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Titolare del Trattamento dei Dati
TOGO MOBILITY SRL, VIA FRANCESCO SELMI 36/38 MODENA, P. IVA 03904160367
Indirizzo email del Titolare: firstname.lastname@example.org
- Togo mobile applications (each an “App”)
- Togo vehicles (each a “Vehicle”)
- the features and services available through our Sites, Apps and Vehicles
- The Information We Collect
- Use and Processing of Information
- Disclosure of Your Information
- Online Advertising
- How We Protect Your Information
- Retention of Your Information
- International Users
- Third Party Links and Services
- Your Choices
- Access and Data Subject Rights
- Contact Information
THE INFORMATION WE COLLECT
We collect information (i) directly from users related to our Services and Interactions; (ii) automatically related to the user’s use the Services and Interactions; and (iii) from third parties. We may combine the information we collect from these various sources.
Information You Provide to Us.
We collect information directly from users related to:
- Account registration, management, profile creation and modification
- Account access and use, as well as uploading content to the Services and other associated activities
- Vehicle use
- Access to and use of the Sites and Apps
- Submission of payment information
- Event registration and attendance
- Participation in surveys, contests, sweepstakes and promotions sponsored by Togo
- Signing up to receive alerts or other information via email, text or instant messages from Togo
- Customer service technical support and related communications
- Participation in communities, commenting on blog entries, interacting with use on social media, and participation in other forums
- Submission of an application or resume to work at Togo
The specific types of information we collect directly from you consist of:
- your name
- e-mail address
- phone number
- postal address
- other contact information
- credit card and billing details, including:
- billing address
- communications preferences
- payment and transaction history
- where required your birthdate and driver’s license information or another identification card
- any other information you submit to the Services or otherwise provide to us.
We also collect certain demographic data if you provide it to us including age, gender, preferred language and current location.
Automatically Collected Information.
We also collect information through automated and technical means as you browse our Sites, use our Apps, or otherwise use the Services, including:
- Location Info and Vehicle Usage. We automatically collect and store location information from your Device and from any Vehicles you use. We collect and store the location information (e.g., city, state or zip code where available) associated with the IP address of the Device you use to access the Services, as well as, with your permission, your mobile device’s location information. Please note that you can change your location settings for your mobile device, but if you choose to do so, certain features may not be available through the App. We also collect precise GPS location information regarding the location of the Vehicle you use, the routes taken by the Vehicle, the rental status of the Vehicles, the Vehicle battery status and GPS chip identifiers and status. We also automatically collect data regarding the date, time and length of the Vehicle usage.
- Analytics. We compile and analyze information derived from the use of our Services, including, but not limited to, aggregate usage patterns, user preferences, peak demand times and common routes.
Information We Collect From Third Party Sources.
In some cases, we collect user information from third parties.
- Third Party Platforms and Social Media Sites. When you interact with us or post content about us on third-party social media platforms (e.g. Facebook, Twitter, Google, Tumblr, LinkedIn, YouTube or Pinterest) we may collect certain information about such interaction. The information that we may collect from third parties is based on your settings and on the policies of the particular social media platforms. We may also allow you to post certain information from such platforms to your Togo profile. Additionally, we may permit you to login to the Services using your personal third-party social media platform accounts. In such instances, you will be asked to consent to our access and collection of certain information from your third-party social media platform account, and such access will be subject to the platform’s policies.
- Other Third-Party Sources. We also may collect information about you that we may receive from business partners, marketers, analysts, and other sources in order to enable us to verify and update the information contained in our records and to better customize the Services to you. Additionally, we may collect information from credit reporting agencies to determine your creditworthiness, credit score, and credit usage. Our collection of such information will always be in compliance with, and solely to the extent permitted by, applicable laws.
- Referrals. We may from time to time conduct a referral service, in accordance with applicable laws, so that you may introduce people you know to our Services. If you choose to use our referral service to tell someone about our Services, we will provide you with a template message and referral code to send to such person. We will only collect such person’s information if he/she signs up to use the Services with the referral code.
DISCLOSURE OF YOUR INFORMATION
We may disclose the information we collect, to the following parties and in the following ways:
- Business Partners and Third Parties. We may share your information with business partners who jointly sponsor events with us, and where required by applicable law, we will obtain your consent prior to doing so. You may withdraw your consent to do so at any time or request that we stop sharing your information (as defined under applicable law) with business partners and third parties by following the opt-out process detailed in the “Your Choices” section below.
- Third-Party Service Providers. We may share your information with our third party service providers that perform functions on our behalf. We may use third party service providers, from time to time, to provide the following non-exhaustive list of services: hosting, billing and payment processing, push notifications, storage, bandwidth, content management tools, analytics, customer service and fraud protection.
- General Business Operations. Where necessary to the administration of our general business, we may share your information with professionals and their agents that we may retain to perform the following non-exhaustive list of functions: accounting, record keeping, legal services, tax services, and other professional services entities or agents.
- Legal Compliance and Protection of Rights. We may also use or disclose your information if required to do so by law or if we believe, in good-faith, that such action is necessary to (i) conform to applicable law or comply with legal process served on us or the Services; (ii) establish, protect and defend our rights or property, the Services or our users, including, but not limited to, the investigation, the prevention or the taking of action related in any manner to illegal activities, suspected fraud, any potential threats to the safety of any person, violations of our Terms of Service, Rental Agreement, Waiver of Liability, and Release, any other agreements or policies, or in relation to any litigation involving us or the Services; and (c) act under emergency circumstances to protect the personal safety of us, our affiliates, agents or users of the Services or the public. We may also provide information to other companies and organizations regarding fraud protection.
