VAIMOO - Support

Privacy Policy of Vaimoo
VAIMOO collects certain Personal Data from its Users.
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Data Controller
VAIMOO Srl, Via San Sabino 21, 70042 Mola di Bari (BA), Italy
Controller’s email address: support@vaimoo.app

Vaimoo has appointed Studio Cartwright Pescatore as Data Protection Officer, with designation of Attorney Marco Zichittella, who can be contacted at the following email address: marco.zichittella@becp.eu

Types of Data collected
Among the Personal Data collected by Vaimoo, either independently or through third parties, are: Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); device information; geographic region; number of Users; number of sessions; session duration; in-app purchases; Application openings; Application updates; launches; operating systems; payment information; Precise Location permission (continuous); Precise Location permission (non-continuous); Approximate Location permission (continuous); Approximate Location permission (non-continuous); Bluetooth File Exchange permission; NFC reader permission; Universally Unique Identifier (UUID); crash data; inertial data; phone number; email; first name; last name; identity document.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information notices displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of Vaimoo.
Unless otherwise specified, all Data requested by Vaimoo is mandatory. If the User refuses to provide it, it may be impossible for Vaimoo to provide the Service. In cases where Vaimoo indicates certain Data as optional, Users are free to refrain from providing such Data, without any consequence on the availability or operation of the Service.
Users who have doubts about which Data is mandatory are encouraged to contact the Controller.

Any use of Cookies - or other tracking tools - by Vaimoo or by the owners of third-party services used by Vaimoo, unless otherwise specified, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through Vaimoo and guarantees that they have the right to communicate or disseminate them, releasing the Controller from any liability towards third parties.

Methods and place of processing of the collected Data

Methods of processing
The Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Controller, in some cases, other parties involved in the organization of Vaimoo (administrative, commercial, marketing, legal staff, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies) may have access to the Data, also appointed, if necessary, as Data Processors by the Controller. The updated list of Data Processors may always be requested from the Data Controller.

If the User has given specific consent (through the relevant dedicated flag in the app or on the website) to the access of personal data by third parties such as communication agencies, commercial partners, analysis and monitoring platforms for experience personalization, Public Administration, the User’s data may be accessible to such entities with which Vaimoo collaborates for the provision of the bike sharing service.

The purpose of such access is to allow statistical/marketing/monitoring analyses on the use of the bike sharing service. In this context, we retain primary responsibility for the processing of the User’s personal data. These recipients may process the data only based on our specific instructions and for no other purpose, unless we have informed the User in advance and obtained consent where required. Furthermore, we impose specific contractual obligations on them to ensure the protection of personal data.

Legal basis of processing
The Controller processes Personal Data relating to the User if one of the following conditions applies:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”). However, this does not apply where the processing of Personal Data is governed by European data protection law;
• processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures;
• processing is necessary for compliance with a legal obligation to which the Controller is subject;
• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
  
• processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

It is always possible to request the Controller to clarify the specific legal basis of each processing activity and in particular to specify whether the processing is based on the law, required by a contract, or necessary to enter into a contract.

Place
The Data is processed at the Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User may refer to the section concerning details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis of Data transfers outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Controller to protect the Data.

The User can verify whether any of the transfers described above take place by examining the relevant section of this document or by contacting the Controller using the contact details provided at the beginning.

Retention period
Data is processed and stored for as long as required by the purposes for which it was collected.

Therefore:
 

• Personal Data collected for purposes related to the performance of a contract between the Controller and the User will be retained until such contract has been fully performed.
  
• Personal Data collected for purposes related to the legitimate interest of the Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Controller may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, once this period expires, the right of access, deletion, rectification and the right to data portability can no longer be exercised.

Purposes of the processing of collected Data
User Data is collected to allow the Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, ensure service security, prevent unlawful uses and acts of vandalism, as well as - where necessary - identify the User in the event of incidents, and for the following purposes: Hosting and backend infrastructure, Analytics, Platform and hosting services, Payment management, Permissions for access to Personal Data on the User’s device, Contact management and message sending, Infrastructure monitoring, Content and feature performance testing (A/B testing), and Registration and authentication.

To obtain detailed information on the purposes of processing and on the Personal Data processed for each purpose, the User may refer to the section “Details on the processing of Personal Data”.

Infrastructure monitoring
This type of service allows Vaimoo to monitor the use and behavior of its components, in order to improve performance and functionality, carry out maintenance, or resolve issues.
 The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter Vaimoo’s activity.

Firebase Performance Monitoring (Google Ireland Limited)
Firebase Performance Monitoring is a monitoring service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the service’s privacy policy.
Place of processing: Ireland – Privacy Policy.

Crashlytics (Google Ireland Limited)
Crashlytics is a monitoring service provided by Google Ireland Limited.
Personal Data processed: crash data; Universally Unique Identifier (UUID); device information.
Place of processing: Ireland – Privacy Policy.

