Privacy Policy

Cogo ApS, CVR 41261560, Sprogøvej 17 4mf, ℅ Eriksson, 2000 Frederiksberg, Denmark (“Cogo”, “the Company”, “we” or “us”), takes all necessary steps to ensure that Personal Data Processed by us regarding our users and app/website visitors is Processed lawfully and fairly. This policy (the “Privacy Policy”) explains why and how we Process Personal Data relating to: (I) Users that install and use the Cogo mobile application (the “app”); (ii) Users that visit the www.cogoapp.io website; (iii) Users that use and access the Cogo Services provided through or enabled by the app (the “services”). The Privacy Policy explains and clarifies your rights in relation to the Company regarding the Processing of your Personal Data and how you can exercise your rights. The Privacy Policy complies with EU General Data Protection Regulation (EU 2016/679) (the “GDPR”).


 

1. CONSENT

By using the Company’s Services you, the user, acknowledge this Privacy Policy and the Company’s approach to protecting your Personal Data. Therefore, it is important that you read and understand the Privacy Policy before using the Services, as defined below. 


 

2. APP USERS & WEBSITE VISITORS

The Company operates a mobile application (“Cogo”, “App”) and the website www.cogoapp.io (“the website”). When using the mobile application or visiting the Company’s website you, the user, have the choice to accept that we use cookies to enhance your experience when using our website. If you accept cookies, you accept that your Personal Data is Processed in accordance with this Privacy Policy and the Company’s approach to protecting your Personal Data. Therefore, it is important that you read and understand the Privacy Policy before accepting the use of cookies and continuing using the app or website.

 

This website’s hosting services are offered by Wix.com Ltd (“Wix”). Wix is committed to observing the EU data protection law. Wix.com participates in, and has certified its compliance with, the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. More information on Wix terms can be found here:

https://www.wix.com/about/privacy

 

We also use Google Analytics to measure the use of our web services. Google Analytics may place cookies on the user’s device to collect data, for example on website’s visitor numbers. More information on Google Analytics’ terms are found here:

https://policies.google.com/privacy/partners?hl=en


 

3. SCOPE

Cogo may contain links to websites, apps, products or services that are operated by third parties. This Privacy Policy does not extend to these third parties on which we have no control, and for which we cannot be held liable. We encourage you to read about the privacy policies, procedures and practices of those third parties.


 

4. DEFINITIONS

“Personal Data” means any information relating to an identified or identifiable natural person. Personal Data may include information such as personal and professional contact details, address, payment information, and cookies placed on a device;

 

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction; and

 

“Services” means any services provided by the Company to its app users or website visitors, for example in our app, once you have given us your consent to track your location, we keep track of your location and movement, including your latitude, longitude, time and speed of travel,  in accordance with the order terms and conditions, which can be found at www.cogoapp.io/privacy.


 

5. TYPES OF PERSONAL DATA

If you use our Services, you may provide Personal Data to us. The types of Personal Data that we collect may, depending on the context, include:

  • name and contact information including address, phone number and email address;

  • company name;

  • delivery and billing information, payment information and other information that you provide in connection with the use or purchase of a product or service;

  • information about preferences and interests based on the use of our app or websites;

  • Your location and movement, including your latitude, longitude, time and speed of travel.

  • collection of location data only happens while Cogo is in the foreground (unless explicitly stated otherwise) and if you’ve granted access to your device’s location services.

  • username and password for our services;

  • unique ID of the device

  • usage details, including the country of origin, the searches you make, the routes you interact with, the type of phone or OS you are using, etc.

  • other information that is relevant for customer surveys, advertisement/marketing or offers; and/or

  • other user-generated information that you actively choose to share through our websites.

 

We may collect your Personal Data from the following sources:

  • any of Cogo’s app or websites, when you use our Services; or

  • from third parties in the form of business partners, such as payment service providers, and companies that the Company engages for marketing purposes.

 

Cogo does not require personal information to be entered in order to conduct a search on our application. We may collect personal information when our on-demand Services are used, or when the User registers with a Mobility Provider or for our newsletter.

 

In order to allow a User to access the Mobility Services of a third-party Provider through Cogo, we may ask the User for certain data which is sent to the Provider, who will process it as independent data controllers. The personal data may includes, but not limited to: name, address, age, nationality, select information on an identity document or driving licence, payment information, password, PIN, etc. This data is processed confidentially and stored securely, and is only transmitted to the Provider of a Mobility Services if the User asks Cogo to access those Mobility Services through Cogo. The communication of that data to the Provider is necessary to enable the User’s request, and without it, Cogo is not able to provide the Service requested.

