PRIVACY POLICY OF THE ‘Justmoove App’ BY CONNECTED MOBILITY VENTURES, S.A. AND SUNHILL TECHNOLOGIES GmbH

Through this Privacy Policy, we inform you about the collection, processing and use of your personal data through the use of the ‘Justmove App‘ (from now on, ‘Justmoove‘ or the ‘Application‘).

Who is responsible for the processing of your data?

Identity of those responsible:Connected Mobility Ventures, S.A. con CIF nº A67140582 (‘XMOBA’)Sunhill Technologies GmbH with German tax ID no. DE253757818 (‘SUNHILL’)
Address:Autovía A-2, km. 585, Martorell (Barcelona).Allee am Röthelheimpark 15, 91052 Erlangen, Alemania
Mail:mydata@xmoba.io
Contact the Data Protection Officer (DPO):dataprotection@xmoba.iodatenschutz@sunhill-technologies.com

XMOBA and SUNHILL act as co-responsible for the processing, which means that they work together in the collection of data and its subsequent processing to be able to offer you in this way the services that are available through the Application. To find out more about the essential aspects of the processing carried out by these entities, please read this policy.

For what purposes will we process your data?

We treat the personal data you provide us, as well as all those collected through the use of the Application, with the following main purposes:

To manage the registration of users in the Application and be able to control the development and compliance of the contractual relationship, in accordance with what is detailed in the Conditions of Use.

For this, XMOBA and SUNHILL will carry out the services that the user may request punctually, such as executing payments in favor of third parties ordered or facilitate the hiring of services from other providers.

More specifically, XMOBA and SUNHILL will deal with the following categories of data and for the purposes specified below:

Personal data categoriesEntity responsible for processingPurposes of processing
Information required for registration (access data, registration information, name, title, address, date of birth, username and password).XMOBA; SUNHILLUser validation and creation of an account at SUNHILL in order to provide the services of the Application.
Basic contact information (phone and email address).XMOBA; SUNHILLContact with the customer for the execution of the contractual relationship; advertising (if applicable, and only for XMOBA).
Additional contact information (nationality, employment and income and contact information – such as ID CARD number).XMOBA; SUNHILLVerification of the customer’s identity before a contract is concluded with the customer and services are provided, verification of the customer’s payment methods, credit assessment of the customer, fraud prevention, treatment of the payment transaction for the purpose of contract execution.
Transaction information, as well as billing and delivery address.XMOBA; SUNHILLPayment processing and fulfillment of the contractual relationship.
Payment information (credit card and bank details.XMOBA; SUNHILLUser account registration and transaction processing, as well as credit rating.
Usage data, in particular, technical and device-related information and data transmission (IP address, fingerprint of the device/ID, functional and web-tracking data, login and web-usage data)XMOBA; SUNHILLCustomization of offers; error resolution, fraud prevention, service improvement, user interface improvement and, if applicable, for marketing.

Respond to any questions that users may send regarding the Application or services to XMOBA or SUNHILL, each one being responsible for any questions they may receive.

Also, and only if you accept it for each case, we will also treat your data for the following additional purposes:

If you give your consent, treat the data about your location in order to offer you a more personalized experience using the Application, prevent fraud and improve the service. Both XMOBA and SUNHILL are responsible for processing the data obtained.
If you request it, to send you advertising, including by electronic means, about the products and services of XMOBA and its partners that may be of interest to the user.

The processing of your data for these purposes is necessary for the provision of the services included in the Application.

What is the legitimacy for the treatment of your data?

The legal basis for the treatment of your data is the execution of the service provision of the Contract conditions of use. With regard to the sending of electronic commercial communications and resolution of any doubts that may arise, as well as the geolocation of the user, the legal basis is the consent given by the user, which may be revoked at any time without affecting the provision of the service.

To whom will the data be communicated?

XMOBA and SUNHILL may communicate the personal data of users when so required by law, for the defense of their rights and legitimate interests, or when necessary in compliance with the services contracted by the user. They will be able to communicate the data of the users to files related to the fulfillment or non-compliance of monetary obligations, when the user does not attend to the payment of certain, due and demandable debts after having been requested previously to the payment of these.