- Other Users. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential and may be accessed by other persons. For example, (i) if you submit a product review one our Sites, we may display your review (along with the name provided, if any) on other Togo or third-party websites; (ii) if you provide a comment on our blog, other blog readers will be able to review your comments; or (iii) if you interact with us on our social media pages, your comments will be publicly available. Therefore, you should take care when using these features. If you want to request removal of information that we have posted about you, please contact us as set forth in the below “Your Choices” section.
- Aggregate/Anonymous Information. We may share aggregated/anonymous information about use of the Services with third parties for research, marketing, analytics and other purposes, provided such information does not identify a particular individual (e.g. such as publishing a report on usage trends). The sharing of such data in this manner is unrestricted.
- Business Transfers. As we continue to develop our business, we may seek to buy, merge or partner with other companies, and user information may be either shared or transferred with respect to the contemplation or completion of such transactions. If we sell or transfer all or a portion of our assets to a third party, customer information would likely constitute one of the transferred business assets. We will comply with any additional restrictions to the extent required to do so under any under applicable laws or regulations.
To request more information about the companies to whom we have disclosed your information, please contact us as set out in the “Contact Information” section.
As with most websites, apps and online services, our Sites, Apps and online Services, use “cookies,” web beacons (a/k/a pixel tags), analytics devices and similar technologies (some of which are operated by third parties) to record your preferences, gather information about the use of our Services, personalize content and ads and track information about the performance of our advertisements. We may also use these technologies to monitor on-line traffic, and make the Services easier and/or more relevant for your use. We may also combine this information with other information we collect from you.
- Cookies. These are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes and associate with small text files that we use to record certain information regarding (i) your use of our online Services; (ii) your preferences and actions; and (iii) your other device and usage data as described above. Some cookies allow us to make it easier for you to navigate our Services, including Sits and Apps, while others are used to (i) enable a faster log-in process; (ii) personalize your use of the Services; or (iii) otherwise allow us to track your activities while using our Services. Many web browsers automatically accept cookies, but you can usually modify your browser’s setting to decline or block cookies. If you delete your cookies or if you set your browser or device to decline or block cookies, some features of the Services may not work properly or at all.
- Pixel tags (a/k/a web beacons or clear GIFs). Pixel tags are tiny graphics with a unique identifier, similar in function to cookies, which are embedded invisibly on web pages or within emails. We or our service providers may use pixel tags in connection with our Services to, among other things, track the activities of users of the Site and App; help manage content; measure ad performance; and compile statistics about usage. We or our service providers also use pixel tags in HTML emails to our customers to help us track email response rates; identify when our emails are viewed; and track whether our emails are forwarded.
Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings. For more information about how to change these settings for Apple, Android or Windows devices, see:
Please note that opting-out of advertising network services does not mean that you will not receive advertising while using our Services or other services, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs.
HOW WE PROTECT YOUR INFORMATION
We take technical, physical and organizational security measures to protect your information against (i) accidental or unlawful destruction, loss or alteration; and (ii) unauthorized disclosure or access. However, no (i) method of transmission over the Internet; and (ii) no means of electronic or physical storage, are absolutely secure. You should take steps to protect your information and prevent unauthorized access to your password or account, such as (i) signing off after using a shared computer; (ii)choosing a robust, unique password; and (iii) keeping your log-in and password private. We are not responsible for any lost, stolen or compromised passwords, or for any activity on your account via unauthorized password activity.
RETENTION OF YOUR INFORMATION
We only retain your information for the period of time required to satisfy the purpose for which it is collected and used (e.g. for the time necessary for us to provide you with customer service, answer queries or resolve technical problems); provided, however, we may retain your information for a longer period of time if we are legally obligated to do so, or if necessary to establish, protect or defend legal claims involving Togo.
THIRD PARTY LINKS AND SERVICES
If you would like to update your preferences on the types of communications you receive from us, or opt out of marketing communications from us, you may do so at any time by updating the communication preferences in your account profile or by emailing us at email@example.com. Please note that we may continue to send non-promotional communications such as important notices, payment confirmations and transaction-related emails and other information about your use of the Services. If you would like to opt-out of (i) marketing communications; or (ii) being included in any Custom Audience campaigns please see the above “Online Advertising” section for more information.
ACCESS AND DATA SUBJECT RIGHTS
Subject to applicable law and as explained herein, you may have certain rights with respect to the information we collect and process about you.
Access, Correction, Deletion and Objection Rights. You may have the right to access, request correction and deletion of, and object to our use of, your information. To exercise such rights, please contact us as set forth in the “Contact Information” section. You may also access and modify most of the information that you have submitted by logging into your account and updating your profile. Please note that prior versions of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site or Apps for a period of time. In addition, we may retain certain information about you as required by law, or as permitted by law for legitimate business purposes (e.g., if you request that we delete your information but we believe that you have violated our Terms of Service, we may retain such information in order to attempt to resolve such issue before deleting it).
Complaints. If applicable, you may make a complaint to the privacy regulator or supervisory authority. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.