Privacy and Policy - App

SiWeGO srl considers the privacy of its users to be of fundamental importance and guarantees that the processing of personal data entered, collected and processed through the SiWeGO Application takes place in compliance with the rights of the interested party, with particular reference to confidentiality, the protection of personal identity and to the right to the protection of personal data pursuant to and for the purposes of the “Code regarding the protection of personal data “ Legislative Decree 196/2003 (hereinafter, Code), of EU Regulation 2016/679 (GDPR) and subsequent amendments. About that SiWeGO srl has adopted and implemented this Privacy Policy, which is valid as information pursuant to art. 13 of the Regulation for everything concerning the management methods of the Site with reference to the processing of users personal data.

Data controller

The Data Controller is SiWeGO srl, with legal and administrative headquarters at Trentino Sviluppo SpA, Rovereto (TN), P.zza Manifattura n. 1, Cod. Fiscale / P.IVA 02439130226, in the person of its legal representative pro tempore, Dott. Marcello Favalli born in Brescia on 06.05.1978 and residing in Flero (Bs), via Caselle n. 1. By “treatment “ - as better specified in art. 4 of the Regulation - any operation or set of operations, carried out even without the aid of electronic tools, concerning the collection, registration, organization, structuring, conservation, consultation, processing, adaptation or modification, selection, extraction, comparison, use, interconnection, blocking, communication by transmission, dissemination or any other form of making available, limitation, cancellation and destruction of data, even if not registered in a database. “Personal data “ means any information relating to an identified or identifiable natural person (so-called interested party), even indirectly, by reference to any other information, including a personal identification number. This Privacy Policy applies to Users personal data, collected through the application; the same Privacy Policy does not apply to other websites or applications owned by third parties, which can possibly be accessed via a link on the SiWeGO application.

Responsible for the treatment

3. Data Ownership and Visibility and Accountability

The SiWeGO service is based on a platform shared by the users, therefore, it is assumed that, once the data has been entered, they remain available to the entire community of users, within the limits necessary for the performance of the service.

You are responsible for all content, information and data you post or share through the Services. In particular, the user is responsible for any new data or information entered by him, for any modification to pre-existing data and/or in general for any operation of creation, publication and sending of transport requests/offers, which in any case available through the Services any content.

When the user uses a third-party application to access the SiWeGO platform (for example by registering with a Facebook or Google+ account) it may request authorization to access the user s content, information and data. The agreement accepted by the user when adding the application governs the way in which the application can use and transfer content, information and data.

Types of data processed and methods of processing

SiWeGO srlmay collect some personal data from Users:

personal data such as name, surname, address,
telephone and/or mobile number,
fiscal Code,
bank details
tax code and/or VAT number of legal entities,
vehicle insurance if required,
email,
User ID, password and profile picture generated during registration on the platform,
information aggregated while browsing the application,
other personal data provided voluntarily by the User during the registration phase or when requesting goods or services offered by the application or when requesting information sent by e-mail; as well as all data better specified in the Terms and Conditions of Use of the Platform, in particular in point 6.

The User s personal data, therefore, may be processed, by automated means, (i) while browsing, (ii) when registering for the application (necessary to be able to use the services or purchase goods offered by the same), ( iii) at the time of requesting the provision of a single service. Furthermore, in the event that a User contacts SiWeGO to request information, his necessary personal data will be collected to be able to provide him with an answer.

Navigation data

The computer systems and software procedures used to operate the application acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by their very nature could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes the IP addresses or domain names of the computers used by Users who connect to the site, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user s IT environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the SiWeGO application and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the SiWeGO application.

Data provided voluntarily by the User

SiWeGO srl also collects the personal data entered in the registration or service request forms, as well as forwarded to SiWeGO srl by email. This is mainly information necessary to provide the User with the services requested, or to contact the User in response to a request for information.

Users have the option to consent to being geolocated using a satellite tracking system (GPS). Geolocation will take place only with the express consent of the user and in compliance with the provisions of the Regulation and the specific circulars of the Guarantor on the processing of personal data.

Purpose of the processing of personal data

SiWeGO srl will process Users personal data for the following purposes:

for needs relating to authorization operations useful for the use of the platform functions;
enabling and customizing access to the various areas and related contents of the application;
for needs relating to the stipulation and execution of a contract at the request of the User himself and to implement a service or an operation within the scope of SiWeGO srl s activities;
transaction of the sums due to users, concerning the fees due/paid by virtue of a transport commissioned through the platform;
for commercial development needs, customer relationship analysis and marketing, subject to the User s optional consent. For example, SiWeGO srl can send updates and information relating to products or promotions to the User s e-mail address.

Processing methods

The data processing is carried out by means of the operations or set of operations indicated in the art. 4, paragraph 1 of Regulation (EU) 2016/679: any information relating to an identified or identifiable natural person ( “interested “); an identifiable natural person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social.