Permissions for access to Personal Data on the User’s device
Vaimoo requires the User to grant certain permissions, thereby authorizing access to Data on their device, under the terms indicated below.

Permissions for access to Personal Data on the User’s device (Vaimoo)
Vaimoo requires the User to grant certain permissions, thereby authorizing access to Data on their device, as summarized here and as specified in this document.
 Personal Data processed: NFC reader permission; Approximate Location permission (continuous); Approximate Location permission (non-continuous); Precise Location permission (continuous); Precise Location permission (non-continuous); Bluetooth File Exchange permission.

Types of Data collected
If you link, connect, or log in to Vaimoo with a third-party service (Google ID, Apple ID, or Facebook), the third-party service may send us information such as your profile information (e.g., email) from that service.
 The information Vaimoo receives from such services depends on your settings and the third-party service’s privacy policy.

Registration and authentication
By registering or authenticating, the User allows Vaimoo to identify them and grant access to dedicated services.
Depending on the provisions below, registration and authentication services may be provided with the assistance of third parties. Where this occurs, Vaimoo may access certain Data stored by the third-party service used for registration or identification.
 Some of the services listed below may also collect Personal Data for targeting and profiling purposes; for more information, please refer to the description of each service.

Creation of a user account with Google ID and Apple ID
 If the User links, connects, or logs in to Vaimoo with Google ID or Apple ID and/or modifies their Google ID or Apple ID email, such email will automatically be updated accordingly on the User’s Vaimoo account.

Platform and hosting services
These services are intended to host and run key components of Vaimoo, making it possible to provide Vaimoo from a single platform. These platforms provide the Controller with a wide range of tools such as analytics tools, user registration management, comment and database management, e-commerce, payment processing, etc. The use of such tools involves the collection and processing of Personal Data.
 Some of these services operate through servers located in different geographic locations, making it difficult to determine the exact location where Personal Data is stored.

Google Play Store (Google Ireland Limited)
Vaimoo is distributed on Google Play Store, a mobile application distribution platform provided by Google Ireland Limited.
By virtue of being distributed through this app store, Google collects usage and diagnostic data and shares aggregated information with the Controller. Much of this information is processed based on an opt-in declaration.
Users can disable this analysis function directly through their device settings. More information on how to manage analytics settings is available on this page.
Personal Data processed: Usage Data.
 Place of processing: Ireland – Privacy Policy.

App Store Connect (Apple Inc.)
Vaimoo is distributed on Apple’s App Store, a mobile application distribution platform provided by Apple Inc.
App Store Connect allows the Controller to manage Vaimoo on Apple’s App Store. Depending on the configuration, App Store Connect provides the Controller with statistical data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure Vaimoo’s performance. App Store Connect collects such data only from Users who have agreed to share it with the Controller. Users can find more information on how to opt out through their device settings here.
Personal Data processed: Usage Data.
 Place of processing: United States – Privacy Policy.

Analytics
The services contained in this section enable the Controller to monitor and analyze traffic data and are used to track User behavior.

Google Analytics for Firebase (Google Ireland Limited)
Google Analytics for Firebase, or Firebase Analytics, is an analytics service provided by Google Ireland Limited.
To understand Google’s use of Data, please refer to Google’s partner policy.
Firebase Analytics may share Data with other services provided by Firebase, including Crash Reporting, Authentication, Remote Config, or Notifications. The User may consult this privacy policy for a detailed description of other tools used by the Controller.
To enable Firebase Analytics, Vaimoo uses certain identifiers for mobile devices or technologies similar to cookies.
Users may opt out of certain Firebase features through their mobile device settings. For example, they may modify advertising settings available on their device or follow instructions applicable to Firebase provided in this privacy policy.
Personal Data processed: in-app purchases; Application updates; Application openings; Usage Data; session duration; unique device identifiers for advertising (e.g., Google Advertiser ID or IDFA identifier); device information; launches; number of sessions; number of Users; geographic region; operating systems.
 Place of processing: Ireland – Privacy Policy.

Content and feature performance testing (A/B testing)
 The services in this section allow the Controller to track and analyze the User’s response, in terms of traffic or behavior, to changes in the structure, text, or any other component of Vaimoo.

Firebase Remote Config (Google Ireland Limited)
Firebase Remote Config is an A/B testing and configuration service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the service’s privacy policy.
 Place of processing: Ireland – Privacy Policy.

Inertial Data
Inertial data is collected to measure dynamic motion parameters and is used exclusively to detect anomalous behavior or improper use of the vehicle by the User.
Such data is essential to ensure user safety, preserve the integrity of the service, and support operational safety and maintenance activities.

Further information on the processing of Personal Data

Push notifications
Vaimoo may send push notifications to the User to achieve the purposes described in this privacy policy.
In most cases, Users can opt out of receiving push notifications by checking their device settings, such as notification settings for mobile phones, and modifying these settings for Vaimoo, for some or all applications on the device.
Users should be aware that disabling push notifications may negatively affect the use of Vaimoo.