Likewise, XMOBA and SUNHILL may communicate your personal data to companies that exploit vehicle reservation and parking services, toll motorway concessions, mobility services (such as taxis or similar, or car sharing) and automatic payment services through remote reading of magnetic strips. To this end, and depending on the services contracted at any given time, you will be asked punctually for your consent to transfer the data, and you will be informed of the specific companies that will receive your personal data and the purposes for which such data will be delivered.

XMOBA and SUNHILL also use other companies to provide certain services related to Justmoove, such as technical and computer support services. These companies are, in some cases, adhered to the agreement between the European Union and the United States called Privacy Shield (information available, with respect to each company, in the following links:

The Rocket Science Group LLC d/b/a MailChimp —Inc. — https://www.privacyshield.gov/participant?id=a2zt0000000KzLyAAK&status=Active; Zendesk, Inc. — https://www.privacyshield.gov/participant?id=a2zt0000000TOjeAAG&status=Active; Adjust, Inc. —PTY Ltd — https://www.privacyshield.gov/participant?id=a2zt00000004FK0AAM&status=Active; Google LLC — https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active).

In other cases, as in the case of Apple Inc., appropriate contractual measures have been implemented to ensure the levels of protection of personal data.

Finally, we would like to inform you that some of Justmoove’s functionalities are offered through third parties, such as, for example, Google if you use the map functionality, or certain banking and financial institutions, for automatic payment services. In that case, it could be that these third parties treat personal data as responsible, subject to the respective privacy policies to which you can access through the appropriate application in each case.

How long will we keep your data?

XMOBA and SUNHILL retain the personal data of users as long as the user holds the status of client or registered user of the Application, being the personal data retained after the termination of the contractual relationship for a period of five years, in order to meet the responsibilities that may arise from it. In particular, the data necessary to send electronic commercial communications will be treated as long as the user does not revoke the consent given and, once it has been withdrawn, for a period of three years to respond for the responsibilities that may have arisen. For its part, the information relating to consultations will be kept, once it has been resolved, for a maximum period of one year. In any case, when personal data are not necessary for the purpose for which they were collected and until they are definitively deleted, they will be kept in a blocked form.

What are your rights as owner of the data?

Rights

Content

Attention Channels

Access

You will be able to obtain confirmation if your personal data is processed, as well as to consult your specific personal data that is the object of processing.

*In order to exercise your rights, you must attach a copy of your National Identity Card or other document that accredits your identity and indicates the right you wish to exercise.

Rectification

You will be able to modify your personal data when they are inaccurate, as well as to complete those that are incomplete.

Deletion

You may request the deletion of your personal data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.

Opposition

You may request that your personal data not be processed. The data will not be processed, except for compelling legitimate reasons, or the exercise or defense of possible claims.

Limitation of treatment

You may request limitation of the processing of your data in the following cases:
§As long as the accuracy of your data is contested;
§When the processing is unlawful, you oppose the deletion of your data, and request the limitation of its use;
§When your data does not need to be processed but you need them for the exercise or defense of claims;
§When you have opposed the processing of your data for the fulfillment of a mission of public interest or for the satisfaction of a legitimate interest, while verifying whether the legitimate reasons for the processing prevail over yours.

Portability

You will be able to receive, in electronic format, the personal data that you have provided us and those that have been obtained from your contractual relationship with XMOBA and SUNHILL, as well as to transmit them to another entity.

If you believe that your personal data have not been processed in accordance with the applicable regulations, you may lodge a complaint with the competent supervisory authority via the website www.agpd.es.

The right to exercise these rights is free of charge.Para poder ejercer estos derechos, puedes remitir una comunicación a mydata@xmoba.io.

In order to exercise these rights, you can send a communication to mydata@xmoba.io.

As a User you agree to notify any change or modification of the personal data you have provided. Any loss or damage caused to the App, to XMOBA or SUNHILL, or to any third party through the communication of erroneous, inaccurate or incomplete information shall be the sole and exclusive responsibility of the User.