WIND - Privacy Policy

1. General

Wind Tel Aviv (By Byke) Ltd. ("Yango Wind" and/or "Wind" and/or "We") provides a service of renting electric scooters through an application (the "Service"). Wind is committed to protecting the privacy of its users and the personal information they share with it, as detailed in this policy.

The Hebrew version of the privacy policy shall be legally binding for any user using our services within the State of Israel. Any other privacy policy wording given in a language other than Hebrew (including the English version of the privacy policy for Israeli customers) is for informational purposes only, and in the event of a discrepancy in the privacy policy, the Hebrew version shall prevail.

This privacy policy (the "Policy") applies to the use of the service, in Yango Wind and Yango application (the "Application") as well as to the use of our website at the address: https://wind.yango.com/israel (the "Website") and describes how personal information is collected and stored About you within the service, the type of information collected, as well as the way this information is used.

Yango Wind will be entitled to collect personal information as part of your use of the Service, in relation to your use of the Service. Yango Wind may also collect personal information through third parties (the "Partners") such as advertising partners who give you access to or allow you to use websites, programs, products, or services owned or operated by them. The partners can provide Wind with personal information in accordance with the applicable law, and in accordance with the separate agreements between Wind and each of its partners.

The information you provide will be stored, in accordance with the provisions of privacy protection laws, in Wind's database and will be kept for the time necessary for Wind to fulfill the purposes permitted by law and according to this privacy policy.

Please note that you don't have legal obligation to provide us with personal information, and any disclosure depends on your choice and consent and is done of your own free will for the purposes stated in this policy. To the extent that you do not wish to provide Yango Wind with personal information, or to the extent that you object to its use as specified in this policy, you must refrain from using the service in any way (including registration, use of our website or application, or any other use). By using the website, application or service, you acknowledge and agree that you are providing us with personal information of your own free will, for the purposes described in this policy. If you do not agree to any term of this policy, you must stop any use of the service (including the website and the application) and refrain from providing us with any personal information.

Also, providing incorrect information or failing to provide all the required information may prevent you from being able to use the service, damage the quality of the service provided to you, and damage the ability to contact you if necessary. The use of the information you provide will be as specified in this policy.

This policy is an integral part of our terms of use. By using the Service, you agree to this policy.

The conditions stated in this policy are dynamic and may change from time to time, including due to changes in legislation, changes in the services provided by us and changes in our policies. Accordingly, we recommend that you read the policy carefully and review it from time to time to stay up to date. If substantial changes are made in relation to the use of personal information, a notice will be published on the website and in the application. The current terms, as they will be changed from time to time, will enter into force on the date of their publication.

2. Definitions

"Privacy Protection Laws" – Israeli Privacy Protection Law, 1981, the regulations pursuant to it, and the guidelines of the Privacy Protection Authority, as published from time to time.

"Personal information" - any information that identifies or is directly linked to a specific person, including but not limited to: name, age, residential address, telephone number, I.D. number, passport, driver's license, etc., or as otherwise defined in the privacy protection laws.

The terms "processing" and "data subject" shall have the meaning given to them or any substantially similar terms in the privacy protection laws.

3. The type of information we collect and the way we collect it

3.1 Contact information will be collected during the registration process and when contacting us.

3.1.1 Registration:

To use the service, you must provide the required information during the registration process. Without providing the requested information, you will not be able to complete the registration process and use the service. You must provide correct, accurate and complete information.

When you choose to register for the Service, you authorize us to receive, store and use personal information about you. Only users who are at least 18 years old and who have a valid driver's license may register and use the service. You must refrain from providing any personal information to Wind if you are under 18 years of age.

During registration, you will be asked to provide us with identifying information such as your name and mobile number. You will also be asked to scan an identification document such as I.D. card, passport or driver's license as well as upload a photo of your face taken at the time of registration (for cross-checking with the identification document). We will use them to verify the authenticity of your identity and the validity of your identification document before we confirm your registration for the service. This will be done through a third-party service provider. We may require additional references to verify your identity. The scanning of the identification document is a prerequisite for registration, and it is required to comply with the requirements of the laws and regulations according to which the service is operated.

