Vaimoo collects some Personal Data from its Users.
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Owner and Data Controller
VAIMOO Srl, Via San Sabino 21, 70042 Mola di Bari (BA), Italy
Owner contact email: [email protected]
Types of Data collected
Among the types of Personal Data that Vaimoo collects, by itself or through third parties, there are: Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; payment data; Precise location permission (continuous); Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; NFC Reader permission ; Universally unique identifier (UUID); Crash information; phone number; email address; first name.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Vaimoo.
Unless specified otherwise, all Data requested by Vaimoo is mandatory and failure to provide this Data may make it impossible for Vaimoo to provide its services. In cases where Vaimoo specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by Vaimoo or by the owners of third-party services used by Vaimoo serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or shared through Vaimoo and confirm that they have the third party's consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Vaimoo (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
If the User has provided specific consent (by checking the relevant box in the app or on the website) for third parties such as marketing agencies, business partners, analytics and monitoring platforms, and public authorities to access their personal data in order to personalize their experience, the User's data may be shared with these entities, with whom Vaimoo collaborates to provide the bike sharing service. The purpose of this data sharing is to enable statistical, marketing, and monitoring analyses on the use of the bike sharing service. In this context, we remain primarily responsible for the processing of the User's personal data. These recipients can only process the data based on our specific instructions and for no other purpose, unless we have informed the User in advance and obtained their consent, where required. Furthermore, we impose specific contractual obligations on them to ensure the protection of personal data.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Hosting and backend infrastructure, Analytics, Platform services and hosting, Handling payments, Device permissions for Personal Data access, Managing contacts and sending messages, Infrastructure monitoring, Content performance and features testing (A/B testing) and Registration and authentication.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Device permissions for Personal Data access
Depending on the User's specific device, Vaimoo may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of Vaimoo.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Vaimoo.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. Vaimoo may collect, use, and share User location Data in order to provide location-based services.
Approximate location permission (non-continuous)
Used for accessing the User's approximate device location. Vaimoo may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Vaimoo to derive the approximate position of the User on a continuous basis.
Bluetooth sharing permission
Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.
NFC Reader permission
Allows Vaimoo to read contact-less tags.
Precise location permission (continuous)
Used for accessing the User's precise device location. Vaimoo may collect, use, and share User location Data in order to provide location-based services.
Precise location permission (non-continuous)
Used for accessing the User's precise device location. Vaimoo may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Vaimoo to derive the exact position of the User on a continuous basis.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of 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.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
Vaimoo uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Application opens; Application updates; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: Ireland – Privacy Policy.
Mailchimp
Mailchimp is an email address management and sending service provided by Intuit Inc.
Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to 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 privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Device permissions for Personal Data access
Vaimoo requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Vaimoo)
Vaimoo requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Bluetooth sharing permission; NFC Reader permission ; Precise location permission (continuous); Precise location permission (non-continuous).
Types of Data collected
If you link, connect, or login to Vaimoo with a third-party service (Google ID, Apple ID and Facebook), the third-party service may send us information such as your profile information (e.g. e-mail) from that service.
The information Vaimoo gets from such services depends on your settings and the third-party service’s privacy policy.
Handling payments
Unless otherwise specified, Vaimoo processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Vaimoo isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Payments processed via the Google Play Store (Google Ireland Limited)
Vaimoo uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
Personal Data processed: payment data.
Place of processing: Ireland – Privacy Policy.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Pay (Google Ireland Limited)
Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Pricing Plan - Pay as you go
User acknowledges and accepts that the rates may be subject to change upon issuance of the updated version of this Agreement. Rates displayed below are intended VAT incl.
