Privacy Notice
Effective: June 27th, 2024
At FYN and our family of companies (collectively "FYN" "we," "us" or "our"), we are strongly committed to transparency, and we want you ("you" or "your") to understand how we collect, use, share and protect your information. This Privacy Notice ("Privacy Notice") describes how FYN handles information in connection with FYN's websites (including its e-commerce shop), FYN-branded user-owned vehicles, FYN-owned vehicles and related mobile applications and services (collectively, the "Services"), and when you otherwise interact with us. When specified, this policy also describes our data practices related to Juicers. Please also read our User Agreement which sets out the terms governing the Services.
We may change this privacy policy from time to time. In the event of material changes we will i) inform you about these changes in advance and ii) inform you of your right to object to these changes
The Types of Information We Collect
We collect or receive information in different ways. The types of information we collect or receive depends on how you use and interact with our Services. In many cases, you can choose the information you provide to us, although certain information (such as account information) is required for us to provide the Services and if it is not provided, we will not be able to provide the Services. We use and disclose this information for the purposes described further below. The types of information we collect include:
Account Information such as your name, e-mail address, telephone number, date of birth, gender, address details, and payment information such as your credit card details. In order to use certain products, we may also require you to provide photos of your government issued driver's license (front and back) or other government issued ID.
We collect and process location data when you sign up and use the Services. For example, to accurately show you FYN vehicles near your location, it is necessary to collect and record the physical location of your device. Data such as the location of the vehicle, the routes taken by the moped, bike, scooter, or other vehicle and its rental status are also necessary to provide the Services. In the event you register your own vehicle on our Services, we collect location data to show you the location of your vehicle and to enable you to lock and unlock it. FYN also collects location data directly from FYN vehicles including when a FYN user is riding, such as journey information.
When you use certain products (e.g. mopeds) that require a government-issued driver's license and the use of a helmet or other legally required protective gear, we will ask you (and your passenger, if applicable) to take a selfie which we collect, and we may collect images and/or video footage of your ride. By providing us images of your passenger or guest rider, you represent that you have authority from your passenger/rider to share such information with us.
If you link, connect, or login to FYN with a third-party service (e.g. Facebook), the third-party service may send us information such as your profile information from that service.
When you ask for customer service, support or other assistance, you can choose to provide us with your contact information so we can better respond to your requests and we may keep information about your engagement with our support services.
FYN and third parties (such as Facebook) collect information from your browser, computer, or mobile device, which provide us with technical information such as your device's source IP address when you access or use the Services. We use cookies and similar tracking technologies (like pixels and tags) to provide our Services, including to protect the security of the Service, remember your settings and to gather analytics information about you. Third parties may use the technical information to provide measurement services and targeted ads.
We collect information you share on the Services such as when you participate in communities or other forums, or comment on our social media accounts or blog entries. Depending on your camera or photo settings, FYN will receive information you choose or obliged to send us (such as photos of parked FYN vehicles).
We receive information about you when we use third-party partners such as marketing and advertising partners, such as social media networks.
How We Use Information
We use your information, including information about your location, to:
provide the Services to you at your request including to manage your account and ride history. This includes where you access the Services via Integrated Partner services, such as OTOride.
confirm your government-issued driver's license (if provided) is valid, not currently linked to any other FYN account, and has not expired;
verify your selfie matches your government issued driver's license such as by using facial recognition technology.
monitor, track and service the FYN vehicles, including when they are in use by you. Where applicable, this includes collecting images and/or video footage of your ride;
confirm riders and guest riders are wearing a helmet and other legally required protective gear, where required;
ship or deliver products that you purchase through our e-commerce store or otherwise, including associating the unique ID code of any vehicles purchased through our e-commerce store with your account;
process payments, subscriptions or donations and any discounts or special offers such as free unlocks;
communicate with you about your account, interactions or transactions including service- related announcements such as changes to our policies. As allowed by local law, we may also send you surveys or marketing communications on behalf of FYN and/or third parties, including information about features and enhancements to our Services;
personalize advertisements to you (for more information, see the "Advertising and Analytics" section below);
optimize, develop and improve our Services, including for creation and training of machine learning models to optimize, develop and improve our Services (e.g. to improve the accuracy of our helmet detection software). To do this we may use third party analytics providers to understand how the Service is being used and to help us to improve the Services;
where necessary, to comply with our legal obligations including to meet regulatory or local law requirements;
detect, investigate, and prevent activities that may violate FYN's policies or User Agreement or be illegal which may include sharing information with government agencies outside of your home country, such as law enforcement agencies; and
share and collaborate with third parties such as universities, local government authorities and other third parties to build or improve transportation infrastructure, as described in the "Who Do We Share Your Information With?" section below;
Who Do We Share Your Information With?
