Privacy Notice for users of tier vehicles in third party apps

Last update: 8/7/2020

In this privacy notice, we will describe details of our data collection and processing practises when users rent TIER vehicles through third party apps. If you use the TIER app, this privacy notice applies to you.

We call “third party app” or “service provider” the service or services you are using to rent TIER vehicles. These services may be, but are not limited to Jelbi, Ruter, SIXT and Moovel.

The data described below is minimal and very limited in scope due to your personal data being mostly processed in and by the service provider’s app you are using. TIER will generally get access to and process only the data that is absolutely required in order to provide users with the vehicle service.

1. Who controls your data

The entity responsible for your personal data is TIER Mobility GmbH (“we”, “us”, “TIER”), located in Germany, c/o WeWork, Eichhorn Str. 3, 10785 Berlin. You can contact us for enquiries on your personal data via privacy@tier.app.

TIER’s Data Protection Officer contact details are:
dpo@tier.app

2. How we obtained your data

You can rent TIER e-mopeds and scooters in third party apps. If you do so, the third party provider will send us some data associated with you so that we can process the booking in our systems.

3. Types of data we receive and process

  • External anonymous identifiers (e.g. ff9293h-bdaj38-rd) which corresponds to user IDs in the third party service’s system;
  • The existence of a valid driver’s license verification;
  • Vehicle location data;
  • Vehicle velocity data throughout trips.  

In case you are involved in an accident with one of our vehicles, we will ask the service provider to share your personal details with us. We may then collect your full name, phone number and email address in order for our insurance company to process your accident case.

We retain the data described above all the period of your relationship with the service provider and after that in anonymised form for 5 years.

For Jelbi users

We usually receive the data described above along with specific personal data of users, like full names, email addresses and phone numbers. We also act as the controller of the data extracted from your driver’s license and/or ID card. This data, however, is stored by Jelbi and we only have access to the driver’s license verification result (i.e. successful/unsuccessful).

4. Reasons to process your personal data    

Data

Legal Basis

Reasons to process data

User identifier

Vehicle location data

Fulfilment of contract

TIER needs to be able to identify you and locate vehicles so as to provide you with the vehicle service.

Vehicle location data

Fulfilment of contract

TIER needs to process vehicle location data in order to prevent vehicles from being parked outside our business areas.

Driver’s license verification result

Fulfilment of contract

In case you have verified your driver’s license, TIER needs to have access to the verification result in order to determine whether you should be allowed to rent TIER e-mopeds.

For Jelbi users  

In order to drive TIER e-mopeds, you must verify your driver’s license. TIER is the controller of the license verification process and data in the Jelbi app. Although having a successfully verified driver’s license is a requirement for being able to rent TIER e-mopeds, we will only collect your driver’s license data based on your consent. You may withdraw your consent at any time, also by aborting the verification process.  

Driver’s license verification process  

We commission Veriff OÜ, Niine 11, 10414 Tallinn, Estonia (referred to as “Veriff” below), to provide us with the document verification service. Once you consent to have your personal documents verified, you’ll be asked to:    

  1. Take a picture of your driver’s license. If none of the photos you make enable Veriff to verify your driver’s license, you will be redirected to the beginning of the verification process.
  2. Take a picture of yourself holding your driver’s license;
  3. Take a picture of your face. If none of the photos you make enable Veriff to verify your identity, you will be redirected to the beginning of the verification process.  

A video will be recorded throughout the verification process.

Veriff will then inspect and check data for accuracy and completeness, and verify that it has not been manipulated.  

In the event that the pictures taken are insufficient for the verification to be completed, you will be redirected to the start of the verification process.  

Verification data retention  

The data resulting from the verification process will be stored in Veriff’s systems for 24 hours, and Veriff will send Jelbi the following data: 

  • Verification result (e.g. successful/unsuccessful);
  • Driver’s license expiry date;
  • Unsuccessful verification result reason.  

5. Your data protection rights