Annual Subscription - € 24,50
Monthly Subscription - € 8,80
Weekly Subscription - € 4,80
Daily Subscription - € 1,80
Regular bicycle rate first 30 mins - € 0.00
Regular bicycle rate first 31 mins - 60 min - € 0.45
Regular bicycle rate 61 mins – 90 mins - € 0.45
Regular bicycle rate 91 mins – 120 mins - € 0.45
Regular bicycle rate 121 mins – 150 mins - € 0.45
Regular bicycle rate 151 mins – 180 mins - € 0.45
Regular bicycle rate from 181 mins on - € 2,80
E-bike rate first 30 mins - € 0.50
E-bike rate 31 mins - 60 mins - € 0.45
E-bike rate 61 mins – 90 mins - € 0.45
E-bike rate 91 mins – 120 mins - € 0.90
E-bike rate 121 mins – 150 mins - € 0.90
E-bike rate 151 mins – 180 mins - € 1,40
E-bike rate from 181 mins on - € 2,80
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Vaimoo to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Vaimoo.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Microsoft Azure (Microsoft Corporation)
Microsoft Azure is a hosting service provided by Microsoft Corporation.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Germany – Privacy Policy.
Google BigQuery (Google Ireland Limited)
Google BigQuery is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Firebase Cloud Functions (Google Ireland Limited)
Firebase Cloud Functions is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Firebase Cloud Firestore (Google Ireland Limited)
Firebase Cloud Firestore is a hosting and backend service provided by Google Ireland Limited.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Infrastructure monitoring
This type of service allows Vaimoo to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Vaimoo.
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 privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Crashlytics (Google Ireland Limited)
Crashlytics is a monitoring service provided by Google Ireland Limited.
Personal Data processed: Crash information; device information; Universally unique identifier (UUID).
Place of processing: Ireland – Privacy Policy.
Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Firebase Cloud Messaging (Google Ireland Limited)
Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Twilio (Twilio, Inc.)
Twilio is a phone numbers management and communication service provided by Twilio, Inc.
Personal Data processed: phone number.
Place of processing: United States – Privacy Policy.
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy.
Platform services and hosting
These services have the purpose of hosting and running key components of Vaimoo, therefore allowing the provision of Vaimoo from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google Play Store (Google Ireland Limited)
Vaimoo is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Apple App Store (Apple Inc.)
Vaimoo is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of Vaimoo. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Registration and authentication
By registering or authenticating, Users allow Vaimoo to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Vaimoo will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Creation of User account with Google ID and Apple ID
If the User links, connects, or logins to Vaimoo with Google ID or Apple ID and or if the User modifiesy his/her Google ID or Apple ID e-mail, that such e-mail will shall be automatically changed updated accordingly on Vaimoo User’s account too
Further information about the processing of Personal Data
Push notifications
Vaimoo may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Vaimoo, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Vaimoo.
Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by Vaimoo depends on the payment system used.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Vaimoo or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, Vaimoo may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, Vaimoo and any third-party services may collect files that record interaction with Vaimoo (System logs) or use other Personal Data (such as the IP Address) for this purpose.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How “Do Not Track” requests are handled
Vaimoo does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Vaimoo and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through Vaimoo (or third-party services employed in Vaimoo), which can include: the IP addresses or domain names of the computers utilized by the Users who use Vaimoo, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized 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 answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The aforementioned data are stored mainly on servers located within the European Union. However, data provided for sending communications for both purposes of marketing (e.g. “Newsletter”) and payment services (e.g. “Payment gateaways”) are 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 – which data transfers are made in compliance with the applicable Data Protection Laws and the Data Processing Addendum ("DPA") available on its website, and the Standard Contractual Clauses (“SCC”) according to the 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 existing measures include the SCCs to accommodate international data transfers, contractual measures (e.g., standard contractual clauses and supplementary clauses), technical and organizational measures (e.g., access controls, encryption), transfer impact assessments (i.e., to support Stripe’s role as data exporter).
We guarantee that the extra-EU data transfer takes place in compliance with the applicable legal provisions and that your data shall be either not ever used directly by MailChimp and Stripe or sold by them to third parties
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 Data Supervisor)
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 Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of Vaimoo. The Data Controller, unless otherwise specified, is the Owner of Vaimoo.
Vaimoo (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Vaimoo as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to Vaimoo, if not stated otherwise within this document.