PRIVACY POLICY

 

Dear user,

 

this privacy policy explains how user’s personal data are treated.

 

Pursuant to UE Regulation 2016/679, we recommend you read the following information.

 

1.     GENERAL INFORMATION

The owner of the data processing of this site is UP2GO s.r.l., whose legal office is in via Antonio Gramsci, 20 – San Polo d’Enza (RE) – email: info@up2go.it – PEC: up2go@pec.it (hereinafter “UP2GO”).

 

The community of a user (hereinafter the “Community”) is the co-owner of the data processing.

 

In the event of different data ownership, specific privacy policies provided by the Communities to their users will prevail.

 

2.     PURPOSE OF DATA TREATMENT

 

Users’ personal data provided by users themselves are treated solely for the purposes linked to the use of this carpooling service. Every user may use the carpooling service at no cost under the agreement executed by the user’s Community and UP2GO s.r.l.

 

3.     TYPES OF USER DATA COLLECTED

 

Users may provide UP2GO with different data, such as personal identification information (“Personal data”), while using UP2GO website (e.g. when filling out a contact form or a registration form to the carpooling service), while using the UP2GO app or while contacting directly UP2GO via telephone, email or by any other means (website and app are hereinafter called “Platforms”).

 

The information provided by users can be:

 

-       Information required for the purposes of registration to the carpooling service and provided through our website or app, such as Community, name, surname, email address, tax code, password, workplace;

 

-       Any other information (required by the Community to register to the service or provided discretionally), such as the serial number (or any other identification code of the user’s Community), permanent/temporary address, telephone number;

 

-       Car model, car color, car fuel, available places for lifts;

 

-       Previous correspondence between user and UP2GO (via the app chat or via email);

 

-       Replies to any surveys run by UP2GO to assess users’ satisfaction about the provided service.

 

The following information can also be collected automatically:

 

-       IP address of the device used to register to the carpooling service;

 

-       Online registration data to the carpooling service and date of the first access to the app with user’s own credentials;

 

-       List of previous offered and asked lifts, lifts actually carried out and travelled kilometers;

 

-       User’s geolocation during check-in and checkout procedures in order to certify trips;

 

-       List of previous connections to partner apps through links on our Platforms.

 

4.     SCOPE AND LEGAL BASIS OF DATA TREATMENT

 

The conferral of personal data by users is necessary to use the carpooling service under the General Conditions of Use approved by users during the registration procedure.

 

Notably, data may be used for the following purposes, including but not limited to:

 

-       Fulfilling obligations under any agreements signed by the user’s Community and UP2GO and by users themselves and UP2GO, and to provide users with requested information and services;

 

-       Providing Communities with reports on the use of UP2GO, which can also be used to assign any benefits;

 

-       Sending any information about services via email and/or text message and/or any other media (e.g. lifts confirmation);

 

-       Letting users customize their profile;

 

-       Letting users interact with other users about our services or about trips shared with other users;

 

-       Letting users access our support services;

 

-       Ensuring the compliance to the applicable law, the General Conditions of Use and the Privacy policy of UP2GO.

 

-       Sending, pursuant to the applicable law and whenever necessary, with the consent of the user, marketing materials and information to simplify the use or the lifts confirmation procedure and to give recommendations and suggestions on our products and services which may interest users;

 

-       Inform users about any modifications to services provided by UP2GO;

 

-       Manage UP2GO Platforms and execute internal operations such as problem fixing, data analysis, testing and researching;

 

-       Improving UP2GO Platforms to ensure the efficacy of the presented content for users and their devices;

 

-       Improving UP2GO Platforms to ensure their safety.

 

 

5.     RECIPIENTS OF COLLECTED INFORMATION

 

In order to ensure the use of the carpooling service, user’s data can be transmitted by UP2GO to:

 

-       the Community of the user which will treat user’s data as co-owner in order to execute operations such as drafting reports and monitor the use of service; these aggregate or not data are about the use of service (e.g. number of offered/given lifts, number of shared trips, travelled km, saved CO2);

 

-       other users of the Community to the extent necessary for using the carpooling service;

 

-       external companies in charge of managing the service or maintaining the service on behalf of UP2GO;

 

-       third parties (societies which give legal, administrative and tax advice or data treatment centers, etc.) if the transmission is necessary for using the carpooling service;

 