Nature of data provision and consequences of any refusal

Data processing bySiWeGO srlit is based on the execution of the contract stipulated between the company and the user, since this is the legal basis on which the contract is based. Consent to data processing is therefore mandatory and fully implies access to the platform.

The provision of data for marketing, profiling and market research purposes is, however, optional and, for the processing of such data, it is necessary to provide express consent and its failure to provide it will not affect the request for the service formulated by the user.

At any time the user can revoke his consent according to the provisions of the paragraph in this statement.

Minors under the age of 16 cannot authorize the processing of their personal data, unless express consent is given by the parental responsibility holder or whoever takes their place.

Communication and/or dissemination of personal data

The personal data of Users collected bySiWeGO srlthrough the application will be accessible to the bodies and employees ofSiWeGO srlformally designated as Data Processors or Data Processors. Furthermore, the Users personal data may be communicated to companies that supply the goods or services available on the application in execution of the obligations deriving from contracts concluded at the User s request or to provide the service requested by the User. The data is collected and stored on proprietary servers or companies with whichSiWeGO srlhas entered into a contract. Some data may be communicated anonymously and aggregated to group companies or third parties for statistical purposes. For example, the average age of users, the number of visitors from different geographical areas may be communicated. In any case, they are not data that allow Users to be identified in any way. Furthermore, the data may be communicated to third parties during sales, mergers or acquisitions. As part of these reorganization activities, Users personal data could be shared with current or potential buyers. In these casesSiWeGO srlwill obtain written guarantees that personal data will be treated with an adequate level of protection and, in any case, in compliance with current legislation. With the exception of cases explicitly permitted by law, or provided for in this Privacy Policy, personal data will not be communicated or shared without the consent of the user concerned.

The company may make use of its collaborators and third-party companies that carry out call center activities, who will act exclusively as external data processors pursuant to art. 28 of Regulation (EU) 2016/679. In this case, the user s personal data may be communicated exclusively for the achievement of the purposes set out in this information.

Only with prior, free and optional consent that can be withdrawn at any time,SiWeGO srlwill be able to carry out promotional and marketing activities on behalf of third parties with whom it has entered into commercial agreements, concerning products and/or services, even different from those relating to the services offered by SiWeGO. Furthermore, only with the prior, free and optional consent, which can be withdrawn at any time, could the user s data be communicated and/or transferred bySiWeGO srlto commercial partners also located in countries outside the European Union and operating in different product sectors to which they belong, concerning products and/or services even other than those relating to the services offered by SiWeGO, in compliance with the provisions of art. 44 et seq. of Regulation (EU) 2016/679.

Therefore, these subjects will process the user s personal data as independent data controllers pursuant to Regulation (EU) 2016/679 and will be required to provide the user with their independent information. The complete and updated list of subjects who process the user s personal data as independent data controller is available atSiWeGO srlto the e-mail address:privacy@siwego.com.

The user s personal data may be communicated, exclusively in relation to the purposes indicated above, to service companies of which he usesSiWeGO srl, to supervisory and control bodies, to public administrations as well as to other entities or bodies that own and manage databases to which the communication of personal data is mandatory. The subjects belonging to these categories operate as independent data controllers except in the case in which they have been designated data processors pursuant to and by effect of art. 28 of Regulation (EU) 2016/679.

Users personal data are in no way subject to disclosure.

Protection of personal data

SiWeGO srlprotects the personal data it processes by adopting the security measures envisaged by the European Regulation (EU) 2016/679 whose specifications are contained in a specific technical document which can be consulted with an express request formulated by the interested party at the address:privacy@siwego.com. There are measures that prevent unauthorized access by third parties to personal data and the application, or the unauthorized recording or use of personal data. User IDs, passwords and credit card numbers are protected by an encryption system (Secure Sockets Layer – “SSL/TLS”).

SiWeGO srlit will not know nor will it keep the number and codes of the credit card, relying on the external platform Lemon Way which guarantees security and confidentiality in the transaction, to whose Privacy Policy please refer for appropriate information.

SiWeGO may provide links to third-party sites, of which SiWeGO knows and guarantees the security of the functionality of the contents, as well as the security of the data provided to them.

The data provided by the Users will be disclosed to the Users of the Platform itself, limited to what is necessary for the performance of the SiWeGO services.

The user can decide to disclose his data in various ways, by accessing the platform via social networks (for example Google, Facebook, etc.) or by using third-party services that allow the publication of reviews or other information, thus allowing third parties to use them.

Access through social networks and the use of the latter are subject to the terms and conditions as well as the privacy and cookie policies of the social networks themselves.