 

Cogo is a separate entity from the Mobility Providers and their services and Cogo should not be confused with them as clarified in our User Agreement for the website www.cogoapp.io and the Cogo App. Cogo is not a representative of the Providers and does not act on their behalf in the collection of the User’s personal data. As such, the personal data collected independently by Cogo to allow the User to access the Mobility Services, including the login credentials relative to accounts with the Providers of the aforementioned Services, will be processed by Cogo ApS exclusively in the interests of the User and in order to carry out their requests.


 

6. PURPOSE AND LEGAL BASIS FOR THE PROCESSING

Users

In relation to our users, it is necessary for us to Process their Personal Data for the handling and administration of purchases, to make payments, to give access to our app and websites as well as to provide, operate and improve the Services. Consequently, the legal basis for this Processing is that it is necessary for the performance of a contract.

 

We may also Process your Personal Data in order to improve our Services, e.g. the customer service, and to provide you with relevant information and marketing. Such Processing is based on our legitimate interests.

 

The Company may as well Process your Personal Data if there is a legal obligation to do so, for example in accordance with the Danish Book-keeping Act (DK. Bokføringslov 1998:1006).


 

App and Website users

Using cookies is necessary for providing and improving your website experience. The legal basis for this Processing is your consent, which you provide to us by actively clicking “I accept” to the question of whether you accept cookies or not when using our app or visiting our website. For more information on our use of cookies, please see section 9.

 

If you provide us with your contact information through the contact form in our app our on website, we will Process your Personal Data in order to respond to your request.


 

All

If you have chosen to receive our newsletter or any promotional material from the Company, as set out in section 3 below, we Process your Personal Data, i.e. your contact information, based on your consent, for the purpose of sending you the requested material.

 

Further, the Company may Process Personal Data in order to improve its Services, e.g. the customer service. Such Processing is based on the Company’s legitimate interest.

 

Furthermore, after you have submitted your Personal Data for our newsletter, in our job application form, feedback submission  or the registration form, we will have the option to contact you with marketing or promotional materials and other information, unless you choose not to receive such materials, by ticking the appropriate checkbox when providing us with your Personal Data in the above mentioned forms. You will also have the option to opt-out or unsubscribe, from receiving marketing or promotional materials at any time, by choosing the “unsubscribe” option in the emails we send you. If you receive any promotional materials by mail, the material will include specific contact information for unsubscribing from this service.

 

In sum, we Process your Personal Data for the following purposes:

 

  • To facilitate your use of our app, the website, our Services, and products

  • At the request of the User, allow them to book, register, or pay for the Mobility Services offered by the Third-Party Mobility Providers; the booking of those mobility Services requires the User to enter their authentication credentials pertaining to the account activated with the Supplier of the Mobility Service selected on each occasion; those credentials will be stored on the User’s device, following the application of adequate security measures by the Data Controller

  • The provision of the services may also require the sending of service messages and communications, devoid of advertising content, via e-mail, SMS/MMS/USSD or notification within the mobile application. These messages are considered part of our Services and therefore it may not be possible to disable receipt of them.

  • To contact you as part of the ordinary customer relationship

  • To send you newsletters or other marketing material, including surveys and event invitations

  • To provide general customer service and support

  • To gain customer insights and knowledge of how our various services, including app and websites, are used as well as evaluation and improvement thereof

  • To comply with any applicable law


 

Specifically about consent as legal basis for the Processing

In the event that a service that we provide requires your consent, we will always explicitly ask you to give your consent to such a service and to the Processing of your Personal Data in such a case. For example, we will ask for your consent if you would like to subscribe to any of the Company’s newsletters.

 

In the event that we Process your Personal Data based on your consent, e.g. regarding subscription to newsletters, you may withdraw your consent, in whole or in part, at any time by contacting us at privacy@cogoapp.io. Further, if you do not wish to receive marketing and special offers sent by email from us you may withdraw your consent through a link in the email footer.

 

In connection with your giving of consent, you will have to confirm that you have read this privacy policy and that you consent to the processing of your Personal Data as described herein.


 

7. STORAGE

The Company takes all reasonable steps to ensure that your Personal Data is processed and stored securely. Your Personal Data will never be stored longer than permitted by applicable law or longer than necessary to fulfill the above-stated purposes. Your Personal Data will be processed by us during the following time periods.

 

The Company will only store and Process your Personal Data for the following periods of time:

 

Personal Data that has been provided to us through the contact form on our website: Depending on the character of the specific matter but as a general rule, until the specific matter has been handled. There may be instances in which Cogo stores this contact form data for longer periods, specifically to analyze the data and improve our customer support.

 

Personal Data relating to promotional materials: Until you unsubscribe from this service.