-       its own contractors and team members, specifically charged and within their respective duties;

 

-       entities and public administrations for statistical or research purposes and only in aggregate form;

 

-       to whom it may concerns, if required by law or if UP2GO thinks in good faith that this access, storage and disclosure are reasonably necessary to (i) reply to claims against UP2GO, (ii) comply with any legal procedures, (iii) ensure that any agreements with its own users, such as the General Conditions of Use and the Privacy policy, are complied with, (iv) in the event of an emergency which would endanger public health and cause death or physical injuries of any person, (v) in the event of an investigation or (vi) to protect the rights, property and personal safety of UP2GO, its users or any other persons;

 

-       to users, if requested by the users themselves, or to any other operator in the carpooling industry that users may have selected.

 

6.     STORAGE AND TRASMISSION OF DATA TO USERS

 

Collected user’s data are stored in servers, located within the EU.

 

UP2GO does not intend to transfer these data to non-European countries.

 

Should you want more details on the protective measures in place, please get in touch with UP2GO by using the contact information shown in Section 12.

 

7.     PERIOD OF DATA STORAGE

 

Storage of user’s data depends on the renewal of the carpooling service by the Community which user belongs to.

 

When the license agreement ends, user’s personal data shall be anonymized. Only app usage data shall be stored for statistical purposes.

 

In the event that a user asks the Owner of data processing for cancelling their own account and all related data, the Owner sends a request to the Entity in charge of the treatment which within 24 working hours from receiving the request will ensure the data anonymization and will confirm to the Owner that the personal data have been cancelled both on production database and all backup copies. After the cancellation no carpooling service will be provided to the user anymore.

 

8.     USER’S RIGHTS ON THEIR PERSONAL DATA

 

If allowed by law, a user may have the right to obtain a copy of their Personal data which we hold. Before replying to the request, we reserve the right to ask the user for (i) verifying their identity and (ii) providing further details in order to better reply to their request. UP2GO will reply within a reasonable time and in any case within the time set by law. If the user decides to exercise this right, they shall contact UP2GO using the contact information provided below (Section 12).

 

As a user of UP2GO Platforms, the user may have access to their Personal data held by UP2GO through their own account in order to correct, modify or cancel any inaccurate information. Only personal details are modifiable data. Data on app usage cannot be modified by users. User may also update or cancel their own Personal data by contacting UP2GO using the contact information provided below (Section 12). Users may cancel their own online account at any moment and have the right to object to their own data being processed.

 

In some cases, UP2GO may store some information on users, as requested by law or for legitimate purposes. For example, if there is reason to believe that a user has committed fraud of has violated the General Conditions of Use they have agreed on, UP2GO may decide to store some information to avoid illegal actions to be committed on its own Platforms.

 

If a user thinks that their rights have been violated, they also have the right to file a claim to the data protection supervisory authority or to take legal action.

 

Users have also the right to obtain previously provided to UP2GO Personal data on themselves in a structured, commonly used and machine-readable form, as well as to send these Personal data to another Owner of data processing.

 

9.     PASSWORD CONFIDENTIALITY

 

In the event that a user has chosen a password letting them have access to some sections of UP2GO Platforms, they are accountable for keeping this password confidential.

 

10.  LINK TO EXTERNAL WEBSITES AND SOCIAL MEDIA

 

UP2GO Platforms may, from time to time, contain links from and to external websites of advertisers, affiliates or partners of UP2GO. If a user follows the link to any of these websites, they shall keep in mind that these websites apply their own privacy policies and that UP2GO does not take any responsibilities on these policies. Please, read these policies before sending your Personal data to these websites.

 

11.  CHANGES TO THE PRIVACY POLICY

 

Any future changes to UP2GO privacy policy shall be published on this page. If appropriate, users shall be informed or asked to give their consent.

 

12.  CONTACT INFORMATION AND ENTITY IN CHARGE OF DATA PROTECTION

 

For exercising their rights or for sending any request on personal data, user can contact:

 

-       The Entity in charge of Data protection at dpo@up2go.it

-       UP2GO, through the contact page on the website or sending a letter to UP2GO s.r.l., via Antonio Gramsci, 20 – 42020 – San Polo d’Enza (RE)

 

13.  SYSTEM ADMINISTRATOR

 

The system administrator is Melazet s.r.l. whose legal office is in via Tacito, 55 – Modena.