We share your information with FYN's affiliated companies, our service providers, other third parties where it is necessary to perform the User Agreement and as described in this Privacy Notice. In particular, we share your information with:
Our service providers and partners: We share your information with our trusted service providers, partners, and their personnel who provide services to FYN such as hosting data and our infrastructure, providing ID verification services, processing payments and donations, supporting and improving the Services, performing customer service, or providing marketing and advertising services. For example, we share information with credit card issuers in order to process your payments and refunds.
Collaborations with third parties : After removing certain identifiers, such as your name, phone, and e-mail address (where provided), and combining the resulting information with similar information from other users, FYN may use, license, and share your information, including individual trip records and trip location (journey) history, with third parties for research, business or other purposes. For example, FYN partners with universities to collaborate on research projects such as understanding traffic and travel patterns in a city.
Government, regulatory and law enforcement agencies: We may share your information if we believe in good faith that it is reasonably necessary to do so for legal reasons, including to meet local law requirements or as part of a judicial process or to detect, investigate, prevent, and address fraud and other illegal activity, security, or technical issues or to prevent harm or injury to you, members of the public, our staff, other third parties, or ourselves; or if we need to do so to defend our legal rights or property, to take action regarding illegal activities or traffic offenses, or to enforce our contracts, such as our User Agreement.
Integrated Partners: We share your information with third party services which integrate or provide access to FYN vehicles and/or the Services and/or to provide access to third party vehicles on the Services.
Cities, local authorities and public transport operators: We share your information with these recipients where necessary to fulfill conditions of our license or where necessary to operate in a particular city or location or for the purposes of city planning and understanding mobility insights. This may include the recipients contacting riders to request participation in surveys and integration into public transport operators' apps and journey planning apps. The data shared for these purposes includes:
Account information, such as FYN user identifier, name, email address, telephone number, government-issued driver's license, date of birth, and gender;
Trip data, such as trip ID number, date and time of trip, distance of trip and duration of trip;
Location data, such as location of the scooter and the routes taken by the scooter;
Survey data, such as FYN user identifier, survey date, survey type and question and answer (in the case of user experience surveys only). Such survey data may be onward shared by the DfT with their third-party research contractors for the purpose of e-scooter trials.
Pseudonymos data such as vehicle ID, vehicle status, trip ID and way point.
FYN affiliates: We may share your information with FYN affiliate companies to help provide, maintain and improve the Services. As we grow, we may expand our corporate family by establishing local subsidiaries or other affiliates as needed, to help us provide or market the Services.
Business re-organization : We may also share your information as part of a sale, merger, change in control, or in preparation for any of these events.
We may also share aggregated, depersonalized, or deidentified information that cannot reasonably be used to identify you with third parties, including the types of third parties listed above.
Advertising and Analytics
We allow others to provide analytics services and serve advertisements on our Services and on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by FYN and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, measure the effectiveness of our advertising, and better understand your online activity. You can manage your preferences, find more information about interest-based ads, or opt out of having your web browsing information used for behavioral advertising purposes. If you are in the EU, please visit https://www.youronlinechoices.eu/.
Where FYN uses the Facebook pixel (a type of cookie), to provide advertising to you, FYN and Facebook Ireland are joint controllers for this processing. FYN and Facebook Ireland have divided their responsibilities under GDPR in respect of this joint processing, for example, FYN is responsible for providing this notice to you and Facebook Ireland is responsible for managing your individual rights relating to the joint processing. For information on how to exercise your rights with Facebook Ireland in relation to the joint processing, and for information on how Facebook Ireland subsequently processes your personal information as independent data controller, please see the Facebook Data Policy.
We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.
We do not sell or share your personal information with third parties for their direct marketing purposes, except with your consent.
Our Legal Basis for Using Your Information
In Europe, we are required to specify the purposes for which we process your personal information and the legal bases which we rely on to do this. FYN relies on a number of legal bases to collect, use, share, and otherwise process your information for the purposes described in this Privacy Notice, including where:
it is necessary to provide the Services and perform our obligations in accordance with the User Agreement. For example, we cannot provide the Service unless we collect and process basic information about you and your location;
you have provided your consent to us processing your information (in which case you may revoke your consent at any time);
necessary to comply with a legal obligation, including, for example, responding to government agency or law enforcement information requests or to establish, exercise or defend legal claims;
to protect vital interests of our users, staff, and members of the public both on and off the Services;
it is permitted by law, we may process data in the public interest; and / or
the processing is necessary for the purposes of FYN's or a third party's legitimate interests, provided that we have balanced these against your fundamental rights and interests.
How We Transfer Your Information
As we offer our Services in many locations globally, we may transfer your information to or from these locations for the purposes of providing you Services.
