PRIVACY POLICY

Electrip Italy S.r.l. (“We, Company or ELECTRIP”) is the controller responsible for the processing of your data. We handle your personal data carefully and sensibly. Our policies and compliance measures make sure of that. 

In line with this Privacy Policy, it is aimed to provide transparency in accordance with the General Data Protection Regulation (EU) 2016/679 (“GDPR”) by informing you (the “data subject”) regarding the processing of personal data by our Company in connection with use of the ELECTRIP mobile application (“ELECTRIP App”).

Please use the contact information provided on the “Contact Information” section to get in touch with us.

1. PURPOSE OF PROCESSING PERSONAL DATA, LEGAL BASIS AND DATA RETENTION

Your personal data explained in detail below (“Personal Data”) are processed in accordance with the basic principles in Article 6 of the GDPR while you use the products and services offered by our Company through or in connection with the ELECTRIP App. 

The provision of the Personal Data for the purposes described in this Section 1 is a contractual, and - in some cases, such as where used for invoices, a statutory - requirement. Failure to supply the Personal Data for these purposes may make it impossible for ELECTRIP to grant you membership of the ELECTRIP App.

2. ADDITIONAL PURPOSES OF THE PROCESSING FOR WHICH YOUR EXPRESS CONSENT IS REQUIRED

The explicit consent of the data subject must be obtained to process personal data for some purposes within the scope of the GDPR. Your personal data including mobile device identification is processed for the purposes below by our Company only if you have given your express prior consent (please note the exception at point 2.1).

The provision of the Personal Data for the purposes described in this Section 2 is optional.

2.1 Marketing and Profiling Activities

Failure to supply the Personal Data or give your consent for these purposes will mean that ELECTRIP will not be able to keep you informed about its new products, services and promotions as specified above.

Please note that your express prior consent to the processing of your Personal Data for marketing purposes is not required where you are contacted.

• by telephone (landline or mobile) or at your postal address as listed in public directories, where you have not registered your opposition to such processing in accordance with the rules applicable to the Public Oppositions Register set up by Italian Presidential Decree no. 178/2010 as amended 
• by us via email concerning the direct sale of products or services similar to those already acquired from us and provided you have not informed us that you oppose the receiving of such emails.

You can withdraw your consent to the processing of your Personal Data for marketing purposes by writing to info-ita@Electrip.net.  

  2.2 Processing of Location Data

If you approve the processing of your location data via the ELECTRIP App, your instant location information is processed so that you can see the nearest electric vehicle charging station on the map to be opened. The location is not recorded or tracked in any system. It is only displayed based on your current location.

You could remove the access of the ELECTRIP App to your location services at any time. The relevant process can be performed from the section on accessing location services in the application settings of your phone.

2.3 Mobile App Notifications 

If you approve the notifications via the ELECTRIP Mobile application, you start to receive notifications on your device where the ELECTRIP Mobile application is installed so that you can receive notifications about charging transactions, account status, payment status of transactions, developments about the ELECTRIP station network and current campaigns. You have the option to turn off notifications at any time you wish. The relevant process can be performed in the section regarding notifications in the application settings of your phone.

3. METHOD FOR COLLECTING PERSONAL DATA

Your personal data is obtained through the ELECTRIP App, our Call Center, WhatsApp, ChatBot, E-mail and social media in line with the purposes and in general the provisions set out in this Privacy Policy. 

4. PARTIES TO WHICH YOUR PERSONAL DATA IS TRANSFERRED

Your personal data may be transferred to the following parties for the purposes specified.

5. PROTECTING OF PERSONAL DATA 

Your privacy is important. That’s why we respect it by taking steps to ensure the security of the processing of your Personal Data and to protect it from loss,misuse, or alteration. Where appropriate, these steps can include technical measures like firewalls, intrusion detection and prevention systems, unique and complex passwords, and encryption. 

We also use organizational and physical measures such as training staff on data processing obligations, identification of data incidents and risks, restricting staff access to your personal information, and ensuring physical security including appropriately securing documents when not being used.

6. INTERNATIONAL TRANSFERS 

Your personal information may be transferred to, stored, and processed in a country other than the one in which it was collected, including Turkey. We perform such transfers, both between ELECTRIP entities and our service providers, using contractual protections that EEA and UK regulators have pre-approved to ensure your data is protected (known as standard contract clauses). ELECTRIP has also carried out the so-called “transfer impact assessment” in order to comply with the jurisprudence of the European Court of Justice. 

7. INFRASTRUCTURE OF ANALYTICS PROVIDERS

We may use third-party Web analytics services in connection with the services provided. These service providers use a variety of tracking technologies such as tags or similar technologies to, 

• Mobile application performance metrics and crash reports
• Remote configuration for software update mechanism

Third-party providers of ELECTRIP can use the means aforementioned to achieve the purposes claimed earlier. They automatically collect data such as your IP address, identifiers for mobile devices (e.g., Android Advertising Identifier or Advertising Identifier for iOS) or similar technology that are used to collect data.

This Privacy Policy does not apply to, and we do not control the tracking technologies and activities of third-party providers and consulting their respective privacy policies is appropriate. You can access detailed information regarding usage of these technologies from “How Google uses data when you use our partners' sites or apps” available on      www.google.com/policies/privacy/partners/

8. RIGHTS OF DATA SUBJECTS 

As Data Subject, you have and, at any time and at no charge, can exercise the following rights:

• to be informed on the purposes and methods of the processing of your Personal Data;
• to access your Personal Data.
• to ask for updating or rectification of the Personal Data we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
• to request erasure of your Personal Data. This enables you to ask us to delete or remove your Personal Data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing or where we are required to erase it to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request;
• to restrict the processing of your Personal Data. This enables you to ask us to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish its accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• to object to the processing, wholly or partly, of your Personal Data where we are relying on legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your Personal Data which override your rights and freedoms;
• where we are relying on consent to process your Personal Data, to revoke your consent freely and at any time, also by clicking on the unsubscribe option at the bottom of our marketing communications;
• you can withdraw your consent to the processing of your Personal Data at any time by writing to 

info-ita@Electrip.net, but this will not affect the lawfulness of the processing based on consent before its withdrawal;

• to ask us to transfer your Personal Data to you or to a third party (so-called “data portability”). We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format;
• to lodge a complaint to the Italian Data Protection Authority if you believe that your personal data have been processed in violation of the applicable legislation (for details, consult www.garanteprivacy.it).

If you wish to request more information regarding our compliance with the applicable legislation, to send questions, concerns or complaints related to this Privacy Policy or to exercise one or more of your rights pursuant to the GDPR, you may contact us via the postal address Milano 20121 via Agnello 6/1 Italy 

ELECTRIP may amend the provisions of this Privacy Policy at any time. The provisions of the Privacy Policy which ELECTRIP has amended shall enter into force on the date they are published.