Pre-contractual information pursuant to Article 3 EU Data Act

MILES vehicles qualify as connected products within the meaning of Article 2(5) of the Data Act. A connected product is a physical object that obtains, generates or collects data concerning its use or environment and that can communicate product data via an electronic communications service.

MILES does not directly access product data from the vehicle’s on-board systems. Product data that are accessible to MILES are generated and transmitted via related services. In the MILES context, the following qualify as related services within the meaning of Article 2(6) of the Data Act: the MILES Mobility App; the telematics unit provided by Invers GmbH, Siegen, Germany (hereinafter “Invers”); and, where installed, the smoke detection sensor provided by Robert Bosch GmbH, Stuttgart, Germany (hereinafter “Bosch”). These services are technically connected to the vehicle and ensure its booking, unlocking, monitoring and operation. The data that MILES holds and controls are limited to those generated and transmitted by these related services.

Certain vehicles may also be equipped with on-board systems from the vehicle manufacturer (original equipment manufacturer, OEM) such as Volkswagen AG or Ford Motor Company, which generate OEM telematics data. MILES does not receive or control such OEM data and cannot provide them. In these cases, the OEM is the data holder within the meaning of the Data Act.

This notice therefore concerns only the product data and related service data that are generated during the use of a MILES vehicle and that are accessible to and controlled by MILES via the related services described above.

Part A: information about the connected product (Article 3(2) Data Act)

1. Type, format and estimated volume of product data

 Product data accessible to MILES are generated and transmitted through the related services. The categories are:
• telematics and vehicle status data (for example, GPS position, routes, distance travelled, ignition status, fuel or battery level, door and window status, lights, tire pressure, error codes)
• driving behavior data (for example, acceleration, braking, speed, cornering, gear changes)

When transmitted to MILES, data are received in structured, commonly used and machine-readable formats such as JSON or XML. Typical volume is several megabytes per rental, depending on trip duration and driving behaviour. Product data that remain exclusively within OEM systems are not accessible to MILES.

2. Continuous and real-time generation

During a rental, product data may be generated continuously and in real time through the related services described in Part B.

3. Storage and retention

Product data accessible to MILES are transmitted by related services to secure servers within the European Union. They are retained for the duration necessary to perform the rental contract, billing and compliance with statutory retention obligations. For the purposes of Data Act access rights, data accessible to MILES are generally available for six months. Product data that remain exclusively within OEM systems are stored and controlled by the relevant OEM.

4. Access, retrieval and, where relevant, erasure

Users may view essential trip data (for example start and end time, distance, duration) in the MILES App.
Users may request access to raw product data that are held by MILES and were generated during their use of the vehicle, free of charge, without undue delay, and in a structured, commonly used and machine-readable format. Users may also request that such data be transmitted to a third party designated by them. Where product data are not held by MILES (for example OEM systems), MILES will inform the user accordingly.

Requests can be made by email to data-protection@miles-mobility.com or by sending a letter titled “Data Act request” to:

MILES Mobility GmbH
Leibnizstraße 49
10629 Berlin
Germany

 

Part B: Information about related services (Article 3(4) DA)

1. Nature, estimated volume and collection frequency of product data obtained by related services

• Invers telematics unit: collects and transmits product data such as vehicle position, routes, speed, acceleration, braking, ignition status and vehicle status in real time, generally at sub-minute intervals
• MILES Mobility App: records product-related events such as booking, unlock and lock, and trip start and end whenever the user interacts with the vehicle through the App
• Bosch smoke detection sensor (where installed): records smoking events and air-quality indicators when triggered. MILES does not use any Bosch crash-detection service
   

2. Nature and estimated volume of related service data
   In addition to product data, related services generate associated service data, for example App usage logs (login, booking attempts, technical error reports) and system communication events between the App, the telematics unit and backend systems. The volume typically amounts to a few megabytes per rental.
    

3. Storage arrangements and retention

• Telematics and App data: stored on servers within the European Union; retained for contract performance, billing and legal obligations (including statutory retention periods for accounting records). For Data Act rights, these data are generally available for at least three months

• Bosch-MILES data (smoke events): stored for the period required to verify incidents and enforce contractual terms, as a rule, up to twelve months

• Bosch-only data: stored and controlled exclusively by Bosch

• OEM telematics data: stored and controlled exclusively by the relevant OEM
   

4. Use of readily available data by MILES and third parties
   MILES uses product and related service data for the execution of rental contracts and billing, fleet management and safety, detection of misuse and enforcement of contractual terms, support, troubleshooting and quality control, and compliance with legal obligations. Data may be shared with third parties acting as technical service providers (for example cloud hosting or telematics platform providers) under contractual safeguards. MILES does not have access to OEM telematics data and does not process Bosch-only data.

5. Identity and contact of the prospective data holder and other data processing parties
   Prospective data holder for data accessible to MILES:
   MILES Mobility GmbH
   Leibnizstraße 49
   10629 Berlin
   Germany
   Email: data-protection@miles-mobility.com
   
   Other data holders: Bosch for Bosch-only data; the relevant OEM (for example Volkswagen AG or Ford Motor Company) for OEM telematics data.
6. How users can request data sharing or end sharing
   Under Articles 4 and 5 of the Data Act, users may request that MILES transmit product and related service data held by MILES to a third-party data recipient, free of charge, without undue delay, and in a structured, commonly used and machine-readable format. Users may request termination of such data sharing at any time.
   
   Requests can be made by email to data-protection@miles-mobility.com or by sending a letter titled “Data Act request” to:
   MILES Mobility GmbH
   Leibnizstraße 49
   10629 Berlin
   Germany
7. Complaint right
   Users have the right to lodge a complaint alleging an infringement of Chapter II of the Data Act with the competent authority designated pursuant to Article 37 of the Data Act.
8. Trade secrets
   Certain data may contain trade secrets. Where this is the case, disclosure and access will be provided under safeguards that protect confidentiality, in accordance with the Data Act.
9. Terms of use and quality of service for access and transmission 
   Requests under the Data Act are handled without undue delay and free of charge. Data are provided in a structured, commonly used and machine-readable format (for example, CSV or JSON). Availability of the access channel may be subject to maintenance windows and system uptime of the related services and backend systems. If a requested dataset is not held by MILES or is held exclusively by Bosch or an OEM, MILES will inform the user accordingly.
10. Duration and termination of the contract between the user and the prospective data holder
    The rental contract is concluded for the duration of each booking. The terms of termination are set out in the General Terms and Conditions and General Rental Terms and Conditions of MILES Mobility GmbH. Access to product and related service data persists only for as long as necessary under the retention rules described above.