Elettrigo Privacy Policy

Privacy Policy of EPS City by De Stefano Tiziana regarding the ElettriGo Bike Sharing System

Privacy Policy

This privacy policy applies to the Elettrigo app (hereby referred to as "Application") for mobile devices that was created by Elettrigo (hereby referred to as "Service Provider") as a Commercial service. This service is intended for use "AS IS".

Information Collection and Use

The Application collects information when you download and use it. This information may include information such as

Your device's Internet Protocol address (e.g. IP address)

The pages of the Application that you visit, the time and date of your visit, the time spent on those pages

The time spent on the Application

The operating system you use on your mobile device

The Application collects your device's location, which helps the Service Provider determine your approximate geographical location and make use of in below ways:

Geolocation Services: The Service Provider utilizes location data to provide features such as personalized content, relevant recommendations, and location-based services.

Analytics and Improvements: Aggregated and anonymized location data helps the Service Provider to analyze user behavior, identify trends, and improve the overall performance and functionality of the Application.

Third-Party Services: Periodically, the Service Provider may transmit anonymized location data to external services. These services assist them in enhancing the Application and optimizing their offerings.

The Service Provider may use the information you provided to contact you from time to time to provide you with important information, required notices and marketing promotions.

For a better experience, while using the Application, the Service Provider may require you to provide us with certain personally identifiable information, including but not limited to Name, Surname, Email Address, Postal Address, Billing Address, Contact Number, Payment Information (if applicable), Hourly Records Related to Calls and Assisted Pedal Bike Pickup Stations (including date and time), Geographical Location (with user consent for additional services). The information that the Service Provider request will be retained by them and used as described in this privacy policy.

Who does this Privacy Policy apply to?

For EPS City by De Stefano Tiziana ("we" or "our"), privacy protection is an absolute priority, so we collect and process the Data Subject's Personal Data securely. In order to protect the Data Subject's privacy, EPS City by De Stefano Tiziana operates in accordance with EU Data Protection Legislation, in particular with the General Data Protection Regulation no. 679/2016. We advise the Data Subject to carefully read this Privacy Policy regarding the ElettriGo Bike Sharing System (hereinafter "ElettriGo") before accepting its contents.

This Privacy Policy regarding ElettriGo ("Policy") applies to the Data Subject as a user of the Smart Bike service or the Bike Sharing System ("User"); its purpose is to explain to the Data Subject the methods, timing, and purposes of processing their Personal Data. It also specifies the Data Subject's rights regarding the processing of their Personal Data, and how they can exercise them.

Why is this Policy important?

EPS City by De Stefano Tiziana, located at Corso A. De Gasperi,146 C/mare di Stabia(NA) and Corso Italia 242, Sorrento (NA), registered in the Companies Register with tax code DSTTZN75D55C129K is the Data Controller. We have an obligation to explain to the Data Subject how we process their Personal Data as a User of ElettriGo.

EPS City by De Stefano Tiziana is obligated to explain to the Data Subject how we process their Personal Data as a User of ElettriGo.

EPS City by De Stefano Tiziana offers the Bike Sharing service in the municipalities of the Sorrentine Peninsula (Sant’Agnello, Meta, Piano di Sorrento, Sorrento, Massalubrense) called ElettriGo ("Service"), which allows users to rent a bike through registration on the website www.elettrigo.it and the ElettriGo smartphone application or at the front office located at Corso Italia,242 Sorrento(NA), Assisted Pedal Bike pickup stations, or any other adequately provided mechanism ("the Platforms"), in accordance with the terms of use available on the website www.elettrigo.it. EPS City by De Stefano Tiziana manages the ElettriGo service. In order to make this service available, we need to collect and process the Data Subject's Personal Data.

"Personal Data" means any personal information concerning an identified or identifiable natural person as defined under applicable European legislation (and in particular, the General EU Data Protection Regulation no. 679/2016).

What is the purpose of this Policy?

This Policy explains to the Data Subject the practices we have adopted since May 25, 2018, regarding the processing, use, and disclosure of the Personal Data they provide through our Platforms.

What type of Personal Data do we collect, how, and for what purposes?

