Privacy Policy

MERCURY PRIVACY POLICY 

Effective December 2023

Pursuant to article 13 EU Regulation 2016/679

1.     Introduction

The protection of your privacy is one of our top priorities. We are committed to taking the most appropriate organizational and security measures in compliance with the EU Regulation 2016/679 (“General Data Protection Regulation” or “GDPR”) and any other applicable regulation to protect the personal data you choose to entrust to us. We collect information about you (as a “User”) when you download our Mercury-E App, register a new MERCURY account, use our bike-renting services (“Services”) and through other interactions and communications you may have with us. For more information about our Services click here: https://www.mercury-e.gr.

This privacy policy explains what personal data we collect from you, how and why we use it and your choices and rights regarding your data.

By using our app, you accept the practices described in our privacy policy. If you do not agree to the terms of this Privacy Policy, you may not use the app.

2.     The Data Controller. Who is responsible for the processing of your data?

The Mercury-E App and the Services provided through it are managed by MERCURY.e I.K.E. (hereinafter “we” or “us”) a company incorporated under the laws of Greece with registered office in Agiasmenos, Ierapetra Lasithiou. Should you have any questions about this Privacy Policy you can contact us any time at support@mercury-e.gr.

3.     Data Protection Officer contact details

For any question concerning your personal data you may also contact our DPO at support@mercury-e.gr. Please add DPO to the subject heading.

4.     What data we collect and process

4.1.          Data you provide directly to us

We collect information you provide directly to us, such as when you create or modify your account, request our Services, contact customer support, or otherwise communicate with us. This information includes: your name, email, phone number, postal address, payment method, billing and contact information, services requested, and other information you choose to provide.  Data may also be collected when you upload content to the app., participate in surveys, contests, sign up to receive notifications or other information via email, text or instant message from Mercury Request for Customer Service, support requests or other help as well as from app-related communications, e.g. account verification; technical notification.

4.2.          Information we collect through your use of our services

When you use our Services, we collect the following information about you:

Location Information: When you use our bicycle-rental Services, we collect location data about your trip. To start and terminate the individual rental, we need to record the starting and final position of our bike, the distance travelled, the time and date of lease as well as the IP address of your Mercury bike.

If you allow the Mercury App to access your location through the permission system used by your mobile operating system such as iOS or Android (“Platform”), we may also collect the precise location of your device when the app is running in the foreground (app open and on-screen) or background (app open but not on screen). If you initially allow the collection of this information, you can later disable it at any time by changing the location settings on your mobile device. However, this will limit your ability to use certain features of our Services.

Transaction Information: We collect transaction details related to your use of our Services, including the service requested, credit card details, date and time the service was provided, amount charged, and other related transaction details.

Cookies: The Mercury App uses cookies and similar technologies (in short “Cookies”) to optimize the functioning of the app and to offer an easier navigation through a user-friendly interface. Cookies are small files that are stored on your device. We use both “Session” cookies and “persistent” cookies. We do not use Flash cookies, web storage, web beacons or other technology that tracks your browsing history across multiple apps. We collect information about how Users interact with our App and Services acquiring information about the preferences expressed, settings chosen and your exposure to our ads. If you delete your cookies or set your browser or device to reject these technologies, some features of the app may not work or may not work as designed. We inform you that advertisers that place ads in the app may use cookies. Moreover,  we use cookies to estimate the size of our audience and determine whether yours is a repeat visit or a first-time visit. We also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”), on our apps.

We may also collect non-identifiable demographic data such as age, gender, and post code as part of the collection of personal information.

We may use push notifications to communicate with you:

When you park in not allowed areas.

To remind you to lock the bike.

To notify you of a fine as regulated by our Terms and Conditions.

Device Information: We collect information about your computer, mobile device, or other device you use to access the app., including, for example, the hardware model, operating system and version, IP address, geolocation data, preferred language, unique device identifier, serial number and other transactional information. We also collect device information about the Mercury vehicle, including timestamps, battery status.

Call and SMS Data: To facilitate our Services, we may communicate with you via call or SMS message through which we will collect the call data, including the date and time of the call or SMS message, your phone number, and the content of the SMS message. In particular, we may contact you by telephone (i) when we receive a report that the vehicle has been parked outside of permitted areas, if it appears from our systems that you were the last user of the vehicle, (ii) to handle any complaints about charges for breach of our T&C.

Log Information: When you interact with our Services, we collect log files and information, such as device IP address, access dates and times, app features or pages viewed, app/ software crash reports and other system activity, type of browser, analytics and other information about your use of the app, including GPS routes and the status of GPS chips and additional ‘traffic data.

