Privacy Policy

About us

Data Controller: Limited Liability Company (LLC) "Neiboo", registered in the Enterprise Register of the Republic of Latvia with registration No. 40203450673 (hereinafter – Enterprise)

In the Privacy Policy, the use of any word ‘you’, ‘your’, or similar expressions means any visitor of Neiboo Mobile application and it's corresponding API's, Neiboo Renters application, Neiboo Website “neiboo.com” altogether (hereinafter – the Platform). Terms such as ‘we’, ‘our’ or similar expressions mean Enterprise.

Personal Data

Personal Data is any information, that can be used to identify an individual.

When processing personal data, Enterprise complies with the provisions of the General Data Protection Regulation No. 2016/679 and the Personal Data Processing Law of the Republic of Latvia, as well as other Latvian legislation to ensure personal data protection.

The Privacy Policy shall explain how the Enterprise shall process personal data, the procedures for exercising the rights of a data subject, and issues related to the protection of personal data. The Privacy Policy of the Enterprise shall apply to the processing of personal data by and in connection with the operation of the Platform. Customers who purchase goods or use services on the Platform are subject to the additional terms and conditions outlined in the General Terms and Conditions and Distance contract as well.

What is our commitment?

With this Privacy Policy, the Enterprise commits to ensure personal data protection under the appropriate legislation and to comply with Good practice principles when processing and storing personal data:

- manage personal data following the law, in an honest and transparent way, providing information about personal data management processes as well as bout legal basis and purpose. Personal data shall be managed solely by personnel who in their duties require such actions.

- manage personal data with clear, specific, and legitim porous, and not manage with purpose not related to initial intent.

- to apply data amount and management minimization principles – to manage only required data that is necessary to reach the required goal;

- to ensure data precision – to improve and adjust unprecise data, except, if legislation requires otherwise;

- to store data, not exceeding the amount required to reach the required goal or time defined in legislation;

- apply and improve appropriate technical and organizational processes, to ensure personal data confidentiality, integrity, and safety, including protections against unauthorized or unlawful management as well as unintentional loss or damage.

What categories of personal data do we collect and why?

Ensuring Platform functions (providing services)

Providing services through the Platform, such personal data is managed, that relate to user actions on the Platform, as well as transactions and services, provided through the Platform and all actions required for the fulfillment of such services. Including occasions, when you wish to utilize customer withdrawal rights, if you have any questions or objections about an item provided by service, management of personal data will be required, to ensure the resolution of the mentioned actions. Without this personal data, the Enterprise could not adequately provide services, to ensure the functionality of the Platform and actions and services provided through the Platform.

Ensuring the functionality of the Platform

Personal data and/or category:

- Personal information (name, surname, title, representation rights)

- Contact information (e-mail address, phone number)

- Person identification, autentification statuss

- User-generated data and other data on the Platform and related technical information

- Registered user data

- Rental transactions (items, time logs, terms, etc.)

- Audit logs of actions performed on the platform's information systems.

Legal basis

Execution of obligations prescribed in legislation (including organizing accounting and recording transactions, ensuring compliance with service conditions, and facilitating the exercise of withdrawal rights).

Our legitimate interest is to ensure and promote the availability of services, receive payment, provide convenient service to customers, and provide evidence in case of claims.

Payments within the Platform

Personal data and/or category:

- payment method

- payment information (for example, account number, debit/credit card data, payment credentials and payment status, amount, and time logs)

Legal basis

Payments within the Platform are carried out by third-party payment provider. Payment credentials (Stripe user number, title, card number, card validity deadline, card type, invoice address), that are transferred to payment provide, this data is not accessible to Enterprise.

Renters section on Neiboo Platform

Personal data and/or category:

- Personal information (name, surname, title, representation rights)

- profile photo (not mandatory)

- Contact information (e-mail address, phone number)

- With person-related legal entity data (legal address, registration number, VAT id number)

- Personal additional identification data (personal number, "Screen name" (if a person for public use wishes to provide a different name))

- Rental item data (item, description, manufacturer, model, incentivization id, photo, category, year of manufacturing, value, rent price per hour, rent price per day, additional equipment, required locker dimensions, owner).

- Rental station subscription information (customer, locker, that is booked, subscription time, start date, end date, status)

- Placement information of the leased item (placed item, subscription, name, surname, email, phone number, status).

Legal basis

Our legitimate interest is to ensure and promote the availability of services, receive payment, provide convenient service to customers, and provide evidence in case of claims.

Transactions on the Neiboo platform and platform functionality.

