Privacy policy

We are the Cyprus Company 2go mobility Ltd with the following scope of activities: short-term and long- term rental services as well fleet management.
toGO’s privacy policy outlines our commitment to respecting our members’ personal information. We endeavor to communicate clearly what information we will collect, the reasons for collecting personal member information, the ways that the confidentiality of this information is protected, and finally, how members can request a copy of the personal information that is recorded.
toGO is an independent co-operative and member information is not automatically shared with other organizations with which we are affiliated. Members (and potential members) can always choose not to provide toGO with some or all personal information; however, this decision may prevent toGO from determining membership eligibility and the ability to provide members with full access to available or requested services. We will not collect your personal information without your consent.

toGO is responsible for the personal information that is collected from our members. toGO’s Data Controller can be reached by email at gdpr@togorent.com or at
Data Controller , toGO
2GO MOBILITY LTD
26, Tomb of the King, shop 8
8046 Pafos

The processing described in Section 4 is performed on the following legal bases in accordance with the EU General Data Protection Regulation (GDPR 2016/679):

• Data processing for contract fulfillment: Article 6 Section1 b) GDPR
• Data processing based on your consent: Article 6 Section 1 a) GDPR
• Data processing for the pursuit of legitimate interests: Article 6 Section1 f) GDPR
• Data processing for compliance with legal requirements: Article 6 Section1 c) GDPR

"Safeguards" as defined by Art. 46 GDPR when using service providers as set forth in the section "Recipients of personal data" are provided by standard data protection clauses as approved or adopted by the European Commission, binding corporate rules, or similar instruments. For an electronic copy of the relevant excerpts, please contact the corporate data protection officer.
As a data subject affected by data processing, you have the right to information (Art. 15 GDPR), rectification (Art. 16 GDPR), data erasure (Art. 17 GDPR), restriction of processing (Art. 18 GDPR) and data portability (Art. 20 GDPR).
If you feel that the processing of your personal data is in breach of legal requirements, you have the right to file a complaint with the responsible data protection supervisory authority (Art. 77 GDPR).

toGO collects personal information so that we can:

• Determine membership eligibility;
• Communicate with members about their participation in toGO’s carsharing program and other services requested by the member—including but not limited to follow-up about vehicle bookings and usage, invoices, newsletters, organizational announcements, etc.;
• Improve our services through member surveys and consultation conducted directly by toGO or by approved third parties;
• Ensure members are using vehicles in an appropriate manner;
• Ensure policies pertaining to carsharing with toGO are followed by members;
• and Comply with legal and insurance requirements.

As part of member participation in a carshare program, toGO collects a variety of information about its members. Typically, such information includes but is not limited to:

• Contact information, including your home address, telephone number, and email address;
• Member eligibility and insurance needs, including such items as driver’s licence, driving records (listing traffic violations) and claims history (listing claims made on your insurance policies);
• Credit information and history, including your credit report;
• Payment information, including your banking information, a record of your payment, your credit card information if you choose to make payments by credit card, and other information that you provide so that we can collect payment;
• Vehicle usage information, including driving speeds and vehicle location;
• Membership history at toGO;
• and Publicly available information.

For a majority of the time, toGO collects personal information directly from the member through application forms, surveys, member-initiated communications, and information that a member directly requests a third party to send to toGO. If we are communicating with a member by telephone, email or any form of electronic communication, we may record such communication for quality assurance purposes. In-vehicle telematics will provide information on vehicle usage including but not limited to driving speeds and locations. In some appropriate circumstances, we obtain information from third-party sources—for example, affiliated carshare organizations whose members want to become roaming members with toGO. Driving records and credit information may be obtained from third-party sources such as other insurers or credit reporting agencies, as appropriate.

Member knowledge and consent are required for the collection, use or disclosure of personal information, except as required or permitted by applicable law. toGO only collects, uses or discloses personal information for purposes that are necessary to deliver carsharing services, or that we believe members would consider appropriate under the circumstances. For these purposes, we may make personal information we collect available to our employees, agents, service providers, insurers and business partners. When a person becomes a member of toGO, we will use his/her name and address for mailing and billing purposes, including sending account statements and newsletters.
Except as set out in this policy, or as required or permitted by applicable law, toGO does not sell or disclose any personal information to any other organization and toGO will not transmit personal information to third parties without first obtaining consent to do so. toGO will never sell our member information. toGO may, however, disclose information in the following cases:

• to our lawyers and auditors;
• to a police force as required by law;
• in emergency situations affecting the life, vital health or safety of a member or individual;
• to all other persons or government agencies authorized by law;
• to credit reporting agencies or to an agent retained by toGO in connection with the collection of your account, if your account is in default or if requested by you;
• to a person who, in the reasonable judgment of toGO, is seeking information as a member’s agent;
• or to a third party or parties where you consent to such disclosure.

toGO will also occasionally share aggregated information about our members. This information does not contain any personal information.

