Mileus Privacy Policy
Introduction
Mileus CZ s.r.o., ID no.: 06992978, Rybná 716/24, Nové Město, 110 00 Praha 1, file no.: C292679 incorporated with the Municipal Court in Prague, controller of personal data (hereinafter “Mileus”, “Our Company”, “we”, “us”, or “our”) pay great attention to the protection of personal data. In this document you will find information about the type of data that we process, regarding in particular our customers and our users (hereinafter “Users” or “you”) (the users of the Mileus website or various applications), whether the data are processed on the basis of consent or some other legal reason, the purpose for which we use the data, to whom we may transfer the data and what your rights are in connection with the processing of your personal data.
These Principles are prepared in compliance with the legal regulations regarding the processing of personal data, including in particular Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter as “GDPR”).
It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.
Definition of basic terms
Expressions “Controller”, “Joint Controllers”, “Processor”, “Personal Data”, “Processing” used in this text need to be interpreted in the context of GDPR:
1. Controller under Article 4(7) GDPR means any natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. In relation to your personal data we act as the controller.Where two or more controllers jointly determine the purposes and means of processing, they are “joint controllers” as defined in Article 26 GDPR. The data subject must be informed on the material elements of the arrangements between the joint controllers to determine their respective responsibilities, in particular as regards the exercising of the rights of data subjects and their respective duties to provide information referred to in Articles 13 and 14 GDPR.
2. Processor as defined in Article 4(8) GDPR means a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controllers.
3. Personal data means all information relating to an identified or identifiable natural person (i.e. the data subject).
4. Processing of personal data under Article 4(2) GDPR means any operation or set of operations with personal data or sets of personal data which is performed with or without 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.
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the following details:
Name of Data Privacy Manager: Juraj Atlas
E-mail address: privacy-manager@mileus.com
The MILEUS platform
Mileus is a technological platform which is operated by Our Company and which enables on-demand transportation service providers to integrate with public transportation network and public transportation service providers in order to automatically interconnect the two modes of transportation into seamless passenger journeys.
Our Company can, at times and in some geographies, also operate an extension of Mileus technological platform that connects the providers of transport/taxi services (fleet operators and their drivers) and mobile customers/passengers and which is accessible via a mobile application or a website.
Our services also include our website at https://mileus.com, our website application at https://try.mileus.com, and any additional websites or web applications owned and operated by Mileus or its affiliates, our downloadable mobile application(s) and related transportation information, and additional services.
We process your personal data only for the purposes of which you have been informed by our company. What personal data we process and for what purpose depends on the manner in which you have provided the personal data to us. Via our website at https://mileus.com or various Mileus mobile and web applications, you have the opportunity to provide us with data such as the following:
Visitor to our website
If you visit our website at https://mileus.com or use our applications, we automatically process some of your personal data to the extent, for the purpose and for the period and for the reason (legal grounds) specified here:
| Purpose | Improvement of website and applications | |
| Scope of processed data | Data on your behaviour at the website or any Mileus applications operated as part of our website (through cookies or similar technologies) | |
| Legal grounds | Our Company’s legitimate interest in improving our website. | |
| Period of processing | 24 months from the last visit to our website | |
| Purpose | Preparation of statistics and reports on the use of the website and applications | |
| Scope of processed data | Data on your behaviour at the website or any Mileus applications operated as part of our website (through cookies or similar technologies) | |
| Legal grounds | Our Company’s legitimate interest in the measurements of the efficiency of our website and our applications, including the advertisements on the website. | |
| Period of processing | 24 months from the last visit to our website | |
You have the right to object to the processing of your personal data for the purpose of pursuing our legitimate interest in improving and measuring the efficiency of our website. If there is no legitimate reason for us to continue the processing of the personal data for these purposes despite your objection, we will terminate the processing of your personal data in this context.
