Privacy Policy

Your privacy is our priority

We are fully aware of the importance of your privacy and we implement data protection rules seriously. Our main goal is to assure you a smooth and safe online experience while using our Service, as defined in HALA Terms and Conditions of Use, as we are convinced that our success is based on transparency and trust with our users.

We would, therefore, like to take this opportunity to give you a complete overview about our practices for the processing and protection of your Personal Data, as defined below. As you are a user of our Service we want you to know how we collect, store and process your Personal Data.

We have created this Privacy Policy for you to receive all the information you need. We invite you to carefully read all the information we provide and if there are any questions remaining, please do not hesitate to contact us at any time. You can also send all inquiries regarding your Personal Data and how we use it directly to: [e-mail] We will promptly reply to you.

Hala Service

The service is provided by HALA Mobility India Pvt. Ltd, Sai Ganga colony, Saidabad, Hyderabad, Telangana (“HALA ” or “ we/us/our ”).

HALA provide an online platform (hereinafter referred to as, the “ Service ” or “ Services ”) intended to offer the possibility for a customer (hereinafter referred as “User” or “you”) to rent a moto that we provide for a short trip in the city. This service is accessible via the Internet website through the following URLs www.halamobility.in (the website) and/or as a mobile application entitled “HALA” (the “App”).

Each user may also use the services of HALA and his/her personal Data will be used as set forth below (HALA).

The services are described extensively in the Hala Terms and Conditions.

HALA is responsible for the processing of your Personal Data that is collected through your use of our Service and Website. This means that HALA is notably in charge of their collection, their safety and their use for the purposes that HALA details in its privacy policy in compliance with the data protection rules. At the time of registration as a User, you consent to such processing and you warrant the accuracy of all data provided by you.

DATA COLLECTED AND THEIR FINALITY

What is personal data?

“Personal Data” covers any information relating to an identified or identifiable natural person, such as your name, your address, your telephone number or your email address. Personal data can also cover information allowing to identify you, directly or indirectly, in particular by reference to an identification number like an IP address.

What data does HALA use?

HALA collects and uses different sets of data to provide you with its Service and improve your experience on its Website and Application. This data can be either personal or not.

Cookies:

Some of this data may be collected via cookies. HALA uses different cookies that are useful to provide a better experience, it includes:

- A unique identifier to send or reply to you via chat messenger when needed - an encrypted token to reconnect automatically to your session - Your language preference, browser type, time zone, referring URL - Last registration step, to activate remarketing campaigns

You can freely manage cookies into your browser parameters.

App data:

Additionally, HALA collects and store the following data when you are using our App

Device identification, Android and IOS operating system name and version, device’s time zone and language, IP address. HALA uses these App Data only for the purpose of the service we provide to you and statistics usage.

User Data:

If you want to rent one of our scooter, you shall create an account and submit the following information:

first name, last name, phone, email, Identity documents and driving license, postal address, date of birth.

HALA will collect, process and use this data only for the purpose of providing the service to his users.

Identity documents and driving license are used to ensure you have the right to drive a scooter in the countries where HALA operate, via own operations or via a franchising contract. These files are reviewed manually once your registration is submitted and is exclusively done by the the clients support team that are the only authorized people to access the files.

These documents are also collected, in accordance with the Terms of Service, in order to verify the identity of the user for the purpose of insurance or when the user is not solvent.

Payment Data

Additionally to your registration, you shall provide the following payment data that will be processed at the end of each ride or article bought in the HALA Store:

Full name of the cardholder, details of the payment card.

HALA, through the services of the payment providers Stripe, will collect, process and use the Payment Data for the purpose of providing the service and payment, thus the credit card number are hidden in the app, website and back office. HALA doesn’t collect or save any credit card information. This part is done by our payment provider according to the highest safety measures applicable in the e-commerce sector. Notably, the transaction will be made through a secured and encrypted process.

Chat message Data:

On the HALA App or website, users can contact anytime the support team through the messenger that is provided by a tierce party called Intercom. Chat messages are visible by the HALA support client team and can be assigned to other team member at HALA for several reasons (technical related question, partnership, etc....).

