PRIVACY NOTICE ON THE PROCESSING OF PERSONAL DATA
Introduction
Powandgo's mission is to revolutionize the electric mobility sector by offering an innovative and accessible platform for sharing charging points. We are committed to facilitating the adoption of electric vehicles through an extensive network of private charging stations, making the process more convenient, efficient, and sustainable. We aim to build a future where every electric vehicle owner can easily find a charging point, wherever they are, reducing range anxiety and promoting a greener lifestyle. Working with companies, public entities, and communities, Powandgo aspires to be at the center of an electric mobility ecosystem that values renewable energies, supports the ecological transition, and actively contributes to the fight against climate change. Our vision is of an interconnected society where the sharing of energy resources becomes the norm, paving the way towards a clean and sustainable energy future for everyone. This Privacy Policy is applicable to www.powandgo.com , Powandgo apps, and other sites, applications, communications, and services related to Pow and Go available on our website, mobile devices, PCs, or other platforms. By downloading, accessing, and registering to the application, the user agrees that their data will be collected and used in accordance with this notice. If in doubt about providing data or allowing its use as specified in this privacy notice, the user should refrain from using the application or contact the data controller for further information regarding personal data processing.
Data Controller
POWANDGO SRL
Via Orzinuovi n. 20 - 25125 Brescia
VAT no. 04466220987
Email address of the Data Controller: privacy@powandgo.com
1. Data Source
Except for navigation data, which is governed by the cookie policy, the personal data collected are voluntarily and directly provided by the user through the use of the Application.
2. Data Recipients
This Notice applies to Users of the App. In the following text, these subjects are referred to as "data subjects" involved in personal data processing.
3. Categories of Data Processed, Purposes of Processing, and Nature of Data Provision
Personal data may be freely provided by the User, or in the case of Usage Data, collected automatically during the use of this Application. The data voluntarily provided by the user for utilizing the Application's features (such as registration, management of contracted products/services) include personal details, contact information, data related to the use of services/products managed via the Application, including consumption data, user geolocation, geolocation of charging points, billing fiscal data, credit card and IBAN details, model and license plate of the transportation vehicle, and a photograph of the identity document. The data controller processes data concerning activities connected to the use of the application and the information provided by the data subject, such as: created content, content provided through our camera functions or photo settings or voice functions, sent and received messages and their contents, metadata about contents and messages, in compliance with applicable laws, types of contents viewed and their interaction modes, purchases or other transactions made, including credit card information, and time, frequency, and duration of activities on our application. We collect information about groups, accounts, other users, and communities with which the data subject interacts or is connected. This includes how they interact with these elements, and we also collect contact information, such as names and email addresses or phone numbers, if the data subject chooses to upload or import them from a device (e.g., by syncing a contact list). Among the Personal Data collected by this Application, either independently or through third parties, are :
• Contacts Permission;
• Camera Permission;
• Approximate Location Permission (continuous);
• Microphone Permission;
Stored information on the device.
Access to some data and information present on the User's device is necessary to utilize the app and the functionalities it offers. Specifically, the app can access the camera and images on the device to allow the User to post photos alongside their profile or within the community and the microphone to enable the user to share audio messages. Such information is used only to the extent necessary to allow the User to utilize the specified functionalities. The decision to allow or deny access to such data can be changed at any time by the User directly from their device.
• Social Media Account Permission;
• Navigation Data: data provided through the use of the Application, processed to enable the correct functioning of the Application itself. In this regard, we invite you to read the Cookie Policy available on the Application, which governs this type of data;
• Usage Data;
• Email;
• Password;
• Unique device identifiers for advertising (such as Google Advertiser ID or IDFA, for example).
Common Personal Data.
When submitting an invitation request (necessary to obtain the access code for registration), the User's identifying and contact data are acquired. During registration, the User confirms and supplements the identifying personal data acquired, deciding to include an image of themselves to be used as a profile photo. Users who use the app, taking advantage of the sharing functionalities offered, can also decide to provide additional common personal data by publishing it within dedicated areas.
Data processing is carried out to:
• Enable registration and account creation;;
• Utilize the functionalities offered by the app;
• Fulfill obligations arising from the relationship with the registered user. The legal basis is the execution of pre-contractual measures and the contractual relationship;
Unless specified otherwise, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. Where this Application indicates some Data as optional, Users are free not to communicate such Data, without any consequences on the availability of the Service or its operation. Users who are unsure about which Data are mandatory are encouraged to contact the Data Controller. The use of Cookies - or other tracking tools - by this Application or the owners of third party services used by this Application, unless otherwise specified, serves to provide the Service requested by the User, in addition to 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 this Application and guarantees that they have the right to communicate or distribute them, releasing the Data Controller from any liability to third parties.
