Privacy Policy

Last Updated: 11 Apr 2023

Tumba Solutions Ltd., UIC 203100748, 1504 Sofia, 14A San Stefano street, groundfloor, ap. 34 ("us", "we", or "our") operates the WeRide Today mobile application (the "Service"). This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of personal information when you use our Service. Please also read our Terms of Service which sets out the terms governing the Services.

We are committed to protecting your privacy and ensuring that your personal data is processed in accordance with applicable data protection legislation, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), United States' Health Insurance Portability and Accountability Act (HIPAA) and other relevant laws and regulations.

This Privacy Policy was written in English. To the extent a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this Privacy Policy does not apply to third party products or services or the practices of companies that we do not own or control, including other companies you might interact with on or through the Services.

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Information Collection and Use

While using our Service, we may ask you to provide us with certain information that can directly or indirectly identify you and be used to contact you. Personally identifiable information may include, but is not limited to:

  • Location data: When you enable the "ride mode" feature or request location-based information, we collect your latitude and longitude coordinates to provide you with relevant content and services.
  • Personal Information: If you request to access, edit or delete your personal information, or inquire about any other privacy-related concerns or questions, we may require you to verify your identity before responding to such requests. In that case we may collect this information with your consent, which is provided when you create an account on our app. This includes your name, email address, date of birth, gender, and any other information you provide to us directly through our app, third party applications or via email following the best practices for securing personal information.

Health Information

WeRide Today may collect or infer health information. Certain health information may be inferred from sources such as weight or other measurements, including power, cadence etc... Before you can upload health information to WeRide Today, you must give your explicit consent to the processing of that health information by us. You can withdraw your consent to WeRide Today processing your health information at any time.

Log Data

When you access the Service through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device's unique device ID, the IP address of your mobile device, your mobile operating system, the type of mobile internet browser you use, and other diagnostic data ("Log Data").

Cookies

Cookies are files with a small amount of data that are commonly used as unique anonymous identifiers. Our Service does not use cookies explicitly. However, third-party services used in our app may use cookies to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device.

Service Providers

We may employ third-party companies and individuals to facilitate our Service, provide the Service on our behalf, perform Service-related services, or assist us in analyzing how our Service is used. These third parties have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Community Available Information

When you log in the WeRide Today App, your nickname, avatar and routes or rides are set to be viewable by everyone by default. As WeRide Today is a social biking network your nickname, avatar and routes or rides can be accessed by other community members.

Security

The security of your personal information is important to us, but remember that no method of transmission over the internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

International Transfer

Your information, including personal information, may be transferred to — and maintained on — computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those in your jurisdiction.

Data Retention

We will retain your personal information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal information to the extent necessary to comply with our legal obligations ( for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Children's Privacy

Our Service does not address anyone under the age of 13 ("Children"). We do not knowingly collect personally identifiable information from children under 13. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us. If we become aware that we have collected personal information from a child under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

Data Protection Authority

If you are a resident of the European Economic Area (EEA) and you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. You can find their contact details here.

California Privacy Rights

If you are a California resident, you are entitled to certain information and have certain rights under the California Consumer Privacy Act (CCPA). Throughout this Privacy Policy, we have disclosed what information we collect, how it is used, and the types of third parties that may receive your information. Under CCPA, you also have the following rights:

  • Right to Access: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
  • Right to Delete: You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

To exercise your rights under CCPA, please contact us using the contact information provided in this Privacy Policy.

Consent & Processing

By using our Service, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. "Processing" refers to any operation or set of operations performed on personal data, whether or not by automated means. It includes activities such as collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, combination, restriction, erasure, or destruction of personal data according to the international personal data law.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Data Breach

In the event that we become aware of a security breach, unauthorized disclosure, or inadvertent disclosure concerning your personal information, we will take appropriate steps to address such incidents. We will also notify you and any applicable authorities, as required by law, about any data breaches that may have affected your personal information.

Changes in Ownership

In the event that we are involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets, your personal information may be transferred as part of the transaction. In such cases, we will notify you via email and/or a prominent notice on our website of any change in ownership, as well as any choices you may have regarding your personal information.

Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the Republic of Bulgaria. Any disputes arising in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Sofia City Court.

Your Rights

You have certain rights in relation to your personal information, including the right to access, correct, update, or request deletion of your personal information. If you wish to exercise any of these rights, please contact us using the contact information provided below.

EU Privacy Rights

If you are an EU citizen or a resident, the GDPR is the EU data privacy law that applies to organizations that handle personal data whether they are EU-based organizations or not, known as "extra-territorial effect".

In that case, with regard to the processing of your Personal data by us for the purposes specified in this Privacy Policy, you have the following rights:

  • Right of information: to obtain information regarding the processing of Your personal data on our part. The present policy has been prepared and made available to You with respect to this right.
  • Right of access: to obtain confirmation whether personal data relating to You is being processed as well as to obtain access to these data, incl. to request a copy of the data.
  • Right of rectification: to request rectification or completion of Your personal data in case the data are inaccurate or incomplete.
  • Right of erasure: to request the erasure of Your personal data if there are the grounds for this provided for in the GDPR
  • Right of restriction of processing: to request restriction of processing of Your personal data within the limits provided for in the GDPR, if there are grounds for this.
  • Notification of third parties to whom the personal data has been provided, of any rectification, erasure or restriction of processing of personal data unless this is impossible or requires a disproportionate effort on our part;
  • Right of data portability (if applicable): to receive the personal data which You have provided to us, in a structured, commonly used and machine-readable format and to transmit those data to another controller without hindrance if there are the grounds for this provided for in the Regulation;
  • Right not to be subject to a decision based solely on automated processing (i.e. without human intervention), including profiling within the meaning of the GDPR. For avoidance of any doubt we do not process Your personal data in this manner.
  • Right to withdraw consent for processing, at any time and without detriment, when the processing is based on consent;
  • Right to lodge a complaint with a data protection supervising authority in case You consider that the processing of Your Personal data infringes GDPR or any other applicable requirements for data protection.
  • Right to object to processing of your personal data, which is based on legitimate interest, pursuant to Art. 6 (1) (e) GDPR. In the event of such an objection, we will consider your request and, if it is reasonable, we will comply with it. If we believe that there are compelling legal grounds for processing, or that it is necessary to establish, exercise, or defend legal claims, we will inform You of that.
EU Data Protection Authority

If you believe we are unlawfully processing your personal information, you have the right to complain to your local data protection supervisory authority. You can find their contact details here.

The data protection supervising authority in the Republic of Bulgaria is the Commission for Personal Data Protection, with its registered address: 2 Prof. Tsvetan Lazarov Blvd, 1592 Sofia, Bulgaria, Website.

California Privacy Rights

If you are a California resident, you are entitled to certain information and have certain rights under the California Consumer Privacy Act (CCPA). Throughout this Privacy Policy, we have disclosed what information we collect, how it is used, and the types of third parties that may receive your information. Under CCPA, you also have the following rights:

  • Right to Access: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.
  • Right to Delete: You have the right to request that we delete any of your personal information that we collected from you, subject to certain exceptions.
  • Right to Non-Discrimination: We will not discriminate against you for exercising any of your CCPA rights.

Contacting Us

If there are any questions regarding this Privacy Policy, you may contact us using the information below:

Tumba Solutions Ltd.
1504 Sofia, 14A San Stefano street, groundfloor, ap. 34
weride AT tumba.solutions

By contacting us and providing your contact information, you can:

  • Request access to the personal information we hold about you.
  • Request that we correct or update any personal information we hold about you.
  • Request that we delete any personal information we hold about you.
  • Inquire about any other privacy-related concerns or questions.

Please note that we may require you to verify your identity before responding to such requests.

Changes to This Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time. If we make any material changes to this Privacy Policy, we will notify you either through the email address you have provided us or by placing a prominent notice on our website. Your continued use of the Service after such modifications will constitute your acknowledgment of the modified Privacy Policy and your agreement to abide and be bound by the modified Privacy Policy.