We may use the ElettriGo system Platforms to collect the following Personal Data, at the times and for the purposes specified below:

Name and surname of the Data Subject, at the time of their first registration, in order to identify them;

Gender of the Data Subject, at the time of their first registration, in order to identify them;

Email address of the Data Subject, at the time of their first registration, in order to identify them, verify their order, keep them updated, and transmit important information about the progress of their order and send them information that may interest them;

Postal and billing address of the Data Subject, at the time of their first registration, in order to identify them and process their order;

Contact number of the Data Subject, at the time of their first registration and at any other time during the transaction, in order to identify them and communicate with them;

Payment information, at the time of their first registration and at any other time during registration, in order to complete their order;

Direct debit data and related mandate of the Data Subject, at the time of their first registration and at any other time during registration, in order to complete their order;

Hourly records related to calls and Assisted Pedal Bike pickup stations (including date and time), during a call to our customer service or at the time of pickup and return of a bike, to monitor the safety of our Assisted Pedal Bikes and prevent unauthorized use;

Secure access credentials if the Data Subject registers to access protected or restricted areas of our Platforms, e.g., to access their customer account or the marketing preferences section of the control panel;

Geographical location (anonymized), to record the location of our Assisted Pedal Bikes, for security reasons and to prevent theft;

Geographical location, if the Data Subject uses our Platforms, to provide additional services such as those based on location mentioned below. In case of Platform usage, we may process additional Personal Data of the Data Subject, with their consent, as specified below (see: Location-based services).

Medical information related to insurance claims, in order to support the Data Subject in managing a compensation claim;

Reports to Judicial Authorities and related documentation

Photographic material sent by the User

As well as provided for in the Privacy Policy of EPS City by De Stefano Tiziana.

In certain circumstances, we may request additional Personal Data from the Data Subject in order to respond most appropriately to their needs. Failure to provide the requested Personal Data by the Data Subject may result in limiting their ability to access the Service or our ability to provide them with necessary assistance.

Sensitive Personal Data

We will not ask the Data Subject to provide us with their Sensitive Personal Data, unless it is necessary within the scope of an insurance compensation claim or if we need to report an issue to the judicial authority.

The term "Sensitive Personal Data" refers to Personal Data concerning: race or ethnic origin, political opinions, religion or other similar beliefs; membership of a trade union; physical or mental health; sex life or convictions. If the Data Subject provides Sensitive Personal Data, EPS City by De Stefano Tiziana will request their explicit consent for such information to be used exclusively for the purposes for which it was provided.

What are the purposes and legal bases for collection?

In addition to the previous purposes, we may collect this information in order to make all the features of ElettriGo available to the Data Subject, particularly: to verify and process usage; for payments related to the use of the service; to keep them updated on the activities they perform in relation to the service; to respond to their inquiries; to support them in the recovery of a lost or stolen bike and to provide assistance in case of injury or mishap. We are able to do this because the Data Subject has registered to use ElettriGo and the legal basis that authorizes us to process such data is to fulfill the obligations of a contract, unless otherwise specified.

Another valid legal basis is our legitimate business interest and those of the municipalities of the Sorrentine Peninsula (Sant’Agnello, Meta, Piano di Sorrento, Sorrento, Massalubrense) regarding our agreement to use certain information to personalize our Platforms based on the characteristics of the Data Subject and to improve their user experience; to adapt and improve our Platforms; to provide customer support and resolve complaints (this may involve verifying the Data Subject's personal information or choosing to have it verified by third parties if necessary to provide personalized services); to manage the provision of Assisted Pedal Bikes on behalf of the municipalities of the Sorrentine Peninsula (Sant’Agnello, Meta, Piano di Sorrento, Sorrento, Massalubrense); to provide information about the Data Subject to our support department and the team responsible for the recovery of Assisted Pedal Bikes; to prevent fraud; to communicate delivery times, service information, and other updates to the Data Subject; and for statistical purposes involving data anonymization. We may also process Personal Data from third-party applications necessary to operate the Service.

We may need to share the Data Subject's data with local law enforcement, including the police, if we are required to do so by law, to fulfill our legitimate interests, or to protect the interests of the Data Subject or other parties.

Direct Marketing and Promotions

To enhance the user experience of our ElettriGo system, relying on our legitimate business interests, we may use the Data Subject's email address to inform them about platform developments, special offers, and promotions.

[ ] I consent

With the Data Subject's explicit consent, we may share their contact details with our Smart Bike/Sharing System service partners, as well as use them for consent tracking purposes, customer consumption habit analysis, and market research.