4. Purposes, Legal Basis for Processing, and Data Retention Period
a. Personal data voluntarily provided by the user will be processed for the purpose of: (i) enabling registration and subsequent recognition of the user during the login phase; (ii) providing the user with the requested services and allowing them to manage the products/services utilized by POWANDGO SRL; If the registration is completed successfully, profile data are retained as long as the user maintains an active account within the app (with the sole exception of the photo if uploaded, which can be deleted at any time by the User). Any images or data published by the User taking advantage of the sharing features offered will be maintained until there is a request for deletion by the User. This is without prejudice to any defensive needs and regulatory obligations, for which data may be retained beyond the terms indicated. b. Purposes related to specific services: Data voluntarily provided by the user in the context of filling out forms and services for re-contact and interactive chats are processed solely to provide the user with the explicitly requested service
Examples of Data for Which Consent is Not Required:
1 - Execution of a Contract
Our systems automatically process information about you and others that we collect and store to create and maintain your account and profile; facilitate content sharing; provide and manage functionalities; and deliver content sharing services. We use the information available to us to develop, analyze, and test improvements to our application, verify accounts and activities; identify and resolve violations of our terms or regulations, investigate suspicious activities; detect, prevent, and counteract dangerous or illegal behaviors (e.g., monitoring and, in some cases, removing content that has been reported to us); detect and stop threats to our employees and properties.
Communications with You:
We use the information you have provided regarding product issues, research, or information about our terms and policies. We also use contact information, such as your email address, to provide a response when you contact us.
Categories of Information We Use
• Reviews and Comments:
The reviews and comments you view or interact with, and their modes of interaction, purchases or other transactions you make, the timing, frequency, and duration of your activities, friends.
• Information on Apps, Browsers, and Devices:
Features and software of devices.
• Activities Performed on the Device:
For example, whether our app is running in the background or if there are mouse movements.
• Identifiers:
Identifiers that distinguish your device from those of other users, device signals.
• Shared Information via Device Settings:
Such as GPS location.
• Network Information:
Information about the network to which the device is connected.
• Performance Reports:
Reports on the performance of our products on your device.
• Cookie and Similar Technologies:
Information from cookies and similar technologies.
2 - Legitimate Interests
• Providing Advertising Products:
Creating statistical data, in addition to providing personalized experiences, offering suggestions, making corrections, and analyzing and improving our application.
• In Our Interest:
To deliver accurate and reliable reports to our advertisers, developers, and other partners, ensuring precise pricing and performance statistics. This is to provide seamless, consistent, more engaging, and innovative experiences in communication, interaction, and sharing.
Categories of Information We Use
• Reviews and Comments
that you view or with which you interact, and their modes of interaction, apps and functions you use, and actions taken within them, purchases or other transactions you make, time, frequency, and duration of your activities on our products.
• Device Features and Software
activities you perform on the device, such as if our app is running in the background or if there are mouse movements, identifiers that distinguish your device from those of other users.
• Device Signals
information you have shared through your device settings, information about the network to which the device is connected, including your IP address, information from cookies and similar technologies
3 - Legal Obligation
Processing of information imposed by law or public authorities, processes necessary to comply with requests from law enforcement; consumer matters: to fulfill obligations as required by corporate and tax laws or industry-specific regulations.
Categories of Information We Use
The categories of information vary according to the specific circumstances of each legal obligation or request. Only the information necessary to fulfill the relevant legal obligations will be processed.
With the specific consent of the USER, the USER's data may also be used for the following purposes:
c. Additional Purposes: promotional, commercial, and marketing:
1. Sending/communication by POWANDGO SRL of advertising material, information, and promotions about new products/services of POWANDGO SRL and/or other third-party companies;
2. Direct selling and/or placement by POWANDGO of products/services, offers, and promotions of POWANDGO itself and/or other third-party companies via different sales channels or third-party companies engaged;
3. Assessing the level of satisfaction with the quality of the product/service provided, conducting studies, and statistical and market research.
d. Additional Purposes: communication of data to third parties:
4. The CLIENT's data may be communicated to third-party companies that operate in the field of marketing, mass distribution, telecommunications, television entertainment, financial institutions, insurance institutions, automotive manufacturers, or companies that produce and sponsor innovative products related to the world of INNOVATIVE STARTUPS/SOCIAL MEDIA. These third parties, acting as independent data controllers, may in turn use the CLIENT's data for the same purposes as mentioned in the previous letter
5. Related to the promotion, marketing, and direct selling of their goods and/or services both by electronic means (such as SMS, instant messaging, email, etc.) and traditional methods (such as mail, telephone, fax, and/or invoice attachment).
e. Profiling Purposes:
Activities focused on studying and analyzing habits and consumption patterns aim to enhance the commercial offerings and carry out targeted promotions of products and/or services. Such marketing efforts are specifically tied to the results of these studies and analyses. Only if you have consented to the processing for the purposes stated in the previous section will your data be utilized for targeted marketing activities. These include sending communications about advertising, informational, and promotional materials regarding new products/services by POWANDGO, related to the mentioned study and its findings, offering deals and information potentially of greater interest to you. If you have consented solely for processing as described currently, your data will only be used for creating case studies, behavioral models, and analyses of your consumption habits and preferences, strictly for internal use at POWANDGO.