Online sale of goods and services
 The Personal Data collected is used to provide services to the User or to sell products, including payment and possible delivery. The Personal Data collected to complete payment may include credit card details, bank account details used for transfers, or other payment instruments provided. The payment Data collected by Vaimoo depends on the payment system used.

User rights
Users may exercise certain rights regarding the Data processed by the Controller.
In particular, the User has the right to:

• withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously given.
  
• object to processing of their Data. The User may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided below. 
•  access their Data. The User has the right to obtain information about the Data processed by the Controller, certain aspects of the processing, and to receive a copy of the Data processed.
  
• verify and request rectification. The User may verify the accuracy of their Data and request it to be updated or corrected.
  
• obtain restriction of processing. Under certain conditions, the User may request the restriction of the processing of their Data. In such a case, the Controller will not process the Data for any purpose other than storage. 
•  obtain erasure or removal of their Personal Data. Under certain conditions, the User may request the deletion of their Data by the Controller. 
• receive their Data and have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transmitted to another controller without hindrance. This provision applies when Data is processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party, or pre-contractual measures.
• lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details on the right to object
Where Personal Data is processed for a public interest, in the exercise of official authority vested in the Controller, or for the purposes of the legitimate interests pursued by the Controller, Users have the right to object to processing on grounds relating to their particular situation.
Users are informed that, if their Data is processed for direct marketing purposes, they may object to such processing without providing any justification. To determine whether the Controller processes data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise rights
To exercise User rights, Users may send a request to the Controller using the contact details provided in this document. Requests are free of charge and will be processed by the Controller as soon as possible, in any case within one month.

Further information on processing

Legal defense
The User’s Personal Data may be used by the Controller in legal proceedings or in the preparatory stages leading to possible legal action for the defense against abuse in the use of Vaimoo or related Services by the User.
 The User declares to be aware that the Controller may be required to disclose Data by order of public authorities.

Specific information notices
Upon request, in addition to the information contained in this privacy policy, Vaimoo may provide the User with additional and contextual notices regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance
 For operational and maintenance purposes, Vaimoo and any third-party services used may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy
 Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests
Vaimoo does not support “Do Not Track” requests.
 To determine whether any third-party services used support them, Users are invited to consult their respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, where possible, on Vaimoo, as well as, where technically and legally feasible, by sending a notification to Users through any contact information available. Please check this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes affect processing activities based on consent, the Controller will collect the User’s consent again, if required.

Definitions and legal references

Personal Data (or Data)
Any information that, directly or indirectly, even in connection with any other information, including a personal identification number, allows a natural person to be identified or identifiable.

Usage Data
 Information collected automatically through Vaimoo (including from third-party applications integrated into Vaimoo), including: IP addresses or domain names of the computers used by the User connecting to Vaimoo, URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful outcome, error, etc.), the country of origin, browser and operating system features used by the visitor, various time details of the visit (e.g., time spent on each page), and details about the path followed within the Application, with particular reference to the sequence of pages visited, parameters related to the User’s operating system and IT environment.

The above data is mainly stored on servers located within the European Union. However, data provided for sending communications for marketing purposes (e.g., “Newsletter”) and for payment services (e.g., “Payment gateways”) is stored on servers located in non-EU countries at the following companies:

• MailChimp – The Rocket Science Group, LLC, 512 Means St., Suite 404, Atlanta, Georgia 30318 – whose data transfers are carried out in compliance with applicable data protection laws and the Data Processing Addendum (DPA) available on its website and the Standard Contractual Clauses (SCC) pursuant to Art. 46 of the GDPR;
• Stripe Payments Europe, Ltd. – which implements appropriate safeguards and measures to ensure an adequate level of protection of personal data transferred outside the EEA and Switzerland. Stripe’s measures include SCCs for international data transfers, contractual measures (e.g., standard contractual clauses and supplementary clauses), technical and organizational measures (e.g., access controls, encryption), and transfer impact assessments.

User
The individual using Vaimoo who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Processor (or Processor)
The natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Controller)
The natural or legal person, public authority, service, or other body which, alone or jointly with others, determines the purposes and means of processing personal data and the tools adopted, including security measures relating to the operation and use of Vaimoo. Unless otherwise specified, the Data Controller is the owner of Vaimoo.

Vaimoo (or this Application)
The hardware or software tool by which Users’ Personal Data is collected and processed.

Service
The Service provided by Vaimoo as defined in the relevant terms (if any) on this site/application.

European Union (or EU)
 Unless otherwise specified, any reference to the European Union in this document includes all current Member States of the European Union and the European Economic Area.

Legal references
This privacy policy is drafted on the basis of multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to Vaimoo.