[ ] I consent

If the Data Subject no longer wishes to receive such information, they can unsubscribe following the instructions described in the "Right to Object to Processing for Marketing and Promotions" section.

Location-Based Services

EPS City by De Stefano Tiziana may collect, use, and share precise location data, including real-time geographic location of the User's bike, to offer location-based services on our ElettriGo system. Location-based services may use, if available, GPS technology, Bluetooth, and the user's IP address, crowd-sourced wifi hotspots, and other technologies to determine the approximate location of the user's device and biking distance on assisted pedal bikes.

The use of these devices is solely aimed at ensuring the proper functioning of the Bike Sharing service through Assisted Pedal Bikes and protecting the integrity of EPS City by De Stefano Tiziana's corporate assets, with particular reference to the "Theft Reporting" functionality.

Data Subject Rights

Under the General Data Protection Regulation n. 679/2016, the Data Subject has the right to receive information and access to all Personal Data concerning them in our possession, and these rights may include, for example, the right to request the modification or deletion of their Personal Data; the right to withdraw their consent; the right to know the purposes for which their Personal Data is processed and the recipients to whom the Personal Data may be disclosed (subject to legal and regulatory requirements).

If one does not agree to submit their Personal Data to the processing described in this Privacy Policy, please do not submit your Personal Data to EPS City by De Stefano Tiziana through the Platform or any other means.

Right to Rectification of Personal Data

We undertake the responsibility to maintain accurate records of Personal Data after their communication, but we do not undertake the responsibility to confirm the accuracy of Personal Data if the Data Subject does not update it.

If the Data Subject informs us that their data is no longer correct, we will modify or update them (provided that such communication is accurate and legitimate). The Data Subject may report any inaccurate data to us by contacting our customer support at info@elettrigo.it

Right to Obtain Copies of Personal Data and Right to Data Portability

Where permitted by law, the Data Subject has the right to contact us to request a copy of the Personal Data concerning them that are subject to processing. Before responding to their request, we may ask the Data Subject to (i) allow us to verify their identity and (ii) provide additional details to enable us to better respond to their request. The Data Subject may also request that their data be transferred to another entity. To exercise this right, the Data Subject can contact customer service by sending an email to info@elettrigo.it

Right to Erasure of Personal Data or Restriction of Processing of Personal Data

In certain circumstances, the Data Subject has the right to obtain from us the deletion of their Personal Data, for example, if we no longer need it, or if they withdraw their consent (if applicable). If we have shared their data with third parties, where possible, we will communicate this decision to them.

Right to Withdraw Consent

If the Data Subject has provided their consent to the processing of their Personal Data by us in the cases and for the purposes described above at any time and subsequently wishes to discontinue such processing, they may unsubscribe by contacting our dedicated customer support via email at info@elettrigo.it

Rights related to Automated Decision-Making and Profiling

The Data Subject has the right not to be subject to decisions based solely on automated processing, including profiling. We have the right to resort to this type of decision-making only if the decision is necessary for the conclusion or execution of a contract; or is authorized by Union or Member State law to which we are subject; or is based on the Data Subject's explicit consent. We will always inform the Data Subject of the possible use of such activities during the use of their Personal Data.

Right to Object to Processing for Marketing and Promotions

The Data Subject has the right to object to receiving promotional and marketing communications through the following methods:

Modifying their marketing preferences in the User area of the ElettriGo portal.

If the Data Subject withdraws their consent to receive future promotional and marketing communications, we will no longer contact them for direct marketing purposes. However, this will not prevent the Data Subject from using our ElettriGo platforms.

For any questions or complaints regarding the handling of their Personal Data, the Data Subject can contact our Office at Corso Italia, 242 Sorrento (NA).

Personal Data of Children

Our platforms are not intended for children under the age of 14. Therefore, we will not intentionally undertake any processing activities of their personal data through such platforms.

Third-Party Websites

The presence of links to websites not owned by EPS City by De Stefano Tiziana in our platforms does not imply any responsibility or approval from us regarding such sites. Third-party websites are governed by different terms of use (including privacy policies), and the user is solely responsible for viewing and using each of these sites in accordance with the applicable terms of use. EPS City by De Stefano Tiziana disclaims any responsibility arising from the management of Personal Information by third-party websites, which are excluded from this Policy unless otherwise specified.

