CommuteSaver Inc Privacy Policy

COMMUTESAVER Updated 03

⚠️ If you do not accept the terms of this privacy policy, please do not access the application.

1. INTRODUCTION
CommuteSaver Inc, a company with the registration number 559350-4870 and registered address at Lindholmsbacken 142, 127 49, Skärholmen, Sweden, doing business as “CommuteSaver”, (“CommuteSaver”, “we” or “us”) is responsible for the processing of your personal data, as described in this privacy notice (“Notice”). We understand that your privacy is important to you, and we want you to feel that you can trust CommuteSaver when you share your personal information with us. This Notice is published with the aim of enabling you to understand the instances where CommuteSaver is responsible for the processing of your personal data, how we process your personal data, why we do so, and to inform you about your data protection rights. You have a right to information about how we process your personal data, therefore, we encourage you to read this Notice in full. We are responsible for and committed to processing personal data in accordance with applicable data protection laws, such as the EU General Data Protection Regulation 2016/679 (“GDPR”) and applicable national data protection legislation. You can always get in touch with us by using the contact details set out in section 9 below. In light of the volume of information in this Notice, if you only want to access a particular section of this Notice, you can click on the relevant link below to jump to that section:

SCOPE
WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT
WHY AND HOW WE USE YOUR PERSONAL DATA
RETENTION PERIODS
RECIPIENTS AND TRANSFERS OF PERSONAL DATA
YOUR RIGHTS
INFORMATION ABOUT CHANGES TO THIS NOTICE
CONTACT INFORMATION

2. SCOPE

This Notice applies when we process personal data, that is any information (or combination of such information) that directly or indirectly can identify you as a unique person. Information that can directly identify you is, for example, your name or your email address. Information that can indirectly reveal your identity is, for example, your job role in a specific company or an internal reference number. Please note that we will not collect any categories of personal data that are considered special categories of personal data under the GDPR (e.g., information about your racial or ethnic origin or health, political opinions, religious or philosophical beliefs, or trade union membership) or about your criminal background

(i) You visit and interact with us through our website https://commutesaver.net (“Website”).
(ii) You use the CommuteSaver application (“App”) for the instances that we are the controller of your personal data.
(iii) We are entering into commercial dialogues with you when you represent an existing or prospective customer of ours.
(iv) When you represent an existing customer of ours

This Notice does not apply to the extent we process personal data in the role of a processor (as a service provider) on behalf of our corporate customers which is your employer, in relation to the provision of our services. In other words, when you are using our App, we will process your personal data on your employer’s behalf and under their instructions and this specific corporate customer remains responsible for the processing and is the controller of the personal data. For detailed privacy information related to a CommuteSaver customer who uses our services as the controller, please contact the customer in question directly. Kindly note that we are not responsible for the privacy or data security practices of our customers, which may dier from those explained in this Notice.

3. WHAT PERSONAL DATA WE COLLECT AND HOW WE COLLECT

3.1 SOURCES OF PERSONAL DATA

The sources of the personal data will depend on the purpose of the processing. Most of the time, we collect your personal data directly from you, such as when you fill in a form on our Website, or when you use our App. In the latter case, personal data will also be generated internally by our systems, such as internal reference numbers. However, in order to identify business opportunities, we will also collect your personal data that is publicly available, for example, information about you on your employer’s website or social media such as LinkedIn.

3.2 CATEGORIES OF PERSONAL DATA THAT WE PROCESS

The personal data we collect, and process can be categorized in the following categories:

COMMUNICATION DATA

This category includes personal data that we collect through our interaction and includes the content of our communications with you, such as:
Communication content (e.g., email content or your feedback)
Any other relevant information that you will disclose to us

CONTACT DATA

This category includes personal data that will enable us to get in touch with you, as well as understand a bit more about the company that you represent, such as:

First and last name
Business email
Business phone number
Organization name
Internal reference number

SIGNATURE DATA

This category includes personal data collected or generated by us to electronically sign an agreement, such as:

Your signature
Time and date of signature

TECHNICAL DATA

This category includes personal data that we will collect when you are using our App and that we will process for our own purposes and for which we are a controller, such as:

Device type
User ID

TRANSACTION DATA

This category includes personal data that we are required to collect when we administer and/or manage our accounting, such as:

Invoices

USER DATA

This category includes user account and user-generated personal data that we collect on behalf of our corporate clients when you are using our App for which we are a processor and our client is the controller, such as:

- First and last name
- Email (whether personal or business)
- Phone number (whether personal or business)
- Commute route (starting and ending point)
- Location

Coordinates

Timestamps

Data from motion detector
Car registration number (only for Swedish Users)
Photo (optional)

4.WHY AND HOW WE USE YOUR PERSONAL DATA

4.1 When you visit and interact with us through our Website

4.1.1 When you interact with us through our Website

Purpose	To respond to your inquiries regarding our services when you fill in relevant forms on our Website or when you contact us via other communication channels.	To send you our newsletter.	To publish testimonials on the Website or other channels.
You as a(n)…	Requester	Subscriber Representative of a prospective or existing customer User	Representative of an existing customer
Your personal data processed	Contact data Communication data	Contact data	Contact data Communication data (post content)
Legal basis upon which we process the personal data	We base the processing on our legitimate interest in responding to your inquiries about our business operations and communicating with you.	We base the processing on our legitimate interest in keeping you informed about our business operations and sharing relevant content with you.	We base the processing on your prior consent.
How long we will store your personal data	For as long as we have an active dialogue and 1 year after our last communication.	For as long as you don’t indicate otherwise. You can always unsubscribe from our mailing list by clicking the unsubscribe button at the end of each email communication we send over.	For as long as we have your consent. You can always withdraw your consent by contacting us at legal@commutesaver.net and we will remove your post promptly.

4.1.2 Cookies and similar technologies

When you interact with us through our Website, if you agree, we place Cookies on your device which will collect and share with us technical information, such as your IP address and the type of browser that you are using which constitute personal data. We will further process this personal data collected through the cookies based on your consent For more information about the types of cookies we use, the personal data categories processed, the purposes of processing and retention time, as well as how you can control cookies, please read our Cookie Notice available her

4.2 When you use the App

Please note that if you are using our App as an authorised user of our customers, we are processing your personal data on behalf of this specific customer who is responsible for assigning access to our services. In such cases, our customer at hand is the controller of the personal data, therefore for more information about the processing, consult the respective customer.

4.2.1 CommuteSaver as a Controller of your personal data

Notwithstanding the above we remain the data controller for certain purposes of processing when you are using our App, which are the following:

Purpose	To respond to a request that you have sent to us regarding the provision of technical support and resolve the matter.	To be able to operate the App, including maintenance, troubleshooting, and debugging.	To improve our services by processing the feedback that you provide to us by [**].
You as a(n)…	User	User	User
Your personal data processed	Contact data Communication data To resolve the issue, we may need to access your account and as a consequence any relevant personal data therein.	Technical data	Communication data
Legal basis upon which we process the personal data	We base the processing on our legitimate interest in offering support to our users.	We base the processing on our legitimate interest to operate and ensure the proper functionality of our App.	We base the processing on our legitimate interest to process your feedback and improve our services.
How long we will store your personal data	For one year after the resolution of the matter.	For one year.	[**]

4.2.2 CommuteSaver as a Processor of your personal data

When you use our App and this processing is taking place on behalf of our corporate customers, we will process your personal data in accordance with the data processing agreement in place between us and the customer at hand, the customer’s instructions as communicated to us from time to time, and applicable data protection law requirements.

(i) Our service

To provide our services, CommuteSaver collects your personal data so that we can:
· Create and send aggregated and anonymized Co2 reports to your employer, based on statistics from all eployees using CommuteSaver at your workplace.
· View your own individual statistics in the mobile application related to your daily commute.

(ii) Personal data categories

To be able to use our App, we will need to process certain personal data of yours, such as User data, as defined in section 3.

(iii) Retention

We will process the above-mentioned personal data for as long as you have an account with us, otherwise for as long as there is a contractual relationship between us and our corporate client who assigned you access rights to our App (your employer). Should that contractual relationship come to an end, we will delete or anonymise this personal data.

(iv) Access and sharing

This personal data will be only accessible by you and by us in certain cases when needed. We will not share this personal data with our corporate clients who will only receive anonymised reports.