If you are habitually resident in the European Economic Area (" EEA"), Switzerland or the United Kingdom, we will transfer or transmit your information to the United States and other countries outside of where you live for storage, processing and the other purposes described in this Privacy Notice. Countries which are outside the EEA, Switzerland or the United Kingdom may not offer the same level of data protection as in your home country, for example there is currently no adequacy decision in respect of the United States. Where the European Commission has recognized a country as providing an adequate level of data protection, FYN may rely on the Commission's adequacy decision, as applicable, to transfer data.
FYN also relies on Standard Contractual Clauses approved by the European Commission to transfer data from the EEA, Switzerland and the United Kingdom to the United States and other countries outside of where you live. You may request a copy of Standard Contractual Clauses by contacting us at fyn.mob.cy@gmail.com.
In certain limited circumstances, we may use derogations, such as the contractual necessity derogation, where appropriate to process personal information, when there are no other data transfer mechanisms applicable. For example, where the transfer of information is necessary to provide our Services as set out in the User Agreement.
How Long We Keep Information
We keep your information for as long as is reasonably necessary to provide the Services to you or until your account is deleted, whichever is longer, subject to any longer period as may be required by applicable law or notified to you. Examples of some of our retention periods are set out below.
Type of Data
Retention Period
Account information
Lifetime of the account. Certain information relating to transactions relating to an account are retained for 7 years in line with FYN's accounting obligations.
Government issued driver's license information and result of verification of whether selfie matches ID
After we conduct verification checks to ensure the license is valid, we retain only limited verification information for fraud prevention purposes and in order for you to use the Services. When we use facial recognition technology to verify that your driver's license matches your image, we retain only information about whether the image matched. We retain this information for the lifetime of the account unless a different period is required by law in your jurisdiction.
Customer support queries
Lifetime of the account.
When you delete your account, it may take us additional time to fully delete your information from our databases and system logs. We may also retain information from deleted accounts to prevent fraud, collect fees, enforce the User Agreement, to comply with our legal obligations or enforce our legal rights.
Your Rights
While some of these rights apply generally, certain rights apply only in limited cases. Some of these rights may not apply to you if you are based outside the regions indicated below.
EEA / Swiss / UK Rights
If you are habitually located in the EEA, Switzerland or the UK, you benefit from a number of rights in relation to your information.
Right to object (marketing) - You have the right to object to processing for direct marketing purposes at any time.
Right to object (legitimate interest) - Where we process your information based on legitimate interests, you can object to this processing in certain circumstances. Unless we have compelling legitimate grounds or where it is needed for legal reasons, we will cease processing your information when you object.
Right of access - You can access much of your information by logging into your account. You can also request a copy of the information we have about you and information explaining how the information is used.
Right of rectification - You have the right to request that we rectify inaccurate information about you.
Right of erasure - You have the right, in certain cases, to request that we delete your information, provided there are valid grounds for doing so and subject to applicable law.
Right to restrict processing - You have the right, in certain cases, to temporarily restrict the processing of your information by us, provided there are valid grounds for doing so.
Right to data portability - You may have the right to receive certain of your information in a structured, commonly used and machine-readable format and to transmit such information to another controller.
Right to withdraw consent - Where you have previously provided your consent, such as to send you direct marketing, you have the right to withdraw consent at any time. However, this will not affect the lawfulness of the processing based on consent before its withdrawal. Furthermore, even in case of a withdrawal, we may continue to use your information as permitted or required by law.
Right to provide guidance on the management of your data after your death - You have the right to provide us with specific guidance on the storage, deletion of communication of your personal data after your death.
Please get in touch with us as set out in the "Who Is Responsible for My Information?" section below if you would like to exercise any of these rights or in case you should have any concerns about how we process your information. For security purposes, we may require that you follow certain steps in order to verify that you are the owner of a FYN account. For example, we may require that you have a verified email associated with your FYN account and that you get in touch with us using the verified email associated with your FYN account. You also have the right to lodge a complaint with your local supervisory authority for data protection. You can access a list of EU supervisory authorities here. You can also contact FYN's Data Protection Officer at fyn.mob.cy@gmail.com.
Your Choices and How You Can Manage Your Information: We believe you should have choices about the collection, use and sharing of your information. If you do not want FYN to collect your information, please do not use the Services.
Emails and Other Communications: If you would like to change the types of communications you receive from us, including opting out of promotional communications from us, you may do so at any time by updating the communication preferences specified in your account profile. We may continue to send non-promotional communications and other information about your use of the Service.
Accessing and Managing Your Information: If you have an account with FYN, you can review, change or delete your information by logging into your account and editing your profile. You can change your mobile phone number or email address by using our in-app change feature. You can delete your FYN account at any time by submitting a request to us at fyn.mob.cy@gmail.com or by using the in-app "Submit a Request" feature.