Personal data and/or category

- Transaction data on the platform (renter, placement information, payment method, payer, start date, end date, status, payment amount)

- Booking status (Booked item, renter (lessor), intended renter (lessee), payment method, payer, start date, end date, status, payment amount)

- Claims and disputes information (description, photo, status)

- Rental station data (description, address, type, working hours, phone number, rental station coordinates, technical integration data, dimensions, locker ID, person interaction logs with rental station)

Legal basis

Our legitimate interest is to ensure and promote the availability of services, receive payment, provide convenient service to customers, and provide evidence in case of claims.

Registration on the Platform. (functionality of registered users)

Personal data and/or category

Legal basis

- Personal information (name, surname, title, representation rights)

- e-mail address, phone number

- logs of received services

- with services related status information

- Registered profile information (incl., username, profile status, and type), user added information

- with platform access related technical information and logs

Direct marketing, advertising and newsletter

With your permission, we will inform you about news and useful information, that relates to our provided services. If you wish to receive news you need to apt in on our Platform.

Personal data and/or category

Legal basis

- Personal information (name, surname, title, representation rights)

- contact information (e-mail address)

- with platform access related technical information and logs

Your permission

Investigation and prevention of unauthorized and malicious actions directed against us

To identify and prevent unauthorized and malicious activities against the Enterprise. (for example, investigate and prevent a break-in or unauthorized editing of the platform or disruption of the access to the Platform, as well as fraud attempt cases), we can collect and analyze data available to us, and provide it to law enforcement authorities or institutions for the prevention of information technology security incidents.

Personal data and/or category

Legal basis

- User-generated data, Platform browsing logs, information about user devices and settings, for example, language settings, time zone, operating system, IP and MAC addresses, browser settings, Other information about the use of the Platform, and other information of identification.

- Personal data (name, surname, title, representation rights, other provided information)

- Contact information (e-mail address, phone number, address)

- Payment credentials, payment data, payment method

- Service delivery information (delivery address, provided services information, provided services logs)

Our legitimate interest is to prevent malicious or service disruption activities or investigation of unlawful actions against Enterprise.

To fulfill a legal obligation stipulated in applicable legislation.

Your provided data, when you are in communication with us

When you contact us (including, to investigate claims) information necessary to us to reply to your inquiry, our available data can be used. Contact information, as well as Platform use of transaction data, can be used, to review investigate, and reply to claims, or cases when the Enterprise is investigating to settle disputes between users, as far as intended by Platform functionality.

Personal data and/or category

Legal basis

- Personal data (name, surname, title, representation rights, other provided information)

- Information related to representation rights (credentials, representation rights)

- Other informative data.

- Contact information (e-mail address, phone number, address)

- Data of used services (for example, rental item information, transaction information, and status)

- History logs of used services and rented items

- Payment credentials, Payment information, payment method

- User-generated data and other data related to the use of the Platform

To fulfill a legal obligation stipulated in applicable legislation.

Our legitimate interest is to provide customer service.

Sources where we collect personal data and the correctness of the data collected?

Personal data we collect from you. We accumulate information, when you browse and use Platform, providing us with the data (including data filled in Platform fields), as well as data, that you contact us. We can collect data from our service providers, that ensure the functionality of the Platform, including statistics data of its functionality, cyber security, and brake-in prevention data.

We can collect data from other Platform Users, as far as other users are related to a particular case (for example, sub-users in the user account, and communication, that is related to transactions, etc.)

If your data provided to us, has changed (for example, contact information for receiving news), you are required to contact us without a delay to update outdated or erroneous data.

To whom do we provide your data?

- Service providers and our partners

To fulfill our obligations, and to ensure Platform functionality and services of the Enterprise, we submit your data to companies and entities, that provide services to us, for example, payment service providers, delivery service providers, and others with platform functionality-related service providers. As well as service providers related to Enterprise functions (IT services providers, outsourced accounting service providers) in specific functions are considered as your data managers.

In regular operations your data are submitted to the payment provider (usually Stripe), and data storage services provider (usually Amazon Web Services Europe), for accounting purposes related data to be submitted to accounting and with it related services providers.

Cookies are collected by us and our service providers, which provides Platform functionality, by analyzing and collecting data about your browsing on the Platform.

If any communication tools are added to the platform, your data is provided to corresponding service providers.

We apply reasonable effort, to check all service providers, that in accordance with the task given by us collect and manage your data. Service providers are not permitted to use your data for any other purpose.

- Other users on the Platform

Please note that all data provided by the platform user, in case of a claim or dispute, can be submitted to other Platform users, as far as it is related to transactions concluded on the Platform, or to investigate and/or mitigate any illegal or malicious activity. For example, lessees are provoded with the lessor data, that is required to receive and return items, and lessors are provided with lessee data, in case of theft of the item, delay in a return of the item, damage of the item, and other cases related to the functionality of provided services.