4.3 When the company that you represent is a CommuteSaver customer or a prospective customer

In case you represent an existing customer of ours or if you hold a key position within the organisation of a prospective customer, we will process your personal data for the following purposes:

Purpose	To market our services.	To sign relevant agreements with CommuteSaver.	To manage our relationship with our (existing and prospective) customers and day-to-day operations.	For billing and invoicing purposes.
You as a(n)…	Representative of a prospective customer	Customer representative (signatory party)	Existing and prospective customer representative	Existing customer representative
Your personal data processed	Contact data Communication Data	Contact data Signature data Any personal data that an agreement may contain	Contact data Communication data	Contact data Transaction data
Legal basis upon which we process the personal data	We base the processing on our legitimate interest to market our services to persons in key positions within organisations that we consider would be interested in our services.	We base the processing on our legitimate interest to ensure that relevant agreements are in place with our customers.	We base the processing on our legitimate interest to administer our relationship with the company that you represent.	We base the processing on our legitimate interest to be able to administer our accounting, as well as on our necessity to comply with legal obligations, such as bookkeeping laws.
How long we will store your personal data	1 year after our last communication. Note that if you wish that you do not want to be contacted from us for marketing purposes, we will store your personal data in a separate “Do-not-contact-me” list to ensure that your request is respected.	10 years according to the Swedish Act on Limitations.	For representatives of prospective customers, 1 year after our last communication with you. For representatives of existing customer, 10 years according to the Swedish Act on Limitations.	7 years after the end of the year of collection in accordance with the Swedish Bookkeeping Act.

4.4 To enable us to comply with legal obligations and defend against legal claims

Purpose	To comply with various legal obligations.	To enable CommuteSaver to establish, exercise or defend legal claims. “Legal claims” in this context is not limited to current legal proceedings but also includes: . actual or prospective court proceedings; · obtaining legal advice; or · establishing, exercising or defending legal rights in any other way.
You as a(n)…	Representative or signatory party of an existing customer	Any of the above-listed attributes, depending on the relevance in relation to the specific matter
Your personal data processed	In order to comply with applicable laws, we are obliged to process certain personal data. The personal data categories collected and stored for this purpose may vary depending on the specific requirements stipulated in, for example applicable tax, accounting, or book-keeping legislation.	For this purpose, we will process any personal data listed in section 3.
Legal basis upon which we process the personal data	For this purpose, the processing of your personal data is based on our necessity to comply with legal obligations.	We base the processing on our legitimate interest to be able to establish, exercise, and defend against legal claims.
How long we will store your personal data	The retention of your personal data at hand will depend on the legal requirement at hand. For more details about the retention in relation to legal requirements, please contact us at legal@commutesaver.net.	10 years according to the Swedish Act on Limitations, unless otherwise stipulated in another applicable law.

5. RETENTION PERIODS

We Retain The Personal Data We Collect From You Where We Have An Ongoing Legitimate Business Need To Do So (E.G., To Provide You With Information You Have Requested Or To Comply With Applicable Legal, Tax, Or Accounting Requirements, Or To Exercise Or Defend Legal Claims). Please See Section 4 For Information On The Specific Retention Periods We Apply For The Purposes We Have Set Out Above. When We Have No Ongoing Legitimate Business Need Or Legal Reason To Process Your Personal Data, We Will Either Delete Or Anonymise It Or, If This Is Not Possible (For Example, Because Your Personal Data Has Been Stored In Backup Archives), Then We Will Securely Store Your Personal Data And Isolate It From Any Further Processing Until Deletion Is Possible.

6. RECIPIENTS AND TRANSFERS OF PERSONAL DATA

We Disclose The Personal Data Described Above To The Following Categories Of Recipients:

(a) Courts and similar judicial entities and/or authorities if we are required to do so by law.

(b) Service providers upon which we rely for our core operational activities.

( c ) If there is a change in ownership of our business, we will share personal data with the new owners so that they can continue to operate our business, provided that the new owners will only process personal data as we have set out in this Notice.

For customers based in the United States
All processing of your personal data takes place within the United States.

For customers based in the EU/EEA
Currently all processing of your personal data takes place within the EU/EEA. However, if our processing of personal data will entail a transfer of your personal data outside the EU/EEA, we will ensure that adequate safeguards are in place to make sure that your personal data will remain protected in accordance with this Notice and applicable data protection laws. We will do this through one of the following measures:

(i) By transferring the personal data to a country that is on the European Commission’s list of countries with an adequate level of protection, or;

(ii) By implementing a transfer mechanism such as the controller-to-controller or controller-to-processor standard contractual clauses that have been approved by the European Commission (as applicable from time to time) for the transfer of personal data to third countries.

If a standard contract is deemed ineffective due to national law of the country of destination, we will take additional technical, organisational, or contractual measures to ensure an adequate level of protection when transferring personal data to countries covered by paragraph (ii) above.