3.1.2 Contact us:

Whenever you wish to contact us through our customer service, you will be asked to provide us with your name, your email address, and the content of the inquiry you wish to direct to us. Yango Wind will be entitled to record your request and collect additional personal information when you contact us, and as part of any additional communication (whether in writing or via telephone calls).

When you communicate with us through the app, the website, email or otherwise, we may monitor and save phone calls, emails, live chats as well as record any communication between you and Wind's customer service representatives.

3.2 Payment method details will be provided by you at the time of registration for the service or at the time of start of use and will be entered in your personal account. You will be asked to provide us with payment details for renting the scooter. Yango Wind may require additional information to verify your identity, before allowing you to perform any action involving payment services.

3.3 Information for safety purposes. Yango Wind will be entitled to use technological tools of third parties to verify that you are wearing a helmet before each use of the scooter and for this purpose Wind will be entitled to require you, before each use of the scooter, to take a selfie of you wearing a helmet. If Yango Wind has placed such a requirement, identifying the wearing of a helmet through such a photo, which will be performed by a third party, is a prerequisite for using the scooter.

4. Location data collection

Yango Wind uses location-based services based on navigation system technology, in order to determine your location and the location of the scooter, and to provide you with information that corresponds as much as possible to this location (such as locating scooters available for your use, providing information about the operating area, its boundaries, current applicable prices in your area, etc.) Among other things, we collect information about the points of origin and destination of your ride.

Wind will not be able to provide you with the services if you do not agree to use this technology.

Additionally, for content matching, security, and marketing purposes, we may collect information about your general location as reflected by your IP address.

5. Collection of information during the use of the service

When you use the Service, Wind collects information about your use, including all of these:

1. The extent, frequency and manner of your use of the service (including the application and website);

2. The date and duration of your use of the service (including the application and website);

3. The distance of your ride;

4. Location of the start and the end of your  ride;

5. Unusual events, such as:

A. Accident of any kind;

B. Property damage;

C. Theft and damage of scooters and/or other means of transportation;

D. Any indication that you are under 18 or not wearing a helmet;

6. The location of your computer or mobile device and information such as IP address, through which you access the Service;

7. The type of operating system you are using;

8. Device type and device information, and more.

9. Also, Wind will be entitled to use the services of third parties to collect and analyze anonymous, statistical and cumulative information in connection with your use of the service. This information is usually collected automatically and stored in the "log" files of the service servers.

6. The purposes of using the information

We will use information about you for the following purposes:

• Allow you to use the service, rent and return a scooter and pay the rental fee;
• Verify your identity and age and identify you during your access to and use of the service, including photo and identification document verification as well as helmet identification through third parties;
• For operational needs, as well as to improve and enrich the services and content offered within the service, including the creation of new services and content that match the requirements and expectations of the users, as well as to change or remove services and programs from the service; The information Wind uses for this purpose will mainly be statistical information or information that has been completed, and that does not identify you personally;
• Allow you to adjust the service to your preferences;
• For contact, customer service, management, optimization and control of the service;
• Send you operational messages regarding the service, including messages regarding the scooters you rented, tax invoices and transactions, and similar messages;
• To send you from time to time by Wind and/or other companies related to Wind in Yango group information about the service, surveys, newsletters, as well as promotional information, marketing messages and information regarding the products and services of Wind and of the other companies related to Wind in Yango group, including information matches to you personally, to your preferences and consumption habits. You can choose at any time not to receive additional advertisements, through the application settings or in accordance with the instructions found in the message itself;
• Send you surveys and questionnaires on behalf of local authorities and governmental and public authorities;
• Contact you, when this is required in Wind's opinion;
• For the purposes of information security and handling of information review and correction requests;
• For the purpose of analyzing statistical information, controlling it and handing it over to third parties; This information will not identify you personally;
• For the proper operation and development of the service
• For the purpose of meeting the requirements of the local authorities where the service operates, or the requirements of other authorized authorities;
• To enforce the terms of use, in order to comply with the requirements of any law, regulation or other legislation, as well as to assist the competent authorities and courts, or any other third party, when in Wind's opinion, this is necessary;
• For the purpose of defensiveness in any dispute, claim, demand or legal proceedings, if any, between you and Wind and/or anyone on its behalf, as well as for the purpose and protection of our legal rights and legitimate interests and those of others;
• For any other purpose listed in this policy or the terms of use of the service.

