1. Identity and contact details of the Data Controller

The Data Controller is GoVolt Srl, with registered office in Via Vincenzo Monti 15, 20123 - Milan, which can be contacted at the following address: it@govoltmobility.com

2. Contact details of the Data Protection Officer

GoVolt has designated a Data Protection Officer, who can be contacted at the following email address: dpo@govoltmobility.com.

3. Purpose of processing and legal basis of processing

a) Necessary legal and contractual purposes - processing necessary to fulfill a contractual or legal obligation to which the data controller is subject or to execute a specific request from the interested party

Your personal data may be processed, without the need for your consent, in cases where this is necessary to fulfill obligations arising from provisions of law in both civil and fiscal matters, community legislation, as well as rules, codes or procedures approved by Authorities and other competent Institutions. Furthermore, your personal data may be processed to follow up on requests from the competent administrative or judicial authority and, more generally, from public bodies in compliance with legal formalities. Your personal data will also be processed for purposes relating and/or connected to the provision of services by GoVolt, such as specifically

• For the performance of obligations arising from the General Conditions, the Regulation and/or the provision of ancillary and/or connected services to such contracts. In such cases, we inform you that pursuant to the applicable legislation on personal data, the acquisition of your consent is not required if the processing is necessary to perform obligations arising from a contract, while, during the negotiation phase, it is also not mandatory to acquire consent if the processing is necessary to fulfill - before the conclusion of the contract - your specific requests;
• For the provision of services requested by the customer by registering on the website and/or App and creating their own account and profile, including the collection, storage and processing of data for the purposes of establishing and subsequently managing the operational, technical and administrative relationship (and the account and profile created by the customer) connected to the provision of services and the sending of communications relating to the performance of the services;
• For the management of payments (with related processing - in accordance with the law - of payment data, including the identification details of credit cards or prepaid cards) of the requested services and any additional economic charges, in accordance with the provisions of the General Conditions and/or other specific contractual conditions published on the website or otherwise made available to the customer; or fulfillment of legal, accounting, fiscal, administrative and contractual obligations connected to the provision of the requested services;
• For the management of relationships with third-party public authorities and bodies for purposes connected to specific requests, the fulfillment of legal obligations or specific procedures (e.g. re-notification to the actual offender of reports of violations of the Highway Code);
• For the preparation of measures aimed at protecting against credit risk, including activities aimed at identifying the customer and his economic reliability/solvency, even during the contractual relationship. Such data - the provision of which is necessary for the operational, economic and administrative execution of the service - will also be processed with electronic tools, recorded in specific databases, and used strictly and exclusively within the scope of the existing contractual relationship.

Since the communication of your data for the aforementioned purposes is necessary for the maintenance and provision of all services connected to the contract, failure to communicate will make it impossible to provide the specific services in question.

b) Commercial, marketing and profiling purposes - consent (optional and revocable at any time)

Your personal data may also be processed, subject to your consent, for the following additional purposes functional to the activity of the Data Controller or a third party:

• Marketing by the Data Controller: sending promotional and commercial communications relating to services/products offered by the Data Controller or for participation in initiatives and offers; These activities may concern products and services of the Data Controller, as well as of companies controlled by GoVolt or its commercial partners and may also be carried out through an automated calling system, without the intervention of an operator, including electronic mail, and MMS (Multimedia Message Service) and SMS (Short Message Service) type messages.
• Profiled marketing by the Data Controller: analysis of your preferences, habits, behaviors and interests, inferred for example from your use of our services, in order to send you personalized commercial communications/carry out targeted promotional actions in your favor. The processing of your personal data for profiling purposes will take place, in the event of consent, with data processing tools that, following cross-referencing, will create a commercial and behavioral profile of you. Furthermore, such data and/or information will be associated with any and/or additional data and/or information already in our possession following your subscription to our services. Such activities may concern products and services of the Data Controller, as well as of companies controlled by GoVolt and may also be performed through an automated call system, without the intervention of an operator, including electronic mail, and MMS (Multimedia Message Service) and SMS (Short Message Service) type messages.