7. YOUR RIGHTS

YOUR RIGHT	WHAT DOES IT MEAN	HOW YOU CAN EXERCISE YOUR RIGHT	CONDITIONS AND LIMITATIONS
Right to access	You have the right to access and receive a copy of your personal data that we process, as well as other supplementary information at any given time.	Such requests should be made to legal@commutesaver.net. If possible, please specify the type of information you would like to access to ensure that our disclosure meets your expectations.	Your request may not affect the rights and freedoms of other individuals, such as their privacy and confidentiality rights.
Right to rectification	You can challenge the accuracy of your personal data at any given time. Depending on the purpose of the processing you can request the completeness of your personal data. If your personal data is indeed inaccurate, you are entitled to have the inaccurate data removed, corrected, or completed, as appropriate.	We encourage you to notify us of any inaccuracies regarding your personal data as soon as they occur, including changes to your contact details. A request to exercise this right is made in writing to legal@commutesaver.net	If appropriate, we may ask you to provide a supplementary statement, depending on the purpose of processing.
Right to erasure	In certain cases, you are entitled to have your personal data erased (also known as the “right to be forgotten”), such as in cases where the personal data is no longer needed for the purpose for which it was collected, or if we no longer have a legal basis to continue processing it.	A request to exercise this right is made in writing to legal@commutesaver.net.	Kindly note that this right is not absolute and there are various lawful reasons why we may not be able to erase your personal data, for example: (i) where we have to comply with a legal obligation, (ii) in case of exercising or defending legal claims, (iii) where there is another lawful purpose for processing your personal data at hand.
Right to objection	You have the right to object to the processing of your personal data at any time. This means that we will stop or be prevented from processing further your personal data. You have the absolute right to object to receiving further marketing material or communications from us.	A request to exercise this right is made in writing to legal@commutesaver.net. If possible, please specify to which purpose of processing you wish to object toensure that our actions meet your expectations.	This right is only applicable where the processing is based on our legitimate interest which does not override your rights and freedoms. For more information see section 4.
Right to restriction	By exercising this right, you limit the way we will process your personal data for a certain period of time. This right is an alternative to requesting the erasure, in case you don’t want the deletion of your personal data.	A request to exercise this right is made in writing to legal@commutesaver.net. If possible, please specify for how long you would like to restrict the processing, to ensure that our actions meet your expectations.	You have the right to request the restriction of the processing of your personal data in certain circumstances, such as: i. If you have contested the accuracy of your personal data. ii. If you consider that your personal data has been unlawfully processed and you oppose to erasure of your personal data. iii. When we no longer need the personal data, but you need to keep it in order to establish, exercise or defend a legal claim.
Right to withdraw your consent	You have the right to withdraw your consent to any processing for which you have previously given consent at any given time.	A request to exercise this right is made in writing to legal@commutesaver.net.	If you withdraw your consent, such withdrawal will only take effect in regard to future processing.

Your Rights Relating To The Use Of Our Services

As Already Described Above, We Will Also Process Certain Personal Data On Your Employer’s Behalf Which Is Our Corporate Customer. In Such Case, If Not Stated Otherwise In This Notice Or In A Separate Disclosure, We Process Such Personal Data As A Processor On Behalf Of Our Customer (And Its Ailiates) Who Is The Controller Of Such Personal Data. Kindly Note That If Your Data Has Been Submied To Us In Our Role As A Processor And You Wish To Exercise Any Rights You May Have Under Applicable Data Protection Laws, Please Inquire With The Respective Customer Directly. However, If You Still Wish To Submit A Request To Exercise Your Rights Directly To Us, Please Make Sure That You Provide Us With The Name Of The Customer Who Submied Your Data To Us. We Will Refer Your Request To That Customer And Will Support Them As Needed In Responding To Your Request Within A Reasonable Timeframe.

8. CHANGES TO THIS NOTICE

If We Make Changes To This Notice, We Will Notify You On Our Website. You Can See When This Notice Was Last Updated By Checking The “Last Updated” Date Displayed At The Top Of This Notice. Significant Changes To How We Collect Or Process Your Personal Data Will Be Notified To You Via Email.

9. CONTACT INFORMATION

Our contact information is:
Name: CommuteSaver Inc
Address: 2930 Domingo Ave, #1441
Phone number: +1 510 916 8534
Email address: legal@commutesaver.net