7. Transfer of information to third parties

Yango Wind may transfer to third parties, both in Israel and abroad, the information you provide and that will be collected about you and your use of the service, to the extent required, and only in the cases listed below:

• For the purpose of performing the service through subcontractors and suppliers that help Wind provide the service (such as credit card payment processing companies, equipment support and maintenance companies, software providers, information storage, accountants, lawyers, customer service centers). For example, for the purpose of proper use of the service, the photo you attach when registering for the service, the photo you attach before or during the use of helmet identification, as well as any other document you provide to us during registration or in another way (such as an ID document), will be transferred to the provider of personal identification or helmet identification services for the purpose of Processing.
• Yango Wind may provide details about you and the details of your use of the service and/or identify you to authorized authorities and/or law enforcement agencies (including municipalities and local authorities), in case of committing an offense or violating the provisions of traffic laws or applicable laws (including municipal ones) , including the laws and regulations relating to the permitted area for riding, speed and parking, as the case may be, or in the case where Yango Wind has another legal obligation to transmit the aforementioned information.
• A judicial order or a demand from a competent authority ordering Wind to provide details or information about you to third parties;
• In order to provide you with support services and personalized offers;
• In order to establish or protect our legal rights, as required to enforce our Terms of Use or other contracts; defend in the framework of any dispute, claim, demand or legal proceedings, to the extent that there may be any, between you and Wind or anyone on its behalf, including fines or other penalties for violating the traffic laws or regulations of the local authority where you used (including parking) the scooter; Detection and prevention of theft, fraud or any other illegal activity, including a threat to the rights of users or the rights of Wind. In the case that the provision of the information is required in order to prevent serious bodily harm or property damage to a third party;
• Transferring information to other companies related to Wind, such as its subsidiary or parent company, subject to the provisions of this policy for the purpose of providing information storage services as well as for direct mail advertising purposes;
• To the extent required in order to comply with the requirements of local authorities where the service is operated or other authorized authorities;
• In order to provide anonymous, aggregated and statistical information to companies or other organizations related to Wind, as well as suppliers, business partners, advertisers and any third party, and share it with them; Wind will not knowingly disclose your identity to the aforementioned third parties without your consent and will transmit information while taking measures that will make it difficult to identify you with a reasonable effort;
• To the extent that Wind organizes its activities or the service within another entity, merges with another entity, it will be entitled to transfer the information in Wind's database to the new entity, provided that the other entity accepts the provisions of this privacy policy;
• In accordance with your express request or with your consent;
• Wind's database is stored with web hosting and data backup service providers that may be located abroad, in Russia.

By using the website and/or the application and/or the service, you hereby give your informed consent to the use of the information, its processing, its storage, or the transfer of the information to other countries, including those that do not provide the same level of information protection as in Israel. If information about you is transferred outside the borders of Israel, Wind will export the information in accordance with Israeli law, subject to appropriate security measures being taken, or when the information is exported in a way that ensures adequate legal protection. In such a case, the information may also be subject to law in the country where it is stored and processed.

8. How to contact to Yango Wind

To the extent that you wish to withdraw your consent to this policy and/or to the extent that you believe that your privacy has been violated during the service and/or to the extent that you have a question regarding this policy, please contact us via email: wind.il.support@yango.com or via registered mail: Lincoln 20, Tel Aviv.

9. Cookies

Wind may use "cookies" which are small files that remain on your computer and allow you to save information for the purpose of regular and routine operation, including for the purpose of collecting statistical data on the use of the website, verifying details, adapting the website to your personal preferences, for information security purposes, and more. For more information about the cookies we use on the site, see the cookie policy.

