims to inform you about how SMOOVY SRL (with its registered office at B-1200 Brussels, Rue d’Octobre No. 51 and registered with the Crossroads Bank for Enterprises under No. 0741.693.870, operating under the name HOOBA, hereinafter: "Hooba" or "We", "Our") as the data controller, processes certain personal data concerning you when you use the Hooba-Sharing application ("Our Application") as a user ("data subject" or "you") and the rights you have.

 

1. Categories of Personal Data Processed

Generally, when you use Our Application, We process your identification data and data related to its use.

When you use Our Application, We process the following personal data:

Identification Data

• Your name, first name, and the organization for which you work or the entity through which you access Our services;
• Your email address, phone number, and password;
• Your credit card number for using a paid fleet;

Data Concerning the Use of HOOBA-Sharing

• Access logs; and
• Location data when you use the application, a Hooba fleet vehicle, or a connected lock (smart lock); and
• "End-of-ride photos" that you must take and submit at the end of your ride as well as camera access to scan the vehicle's QR code to rent it.

 

2. Purposes of Processing, Legal Basis, and Retention Period

Purposes : Your personal data is processed to allow you to use Our Application, the Hooba service, and to manage access to and maintenance of Our application, vehicles, and accessories.

Legal Basis for Processing : The processing of your personal data is based on Hooba’s legitimate interest, namely, fulfilling Our contractual obligations to Our clients (the entity providing you access to Our services, such as your employer or the owner of the building where you work or reside).

Data Retention Period : Hooba will delete or anonymize your personal data within 12 months after the deactivation of your user account. However, certain data may be retained longer if necessary to meet legal or contractual obligations.

 

3. Transfer of Personal Data

Hooba transfers your personal data to its application provider, Joyride, located in Canada. Joyride is subject to the Canadian Personal Information Protection and Electronic Documents Act of April 13, 2000. This data transfer is governed by an adequacy decision of the European Commission dated December 20, 2001, which ensures an adequate level of protection for your data in Canada. Hooba may also disclose your personal data to other subcontractors or third-party service providers who perform certain services (payment services, email services, etc.) on our behalf. These providers are required to comply with adequate security measures and confidentiality obligations.

 

4. Joyride: Joint Controller and Separate Controller

Hooba and Joyride are joint controllers for the collection of your personal data via Our application and the transmission of this data to Joyride. The main lines of the agreement between Hooba and Joyride are available in the appendix to this policy. You can find more information about Joyride's processing of your personal data on their website: https://joyride.city/privacy-policy/.

Joyride also processes your personal data as a separate controller within the scope of your use of Our application, particularly to improve its services. You can find more information about Joyride's processing of your personal data on their website: https://joyride.city/privacy-policy/.

 

5. Security Measures

Hooba implements appropriate technical and organizational measures to ensure a level of security for the processing and collected data concerning the risks presented by the processing and the nature of the data. In any case, Hooba implements appropriate security measures to protect your personal data against loss, theft, misuse, alteration of the received information, unauthorized disclosure, or use.

 

6. Your Rights

As a data subject, provided the legal conditions are met, you have the right to access your personal data as collected and processed by Hooba and to request its rectification if inaccurate or deletion in certain limited cases or if it is no longer necessary. You also have the right to request the restriction of processing, data portability, and the right to object to the processing of your personal data due to your particular situation. You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data constitutes a violation of applicable legislation.

To exercise your rights, simply contact Hooba by sending a written and signed request to the email address [management@hooba.eu] or by postal mail to HOOBA – Rue Henri Chomé No. 39, B-1030 Brussels, Belgium, accompanied by a copy of your identity card or any other document proving that you are the data subject concerned by the personal data.

In Belgium, you can file a complaint with the Belgian Data Protection Authority. More information can be found on the authority’s website: https://www.autoriteprotectiondonnees.be/citoyen/agir/introduire-une-plainte.

 

 

Appendix 1: Information to be provided to data subjects

 

Essence of the Joint Controller’s agreement

 

Introduction

This notice is provided to inform you about the essence of the Joint Controller Agreement

between Hooba and Joyride (the "Joint Controllers"). Both companies are responsible for

protecting your data and ensuring your rights under the GDPR when you use the Hooba-Sharing

application.

 

Essence of the Joint Controller’s agreement

Who collects your data : Hooba and Joyride jointly collect your personal data when you use the

Hooba-Sharing application. The joint collection of your personal data by Hooba and Joyride is

necessary to offer you the micromobility rental services and for the Joint Controllers to perform

their duties.

Why they collect your data :

• Hooba uses your data to provide you the micromobility services.

• Joyride uses your data to maintain and improve its products and services.

How they use your data : Both companies have committed to following strict data protection

rules. This includes: keeping your data secure, only allowing authorized personnel to access

your data, and responding to your requests related to your data.

Data subjects’ rights : You have several rights concerning your data under the GDPR. Hooba

is designated as the primary point of contact for all requests related to your rights under the

GDPR, including the rights to access, rectify, erase, restrict processing, data portability, and

object to processing as described in Articles 15 to 22 of the GDPR.

For further details : Please refer to Hooba's privacy policy and/or Joyride’s privacy policy for a

more comprehensive explanation of how your data is handled.