INFORMATION ON THE PROCESSING OF PERSONAL DATA
- Identity and contact details of the Controller
The Controller is GoVolt S.r.l., VAT: 01556680294, with a registered office in Via Marina 3, 20121 – Milan, which can be contacted at the following email address email@example.com.
- Contact details of the Data Protection Officer
GoVolt has appointed a Data Protection Officer, who can be contacted at the following email address firstname.lastname@example.org.
- Purpose of the processing and legal basis for the processing
- Purpose of law and necessary contracts – processing necessary to fulfill a contractual or legal obligation to which the controller is subject to execute a specific request of the subject.
Your Personal Data may be processed, without the need for your consent, in cases where this is necessary to fulfill obligations arising from statutory provisions both in civil and tax matters, of Community legislation, as well as rules, codes or procedures approved by Authorities and other competent Institutions.
Furthermore, your Personal Data may be processed to follow up requests from the competent administrative or judicial authority and, more generally, from public entities in compliance with the legal formalities.
Your Personal Data will also be processed for the purposes related and / or related to the provision of services by GoVolt, which specifically are:
– for the performance of obligations arising from the General Conditions, the Regulations and / or the provision of ancillary services and / or related to these contracts. In such cases, we inform you that under the applicable law regarding personal data, the acquisition of your consent is not required if the processing is necessary to fulfill obligations arising from a contract, while, during the negotiation phase, it is also not mandatory to acquire consent if the processing is necessary to fulfill – before the conclusion of the contract – your specific requests;
– for the provision of services requested by the customer with registration on the website and / or App and the creation of their account and profile including the collection, storage and processing of data for establishment and subsequent operating, technical and administrative management of the relationship (and of the account and profile created by the client) connected with the provision of services and to the provision of communications relating to the performance of the services;
– for the management of payments (with the relative processing – according to the law – of payment data, including credit card or prepaid card identification details) of the services requested and of any additional economic charges, based on the provisions of the General Conditions and/or other specific contractual conditions published on the website or otherwise made available to the customer; or fulfillment of legal, accounting, fiscal, administrative and contractual obligations related to the provision of the requested services;
– for the management of relations with third-party authorities and public bodies for purposes related to particular requests, the fulfillment of legal obligations or particular procedures (e.g., renotification of violation of the rules of the Italian road regulations Code to the actual violator);
– for the preparations of measures aimed at protecting against credit risk, including activities aimed at identifying the customer and its economic/solvency reliability, also during the contractual relationship. This data – the provision of which is necessary for the operational, economic and administrative execution of the service – will also be processed using electronic tools, recorded in special databases, and used strictly and exclusively in the context of the existing contractual relationship.
Since the communication of your data for the aforementioned purposes is necessary for the maintenance and provision of all services related to the contract, failure to communicate will make it impossible to provide the specific services in question.
b) Commercial and marketing purposes – consent
Your Personal Data may be processed, subject to your consent, for the following
other functional aims of the Controller or of a third party:
– market research, user profiling, economic analysis and statistics;
– marketing of the services of the Controller and / or of a third party, sending of advertising / informative / promotional material and participation in initiatives and offers aimed at rewarding the customers of the Controller;
– surveys of the degree of customer satisfaction on the quality of services provided.
These activities may concern products and services of the Owner, as well as companies controlled by GoVolt or their business partners, and may also be carried out through an automated call system, without the intervention of an operator, including electronic mail, and messages such as MMS (Multimedia Message Service) and SMS (Short Message Service). The consent to the processing of data and communication to the subjects indicated below for the aforementioned purposes is optional and can be directly revoked by the customer within his personal area.
c) Defense of a right in court
In addition, your Personal Data will be processed whenever necessary for the purpose of ascertaining, exercising or defending a right of the Controller or other companies falling within the GoVolt control scope in court.