Consent to the processing of data and communication to the subjects indicated below for the aforementioned purposes is optional and may be directly revoked by the customer by entering his personal area.

c) Defense of a right in court

In addition, your personal data will be processed whenever necessary to ascertain, exercise or defend a right of the Owner or other companies within the GoVolt control perimeter in court.

d) Legitimate interest of the Data Controller

The Data Controller may process, without your consent, your personal data in the following cases:

• In the case of extraordinary merger, sale or transfer of a branch of business, in order to allow the implementation of the operations necessary for the due diligence activity and preliminary to the sale. It is understood that the data that are exclusively necessary will be processed for the aforementioned purposes, in the most aggregated/anonymous form possible.
• Analysis of the use of scooter sharing services used, to identify habits and propensities to consume, to improve the services provided and to satisfy specific customer needs, or preparation of initiatives connected to the contractual relationship and aimed at improving the services provided, such as the possible carrying out of surveys to obtain suggestions from customers;
• Provision of a geolocation system for company vehicles/assets and any possible measures to protect them against any acts carried out by customers/users that are illicit or fraudulent
• Market research, economic and statistical analysis (in this case personal data will be processed anonymously and in aggregate form);

4. Recipients of personal data

In order to pursue the purposes indicated in point 3, the Data Controller may communicate your personal data to third parties, such as, for example, those belonging to the following subjects or categories of subjects:

• Police forces, armed forces and other public administrations, for the fulfillment of obligations established by law, regulations or community legislation. In such cases, based on the applicable legislation on data protection, the obligation to acquire the prior consent of the interested party to such communications is excluded;
• Companies, entities or associations, or GoVolt controlling, controlled or associated pursuant to Article 2359 of the Civil Code, or between these and GoVolt subject to joint control, as well as between consortia, business networks and groupings and temporary associations of companies and with the subjects adhering to them, limited to communications made for administrative and/or accounting purposes;
• Insurance companies responsible for settling claims;
• Companies specialized in debt collection;
• Companies specialized in the management of commercial or credit information, or advertising promotion;
• Other companies that carry out the activity of scooter sharing of vehicles and/or ancillary services with which the Owner has agreements of various types;
• Other companies contractually linked to the Data Controller that carry out claims management activities. The Data Controller guarantees the utmost care so that the communication of your personal data to the aforementioned recipients concerns only the data necessary to achieve the specific purposes for which they are intended. Your personal data is stored in the Data Controller's databases and will be processed exclusively by authorized personnel. The latter will be provided with specific instructions on the methods and purposes of the processing. Furthermore, such data will not be communicated to third parties, except as provided for above and, in any case, within the limits indicated therein. Finally, we remind you that your personal data will not be disclosed, except in the cases described above and/or provided for by law.

5. Transfer of personal data outside the EU

In the context of the contractual relationships between GoVolt and its subsidiaries, as well as between the subsidiaries themselves, for some of the purposes indicated in point 3, your personal data may be transferred outside the EU, including by being included in databases shared and managed by third-party companies that may or may not be part of the GoVolt control perimeter. The management of the database and the processing of such data are bound to the purposes for which they were collected and are carried out in full compliance with the confidentiality and security standards set out in the applicable personal data protection laws. Whenever your personal data is subject to international transfer outside the territory of the EU, the Data Controller will adopt all appropriate and necessary contractual measures to guarantee an adequate level of protection of your personal data in accordance with what is indicated in this information on the processing of personal data, including, among others, the Standard Contractual Clauses approved by the European Commission.

6. Data retention period

The data will be retained for a period of time not exceeding that necessary for the purposes for which they were collected or subsequently processed in accordance with the provisions of the law. Your data will be retained for ten years from the end of the existing contractual relationship, in order to allow GoVolt to defend itself from possible claims made in relation to the contract itself. At the end of this period, they will be deleted or otherwise irreversibly de-identified, unless further retention of some or all of the data is required by law.