User in the role of a transportation consumer (passenger) of our MOBILE AND web applications (consignor)
Use of the Mileus Market Validation application by a potential passenger
We process your personal data that you have provided to us during the use of the Mileus Market Validation application and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose |
Provision of Mileus services |
|
| Scope of processed data | Home address, work address, e-mail address, user ID assigned by us, your feedback and selected choices in our survey | |
| Legal grounds | Necessary for performance of the application or our ability to fulfill our promise to send you any incentive offered | |
| Period of processing | Home address, work address, e-mail address, weekly commuting habits, and other information provided by you | For 2 years from the submission of the information |
| Your feedback and selected choices in our survey, IP address, user ID assigned by us, information on device accessing Mileus web application (i.e. device type, web browser, etc.) | For 3 years from accessing Mileus Market Validation web application | |
Passenger registration in the Mileus application
By means of the registration form you, as the customer – passenger (or a consignor, for the purposes of this document referred to jointly as the “passenger”), have the opportunity to create your user profile in the Mileus application through which you can use our services. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Registration of user, management and administration of user profile. | |
| Scope of processed data | First name, surname, phone number, e-mail address, IP address, user ID assigned by us, unidirectional hash of payment card | |
| Legal grounds | Necessary for performance of contract, or for implementation of measures adopted before the entry into contract during your registration application. | |
| Period of processing | Until cancellation of registration by user, however, at the maximum for 3 years from the last login. | |
Inserting Passenger’s photo (user’s portrait) in the user profile
Inserting your photo in your user profile is entirely optional. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Recognition for provision of service. | |
| Scope of processed data | Portrait photo | |
| Legal grounds | Consent for Processing of Personal Data | |
| Period of processing | Until withdrawal of consent for personal data processing or until erasure of these data by user in his or her user profile. | |
For you the statement of these personal data is entirely voluntary. You always have the right to withdraw your consent for the processing of personal data in the manner specified below (see item #8 of the “What rights do you have?” section below).
Use of Mileus application by Passenger user
We process your personal data that you have provided to us during the registration and the use of the Mileus application and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Provision of Mileus services. | |
| Scope of processed data | First name, surname, phone number, e-mail address, user ID assigned by us, unidirectional hash of payment card, localization data, GPS coordinates for the time from ordering the service to the end of the ride) information on mobile phone type. | |
| Legal grounds | Necessary for performance of contract. | |
| Period of processing | Localization data (GPS coordinates for the time from ordering the service to the end of the ride), information on mobile phone type | For 3 years from the last provision of the Mileus service. |
| First name, surname, phone number, e-mail address, IP address, user ID assigned by us, unidirectional hash of payment card, information on mobile phone type. | For 3 years from the expiry of contract. | |
| Basic data on legal relationship and its existence (first name, surname, contact data). | For 10 years from the expiry of contract. |
|
If you decide to use the Mileus services, these data are necessary for us to be able to handle your service order and on the basis of this order procure for you a customer for the service.
Sending product and service offers and tailor-made offers
We want to stay in contact with you. In this case, we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Sending our product and service offers and tailor-made offers | |
| Scope of processed data | E-mail address, user ID assigned by us, home address, work address, your feedback and selected choices in our Market Validation survey | |
| Legal grounds | Legitimate interest in staying in contact with you and sending you special offers tailored to your needs. | |
| Period of processing | For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the Mileus application or last visit to Mileus website, whichever comes later. | |
As regards the sending of our product and service offers, which include customised offers as well, we would be glad if we could stay in touch with you. To avoid sending you offers you are not interested in, we use the information you provided us with while using Mileus Market Validation application. However, we do not want to cause you any inconvenience, therefore, you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single commercial communication (see item #8 of the “What rights do you have?” section below).
You have the right to object to the processing of your personal data for the purposes of sending commercial communications, and based on the objection, we will stop sending you commercial communications and terminate the processing of your personal data in this context.
Sending product and service offers and tailor-made offers of our business partners
We would like to send you commercial communications in the form of newsletters and product and service offers of our business partners as well as their tailor-made offers. In this case, we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Sending product and service offers and tailor-made offers of our business partners | |
| Scope of processed data | E-mail address, user ID assigned by us, your feedback and selected choices in our Market Validation survey | |
| Legal grounds | Consent for processing of personal data and sending of commercial communications. | |
| Period of processing | For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the Mileus application or last visit to Mileus website, whichever comes later. | |
The statement of these personal data is entirely voluntary for you, however, these data are necessary so that we can send you commercial communications with the product and service offers of our business partners.
To avoid sending you offers you are not interested in, we use the information you provided us with while using Mileus Market Validation application.
You always have the right to withdraw your consent for the processing of personal data in the manner specified below in the item #1 of the “What rights do you have?” section.
User in the role of an individual on-demand transportation provider (driver) of our mobile and web applications
Use of the Mileus Driver mobile application
Driver registration in the Mileus application.
You have been registered into the Mileus platform by your fleet operator. By means of the registration form your driver profile in the Mileus application has been created through which you can use our services. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose |
Registration of user, management and administration of user profile. |
|
| Scope of processed data | First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car identification (car color, brand, make, year of manufacturing, registration plate). | |
| Legal grounds | Necessary for performance of contract, or for implementation of measures adopted before the entry into contract during your registration application. | |
| Period of processing | First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car identification (car color, brand, make, year of manufacturing, registration plate). | Until cancellation of registration by user, however, at the maximum for 3 years from the last login. |
For you the statement of these personal data for the purposes of user registration, management and administration of the user profile is entirely voluntary, nevertheless, without these data we are not able to perform the account registration.