 

Personal Data for direct marketing purposes: If you are a customer, we may process your Personal Data for direct marketing purposes for as long as two years after the customer relationship has ended, unless you object to your Personal Data being used for direct marketing purposes.

 

Personal Data relating to purchases: For as long as the customer relationship lasts, which corresponds with the expiration of ride credits, and for two years after that. However, when the customer relationship ends, only your name and information about what purchases and/or what kind of requests you have made will be stored.

 

Legal obligation: The Company saves any documentation that constitutes accounting information in accordance with applicable accounting legislation.

 

Consent: In cases where we process your Personal Data based on your consent, we will only save your Personal Data for as long as we still have your consent.


 

8. TRANSFER OF DATA

The Company may transfer Personal Data about its app users and website visitors to a third party. Such transfers may be made to companies within the EU or the EEA (i.e. all EU member states together with Iceland, Norway, and Lichtenstein). Transfers may also be made to Third countries which are recognized by the EU Commission to have an adequate level of protection. For example, Cogo may work with certified companies in the United States that comply with legal frameworks that establish an equivalent level of protection with EU law. To learn more about the Privacy Shield Frameworks, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list. These third parties are the Company’s service providers or collaboration partners who perform tasks assigned to them on the Company’s behalf. Please note that we always observe great caution when transferring your Personal Data and your Personal Data is only transferred in accordance with this privacy policy and after taking appropriate security measures. Inter alia, we transfer your Personal Data to the following entities:

 

Business partners

For instance, when you purchase or access services from a third party (e.g. a mobility operator) through our app, we will share the information required to ascertain your lawful use of those services (including tokenized payment information, relevant personally identifiable information, and any relevant location data). For example, if you try to unlock an electric scooter, we may verify your location to ensure that you’re near the station before you unlock the electric scooter.

 

Further, in case of a prospective business transaction, you agree that Cogo may disclose anonymous and aggregate information to another corporation in order for the parties to determine whether to proceed with such transaction. In case a business transaction is completed, you agree that any information may be transferred to the corporation that owns Cogo or the relevant part of it in order to carry its business. A “business transaction” includes, but is not limited to, a reorganization, merger, purchase, sale or other acquisition or disposition of a corporation or any of its assets.

 

Further, in case we are required to comply with applicable law and regulations and lawful requests or orders or if it is otherwise permitted by law (i.e., protect and defend our rights, situation that threatens life, health or safety, etc.).

 

We also disclose anonymous and aggregate information to certain third parties for research, product development or other business purposes. For instance, we may share information with mobility operators to help them analyze and improve their services.


 

Third-party service providers

While using Cogo, we may be using third party software and/or service for various needs, inter alia, in order to collect and/or process the information detailed herein (the "Third Party Service Provider"). Note that these are independent software and/or service providers and we do not take any liability about the information collection policies of these providers, or about any kind of issue, legal or otherwise, relating thereto.


 

9. COOKIES

Our app and website use cookies, web beacons and other similar technologies to distinguish you from other users of our Service. This helps us to provide you with a good experience when you use our app or browse our website and also allows us to improve our site.

 

A cookie is a small file of letters and numbers that we store on your phone or browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.


 

We use the following cookies:

 

A) Strictly necessary cookies

 

These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our app and website, use a shopping cart or make use of e-billing services.

 

App location

We collect information about your location if you enable the location service using the settings on your mobile device or with your consent that may be required by law. You can change the privacy settings of your device at any time by disabling location information sharing with our services. Choosing to disable the location services will affect certain features of our services (such as “finding rides near me”). If you have questions about the privacy settings of your device, we recommend contacting the manufacturer of your device or your mobile service provider for assistance.


 

B) Analytical/performance cookies

 

They allow us to recognize and count the number of visitors and to see how visitors move around our app and website when they are using it. This helps us to improve the way our app and website works, for example, by ensuring that users are finding what they are looking for easily.


 

Google LLC (“Google Analytics”)

Cogo is using Google Analytics in order to gain further understanding of how the website is used. Data such as pages viewed and time on site is stored in Google Analytics. You can opt-out of having your site activity available to Google Analytics by installing the Google Analytics opt-out browser add-on:

https://chrome.google.com/webstore/detail/google-analytics-opt-out/fllaojicojecljbmefodhfapmkghcbnh?hl=en


 

The Rocket Science Group LLC d/b/a MailChimp (“MailChimp”)

We use MailChimp to manage our newsletter and other email lists. There’s no third-party tracking in messages we send through MailChimp besides MailChimp’s own analytics, which may aggregate how many subscribers open a message or click the links inside. MailChimp’s privacy policy is available at http://mailchimp.com/legal/privacy.


