Version update: 27 October 2021
Who is FlexClub and how can you contact us?
The party responsible for the processing of your personal data is FlexiiDrive B.V., acting under the name FlexClub, a private limited liability company established in The Netherlands, having its offices at Vijzelstraat 68, 1017 HL Amsterdam, the Netherlands, registered at the Amsterdam Chamber of Commerce under number 69954283.All questions regarding the processing of personal data by FlexClub can be addressed to email@example.comFor security related queries, please email us at firstname.lastname@example.org. For any other queries, including opt-out requests, please email us at email@example.com or send us a letter at Vijzelstraat 68, 1017 HL Amsterdam, the Netherlands.
How do we process your personal data?
Customer service To provide customer service FlexClub may collect and process your personal data to be of service to you and to respond to any questions you submit through email or the contact form on the website, including helping you with any issues which may arise regarding our website and/or services.
The processing of these personal data is necessary for the purposes of the legitimate interests pursued by FlexClub (Article 6.1(f) GDPR), namely being able to serve you efficiently and to optimise FlexClub´s customer service. FlexClub will delete your personal data within 1 month after responding to your message or resolving your complaint.
Careers When applicants provide us with personal data, we will process such personal data for recruitment and selection purposes. The personal data and documents provided by you may include your contact details, CV and motivation letter. We may process this personal data to determine your eligibility for the vacancy for which you have applied or, in case of an open application, to determine your eligibility for a position within FlexClub. An assessment may be a part of the selection procedure. FlexClub has a legitimate interest in the aforementioned data processing activities (Article 6.1(f) GDPR), which includes the recruiting of suitable new staff that meet our high standards of service.
FlexClub stores applicants’ personal data during the recruitment and selection procedure. Your application data will be deleted (in the event of rejection) by FlexClub no later than 4 weeks after the end or completion of the application procedure. Only with your consent will FlexClub retain your application data for a period of 1 year in order to be able to inform you if a suitable position becomes available for you at a later date.
How do we share your personal data?
Sharing with Other Parties in Subscription TransactionsFlexClub enables Vehicle Partners to offer their vehicles for subscription to Members. If you use FlexClub Services, FlexClub may provide your personal information to the other party (or parties) in that transaction as reasonably necessary to facilitate the subscription transaction. For example, FlexClub may provide your mobile phone number to facilitate communication or your photograph to facilitate identification.
Sharing with Vendors and Service ProvidersFlexClub may also share personal information with vendors and service providers who are engaged by or working with us in connection with the operation of our website and who need access to such information to carry out their work for us. In some cases, the service provider may be directly collecting the information from you on our behalf. FlexClub will choose service providers who give sufficient guarantees to protect personal data and implement appropriate measures to comply with applicable data protection laws. Service providers we make use of are: External hosting providers, including cloud providers for the storage and management of data;Third party vehicle fleet providers;Third party insurance providers;Third parties that provide tools for analytical purposes;Payment service and collection providers in order to process and collect your payments;Third parties that provide services with regard to credit checks, fraud detection (as described above) and tools with which FlexClub is able to verify the personal data you provided; Other specific tasks that have been outsourced, including IT support, customer service and email marketing.
Sharing with Insurance CompanyIn order to have the insurance company provide insurance coverage when you subscribe to a car, FlexClub or the Vehicle Partner shall share your personal data when you subscribe to a car with the insurance company. The data transfer to the insurance company is required in order to set up insurance coverage between you and the insurance company, to verify if you meet the requirements, the vehicle is not registered stolen or missing, and to verify your identity and ownership of the vehicle. The processing of your personal data in this context is necessary for the performance of a contract with an insurance company to which you are a party (Article 6.1(b) GDPR).
Sharing for Other PurposesFlexClub may disclose personal information in the good faith belief that we are lawfully authorized or required to do so, or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of FlexClub, our users, our employees or the public. That includes actions we may take to protect FlexClub or our users from fraudulent, abusive, inappropriate or unlawful use of our site or platform. Information about our users, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale of company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of FlexClub.You understand that when you use the site, information you post in your profile or in any other area of the site will be available to other users and in some cases may be publicly available.
Do we transfer your personal data outside the European Economic Area?
Some of our service providers and vendors are located outside the European Economic Area (EEA), including South Africa, Mexico and the United States. To comply with EU data protection laws around international data transfers, FlexClub only allows service providers outside the EEA to process your personal data if they apply the European Commission’s Standard Contractual Clauses (Article 46.2(c) GDPR). For more information on where and how the relevant document may be accessed or obtained, please contact us.
What are your rights?
Under the GDPR, you have a number of rights with regard to your personal data and the processing thereof:Right to access You have the right to obtain confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to your personal data and additional information about the processing of your personal data.Right to rectification You have the right to request the rectification of inaccurate personal data concerning you.Right to be forgotten You have the right to ask us to erase your personal data (right to be forgotten) for example if the personal data are no longer necessary in relation to the purposes for which they were collected; you withdraws consent on which the processing is based, and where there is no other legal ground for the processing; or the personal data have been unlawfully processed.Right to restriction You have the right to obtain restriction of processing of your personal data, for example when you have contested the accuracy of your personal data.Data portability You have the right to receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller, where the processing is based on your consent or on a contract.Right to object You have the right to object to processing of personal data which is based on our legitimate interests. We shall no longer process the personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims. Where personal data are processed for direct marketing purposes, you always have the right to object to processing of personal data for such marketing. In that case, we shall no longer process your personal data for such purposes. If you wish to opt-out of marketing and promotional emails, please contact us at firstname.lastname@example.org. You may not opt-out of receiving service-related emails. Withdraw consent Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. You may send your request to email@example.com. We will respond to your request without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If we do not take action on your request, we will inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action. In that case, you also have the right to lodge a complaint with the supervisory authority and to seek a judicial remedy.
It is possible that, despite our careful approach, you have a complaint about the way FlexClub processes your personal data and/or the way we deal with your rights. In that case, you may also submit a complaint to the national data protection authority through their website.