We collect this data for historical reason, to improve the overall experience and detect fraud if there are. Messages are automatically deleted after 9 months.

Also, we use parts of the message data (anonymized) in order to create saved replies for future use, improve our internal FAQ and add information to our guide in the app.

Scooters telematics data:

Each scooter that HALA provide to the users has an embedded software that collect and send data to our own server, this includes:

GPS coordinates, speed, accelerometer, battery status and level and other sensors information

In order to rent the scooter and offer the user the ability to locate, start and stop them from the app, we process this data and log them to improve our system. These data are also needed by the support team to help remotely a user that has any problem.

We also use geolocation and accelerometer data to detect incident or possible theft. Though all these data are not personal, we may access them to link to a potential user when we suspect a fraud.

How long is your personal data stored?

We only keep your personal data for the period necessary for the performance of our Services and the duration of your membership.

We archive personal information from closed accounts in accordance with rules applicable to the protection of your data only in order to comply with legal obligations, prevent fraud, collect any remaining fees that are due, resolve disputes, troubleshoot problems, assist with any investigations, enforce our terms and conditions, and take other actions otherwise permitted by law.

How is our exclusion list managed?

In accordance with our Terms of Services, and in order to guarantee the reliability and security of the operations carried out via the Services offered on our Site and our Application, HALA sets up an exclusion list of Users in the case of proven and verified fraud by our teams. If you register and you are on this list, the user's profile is blocked and the User is no longer allowed to use the Services offered by HALA.

HALA keeps the personal data of the Users concerned by this fraudulent activity for probationary purposes.

The exclusion list includes the reasons for registration and is regularly updated. User profiles are deleted from the list of regularisation of the incident that gave rise to the registration.

Does HALA share your data with third parties?

We do not sell personal data to third parties.

We may transfer personal data to our contractual service providers as listed previously. Before doing so, we take steps to ensure that your personal data is treated with adequate protection as required by data protection laws and HALA's internal policies.

HALA shall be entitled to process and use the User’s log data that is automatically collected (Server Log files) for the purpose of identifying, delimiting and removing malfunctions and errors in the telecommunication systems. If the requirements are met, HALA may use log data that is necessary to uncover any unlawful use of the telecommunication systems and services. In accordance with prevailing legal provisions, HALA may be required to provide information to criminal prosecution authorities and courts for prosecution purposes. In such situation, HALA may not inform you about the disclosure of your Personal Data to authorised third parties.

Your rights

As a user, you may exercise the following rights attached to your personal data:

• Permission to access

• Right of rectification

• Right to obliteration (right to oblivion)

• Right to limitation of treatment

• Right to data portability

• Right of opposition

To exercise any of these rights, you can contact us anytime on the chat of the application or also contact us by email on [e-mail] . We will respond promptly.

Security

What data security measures do we implement?

We employ efficient technical and organisational measures in order to safeguard the Service and other systems against loss, destruction, access, changes or the distribution of your data by unauthorised persons according to current the state of art. The data transfer between the Service and the Server is [SSL] encrypted.

The access to your HALA account is only possible after entering your personal password directly or through auto login processes. You should always treat your access information confidentially and close the browser window or sign-out, once you have ended your communication with us, particularly if you share the use of the computer and/or device with others.

HALA will store your data on servers, which are located in Mumbai and managed by AWS which is part of the Amazon that aims to promote the correct application of the GDPR. We also store users’ documents encrypted on a datacentre located in Paris (France) on Amazon Web Services Inc., which also participates in the Privacy Shield framework regarding the collection, use, and retention of personal information from Indian users.

Can we modify the Privacy Policy?

HALA reserves the right to modify or amend this Privacy Policy at any time, taking into account currently applicable data protection provisions. You will be notified once you log-on to our Service through the website or/and App if there are any changes. You will have the right to object by writing to [e-mail] according to the provisions as set forth in the terms of use.

Contact us

For any questions about personal data, you can contact us at the following address:

HALA Mobility India Pvt. Ltd, Hyderabad, Telangana

Or [e-mail].

Or [phone]