Inserting Driver’s photo (user’s portrait) in the user profile
Inserting your photo in your user profile is entirely optional. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Recognition for provision of service. | |
| Scope of processed data | Portrait photo | |
| Legal grounds | Consent for Processing of Personal Data | |
| Period of processing | Until withdrawal of consent for personal data processing or until erasure of these data by user in his or her user profile. | |
For you the statement of these personal data is entirely voluntary. You always have the right to withdraw your consent for the processing of personal data in the manner specified below (see item #8 of the “What rights do you have?” section below).
Use of Mileus application by Driver user
We process your personal data that you (or your fleet operator) have provided to us during the registration and use of the Mileus application and some other data concerning you specified in the table below to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Provision of Mileus services. | |
| Scope of processed data | First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car identification (car color, brand, make, year of manufacturing, registration plate), localization data (GPS coordinates for the time from ordering the service to the end of the ride), information on mobile phone type | |
| Legal grounds | Necessary for performance of contract. | |
| Period of processing | Localization data (GPS coordinates for the time from ordering the service to the end of the ride), information on mobile phone type | For 3 years from the last provision of the Mileus service. |
| First name, surname, date of birth, address, e-mail address, phone number, IP address, user ID, numbers and data on the relevant taxi driver licences and certificates, taxi driver’s car identification (car color, brand, make, year of manufacturing, registration plate). | For 3 years from the expiry of contract. | |
| Basic data on legal relationship and its existence (first name, surname, contact data). | For 10 years from the expiry of contract. |
|
If you decide to use the Mileus services, these data are necessary for us to be able to handle your service order and on the basis of this order procure for you a customer for the service.
Sending product and service offers and tailor-made offers
We want to stay in contact with you. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Sending our product and service offers and tailor-made offers. | |
| Scope of processed data | First name, surname, e-mail address, phone number, user ID assigned by us, localization data (GPS coordinates for the time from ordering the service to the end of the ride). | |
| Legal grounds | Legitimate interest in staying in contact with you and sending you special offers tailored to your needs. | |
| Period of processing | For the duration of the legitimate interest, however, at the maximum for 3 years from the last use of the Mileus services. |
|
As regards sending of our customized product and service offers, which includes customized offers as well, we would be glad if we could stay in touch with you. To avoid sending you offers you are not interested in, we use information about the Mileus service that you use. However, we do not want to cause you any inconvenience therefore you have the opportunity to refuse the delivery of commercial communications in the manner specified below and in each single commercial communication (see item #8 of the “What rights do you have?” section below).
You have the right to object to the processing of your personal data for the purposes of sending commercial communications and based on the objection we will stop sending you commercial communications and terminate the processing of your personal data in this context.
Sending product and service offers and tailor-made offers of our business partners
We would like to send you commercial communications containing newsletters and the product and services offers of our partners. In this case we process your personal data to the extent, for the purpose and for the reason (legal ground) specified here:
| Purpose | Sending product and service offers and tailor-made offers of our business partners. | |
| Scope of processed data | First name, surname, e-mail address, phone number. | |
| Legal grounds | Consent for processing of personal data and sending of commercial communications. | |
| Period of processing | Until withdrawal of consent for personal data processing and sending of commercial communications. | |
For you the statement of these personal data is entirely voluntary, however, these data are necessary so that we can send you commercial communications with offers of products and other services.
You always have the right to withdraw your consent for the processing of personal data in the manner specified below (see item #8 of the “What rights do you have?” section below).
To whom do we transfer your personal data?
We cannot always exactly say in advance to whom the personal data will have to be provided. Therefore, we specify the categories of possible recipients and the reasons for which your personal data might be transferred:
| Recipient | Reason for access |
| Persons responsible for the operation of the website, the application and our software (computer systems), including persons providing cloud services and analytical tools. | We need our software provider, who is in the position of the processor, to service our web pages and ensure the operation of our information systems. For the operation of the application, we also use services of third parties. |
| Service providers and persons responsible for distributing e-mails and marketing communication. | A situation may occur in which a third party will be authorised to distribute e-mails containing our product offers, to whom we will provide your e-mail address for that purpose. |
| Service providers during usage of the Mileus application via third party services. | If you opt for using the Mileus applications through another provider (such as Facebook, or Apple for iPhone users), we exchange certain personal data with this provider, without which the registration as per your choice can not be effectuated. |
We want you to know that we will always comply with your right to obtain information regarding to whom, when and for what purpose your personal data was transferred.