Consent for Data Processing:
Consenting to the processing of personal data for the purposes outlined in point 4, letters C), D), and E) is voluntary, and refusal does not impact the delivery of the requested products/services. The CLIENT can object to such processing at any time either by clicking "DENY CONSENT " or by simply contacting POWANDGO.
Period of Data Use for Specific Purposes:
Data collected for the purpose described in letter C) will be retained for no longer than 24 months from obtaining valid, current, and renewed consent, unless earlier revoked by the individual. Similarly, your data gathered for the purposes stated in previous point 4, letter D), will be handled for the same duration. For the objectives set out in letter E), your data will be processed for no more than 12 months from receiving valid, current, and renewed consent, unless earlier revoked.
| Consent | Categories of Information We Use |
|---|---|
| Collection of information that allows us to receive, evaluate, and understand your interests and preferences for purposes such as profiling, marketing, third-party marketing, and offering advertising products. This includes information provided through activated device settings (e.g., access to GPS location, camera, or photos), which we use to deliver the features or services described when you enable these settings, including special categories of data (formerly known as sensitive data). | • Special categories of information subject to special protection that you choose to provide in profile fields (e.g., religious orientation, political orientation, or individuals of interest) or within surveys you opt to participate in, and in cases where you have provided explicit consent, • Content you create (e.g., your contacts and your profile) or other information such as posts or comments, • Information from device settings. |
5. Data Processing Methods
The processing of collected personal data is carried out by authorized personnel using computerized systems that ensure adequate security measures to prevent data loss, unlawful or incorrect use, and unauthorized access.
The processing is performed using automated tools (e.g., using electronic procedures and supports) and/or manually (e.g., on paper) for the time strictly necessary to achieve the purposes for which the data has been collected. In any case, specific security measures are adopted to prevent any breach of personal data, such as data loss, unlawful or incorrect use, and unauthorized access.
However, these measures, due to the nature of the online transmission medium, cannot limit or completely exclude any risk of unauthorized access or dispersion of data. To this end, it is advisable to periodically verify that the computer is equipped with adequate software devices for the protection of data transmission over the network, both incoming and outgoing (such as updated antivirus systems), and that the Internet service provider has taken appropriate measures for the security of data transmission over the network (such as firewalls and anti-spam filters
6. Categories of Data Recipients
The acquired data will be processed by personnel of the organization who are authorized to handle the data and are adequately trained.
The data may be accessed by competent authorities in the event of specific requests that the data controller is legally obliged to comply with, by companies providing computer supply and support services on the app and the systems used to offer the services provided, and by consultants for managing litigation and for legal assistance in case of disputes where their involvement becomes necessary.
It is specified that some of the parties mentioned act as data processors, and the communication to those who operate as independent data controllers is made because it is prescribed by legal obligations or necessary to fulfill the obligations deriving from the contractual relationship or the legitimate interest of the data controller.
The data subject may request from the Data Controller a list of external parties who act as data processors.
However, communication is limited only to those categories of data whose transmission is necessary for carrying out the activities and purposes pursued.
The name, surname, and, if uploaded, the profile photo, will be known to other app users connected to the same host of the organization for which the registration was made.
In the case of a "public" profile publication, the data will be known to all registered Users connected to the Host.
In the case of publication with a non-"public" profile, the data will be known according to the visibility preferences and settings selected.
7. International Transfer
The personal data collected by POWAND GO SRL will primarily be processed in Italy and within the European Union. However, some processing activities may take place in countries outside the EU, ensuring the necessary standards of security, protection, and data safeguarding as required by national and supranational legislation, such as the adoption of Standard Contractual Clauses approved by the European Commission. To know the geographical location of the data, it is possible to contact the Data Controller at the addresses indicated in the previous point.
8. Dissemination of Data
The personal data of the Data Subject will not be disseminated in any way without their specific authorization.
9. Exercise of Rights
Finally, we remind you that pursuant to Regulation 2016/679 (GDPR), the Data Subject has the right to access their data, in particular to obtain confirmation at any time whether their data exists and to know its content, origin, geographic location, and to request a copy. They also have the right to verify the accuracy of the data or request its integration, update, correction, limitation of processing, deletion, anonymization, or blocking of data processed in violation of the law, as well as to oppose their processing in any case. The Data Subject may exercise their rights free of charge by writing to the attention of the data controller at the addresses listed in the heading. The data controller reserves the right to verify the authenticity of the request and will respond within the terms provided by law.
Last Update: 19th of April 2024