- Law enforcement authorities, state and municipal institutions

To fulfill our obligations prescribed under the legislation, we can transfer your personal data to law enforcement authorities (for example, police), to the state and municipality authorities in accordance with their inquiry (for example, the supervisory authority responsible for the protection of personal data). We may disclose your personal data to law enforcement authorities (for example, courts), as well as to state and municipal authorities, also to defend our legitimate interests by preparing, submitting, and defending claims, complaints, and disputes.

Cookies

Use of the cookies

Platform and website as a part of the Platform, as well as other websites, use cookies, to improve experience when browsing and using the Platform and to ensure its appropriate functionality. We invite you to familiarize yourself with the principles of cookie usage.

When using cookies personal data can be collected. When using Platform, you agree with our usage of cookies (unless in your browser cookie usage settings use of cookies is not rejected). Please note – if you choose to disable the required cookies, the web Platform will not be able to function fully.

Information about cookies

Cookies are the information, that is collected and stored by your browser moment when you use our Platform. Next time, when you visit our platform, your browser will remember your actions and information and will apply it for you, for example, your chosen language, and will control the application of cookies. With cookies, the Platform gains the capability to store and apply saved user settings, recognize users, and act appropriately.

Types of cookies and purpose

There are two types of cookies — session and persistent cookies. Cookies also are sorted as first or third-party cookies. The following description of the mentioned terms is for your better understanding of the cookies used and why those are necessary.

Session cookies allow us to recognize you when you are browsing our Platform, storing your choices and settings, and displaying the same way on other pages. These cookies allow you to quickly and conveniently use the same website's different pages, excluding the necessity to apply settings repeatedly to each page separately. Session cookies are non-existent — they end when you close the browser or end the session on the website.

Persistent cookies are ones, that are stored on your computer for a certain amount of time after the session is ended, those allow us to remember user choices and settings the next time visiting the Platform.

First-party cookies are directly stored by the Platform you visit, supported by an infrastructure of the Platform, those are administered by the owner and operator of the Platform, in this case, us. Third-party cookies are provided by other services and are not our property. Third-party cookies may be stored on your device whan visiting our Platform.

List of cookies

Storing time on our Platform is indicated as maximal, and at any time you can delete it.

Type

Service provider

Purpose

Time

Additional information

NEXT_LOCALE

Persistant

Neiboo

Stored user's language settings

1 year

jwt_authorization

Session

Neiboo

Stored user’s access key

1 hour

user_data

Session

Neiboo

Stored user's registration data

Time of session

path_of_views

Session

Neiboo

Stored user's platform view data

Time of session

__stripe_mid

Persistant

Third-party (Stripe)

Set by Stripe, the service we use to process payments, to allow prevention of fraud.

1 year

__stripe_sid

Persistant

Third-party (Stripe)

Stripe is used to make credit card payments. Stripe uses a cookie to remember who you are and to enable Apolitical to process payments without storing credit card information on its own servers.

1 day

How do we use cookies?

To store personal settings

Cookies allow our Platform to remember settings, that impact Platform layout and function. For example, selected language or region, location. These cookies also can allow you to change text font size and other customizable website settings. Cookies also allow convenient use of services, booking, and payment transactions.

For security purpose

We use cookies, to authenticate users, mitigate fraud, to protect user data from unauthorized access and use.

Statistics data collection, browser amount monitoring, and network security

Each time when you visit our Platform, analytics software collects cookies. That allows us to analyze how many users visit our website repeatedly. This way we better understand the browsing habits of our users, as well as, their preferences and interests. This in no way is related to other information. For example, we know that some segment of Platforms is repeatedly visited by some amount of users, but we do not know who they are.

Collected data can also be used, to protect infrastructure from cyber attacks and to mitigate potential harm.

To store registration data

For returning customers opt-in or opt-out information can be stored, as well as can help fill out text fields on the Platform.

Advertisment purouses

We also use cookies, to make advertising more appealing and more suitable to you as our user. Cookies are typically used, for picking suitable advertisements, based on information relevant to the user (re-marketing), to improve the efficiency of advertising, for example, not to show user advertising that is already viewed repeatedly. We use remarketing data only for user segmentation, to help provide appropriate advertising content. Segments are created based on different overall browsing and interaction data and content of visited pages.

If we have permission to use your data for marketing purposes, including profiling, for this purpose we can use also other collected data collected from you, by applying automated management, and creating individualized profiles, that later can be used for tailored marketing purposes.

How to adjust cookie settings?

In most cases, there is no particular way how to disable cookies without partial functionality limitations of the Platform. If you are not certain, about the necessity of the cookies, to fully utilize the provided services, we recommend you to store cookies.

Adjustment of cookies and disabling of cookies are done by the tool provided the first time opening the website.

