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. This Privacy Policy explains how we collect, use, and disclose personal information when you use the Service. Please also read our Terms of Service.

We are committed to protecting your privacy and processing personal data in accordance with applicable data protection legislation, including GDPR, CCPA, HIPAA, and other relevant laws and regulations.

This Privacy Policy was written in English. If a translated version conflicts with the English version, the English version controls. Unless indicated otherwise, this policy does not apply to third-party products, services, or companies that we do not own or control.

By using the Service, you agree to the collection and use of information described here.

Information Collection and Use

While using our Service, we may ask you to provide information that can directly or indirectly identify you and be used to contact you. Personally identifiable information may include:

• Location data: when you enable ride mode or request location-based information, we collect latitude and longitude coordinates to provide relevant content and services.
• Personal information: when you create an account or contact us about privacy requests, we may collect your name, email address, date of birth, gender, and other information you provide directly through the app, third-party applications, or email.

Health Information

WeRide Today may collect or infer health information from sources such as weight, power, or cadence. Before you upload health information to WeRide Today, you must give explicit consent to that processing. You can withdraw this consent at any time.

Log Data

When you access the Service through a mobile device, we may automatically collect information such as device type, unique device ID, IP address, operating system, browser type, and other diagnostic data.

Cookies

Our Service does not explicitly use cookies. Third-party services used in the app may use cookies to collect information and improve their services. You can accept or refuse those cookies and know when a cookie is being sent to your device.

Service Providers

We may employ third-party companies and individuals to facilitate the Service, provide it on our behalf, perform related services, or help us analyze usage. These third parties may access personal information only to perform tasks on our behalf and are obligated not to disclose or use it for another purpose.

Community Available Information

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

Security

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

International Transfer

Your information, including personal information, may be transferred to and maintained on computers outside your jurisdiction, where data protection laws may differ from those in your jurisdiction.

Data Retention

We retain personal information only as long as necessary for the purposes described in this policy. We may retain and use it as needed to comply with legal obligations, resolve disputes, and enforce agreements and policies.

Children's Privacy

Our Service does not address anyone under 13. We do not knowingly collect personally identifiable information from children under 13. If we learn that we have collected such information without parental consent, we will remove it from our servers.

Data Protection Authority

If you are an EEA resident and believe we are unlawfully processing your personal information, you can complain to your local data protection supervisory authority. Contact details are available at the European Commission website.

California Privacy Rights

If you are a California resident, you have rights under the California Consumer Privacy Act. These include:

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

To exercise these rights, contact us using the information below.

Consent and Processing

By using the Service, you consent to our processing of information as described in this policy. Processing includes collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, alignment, combination, restriction, erasure, or destruction of personal data.

Links to Other Sites

Our Service may contain links to sites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for third-party content, privacy policies, or practices.

Data Breach

If we become aware of a security breach, unauthorized disclosure, or inadvertent disclosure involving your personal information, we will take appropriate steps and notify you and applicable authorities as required by law.

Changes in Ownership

If we are involved in a merger, acquisition, bankruptcy, or sale of assets, your personal information may be transferred as part of the transaction. We will notify you of ownership changes and any choices you may have.

Governing Law

This Privacy Policy is governed by the laws of the Republic of Bulgaria. Disputes connected with this policy are subject to the exclusive jurisdiction of the Sofia City Court.

Your Rights

You may have rights to access, correct, update, or request deletion of your personal information. To exercise these rights, contact us using the information below.

EU Privacy Rights

If you are an EU citizen or resident, GDPR applies to organizations that handle personal data, including organizations outside the EU. For processing described in this policy, you have the following rights:

• Right of information: obtain information about how we process your personal data.
• Right of access: confirm whether data relating to you is processed and obtain access to it, including a copy.
• Right of rectification: request correction or completion of inaccurate or incomplete personal data.
• Right of erasure: request erasure of your personal data when GDPR grounds apply.
• Right of restriction: request restricted processing within GDPR limits.
• Notification of third parties: request notification of rectification, erasure, or restriction unless impossible or disproportionate.
• Right of data portability: receive data you provided in a structured, commonly used, machine-readable format where applicable.
• Right not to be subject to solely automated decisions: including profiling within the meaning of GDPR. We do not process your personal data in this manner.
• Right to withdraw consent: withdraw consent at any time when processing is based on consent.
• Right to lodge a complaint: complain to a data protection supervisory authority if you believe processing infringes GDPR or other data protection requirements.
• Right to object: object to processing based on legitimate interest under Article 6(1)(e) GDPR.

EU Data Protection Authority

You can find local data protection authority contact details at the European Commission website. In Bulgaria, the authority is the Commission for Personal Data Protection, 2 Prof. Tsvetan Lazarov Blvd, 1592 Sofia, Bulgaria, Website.

Contacting Us

If you have questions about this Privacy Policy, contact us at:

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

By contacting us and providing contact information, you can:

• Request access to the personal information we hold about you.
• Request correction or update of personal information we hold about you.
• Request deletion of personal information we hold about you.
• Ask about any other privacy-related concern or question.

We may require identity verification before responding to these requests.

Changes to This Privacy Policy

We may update or modify this Privacy Policy at any time. If we make material changes, we will notify you by email or by placing a prominent notice on our website. Continued use of the Service after changes means you acknowledge and agree to the modified policy.