d) Legitimate interest of the Controller
The Controller may process, without your consent, your Personal Data in the following cases:
– in the case of extraordinary operations such as merger, sale or transfer of business branch, in order to allow the realization of the operations necessary for the due diligence activity and precedent to the sale. It is understood that they will be processed for the aforementioned purpose the data only necessary, in the form as muchaggregated/anonymous as possible;
– analysis of the use of shared scooter sharing services, to identify consumption habits and inclinations, to improve the services provided and to meet specific customer needs, or the preparation of initiatives related to the contractual relationship and aimed at improving the services provided, such as for example the possible conducting of surveys to obtain suggestions from customers. This analysis activity is distinguished from the user’s profiling as performed at an aggregated level and without references that can in any way be attributable to the individual customer;
– preparation of a geolocation system for vehicles/corporate assets and any measures to protect them against any acts committed by customers users that are illicit or fraudulent.
4. Recipients of your Personal Data
For the pursuit of the purposes indicated in clause 3, the Controller may communicate your Personal Data to third parties, such as, for example, those belonging to the following subjects or categories of subjects:
– police forces, armed forces and other public administrations, for the fulfillment of obligations under the law, regulations or community legislation. In such cases, according to the applicable legislation on data protection, the obligation to acquire the prior consent of the person concerned to such communications is excluded;
– Companies, bodies or associations, or parent companies, subsidiaries or companies affiliated to GoVolt pursuant to Article 2359 of the Italian Civil Code, between these and GoVolt subject to joint control, as well as consortia, networks of companies and groupings and temporary associations of companies and with the subjects adhering to them, limited to communications made for administrative and/or accounting purposes;
– insurance companies responsible for settlement claims; – Companies specialized in debt collection;
– Companies specialized in the management of commercial or credit information, or advertising promotion;
– other companies that engage in the scooter sharing of vehicles and or ancillary services with which the Controller has agreements of various types;
– other companies contractually linked to the Controller who carry out management claims.
The Controller guarantees the utmost care to ensure that the communication of your Personal Data to the aforementioned recipients only concerns the data necessary to achieve the specific purposes for which they are intended.
Your Personal Information is stored in the database of the Controller and will be processed exclusively by authorized personnel. The latter will be provided with specific instructions on the methods and purposes of the processing. This data will not be disclosed to third parties, except as provided above and, in any case, within the limits indicated therein.
Finally, we remind you that your Personal Information will not be divulged, except in the cases described above and / or required by law.
5. Place of storage of personal data
As part of the contractual relationship between GoVolt and its partners, for some of the purposes indicated in clause 3, your Personal Data will always remain stored inside the EU.
6. Retention period of Personal Data
The data will be stored for a period of time not exceeding that necessary for the purposes for which they were collected or subsequently processed in accordance with the provisions of the legal obligations.
Except for cases in which the law provides for a shorter retention period, your data will be retained for ten years from the end of the existing contractual relationship, in order to allow GoVolt to defend against possible claims in relation to the contract. At the end of this period, the data will be erased or otherwise irreversibly de-identified, unless further storage of some or all of the data is required by law.
- Rights of the interested parties
Rights of the interested parties
– access and request a copy;
– request a correction;
– request a cancellation;
– obtain the processing limitation;
– oppose the processing;
– receive in a structured format, commonly used and readable by automatic device [and to transmit such data to another data controller without any impediment; where technically feasible]. We inform you that you have the right to object at any time to the processing of Personal Data concerning you for sending, by the Controller, communications of a promotional, advertising and commercial nature, as well as for the promotion of events.
7.1 As an interested party, you are granted the following rights on your Personal Data collected and processed by the Controller for the purposes indicated in clause 3.
In particular, in accordance with articles 15 – 21 of the GDPR, in relation to the communicated Personal Data, you have the right to:
- Right to access
You have the right to obtain from the Controller, confirmation that a personal data processing is in progress for you and in this case, to obtain access to personal data and the following information: (i) the purposes of processing; (ii) the categories of personal data in
question; (iii) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular if they are recipients of third party countries or international organizations; (iv) when possible, the retention period of the personal data provided or, if not possible, the criteria used to determine this period; (v) the right to lodge a complaint with a supervisory authority.