7. Rights of interested parties

7.1 As an interested party, you are granted the following rights regarding the personal data collected and processed by the Data Controller for the purposes indicated in point 3.

a) Right of access

You have the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: (i) the purposes of the processing; (ii) the categories of personal data concerned; (iii) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (iv) where possible, the envisaged period for which the personal data will be stored, or, if that is not possible, the criteria used to determine that period; (v) the right to lodge a complaint with a supervisory authority.

b) Right of rectification and erasure

You have the right to obtain the rectification of inaccurate personal data concerning you and, taking into account the purposes of the processing, the right to obtain the integration of incomplete personal data, including by providing an additional statement. You also have the right to obtain the erasure of personal data concerning you if one of the following grounds applies: (i) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; (ii) the data are unlawfully processed; (iii) you have withdrawn the consent on the basis of which the Data Controller had the right to process your data and there is no other legal basis that allows the Data Controller to carry out the processing; (iv) you have objected to the processing and there is no overriding legitimate reason; (v) the personal data must be erased for compliance with a legal obligation.

However, GoVolt has the right to disregard the exercise of the aforementioned rights of cancellation if the right to freedom of expression and information prevails or for the exercise of a legal obligation or to defend its own right in court.

You are also granted the following rights:

a) Right to data portability

You have the right to receive in a structured, commonly used and machine-readable format your personal data provided to GoVolt and processed by it on the basis of consent or another legal basis, as well as the right to transmit such data to another Data Controller without hindrance.

b) Right to restriction of processing

You have the right to obtain from GoVolt the limitation of processing when one of the following hypotheses occurs: (i) for the period necessary for the Data Controller to verify the accuracy of such personal data concerning you whose accuracy you have contested; (ii) in the event of unlawful processing of your personal data; (iii) even if your personal data are not necessary for the purposes of the processing, in any case it is necessary for them to be processed for the ascertainment, exercise or defense of a right in court; (iv) for the period necessary to verify whether the legitimate reasons of the Data Controller prevail over your request to object to processing. You can exercise the rights listed above by sending an email to the certified email address govolt@pec.it, or by writing to the data protection officer dpo@govoltmobility.com. You are also guaranteed the right to contact the competent data protection authority in the event of unlawful processing of your data.

8. Social Network

GoVolt may be present on social networks. The processing of data of people who become followers on social networks (and/or perform any connection or linking action through social networks) of GoVolt's official pages will be governed by this section, as well as by the conditions of use, privacy policies and access rules that belong to the social network in question and that are previously accepted by the Client. GoVolt will process the data in order to correctly manage the presence of its users on the social network, informing them of GoVolt's activities, products or services, as well as for any other purpose permitted by the regulations of the Social Networks. It is prohibited to publish content: (i) that is presumably illegal according to national, community or international legislation or that carries out activities that are presumably illegal or in conflict with the principles of good faith; (ii) that threaten the fundamental rights of people, lack of courtesy on the network, annoy or may generate negative opinions in our Clients or third parties and in general any content that GoVolt deems inappropriate; (iii) that contravene the principles of legality, honesty, responsibility, protection of human dignity, protection of minors, protection of public order, protection of privacy, protection of consumers and intellectual and industrial property rights. Likewise, GoVolt reserves the right to remove, without prior notice, from the website or the company's social networks those contents that are considered inappropriate.

9. Consent to processing and obligation to communicate data

For the processing of the optional data listed above, GoVolt asks for your consent to the processing exclusively for the purposes respectively indicated at the time of registration to GoVolt. In the absence of your explicit consent to the processing of optional data currently in possession of GoVolt and which may be acquired by the same in the future, GoVolt informs you that the benefits and/or effects connected to the processing of the data themselves may be precluded for you, without this having any effect on the existing contractual relationship and on the services provided by GoVolt. When requesting your personal data, GoVolt will specifically indicate the mandatory or optional nature of the provision of the new data requested. The expression of a more specific consent to the Owner in relation to a particular service does not automatically modify any further consents previously given regarding other services on the basis of a different contract.

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