Most mobile Platforms (iOS, Android, etc.) have defined certain types of device data that apps cannot access without your consent. The iOS platform will alert you the first time the Mecrury App requests permission to access certain types of data, for example, location, contacts, photo and camera and will let you consent (or not consent) to that request. Android devices will notify you of the permissions that the Mercury App seeks before you first use the App, and your use of the App constitutes your consent. Please note that if you do not consent to the request you may not be able to access certain features of our Services.

4.3.          Information we collect from other sources

We may also receive information from other sources and combine that with information we collect through our Services. For example:

If you choose to link, create, or log in to your Mercury account through a third party such as a social media (e.g. Facebook, X, Google+, Tumblr, LinkedIn, YouTube or Pinterest,) or a payment provider (e.g., Apple Pay), we may receive information about you or your connections from that site or app., including your account ID. However, we will comply with the privacy policy of the associated social media platform, and we will only collect and store such personal information that we are permitted to collect by those social media platforms. If you publish your social media profile on our Service, we may collect personal information that you make available as part of that profile.

Mercury may collect information that we may receive from other sources or from offline interactions with you to, among other things, enable us to verify and update the information in our records and to better change our app for you. We may also collection personal information from credit reporting agencies to determine things such as credit sore, credit utilisation, in accordance with applicable law.

We may partner with third party advertising companies to better serve ads. These third-party advertisers may use cookies alone or in combination with web beacons or other tracking technologies to collect information about you when you use the apps. Although we restrict their further use of such information, with sufficient data from other sources, such third parties may be able to identify you personally. Third-party advertising companies and other non-affiliated advertisers also display ads on our apps. As part of their service, they may place a separate cookie on your computer or smartphone or use other data collection and tracking technologies to collect information such as your IP address, browser type, the server to which your computer is connected, the area code and postal code associated with your server, and whether you responded to a particular ad. We have no control over these third parties’ tracking technologies, how they may be used, or the information they may collect, and we are not responsible for the privacy policies or content of those third parties. Please visit the sites of the relevant companies to review their privacy policies. We may add to or change the list of third-party ad servers from time to time.

Many of the third-party advertisers that place tracking tools on our apps are members of Programs that offer you additional choices regarding the collection and use of your information. To learn more about the options available to limit the collection and use of your data by third parties, be sure to check out the Network Advertising Initiative and Digital Advertising Alliance websites. You can also find out about your options to opt-out of data tracking by mobile apps for certain ad networks. You can do this through your device settings. Please note that opting out of ad networks does not mean that you will not receive advertising while using our apps or on other apps, nor does it prevent the receipt of interest-based advertising from third parties that do not participate in these Programs. It will, however, exclude you from interest-based advertising that runs through participating networks, as determined by their policies and choice mechanisms.

5.     Why we process your personal data and on what legal basis.

We ensure that we respect your privacy rights. This means that we can only collect your personal data if we have a lawful basis for doing so. Below are the reasons why we may process your personal data and the legal basis for doing so.

5.1.          When you have given your consent to the processing of your personal data for one or more specific purposes (article 6 (1) a. GDPR)

This legal basis includes the following purposes:

To provide you (by e-mail, SMS, messenger, push messages and banner on the App) with information, commercial offerings and personalized advertisements (such as special offers, studies and market research, sending of advertising material) about our Services or on products and services of third companies. Your data will not be transmitted to third party companies, nor in any form shared, for marketing purposes of the latter.

Providing your consent for the purposes above is optional and refusal will not prevent us from processing your registration, fulfilling our contractual obligations with you, providing you with customer support, answering your enquiries and provide you with other requested services. By ticking the appropriate tick box during the sign-up process for the Mercury-E App, you consent to the processing of your personal data in the ways described in this Privacy Policy. You may withdraw this consent at any time, without affecting the lawfulness of our processing of your data prior to such withdrawal, by contacting us at support@mercury-e.gr.

5.2.          When processing of your personal data is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract (article 6 (1) b. GDPR).

We use the information you provide to us (as described in section 4 of this policy) to carry out our bike rental Services in fulfilment of our contractual obligation with you as a User of the Mercury-E App. Processing your personal data is necessary to provide you with our Services and allow us to provide you with the related customer support.

5.3. When processing of your personal data is necessary for compliance with a legal obligation to which we are subject;

This may be the case where e.g.  we need to properly identify you.

5.4.          When the processing is necessary for the purposes of the legitimate interests pursued by us (article 6 (1) f. GDPR).

This includes the following purposes:

We process your personal data collected during the usage of our Mercury-E App in order to identify and resolve possible errors and malfunctions which may occur in providing our Services.

We process your data collected through your use of our Services for internal purposes, including, for example, to prevent fraud and abuses; to solve software bugs and operational problems; to conduct data analysis and research.

