Lime tracks your exact GPS location continuously during rides and while the app is running in the background on your phone.
This analysis describes what Lime's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Precise location data reveals your daily movements, home address, workplace, and travel patterns, making it one of the most sensitive categories of personal data collected by the service.
Your exact GPS coordinates are collected throughout every ride and potentially while the app runs in the background, creating a detailed log of your physical movements that is retained by Lime and shared with third parties including municipalities.
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We collect information about your location, such as data from your device's GPS or IP address, when you use our products.
At Ledger, earning and maintaining our users' trust is a top priority. That's why we are deeply committed not only to protecting your privacy and securing your personal data, but also to being fully transparent about how we handle it.
If you are located in the European Economic Area, Switzerland, or the United Kingdom, you have the right to access, correct, or erase your personal data; the right to restrict or object to our processing of your personal data; the right to data portability; and, where our processing is based on your...
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"We collect your precise geolocation data when you use our Services. This includes location data collected when the Lime app is running in the foreground (app open and on-screen) or background (app open but not on-screen) of your device. We use this data to provide, maintain, and improve our Services, including to allow you to unlock and use our vehicles, to provide you with navigation features, and to detect and prevent fraud.— Excerpt from Lime's Lime Privacy Policy
REGULATORY LANDSCAPE: Continuous precise geolocation collection engages GDPR Article 9 (sensitive data categories, as precise location can infer political, religious, and health information per Recital 75), CPRA's designation of precise geolocation as sensitive personal information requiring opt-in consent for collection in California, and the EU ePrivacy Directive for background tracking. The FTC has historically treated deceptive or unfair location data practices as violations of Section 5. The relevant enforcement authorities are the FTC (US), state AGs (California, Illinois), and EU data protection authorities (DPAs) under the GDPR one-stop-shop mechanism. GOVERNANCE EXPOSURE: High. Continuous background location collection at scale constitutes large-scale processing of sensitive data under GDPR, likely triggering Data Protection Impact Assessment (DPIA) obligations under Article 35. CPRA requires disclosure of precise geolocation as sensitive and provides consumers an opt-out right; the adequacy of Lime's consent mechanisms for this data type warrants review. Retention schedules for granular trip-level GPS data are not clearly specified in the document. JURISDICTION FLAGS: California (CPRA sensitive data opt-in/opt-out requirements), EU/EEA (GDPR Articles 5, 9, 35), Illinois (BIPA if location is combined with biometric data), New York (potential SHIELD Act implications for data security of location records). Background location collection practices may face particular scrutiny in the EU under national implementations of the ePrivacy Directive. CONTRACT AND VENDOR IMPLICATIONS: Data processing agreements with mapping, navigation, and analytics vendors receiving GPS data must be reviewed for GDPR Article 28 compliance. Vendor contracts should specify permissible secondary uses of location data, as broad sharing with analytics providers could constitute onward transfer requiring separate legal basis. COMPLIANCE CONSIDERATIONS: Compliance teams should verify DPIA completion for large-scale location processing, audit background location access permissions against stated purposes, confirm CPRA-compliant sensitive data notices and opt-out mechanisms are functional, and review retention policies for trip-level GPS records given their sensitivity.
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Precise location data reveals your daily movements, home address, workplace, and travel patterns, making it one of the most sensitive categories of personal data collected by the service.
Your exact GPS coordinates are collected throughout every ride and potentially while the app runs in the background, creating a detailed log of your physical movements that is retained by Lime and shared with third parties including municipalities.
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