We use cookies for helmet identification in the Wind application. For more information about the personal information collected through these cookies see http://support.google.com/firebase/answer/6318039?hl=en . These cookies are necessary for receiving the service, and you cannot choose not to receive them.

Cookies are information files sent by our servers to your browser, and then sent back by the browser each time it accesses our servers. The cookies may include a variety of information, such as the web pages you access, the length of time you stay there and IP addresses. We will be entitled to use cookies also to save you the need to re-enter your account information every time you enter the service.

Some of the cookies may expire at the end of the stay on the site and exiting the browser. Other cookies are stored on your hard drive. To the extent that you wish to block our cookies, you may do so by clicking the "Options" button in your browser menu and following the required instructions. Changing these settings is your responsibility. For more information, you can read your browser's help file. However, you should remember that disabling cookies may complicate or even prevent your use of the service, or certain features of it.

10. Data Security

Yango Wind considers the security of the information in its systems of utmost importance. To protect the information, Wind uses operating systems, advanced applications and procedures for the purpose of securing the information, which are designed to minimize the risk of theft, harm, damage, loss or unauthorized access to the information.

However, there is no certainty that these applications guarantee that the information will not be disclosed or that it will be fully secure. Therefore, Wind does not guarantee that the service and the information systems used by Wind will be immune from unauthorized access to the information stored in them. If Yango Wind takes reasonable security measures, it will not be responsible for any damage caused as a result of such unauthorized intrusion and transfer of information to a third party due to such intrusion. By using the Service, you are aware of and agree to these limitations.

11. Your Rights

According to the privacy protection laws, every user of the service, website and application is entitled to review personal information about him that is stored in a database and for this purpose may contact Wind with a request to review such information through the means of communication detailed in Section 8 above.

If you requested the personal information, and found it to be inaccurate, incomplete, unclear, or out of date, you may contact Wind with a request to correct the personal information, all in accordance with and subject to the provisions of privacy protection laws.

After you log into the app using our authentication tool and upgrade your account with a user name (login) and password, you can delete your account entirely (https://clck.ru/sF9Zr).

Please note that some of the information about you may be saved by Wind, as detailed in the section "Saving information" below.

If the information in Wind databases is used for the purpose of contacting you personally, based on your belonging to a population group, determined according to one or more characteristics, then you are entitled according to the Privacy Protection Law to demand in writing that the information relating to you be deleted from the database used to send commercial offers ("direct mail") as mentioned. Information necessary for the management of its business, including documentation of commercial and other operations carried out on the site, will continue to be stored in the Wind databases according to law, but will no longer be used for the purpose of requesting commercial offers as mentioned. If within 30 days you do not receive a notification that the information we were asked to delete has indeed been deleted according to this policy, you will be entitled to apply to the court in the manner provided in the regulations under the law, to order us to act as stated.

When you ask Wind to exercise your rights according to this policy and according to privacy protection laws, Wind may be required to ask you for certain identifying information so that it can verify your identity, and refrain from giving you personal information related to others, which you are not authorized to receive, and ask questions in order to understand better the nature and scope of the personal information you wish to access.

12. Saving information

Wind will retain your personal information as long as your account is active and/or as required to provide you with the service or otherwise permitted by applicable law. If you delete your account and/or stop using the services, Wind will be entitled to continue to retain certain personal information, as much as is reasonably required to comply with its legal and regulatory obligations (including by-laws, guidelines, rules and requirements of local authorities), for accounting needs, to solve disputes with the user, including to defend against a complaint or lawsuit, to prevent fraud or misuse, to enforce the terms of use and/or to protect Wind's legitimate interest.

Note that, except as required by applicable law, Wind will not be required to retain your personal information for any period of time and will be entitled to securely delete it for any reason and at any time, with or without notice.

Except as limited by privacy protection laws, non-personal information will be retained indefinitely.

13. Policy Changes

Wind will be entitled to change this policy from time to time. The updated version of the policy will be published on the website and/or in the application and is binding. The link to the policy published in the service will always link to the latest version of the policy. By continuing to use the service after the updated policy is posted, you agree to the updated policy. If you do not agree to the new policy, you must stop using the service.

Last update: 24.7.2023.