What rights do you have?
Having regard to the fact that Our Company processes personal data concerning you, you have certain rights of which we want to inform you in this section. You can exercise all your rights in any manner which suits you and which allows us to verify that it is really you who submits the request (allows us to check your identity) and we will try our best to satisfy your wishes. However, in order to be able to meet your requirements as best as possible, we need to ask you to exercise your rights in writing at service@mileus.com.
1. Right to withdraw consent: We process some of your personal data on the ground of your consent. You have the right to withdraw your consent for the processing of your personal data, including the consent for the delivery of commercial communications. You can withdraw your consent by sending a request to service@mileus.com. As regards the processing of your personal data for the purposes of sending commercial communications, you can withdraw your consent for the processing of your personal data and the consent for the sending of commercial communications simply by clicking on the relevant link which is included at the end of each commercial communication.
2. Right to access: You have the right to access the personal data concerning you that are processed by our company and at the same time the right to information on what personal data concerning you we process, for how long, what the purposes of their processing are, to whom we disclose the data, and whether we use them for automatic decision-making (and how such automated decision-making works). We will give you a copy of your personal data for free. Only if you ask for more copies, we will have to ask you to pay the necessary cost for their issue.
3. Right to rectification: If you find out that we process incomplete or inaccurate personal data, you have the right to demand that we rectify or, if required by the purpose of the processing of the personal data, supplement the personal data.
4. Right to erasure: You also have the right to the erasure of the personal data concerning you which Our Company keeps and processes. You may only demand erasure if one of the following reasons is present:
- your personal data are no longer necessary in relation to the purpose for which they were collected or processed;
- your personal data have been processed by Our Company unlawfully;
- you have withdrawn your consent based on which your personal data were processed; and we do not have any other reason (legal ground) to further process these personal data;
- you object to the processing of your personal data if these personal data are processed for use in direct marketing (e.g. sending of commercial communications);
- you object to the processing of your personal data which we process on the basis of our legitimate interest and if we will not be able to demonstrate that our legitimate interest prevails over your right to erasure;
- there is a statutory reason for which the erasure of these personal data is required;
- Our Company processes the personal data of a child without parent’s consent to such processing.
We need to warn you that a situation may occur when your personal data may not be erased on the ground of your withdrawal of your consent with the processing of the personal data or your request for erasure of the personal data. These are in particular situations when we are required by law to process your personal data. In a situation like this, Our Company will inform you of the reason for which your personal data may not be erased despite your explicit request for the erasure of your personal data.
5. Right to data portability: Another right that you may exercise is the right to portability. You have the right to receive the personal data concerning you which you have provided to us on the basis of your consent and which we process by automated means. Upon your request, we will give you these personal data that meet these conditions in a commonly used, structured, and machine-readable format or, upon your request, transfer them to another controller specified by you if it is technically feasible.
6. Right to restriction of processing: Whenever you feel that your personal data processed by our company are erroneous, you have the right to demand that we restrict the processing of your personal data for a time necessary to verify the accuracy of your personal data and to rectify the data.You have this right in the following cases:
- the processing of your personal data by Our Company is unlawful but you do not wish for your personal data to be erased;
- Our Company no longer needs your personal data for the purpose for which we have processed them, but you insist on their processing (in particular their retention) by Our Company for the establishment, exercise, or defence of your legal claims;
- you have objected to the processing of your personal data on the ground of Our Company’s legitimate interest, and the restriction of processing in this case shall be valid for the time necessary to verify whether our legitimate interest overrides your right to demand that your personal data are no longer processed.
7. Right to object to the processing of your personal data on the ground of legitimate interest: With view to the fact that we process some of your personal data on the ground of a legitimate interest, you have the right to object to this processing, and on the basis of this objection, we will assess whether the processing of your personal data is in fact in our legitimate interest or whether preference should be given to your right to demand that your personal data are no longer processed.
8. Right to object to the processing of your personal data for direct marketing purposes: You have the right to object to our processing of your personal data for the purposes of direct marketing (e.g. sending of commercial communications). In such a case, we will automatically cease to process your personal data for this purpose.
9. Right to complain: In the event that you find all of the above-described rights insufficient or if you are of the opinion that Our Company in any way violates your rights, you have the opportunity to file a complaint with the supervisory office. You may file your complaint to the Office for Personal Data Protection via the contacts that are available at https://www.uoou.cz/podatelna-uradu/os-1006.
10. Right to contact the appointed person for personal data protection: You can contact our contact person for personal data protection by e-mail at: privacy-manager@mileus.com.
Changes to the privacy notice
This version RC_v2.0_202203 was last updated in March 2022.