- Right to rectify and cancel
You have the right to obtain the correction of inaccurate personal data concerning yourself and, taking into account the purpose of the processing, the right to obtain the integration of incomplete personal data, by providing an additional declaration.
You also have the right to obtain the deletion of your personal data if one of the following reasons is applicable: (i) personal data is no longer necessary for the purposes for which it was collected or otherwise processed; (ii) the data is processed unlawfully; (iii) you have revoked the consent on the basis of which the Controller has the right to process your data and there is no other legal basis that allows the Controller to process the data; (iv) has opposed the processing activity and there is no legitimate overriding reason; (v) personal data must be deleted to fulfill a legal obligation.
However, GoVolt has the right to disregard the exercise of the aforementioned cancellation rights if the right to freedom of expression and information prevails or for the exercise of a legal obligation or to defend one of its rights to trial when sued.
The following rights are also recognized:
a) Right to data portability
You have the right to receive, in a structured, common and readable format, your personal data provided to GoVolt and processed by consensus or other legal basis, as well as the right to transmit such data to another data controller without impediments.
b) Right to limit the processing
You have the right to obtain the limitation of processing from GoVolt when one of the following hypotheses occurs: (i) for the period necessary for the Controller to verify the accuracy of such personal data concerning you which the Controller has contested the accuracy; (ii) in case of unlawful processing of your personal data; (iii) even if your personal data are not necessary for the purposes of the processing, in any case it needs to be treated for the assessment, exercise or defense of a right in court; (iv) for the period necessary for the verification of the possible prevalence of the legitimate reasons of the Controller with respect to your request for opposition to the processing.
You can exercise the rights listed above by sending an email to the certified e-mail address email@example.com, or by writing to the data protection officer firstname.lastname@example.org. You are also guaranteed the right to contact the competent data protection authority in case of unlawful processing of your identity and availability data: name, surname, city of residence, address of residence (street, street number, postcode), mobile phone, tax code, driving license number, expiry date of the license; and related to vehicle traceability: pick up point, drop off point, kilometers traveled, duration of trips.
8. Social Network
GoVolt will be present on social networks. Specifically, GoVolt will have a Facebook profile, Instagram, LinkedIn and a YouTube channel. GoVolt’s activity on social networks will be limited to the publication and sharing of written and / or multimedia content for promotional purposes. The data processing of those who become followers on social networks (and/or perform any action of connection through social networks) of the official GoVolt pages will be regulated by this section, as well as the conditions of use, policies on privacy and access rules that belong to the social network in question and that are previously accepted by the customer.
GoVolt will process the data in order to correctly manage the presence of its users in the social network, informing them of the activities, products or services of GoVolt, as well as for any other purpose permitted by the Social Network regulations.
The publication of the following contents is forbidden: (i) those which are presumably illegal according to national, EU or international law or which carry out activities that are presumably illegal or in conflict with the principles of good faith; (ii) those that threaten the fundamental rights of persons, the lack of courtesy in the network, annoy or may generate negative opinions on our customers or third parties and in general any content that GoVolt deems inappropriate; (iii) those that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, protection of consumers and intellectual and industrial property rights.
Likewise, GoVolt reserves the right to remove, from the website or corporate social networks, any content deemed inappropriate.
9. Consent to processing and obligation to communicate data
For the processing of the aforementioned data of an optional nature (Section 3: Purpose of processing, clause b: Commercial and marketing purposes – consent), GoVolt requests your consent to the processing exclusively for the purposes indicated at the time of registration to GoVolt . In the absence of your explicit consent to the processing of optional data held by GoVolt and acquirable by them in the future, GoVolt informs you that the benefits and / or effects connected to the processing of the data may be precluded from you, without, however, having any effect on the contractual relationship in place and on services provided by GoVolt.
When requesting your personal data, GoVolt will specifically indicate the mandatory or optional nature of the provision of the new data requested.
The expression of a more specific consent to the Controller in relation to a particular service does not automatically modify any further consent previously granted regarding other services on the basis of a different contract.