 

HubSpot, Inc. (“Hubspot”)

We use Hubspot as a service to manage our CRM-database. Hubspot does not use, or allow anyone else to use, our customer data to contact any individual or company. They only use Customer Data to provide their service as permitted by applicable law, their terms of service and their Product Privacy Policy. Hubspot’s privacy policy is available at

https://legal.hubspot.com/privacy-policy

 

C) Functionality cookies

 

These are used to recognize you when you return to our app or website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). They are not used to track visitors on sites that are not hosted by Cogo.


 

D) Targeting cookies / Third party advertising

 

These cookies record your visit to our app or website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose. If you choose not to provide Personal Data Cogo will not be able to personalize advertising targeted towards you in the same way.

 

Facebook, Inc (“Facebook”)

Cogo is using a so-called Facebook pixel to gather information about visitors for marketing purposes. Details about the cookies Facebook use and the data collected can be found in the Facebook Cookie Policy: https://www.facebook.com/policies/cookies/.

 

It is also possible to opt-out of all targeted Facebook advertising here:

https://www.facebook.com/help/568137493302217.

 

LinkedIn Corporation (“LinkedIn”)

Cogo is using a so-called LinkedIn Insight Tag to gather information about visitors to be used for marketing purposes. The LinkedIn Insight Tag creates a unique LinkedIn browser cookie on a visitor’s browser and enables the collection of the following data for that cookie: metadata (such as IP address, timestamp, page events (like page views), and LinkedIn demographic information if there is an active LinkedIn.com member cookie present. For more information see:  https://www.linkedin.com/help/linkedin/answer/65521.

 

Google LLC (“Google”)

Cogo is using visitor data in order to serve advertisements in the Google network (including AdWords), across the internet. The ads are based on visitor data. Google utilizes cookies in order to be able to serve these ads. Visitors can opt out of Google’s use of cookies by visiting Google’s Ads Settings: http://www.google.com/settings/ads.

 

Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.


 

E) Blocking/deleting cookies

 

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. You can find out more about blocking/deleting cookies in specific browsers at http://aboutcookies.org.


 

10. YOUR RIGHTS

You may at any time and free of charge request a transcript of records regarding the Company’s Processed Personal Data regarding yourself. We will then, without undue delay, provide you with an adequate transcript of record.

 

You may at any time contact the Company in order to have us correct inaccurate or incomplete Personal Data regarding yourself. We will then, without undue delay, correct the information in question.

 

You may at any time contact the Company in order to withdraw your consent regarding the Company’s right to Process your Personal Data, as further set out in section 6. This will however not affect the lawfulness of the Processing for the time before your consent is withdrawn.

 

You may at any time request that your Personal Data is transmitted in an electronic format.

 

You may at any time request that the Processing of your Personal Data is restricted or that the Company erase Personal Data regarding yourself. We will then, without undue delay, permanently remove the Personal Data in question from both our servers as well as from any third-party partners if one of the following grounds applies:

 

  • the Processed Personal Data is no longer necessary in relation to the purposes for which they were collected or otherwise Processed;

  • you withdraw consent on which the Processing is based and where there is no other legal ground for the Processing (if applicable);

  • the Processed Personal Data has been unlawfully Processed;

  • the Processed Personal Data has to be erased for compliance with legal obligations

 

You may file a complaint with the Danish Data Protection Agency (Dk. Datatilsynet) if you believe that the Company’s Processing of your Personal Data is not carried out in accordance with applicable laws.

 

All the above mentioned requests to the Company shall be directed to privacy@cogoapp.io. Please note that we may require that you identify yourself in connection with our assistance, for the protection of your privacy and your Personal Data.


 

11. CHILDREN

We do not knowingly collect, use or disclose information from children under the age of 13. If we learn that we have collected information of a child under 13 without first receiving parental consent, we will take steps to delete such information within a reasonable time. If you have reason to believe that a child under the age of 13 has provided information to us, please contact us and we will take steps to delete such information within a reasonable time.


 

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time and any new version will be published in our app and on our website. Thus, we advise you to review this page periodically for any changes. In addition, we will, if you have provided us with your email address, notify you of any material changes by email. The changes are effective immediately after they are posted on this page.


 

13. CONTACT INFORMATION

The Company is the data controller of the Personal Data. If you have any questions or suggestions about this Privacy Policy or other potential privacy and data protection issues, do not hesitate to contact us by sending an email to legal@cogoapp.io and we will examine and reply to all communications within a reasonable timeframe.

 


 

This Privacy Policy was last updated on 29 April 2020

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© 2020 Cogo ApS

 

Company reg. no:

Denmark, CVR 41261560