r2p Tracking’s privacy policy

Introduction

This page is used to inform visitors regarding our policies with respect to the collection, use, and

disclosure of Personal Information if anyone decided to use our service.

If you choose to use our service, then you agree to the collection and use of information in relation

to this policy. The Personal Information that we collect is used for providing and improving the

service. We will not use or share your information with anyone except as described in this Privacy

Policy.

Important information and who we are

r2p Tracking (“r2p”) is the controller and is responsible for your personal data.

r2p have appointed a data privacy manager. If you have any questions about this privacy policy,

please contact them using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: EcoMobility ApS

• Name or title of [DPO OR data privacy manager]: Allan Just

• Email address: privacy[a]r2p.com

• Postal address: Livøvej 23, 888 Viborg

• [Telephone number: +4570200698

You have the right to make a complaint at any time to the Datatilsynet (Data Protection Agency) for

data protection issues.

Changes to the privacy policy and your duty to inform us of changes

r2p keep our privacy policy under regular review throughout the year.

This version was last updated on 5 May 2021. It may change and if it does, these changes will be

posted on this page and, where appropriate, notified to you by email OR when you next start the

App or log onto our privacy policy. The new policy may be displayed on-screen and you may be

required to read and accept the changes to continue your use of the App or the Services.

It is important that the personal data we hold about you is accurate and current. Please keep us

informed if your personal data changes during our relationship with you.

Third party links

Our Sites may, from time to time, contain links to and from the websites of our partner networks,

advertisers and affiliates. Please note that these websites and any services that may be accessible

through them have their own privacy policies and that we do not accept any responsibility or liability

for these policies or for any personal data that may be collected through these websites or services,

such as Contact and Location Data. Please check these policies before you submit any personal data

to these websites or use these services.

The data we collect about you

r2p may collect, use, store and transfer different kinds of personal data about you as follows:

• Identity Data.

• Contact Data.

• Financial Data.

• Transaction Data.

• Device Data.

• Content Data.

• Profile Data.

• Usage Data.

• Marketing and Communications Data.

• Location Data

r2p also collect, use and share Aggregated Data such as statistical or demographic data for any

purpose. Aggregated Data could be derived from your personal data but is not considered personal

data in law as this data will not directly or indirectly reveal your identity. For example, we may

aggregate your Usage Data to calculate the percentage of users accessing a specific App feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly

or indirectly identify you, we treat the combined data as personal data which will be used in

accordance with this privacy policy.

r2p do not collect any Special Categories of Personal Data about you (this includes details about your

race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,

trade union membership, information about your health, and genetic and biometric data). Nor do

we collect any information about criminal convictions and offences.

How is your personal data collected?

We will collect and process the following data about you:

• Information you give us. This is information (including Identity, Contact, Financial, and Marketing

and Communications Data) you consent to giving us about you by filling in forms on the App Site and

the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat).

• Information we collect about you and your device. Each time you visit one of Our Sites or use one

of our Apps we will automatically collect personal data including Device, Content and Usage Data.

We collect this data using cookies and other similar technologies.

• Location Data. We also use GPS technology to determine your current location. Some of our

location-enabled Services require your personal data for the feature to work. If you wish to use the

particular feature, you will be asked to consent to your data being used for this purpose. You can

withdraw your consent at any time by disabling Location Data in your settings.

r2p use cookies and other tracking technologies to distinguish you from other users of the App, App

Site, the distribution platform (Appstore) or Services Sites and to remember your preferences. This

helps us to provide you with a good experience when you use the App or browse any of Our Sites

and also allows us to improve the App and Our Sites.

How we use your personal data

r2p will only use your personal data when the law allows us to do so. Most commonly we will use

your personal data in the following circumstances:

 Where you have consented before the processing.

 Where we need to perform a contract we are about to enter or have entered with you.

 Where it is necessary for our legitimate interests (or those of a third party) and your

interests and fundamental rights do not override those interests.

 Where we need to comply with a legal or regulatory obligation.

r2p will only send you direct marketing communications by email or text if we have your consent.

You have the right to withdraw that consent at any time by contacting us.

Purposes for which we will use your personal data

Purpose/activity

Type of data

Lawful basis for processing

To install the App and

user

Identity

Contact

Financial

Device

Your consent

To process in-App purchases

and deliver Services including

managing payments and

collecting money owed to us

Identity

Contact

Financial

Transaction

Device

Marketing and

Communications

Location

Your consent

Performance of a contract

with you

Necessary for our legitimate

interests (to recover debts

due to us)

To manage our relationship

with you including notifying

you of changes to the App or

any Services

Identity

Contact

Financial

Profile

Marketing and

Communications

Your consent

Performance of a contract

with you

Necessary for our legitimate

interests (to keep records

updated and to analyse how

customers use our products/

Services)

Necessary to comply with

legal obligations (to inform

you of any changes to our

terms and conditions)

To administer and protect

our business and this App

including troubleshooting,

data analysis and system

testing

Identity

Contact

Device

Necessary for our legitimate

interests (for running our

business, provision of

administration and IT

services, network security)

To deliver content and

advertisements to you

To make recommendations

to you about goods or

services which may interest

you

To measure and analyse the

effectiveness of the

advertising we serve you

To monitor trends so we can

improve the App

Identity

Contact

Device

Content

Profile

Usage

Marketing and

Communications

Location

Consent

Necessary for our legitimate

interests (to develop our

products/Services and grow

our business)

Disclosures of your personal data

When you consent to providing us with your personal data, we will also ask you for your consent to

share your personal data with the third parties set out below for the purposes set out in the table.