Storage period

SiWeGO srlkeeps personal data for the time strictly necessary for users to use the services of the application, therefore, the data provided by the user are processed by the company according to the performance of the Services offered by the same. If the user were to cancel his account from the platform, this would result in the termination of the treatment, while the conservation will be extended for the period of 10 years necessary for the fulfillment of obligations and controls imposed by law (anti-fraud, anti-money laundering, theft identities etc.).

If the user has given specific consent for marketing and profiling purposes, the data provided by the same will be processed for a relevant, proportional and not exceeding this purpose, without prejudice to the right to withdraw such consent, withdrawal which results in the cessation of retention of data relating to the same.

Data transfer abroad

SiWeGO srlmay need to transfer user data to other companies or service providers from countries outside the European area (EEA), consisting of the countries of the European Union and Switzerland, Iceland, Liechtenstein and Norway, considered countries with equivalent laws for regarding data protection and privacy, which have therefore obtained a recognition of adequacy by the European Commission. This type of data transfer may occur if the servers on which they will be stored are bySiWeGO srlor by other providers, are located outside the EEA or if you use the services of the application while you are staying in countries outside this area. ThenSiWeGO srlwill ensure that the transferred data is correctly and adequately protected.

If the State does not have equivalent laws on data protection and privacy, third parties will be asked to sign a contract according to EEA standards, compliant with EU legislation.

Information entered by users

With regard to the content entered by users in the application (User Generated Content),SiWeGO srlwill not be responsible for any violations of third party rights and in any case, by entering the data, the User definitively transfers the non-exclusive ownership of the same toSiWeGO srl.

Changes to the information

SiWeGO srlreserves the right to make changes to this privacy policy in order to incorporate changes in the legislation or to adapt to technological innovations. Any changes will be adequately communicated to the owners. In any case, Users are requested to read and periodically consult this Privacy Policy to check for any updates or revisions that may become necessary.

Further specifications of the processing of data collected pursuant to Regulation (EU) 2016/679 and rights of the interested parties

Pursuant to art. of EU Regulation no. 2016/679 (hereinafter “GDPR 2016/679 “), containing provisions for the protection of persons and other subjects regarding the processing of personal data, we wish to inform you that the personal data you provide will be processed in compliance with the aforementioned legislation and the confidentiality obligations to which SiWeGO Srl is bound.

Methods of treatment and conservation

The treatment will be carried out in an automated and/or manual form, in compliance with the provisions of art. 32 of the GDPR 2016/679 regarding security measures, by persons specifically appointed and in compliance with the provisions of art. 29 GDPR 2016/ 679. We inform you that, in compliance with the principles of lawfulness, purpose limitation and data minimization, pursuant to art. 5 GDPR 2016/679, subject to your free and explicit consent expressed at the bottom of this information, your personal data will be kept for the period of time necessary to achieve the purposes for which they are collected and processed.

Scope of communication and dissemination

We also inform you that the data collected will never be disclosed and will not be communicated without your explicit consent, except for the necessary communications which may involve the transfer of data to public bodies, consultants or other subjects for the fulfillment of legal obligations .

Transfer of personal data

Since the storage of personal data could also take place on servers located in countries outside the European Union, your data will in such cases be transferred to these places in compliance with the provisions of articles 44 et seq. of the Regulations as better specified in the Privacy Policy, to which reference is made.

Special categories of personal data

Pursuant to articles 9 and 10 of EU Regulation no. 2016/679, you could give the Company SiWeGO Srl data that can be classified as “particular categories of personal data “ and that is, those data that reveal “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership , as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sex life or sexual orientation of the person “. These categories of data may be processed only with your free and explicit consent, expressed in writing at the bottom of this information.

Rights of the interested party

At any time, you may exercise, pursuant to articles 15 to 22 of EU Regulation no. 2016/679, the right to:

ask for confirmation of the existence or otherwise of your personal data;
obtain information about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the retention period;
obtain the rectification and cancellation of data;
obtain the limitation of the treatment;
obtain data portability, i.e. receive them from a data controller, in a structured format, commonly used and readable by an automatic device, and transmit them to another data controller without impediments;
oppose the treatment at any time and also in the case of treatment for direct marketing purposes;
oppose an automated decision-making process relating to natural persons, including profiling.
ask the data controller to access personal data and correct or cancel them or limit their processing or to oppose their processing, in addition to the right to data portability;
revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation;

j) propose a complaint to a supervisory authority.

You can exercise your rights with a written request sent to SiWeGO Srl, to the postal address of the registered office or to the email address privacy@siwego.com.

I, the undersigned, declare that I have received the above information.

I, the undersigned, in light of the information received

◻︎I give my consent ◻I DO NOT give my consent to the processing of my personal data for the purposes indicated in the information.

◻I give my consent ◻ I DO NOT give my consent to the communication of my personal data to public bodies and private companies for the purposes indicated in the information.

◻I give my consent ◻ I DO NOT give my consent to the treatment of particular categories of my personal data as indicated in the above information.