Security of Personal Data

[The Data Subject's Personal Data (including business information) will be processed with the utmost confidentiality and security. EPS City by De Stefano Tiziana implements appropriate technical and organizational measures in accordance with its legal obligations and industry best practices. Furthermore, in compliance with the provisions of the General Data Protection Regulation n. 679/2016, Clear Channel adheres to strict security procedures regarding the storage and disclosure of Personal Data provided by the Data Subject, in order to prevent unauthorized access as much as possible.

To safeguard the confidentiality of the Data Subject's Personal Data, we adopt industry-standard practices, such as firewalls and Secure Socket Layers protocol. The Data Subject's Personal Data is treated as an asset to be protected from loss, alteration, destruction, and unauthorized access. Our employees and representatives are required to maintain the confidentiality of such data, which is protected from unauthorized access by internal and external users to EPS City by De Stefano Tiziana through various security techniques. Additionally, we employ internal protection systems to allow access to the Personal Data of users only by employees or representatives who need to know it for the performance of a specific function. While total security cannot be guaranteed, we commit to taking appropriate measures in the event of a breach.

If deemed appropriate, the Data Subject will be informed about any violation of their Personal Data.

Transfer of Personal Data

Third Parties

Where it is necessary to involve external service providers for the fulfillment of our contractual obligations or as a result of regulatory requirements, EPS City by De Stefano Tiziana undertakes not to transfer identifiable, non-aggregated Personal Data to entities other than third-party data processors bound by a data processing agreement that reproduces the conditions of this Policy, as provided for therein.

EPS City by De Stefano Tiziana may receive and transmit information about the user using the Platforms, including their Personal Data, to its partners or subcontractors (Data Processors) for technical checks, payments or identity, and delivery services, as well as to providers of analysis services or credit rating agencies;

We share the Data Subject's Personal Data with third-party Data Processors only in the following cases:

Where it is necessary to involve an external service provider for the fulfillment of our contractual obligations related to the provision of the Service to the user (e.g., a payment processing system when we charge the user fees related to the Service);

Based on legitimate business interests, such as:

Within the scope of the usage process, we may use various computer applications to provide the Service to the user.

With a service provider responsible for maintaining our Platforms;

We rely on analytics service providers and search engines to improve and optimize our Platforms.

Additionally, we may disclose user-related information if required by law or if we believe, in good faith, that such access, preservation, or disclosure is reasonably necessary (i) to respond to any claims against us, (ii) in the context of legal proceedings, (iii) to enforce any contracts in place with our users, such as our Terms and Conditions and our Privacy Policy, (iv) in case of an emergency threatening public health or causing the death of a person or serious injury, (v) in the context of an investigation, or (vi) to protect the rights, property, or personal safety of employees and representatives of EPS City by De Stefano Tiziana.

Transfers Outside the European Union

The Personal Data covered by this Policy is processed in Europe. We do not transfer the Data Subject's data outside the European Union without their consent.

Assignment or Merger

In the event of a transfer or merger between EPS City by De Stefano Tiziana or its assets, and another entity, the Data Subject is aware that a portion or all of their Personal Data collected may be transferred to the acquiring or incorporating company. In such a case, we will endeavor to ensure that the acquiring company is obligated to use any transferred Personal Data in accordance with applicable law and this Policy, although we cannot guarantee the enforcement of such requirements or the acquiring company's compliance with them.

Retention of Personal Data

If the user has provided their Personal Data, including location data, to EPS City by De Stefano Tiziana, these will be retained for the duration of their membership in our ElettriGo, for the period required by applicable law, or for a reasonable period necessary to carry out the operational purposes of the bike sharing service (EPS City by De Stefano Tiziana or its third-party data processors will rectify or delete the Data Subject's Personal Data if they are no longer necessary for the operational purposes of the bike-sharing service). If you'd like them to delete the data that you have provided via the Application, please contact them at help@elettrigo.it and they will respond in a reasonable time.

Changes

This Privacy Policy may be updated from time to time for any reason. The Service Provider will notify you of any changes to the Privacy Policy by updating this page with the new Privacy Policy. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

This privacy policy is effective as of 2024-04-14

Your Consent

By using the Application, you are consenting to the processing of your information as set forth in this Privacy Policy now and as amended by us.


Contact Us

If you have any questions regarding privacy while using the Application, or have questions about the practices, please contact the Service Provider via email at help@elettrigo.it.