We may also process your data if you committed an administrative offense during an individual lease or you are in breach of our contractual terms and conditions in order to defend our rights in court.

We process the position data of our bikes in order to develop a statistical model which is able to predict possible future demand and to monitor and analyze usage and activity trends. For such purposes, only data without a direct link to a natural person is processed.

We may use your personal data for the purpose of providing direct marketing advertising via email, SMS, MMS. You may object to direct marketing by clicking on a link at the end of an electronic mail or by sending an e-mail to support@mercury-e.gr.

We process your driving and parking behavior in order to impose fines in accordance with our Terms and Conditions.

6.     Data processor and data recipients

Except where stated we do not disclose your personal information to companies.  

We may share your information:

With our subsidiaries and affiliated entities that provide services or conduct data processing on our behalf.

With vendors, marketing partners, consultants, and other service providers who need access to such information to carry out work on our behalf; these services may include billing, notifications, customer service, fraud protection, IT services etc. We use external IT service providers who provide server infrastructure, IT maintenance or extensive IT solutions (such as cloud services) and software solutions on our behalf.

With Courts, external advisors, Public Authorities or other authorized third parties in response to a request for information by a competent authority if we believe disclosure is in accordance with any applicable law and regulation.

With Tax administrations, for the compliance of tax obligations.

With Public Authorities, in order to identify the users of the vehicles in accordance with traffic applicable law and regulation.

With law enforcement officials, government authorities or other third parties (e.g. insurers/ insurance companies) if we believe your actions are inconsistent with our Terms and Conditions or to protect the rights, property, or safety of us or others, or if there is a complaint, dispute or conflict, which may include an accident, involving you and a third party and such information is necessary to resolve this.

Personal information may also be used or disclosed if required by law or in the good faith belief that such action is necessary to (a) comply with applicable law or to comply with legal process served on us or the app; (b) protect and defend our rights or property, the app or our users, and (c) act in emergency situations to protect the personal safety of us, our affiliates, agents or the app’s users or the public.

In connection with, or during negotiations of, any merger, sale of company assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

With other users, as requested or directed by you, when you wish to share your profile and trip information to engage in social activities or to obtain a promotion code.

With third parties to provide you a service you requested through a partnership or promotional offering made by a third party or us.

With third parties with whom you choose to let us share information, for example other apps or websites that integrate with our Application Programming Interface (API) or Services, or those with an API or Service with which we integrate.

We may allow others to provide audience measurement and analytics services for us, to serve advertisements on our behalf across the Internet, and to track and report on the performance of those advertisements. These entities may use cookies, web beacons, Software Development Kits (SDKs), and other technologies to identify your device when you visit our site and use our Services, as well as when you visit other online sites and services.

Personal data will be processed only by persons/entities previously appointed by Mercury or by its data processors as persons in charge of the data processing, or as data controllers, as applicable for the purposes specified above.

Your personal data may be shared only with third parties that process personal data on our behalf and on the basis of our instructions. Any data processor we appoint will be subject to contractual obligations aimed at protecting your personal data.

We will not sell or rent your personal information as part of a customer list or similar transaction.

7.     Social Sharing Features

The Services may integrate with social sharing features and other related tools which let you share actions you take on our Services with other apps, sites, or media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the social sharing service. Please refer to the privacy policies of those social sharing services for more information about how they handle the data you provide to or share through them. We do not accept any responsibility or liability for these policies. Mercury is not responsible for the actions and privacy policies of third parties and other apps.

8.     Retention of Personal Data

We shall retain your personal data for the period necessary to fulfil the purposes outlined in this Policy unless a longer retention period is required or permitted by law. 

Records can be held on a variety of media (physical or electronic) and formats.

When we no longer need to use your personal data with the purpose of providing our Services to you, your data will be removed from our systems and action shall be taken to properly anonymize it so that you can no longer be identified from it. This anonymized data may be used without further notice to you e.g. for statistical purposes.

A longer period of retention of the same data may apply when we need to comply with legal or regulatory obligations to which we are subject (e.g. retention periods which can result from applicable commercial and/or tax).

9.     Where do we transfer personal data?

Mercury, its customers, affiliates or service providers may transfer information collected about you to recipients and data processors (e.g. technical service providers) across borders and out of your country or jurisdiction around the world. The information we collect through our app may be stored and processed in Greece or any other country where we, our customers, affiliates or service providers maintain facilities. In case these countries are outside the EEA, in compliance with the applicable data protection law, we ensure an adequate level of data protection by entering into agreements including the EU standard contractual clauses issued by the European Commission which guarantees the appropriate safeguards as defined by article 46 GDPR.