Cookies can be deleted in your browser – typically they can be found in “visited website history”.

Browsers also permit blocking cookies on your devices, for example, using the functionality “Enabling anti-tracking measures”. Please note, that in these cases Platform functionality may be limited. To learn about your browser cookie settings please visit the appropriate website of a particular browser.

Transfer of personal data outside the European Union and the European Economic Area. (ES/EEZ)

We strive always to store and manage your data within the European Union and the European Economic Area (ES/EEZ) territory.

On specific occasions, our service providers may be based outside the ES/EEZ, however, on these occasions we verify that our service providers are reliable, as well as that General Data Protection Regulation requirements and conditions are met and we apply safeguards for such data transfers. (for example, applying standard data protection clauses).

How long your data is stored?

All data provided by you are stored as long as you are using our services, (incl., registered user data), or until you do not delete your registered user data (except data, that is stored and managed for a certain amount of time) or you do not revoke, the permission of use of your personal data. Usually, we store data related to accounting for the period required by corresponding accounting regulations and legislation, as well as other purposes such as warranty related to provided services. Usually, the time for storing this data is 5 years. Longer storing of data is permitted, to comply with legislation related to minimal storing times of certain data rot o protect our to protect our legitimate interests.

When this time has lapsed, we safely delete your personal data or we will make those anonymous, so those can't be linked to you.

We also reserve the right to delete and/or irreversibly anonymize your data, if the legal basis has expired or, if use of those is not essential to the further use of services.

You are responsible for storing and deleting data on your device and browser, cache memory, and using appropriate browser tools for deleting data.

How do we protect your personal data?

We ensure, update, and improve safety measures, to protect your personal data from unauthorized access, accidental loss, disclosure, or destruction. For this purpose, we use technology, and technical and organizational measures including using a firewall, updating software, and using data encryption.

What are your rights?

The data subject has general rights as provided by the General Data Protection Regulation and other applicable legal acts, including:

- Access to personal data

You have the right to request confirmation from us whether we process personal data related to you, and in such cases, to request access to this personal data or provide information about the personal data if direct access is not forseen.

- Correction of personal data

If you believe that the information about you is incorrect or incomplete, you have the right to request us to correct or supplement it.

- Withdrawal of consent.

As far as we process your personal data based on your consent, you have the right to withdraw your consent to the processing of personal data at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal, as well as in cases where data processing is carried out on another legal basis.

- Objection to the processing of data for the purpose of addressed information delivery.

You have the right to object at any time to the processing of your personal data for direct marketing, including addressed information delivery purposes.

- Objection to processing based on legitimate interests.

You have the right to object to the processing of your personal data based on our legitimate interests; however, we will continue processing your data even if you object, if we have legitimate reasons to continue processing your personal data. To exercise these rights, please submit a written request to us.

- Deletion

In certain circumstances, you have the right to request us to delete your personal data, but this does not apply to cases where the law requires us to retain the data. To exercise the aforementioned rights, please submit a written request to us.

- Processing restriction

In certain circumstances, you have the right to restrict the processing of your personal data. Please note that if you request the restriction of your data processing, it may affect your ability to receive our services and purchase goods. To exercise the aforementioned rights, please submit a written request to us.

- Transfer of data

You have the right to receive or transfer your personal data to another data controller. These rights cover only the data you have provided to us based on your consent or contract, and if the processing is carried out automatically. To exercise the aforementioned rights, please submit a written request to us.

Which law regulates the operation of the website?

The operation of the website, as well as all relationships between you and the Enterprise, are regulated by the laws of the Republic of Latvia, as well as the relevant applicable laws of the European Union.

Can changes occur in data processing?

If the Enterprise introduces changes to the processing of personal data, these will be notified by making amendments to this privacy policy. The Enterprise may make changes to the privacy policy, with the current version published on the website.

What can I contact if I have any questions?

If you have any questions, comments, or requests regarding the privacy policy or the processing of your personal data, please contact the Enterprise. If you are not satisfied with the response received, you have the right to submit a complaint to the supervisory authority – the Data State Inspectorate. (www.dvi.gov.lv)

Video surveillance

To prevent criminal offenses, ensure security, clarify circumstances of incidents, and address claims, video surveillance is conducted at SIA Neiboo self-service stations. SIA Neiboo ensures the placement of informational signs in areas where video surveillance is conducted. The disclosure of video recording images is strictly in accordance with the purpose of the video surveillance.

Supervisor contact information

To contact us, you can write an email to info@neiboo.com or the postal address: Limited Liability Company "Neiboo", address Silmaļu street 29-7, Salaspils, Salaspils county, LV-2121, Republic of Latvia, phone: +371 20020375.

Revision dated: 02.01.2024.