The privacy statement is applicable to all privacy-sensitive information or personal data which we receive from our clients and users via our apps and online tools, such as the Fynch Platform, Fynch App, ProDrive Learning, the Fynch shop, and SafetyConcern. It is also possible for you to issue personal data to us directly, for example by email or a contact form.
We consider the privacy of our clients and the users of our websites, apps, and online tools to be extremely important. That is why we try to be as careful as possible when processing and protecting personal data. All our employees have signed a confidentiality agreement. They have also been extensively trained in dealing carefully with confidential information. We process the data in accordance with the conditions imposed in the General Data Protection Regulation (GDPR).
In this privacy statement, we explain which data we process, for which purposes it is used, and what your rights are on the grounds of the GDPR.
Processing personal data on the instruction of our clients
In many cases, we process personal data on the instruction of our clients. These are usually parties that have concluded a contract with us for the use of an app or online tool on behalf of their staff or their clients’ staff. We receive personal data from these clients. However, personal data may also be added through the use of the app or the online tool. In these cases, our client is the controller within the framework of the GDPR with regard to the processing of your personal data. This means that our client determines which personal data we process, for which purpose and in which way.
Processing personal data as the controller
It may be the case that we process personal data independently and not on the basis of instructions, for example, if you visit our website(s), download our app, or fill in a contact form. In such instances, we are the controller within the meaning of the GDPR. We only process this personal data if that is necessary for the execution of an agreement to which you are a party, or if the processing is necessary in order to defend the legitimate interests of Fynch Mobility. In addition to this, we may have a legal obligation to process your personal data.
Overview of the personal data we can process
The following is an overview of your personal data we may process. We do not always have all the data summarized below. This depends on the product you are using.
- First name and surname
- Email address
- IP address of the website visitor
- The registration number of the vehicle you used.
- Mobility data (car, bicycle, walking, public transport, or flights)
- Location data
- Refueling card and mobility card transactions
- Damages and fines
- Payment details such as bank account number or activation code
- Employer details such as the name of employer, employee number, department name
The purpose for which the personal data is being processed
We process your personal data for the following purposes: depending on the product you use:
- To analyze driving behavior, journey behavior, or telephone use by participants in our programs and training courses, for example, to promote sustainability and safety.
- To report results and analyses to the client and/or the user.
- To offer the user the possibility of creating an account.
- To allow the user to pay an invoice.
- To enable the user to telephone or email if this is necessary for the execution of our services.
- To inform the client and the user about changes to our services and products.
- To enable us to send gifts from our shop if you exchange coins with us.
We keep your personal data for no longer than is strictly necessary in order to fulfill the purposes for which your data was collected unless we are legally obliged to save certain data for longer.
Issuing to third parties
We are allowed to share your personal data with our clients or other third parties, provided this is consistent with the aforementioned purposes. It may be necessary to issue personal data to parties other than our client for the execution of an agreement which we have concluded with you, or for the protection of one of our legitimate interests, or in order to fulfill one of our statutory obligations.
We conclude data processing agreements with companies that process your data on our instruction, for example, a hosting company, in order to ensure the same level of security and confidentiality that we apply ourselves. We continue to be responsible for this processing.
We can also use this anonymized data to create general analyses, for example with regard to sustainable driving and journey behavior which is relevant to a wider audience. We only publish or share the outcomes with third parties if the data cannot be linked in any way with an identifiable person.
We use your personal data for market research and to optimize our services. Within this framework, your personal data will also be anonymized and untraceable.
Your data will never be sold or shared with third parties for commercial purposes unless you have given your explicit permission.
A cookie is a small text file that is saved on your computer, tablet, or smartphone when you first visit this website. You can choose not to accept cookies by adjusting your Internet browser so that it no longer saves any cookies. You can also delete any information saved previously via your browser settings.
We use the following cookies:
- Functional cookies: these are cookies that are necessary for the technical operation of the App and to make it easy for you to use. They ensure that the website works properly and remembers, for example, your preferences. They also enable us to optimize our website. These are analytical cookies that do not violate your privacy and for which we do not need your prior permission.
- Google Analytics: cookies from the American companies Google are placed on this website as part of the analytics service. Fynch Mobility uses this service to obtain reports about the way in which the website is used and to measure its quality and effectiveness. We use Google Analytics in the way described by the Dutch Data Protection Authority [Autoriteit Persoonsgegevens] so that we are covered by the exception in cookie legislation, meaning that we do not need your prior permission to use Google Analytics.
Access, rectification, or erasure
You have the right to access, rectify or erase your personal data, or to restrict the processing. You also have the right to withdraw your permission for data processing or to object to the processing of your personal data.
In the instances in which our client is the controller, we cannot independently take a decision in response to your request. In those instances, we will forward your request to the controller as quickly as possible.
If we are no longer allowed to process your data, that may have detrimental consequences for the use of our applications and online tools. It may be that we are unable to carry out a full analysis, but it may also be the case that your request or objection makes it impossible to participate in our products and services. If, for this reason, it is no longer possible to participate in a program or training course, we will generally be obliged to report this to our clients.
You have the right to data portability, but only if we have digital personal data which we either process with your permission, or process in order to execute an agreement we have concluded with you. Data portability means you can submit a request to us to send the digital personal data which we have from you in a readable computer file to you or another organization of your choosing.
You can send a request to access, rectify, erase or transfer your personal data, or a request to withdraw your permission or object to the processing of your personal data, to email@example.com.
In order to be sure that the request to access is being made by you, we will ask you to submit a copy of your proof of identity along with the request. In this copy you should black out your passport photo, MRZ (machine readable zone, the zone with numbers at the bottom of the passport), passport number, and Citizen Service Number [Burgerservicenummer (BSN)] to protect your privacy. We will respond to your request as quickly as possible but by no later than within six weeks.
We also want to draw your attention to the possibility you have of submitting a complaint to the national supervisory body, the Dutch Data Protection Authority [Autoriteit Persoonsgegevens].
We take the protection of your data very seriously and take suitable measures to prevent misuse, loss, unauthorized access, unwanted publication, and unlawful amendment. If you have any questions, or are under the impression that your data is not properly secured, or if there are indications of misuse, please contact us via firstname.lastname@example.org.
This privacy statement came into effect on 16 February 2017 and was last amended on the 19th of May 2020.