By registering for and using the app, you consent to the transfer of information to any country where Mercury, its clients, affiliates or service providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

10.  How we ensure the security of your data

We have implemented appropriate physical, technical and organizational measures to safeguard and secure the personal data we collect to ensure a level of security appropriate to the risk, in compliance with the GDPR.

We ensure we keep your data safe. We ensure the secure transfer of your data from your device to our servers. Personal information collected by our app is stored in a secure operating environment that is not available to the public. Our security procedures mean that we may occasionally request proof of identity before disclosing your personal information to you. 

Unfortunately, although we do our best to protect your personal information as soon as we receive it, no transfer of data over the internet or any other public network can be guaranteed to be secure by 100%. We strive to implement state of the art technical and organizational measures to ensure a high level of protection of the data we process, but  we cannot guarantee the absolute security of your data transmitted to us; any transmission is at your own risk.

11.  Your Rights

According to the GDPR you have the following rights:

Right of Access. You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The right of access includes the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipients to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access. You have the right to obtain a copy of the personal data undergoing processing.

Right to rectification: This means that you have the right to ask us for the rectification of inaccurate personal data concerning you or to complete information you think is incomplete You can directly rectify your data modifying your profile data on the Mercury-E App.

Right to erasure: Under certain circumstances you have the right to ask us for the erasure of personal data concerning you and we shall be obliged to erase such personal data.

Right to restriction of processing: You may have the right to request a restriction of the processing of your personal data in certain circumstances. In this case, the respective data will be marked and may only be processed by us for certain purposes (e.g. with your consent or to raise legal claims or for the protection of the rights of another natural or legal person).

Right to data portability: You may have the right to receive the personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit those data to another controller without hindrance from us. Moreover, you have the right to ask that we transfer the information you have provided us with to another organisation, or to you, in certain circumstances.

Right to object to processing: You have the right to object to the processing of your personal data in certain circumstances.

You also have the right to lodge a complaint with the data protection supervisory authority. In Greece the supervisory authority is the Hellenic Data Protection Authority, based in Kifissias 1-3, PC 115 23, Athens, Greece, Telephone: +30-210 6475600, Ε-mail: contact@dpa.gr,  https://www.dpa.gr

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing. In this case your personal data will no longer be processed for such purposes by us.

If you have declared your consent for any personal data processing activities, you can withdraw this consent at any time with future effect. Such a withdrawal will not affect the lawfulness of the processing prior to the consent withdrawal.

To exercise the above rights, you may send us an e-mail to support@mercury-e.gr.

Please note that in some cases we may retain certain information about you as required by law, or for legitimate business purposes to the extent permitted by law. For instance, if you have a standing credit or debt on your account, or if we believe you have committed fraud or violated our Terms and Conditions, we may seek to resolve the issue before deleting your information.

12. Can you Opt Out Your Choices

Although you may not opt out of all data collection when you visit our app, you may limit the collection, the use and share of your identifiable information.  Given that this identifiable information is provided on a voluntary basis, you are invited not to submit to the app information you wouldn’t like us to collect. However, please be aware that in this case, you may not be able to access certain content and some of the apps’ functionalities. 

By updating the communication preferences in your account profile through the app you can change the type of communication you receive from us, including opting out of promotional information from us. Opting out of online behavioural advertising and other targeted advertising made by participating companies through the app,  doesn’t prevent you from still seeing other types of ads on the app, that may not be to your interests.  You can view and modify your information by logging into your account with Mercury.  If any of the information is inaccurate, we may not honour any request to alter or delete personal information if we believe this would violate legal or regulatory requirements.

When referring others to us using our email functionality, please be aware that they may choose not to receive promotional emails from us in the future by following the opt-out instructions in the email invitation. 

Please note that many web browsers automatically accept cookies, but you can change this in your browser to refuse cookies if you wish.  Certain features of our app may not work properly or remain accessible to you if you do decline cookies. 

13. Applicable Law

This app is published in Greece. The Terms and Conditions and the use of Services are governed by the Greek Law. We try to protect the personal information of all the users of our app, and we try and comply with local data protection and consumer rights laws to the extent that they may apply to the services.  

14.  Changes to the Policy

As our app evolves, we may add new services and features and this may affect our privacy policy from time to time. If we make significant changes in the way we process your personal information, or to this policy, you will be notified through the Services or by some other means, such as email. This also applies in case we intend to apply the changes or modifications to this Privacy Policy retroactively or to personal information already in our possession. Your continued use of the Services after such notice constitutes your consent to the changes. We encourage you to periodically review this Policy for the latest information on our privacy practices. If you do not agree with any revised version of this Policy, please do not continue to use the Services.

15.  Contact Us

If you have any questions about this Policy, please contact us at support@mercury-e.gr.