Data Protection Policy for the users of the HOOBA app.

This information notice concerning data protection (« Notice ») aim at informing you about how SMOOVY SRL (established at B-1200 Brussels, Rue d’Octobre n° 51 and registered with the Crossroads Bank of Enterprises under the number 0741.693.870, operating under the name HOOBA, hereinafter: « Hooba » or « We »), as a data controller, processes certain personal data about you when you use the Hooba application as a user (« data subject » or « you »).

 

  1. Categories of personal data processed

The personal data collected and processed include the following information:

  • Identification data

Your last name, first name and the organisation you work for;

Your email address and password;

  • Data concerning the use of HOOBA

Access logs; and

Location data when you use the application, a Hooba fleet vehicle or a smart lock.

 

  1. Purposes of the processing, legal basis and storing period

Purposes: Your personal data are processed to enable you to use the Hooba service and to manage access to and maintenance of the Hooba application, vehicles and accessories.

Legal basis: Hooba’s legitimate interests in fulfilling its contractual obligations to your employer.

Data storing period: Hooba will delete your personal data after a period of [36] months following the deactivation of your user account.

 

  1. Personal data transfer

Your personal data are transferred to Hooba’s sole subcontractor (Lattis), in relation to which Hooba has taken appropriate measures for the protection of your personal data, in accordance with the applicable laws.

Your personal data are transferred to countries outside the European Economic Area, including the United States. An adequate level of personal data protection is guaranteed by the adoption of the European Commission’s standard contractual clauses, which constitute appropriate safeguards for the transfer of data to a third country. 

 

  1. Your rights

As a data subject, provided that the legal conditions be met, you are entitled to request access to your personal data, as collected and processed by Hooba, and to request rectification in the event of inaccuracy or deletion in certain limited cases or when the data are unnecessary. You also have the right to request the limitation of the processing, the portability of personal data and you have 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 consider that the processing of your personal data constitutes a breach of applicable law.

To exercise your rights, simply contact Hooba by sending a written and signed request to the following e-mail address [management@hooba.eu] or postal address HOOBA – Rue d’Octobre n° 51, B-1200 Brussels, Belgium, with a copy of your identity card or any other document proving that you are the person 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 website of the authority: https://www.dataprotectionauthority.be/procedures.