Data security

All information you provide to us is stored on our secure servers. Any payment transactions will be

encrypted using secured sockets layer technology. Where we have given you (or where you have

chosen) a password that enables you to access certain parts of Our Sites, you are responsible for

keeping this password confidential. We ask you not to share a password with anyone.

Once we have received your information, we will use strict procedures and security features to try to

prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

r2p have put in place procedures to deal with any suspected personal data breach and will notify you

and any applicable regulator when we are legally required to do so.

Your legal rights

Under certain circumstances you have the following rights under data protection laws in relation to

your personal data. You also have the right to ask us not to continue to process your personal data

for marketing purposes.

You can exercise any of these rights at any time by contacting us at [[ADDRESS] OR [EMAIL]

EcoMobility ApS

Liveøvej 23

8800 Viborg

privacy[a]r2p.com

Glossary

Lawful basis

Consent means processing your personal data where you have signified your agreement by a

statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a

freely given, specific, informed and unambiguous indication of what you want. You can withdraw

your consent at any time by contacting us.

Legitimate Interest means the interest of our business in conducting and managing our business to

enable us to give you the best service/product and the best and most secure experience. We make

sure we consider and balance any potential impact on you (both positive and negative) and your

rights before we process your personal data for our legitimate interests. We do not use your

personal data for activities where our interests are overridden by the impact on you (unless we have

your consent or are otherwise required or permitted to by law). You can obtain further information

about how we assess our legitimate interests against any potential impact on you in respect of

specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a

contract to which you are a party or to take steps at your request before entering into such a

contract.

Comply with a legal obligation means processing your personal data where it is necessary for

compliance with a legal obligation that we are subject to.

Your legal rights

You have the right to:

Request access to your personal data (commonly known as a "data subject access request"). This

enables you to receive a copy of the personal data we hold about you and to check that we are

lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any

incomplete or inaccurate data we hold about you corrected, though we may need to verify the

accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data

where there is no good reason for us continuing to process it. You also have the right to ask us to

delete or remove your personal data where you have successfully exercised your right to object to

processing (see below), where we may have processed your information unlawfully or where we are

required to erase your personal data to comply with local law. Note, however, that we may not

always be able to comply with your request of erasure for specific legal reasons which will be

notified to you, if applicable, at the time of your request.

Object to processing of your personal data where we are relying on a legitimate interest (or those of

a third party) and there is something about your particular situation which makes you want to object

to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You

also have the right to object where we are processing your personal data for direct marketing

purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to

process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the

processing of your personal data in the following scenarios:

 if you want us to establish the data's accuracy;

 where our use of the data is unlawful but you do not want us to erase it;

 where you need us to hold the data even if we no longer require it as you need it to

establish, exercise or defend legal claims; or

 you have objected to our use of your data but we need to verify whether we have overriding

legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a

third party you have chosen, your personal data in a structured, commonly used, machine-readable

format. Note that this right only applies to automated information which you initially provided

consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data.

However, this will not affect the lawfulness of any processing carried out before you withdraw your

consent. If you withdraw your consent, we may not be able to provide certain products or services

to you. We will advise you if this is the case at the time you withdraw your consent.

Description of categories of personal data

Identity Data: [first name, last name, maiden name, username or similar identifier, marital status,

title, date of birth, gender].

Contact Data: [billing address, delivery address, email address and telephone numbers].

Financial Data: [bank account and payment card details].

Transaction Data: includes [details about payments to and from you and details of in-App

purchases].

Device Data: includes [the type of mobile device you use,] [a unique device identifier [(for example,

your Device's IMEI number, the MAC address of the Device's wireless network interface, or the

mobile phone number used by the Device)],] [mobile network information,] [your mobile operating

system,] [the type of mobile browser you use,] [time zone setting,] [OTHER INFORMATION].

Content Data: includes information stored on your Device, including [friends' lists,] [login

information,] [photos, videos or other digital content,] [check-ins,] [OTHER INFORMATION].

Profile Data: includes [your username and password, in-App purchase history, your interests,

preferences, feedback and survey responses].

Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites

including, but not limited to, [traffic data [and other communication data],] whether this is required

for our own billing purposes or otherwise [and the resources that you access].

Marketing and Communications Data: includes [your preferences in receiving marketing from us

and our third parties and your communication preferences].

Location Data: includes [your current location disclosed by GPS technology.