We collect only the information that we need in order to deliver services and information to you.
We do not use or disclose your personal information for any purposes other than those for which it was collected, except with your consent or as required or permitted by law.
Personal information is retained only as long as necessary for the fulfillment of the purposes for which it is to be used. toGO does not keep personal information if it is no longer needed for the purposes required or as required by law.

Members’ personal information is kept accurate, complete and up to date as is necessary and reasonably practical for the purposes for which it is to be used.

We protect personal information by using safeguards that are appropriate to the sensitivity of the information.
Our Employees’ Responsibilities: Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information, and each employee and contractor signs a confidentiality agreement upon being engaged by toGO. If toGO contracts with an outside agency or contractor, toGO will ensure that they adhere to toGO’s Privacy Policy.

We will make our policies and practices relating to the management of personal information readily available to our members.

Cookies are used by the togorent.com website. A cookie is a small message sent from our web server to your web browser during your visit to our website. Your browser stores the message as a small text file on your computer. The message is then sent back to the server each time your browser requests a page from our web server.
Browsers are normally set to accept cookies, but you can disable this function in your browser settings. Enabling cookies is not strictly necessary for the website to work, but it will provide you with a better browsing experience.
The primary purpose of cookies is to continue to recognize your computer during a visit to our website and to retain your display preferences when you switch from one of our web pages to another, or leave our website and return later.
The information in cookies is not used to identify you personally. We also do not use techniques that combine information generated by cookies with users’ personal data. Information collected automatically.
When you visit our website or use our application, we automatically collect certain non-personal information from your browser or device. This information could include your IP address, device ID, your browser type and language, display preferences, access times, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address. Cookies and Use of Cookie Data.
We may assign your device one or more cookies to facilitate your use of our website or application and to customize your experience. Through the use of a cookie, we may collect information about your online activity on our site, such as the pages you visit, the time and date of your visits, the links you click, and the searches you perform on our site. If you choose to disable cookies, please note that you may not be able to sign in or use some of the interactive features offered on our website. Other Technologies.
We may use standard Internet technology, such as web beacons, pixel tags, local storage and other technologies that facilitate personalization to track your use of our site. We also may use these technologies in advertisements or email messages to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the services we offer our website visitors, to deliver customized advertisement, and to measure the overall effectiveness and relevance of our online advertising, content, design, website navigation or other aspects of our services.
Information collected by third-parties. We may permit service providers or third parties to display advertisements on our site. These advertisers may use tracking technologies, such as cookies, to collect information about your interaction with their advertisements. This information allows them to deliver targeted advertisements and to evaluate the impact of those advertisements.

We store and process your personal data only as long as needed for the respective purpose (see Section 4). Moreover, data is stored and processed only if required for another purpose under Section 4, such as to comply with legal requirements (such as retention obligations under tax or commercial laws). In this case, we limit further data processing to this purpose and the legal basis of further processing.

Upon request in writing, a member will be informed of the existence, use and disclosure of their personal information and will be given access to that information. We will assist any member who informs us that they need assistance in preparing a request concerning personal information. Members may challenge the accuracy and completeness of the information and have it corrected as appropriate.
Accessing Personal Information: If a member wishes to review or verify the personal information that toGO holds about them, or find out to whom we have disclosed it, they can do so by writing to us. toGO will normally respond within thirty (30) days to a request for access to personal information. toGO can refuse access in certain circumstances. Accuracy of Personal Information: A member can ask to correct any of their personal information. The request for correction must be made in writing to us, either by mail, fax or email at the aforementioned address.
Challenging Compliance: Members can address any challenge concerning our compliance with this policy to our Data Controller. toGO has established an internal complaint resolution procedure for privacy and information matters. Complaints are reviewed by the Data Controller, who will consult with the Chief Executive Officer or other advisors, asappropriate. A written response will be provided to the individual, usually within thirty (30) days.

We review this privacy policy at regular intervals to assure compliance with applicable law. We reserve the right to modify or update this privacy policy at any time in order to adapt it to new functions or features on the website or a changed legal situation. The privacy policy available from our website at the time of your visit will be valid with regard to data collected during that visit.