Privacy Policy pursuant to art. 13 European Regulation for the protection of Personal Data 2016/679 (GDPR) on the service of Eagle Electric Transport of Shared Passengers Srl with registered office in Piazza Giovanni Bovio, 22, 80133, Naples.

This Privacy Policy ("Policy") establishes the ways in which we collect, use, store, disclose and protect Personal Data by accessing our Platform and our service. By providing your Personal Data, you accept the terms of this Notice and agree that they will be collected, used and communicated, in accordance with it.The "Eagle Etsp" Policy applies to the Data Subject as a User of the Rental Service of innovative electric powered vehicles provided by Eagle Etsp. Its purpose is to illustrate the methods, timing and purposes of processing Personal Data, the User's rights and how he can exercise them. Data Controller of Personal Data, pursuant to art. 4 point 7) of the GDPR, is Eagle Electric Transport of Shared Passengers Srl with registered office in Piazza Giovanni Bovio, 22, 80133, Naples. The Data Protection Officer is its legal representative to whom the interested party can contact by writing an email to info@eagleet.it.

Personal Data

The personal data of the interested party are collected, at the times and for the purposes specified below:

• -name and surname, at the time of his first registration, in order to be able to identify him;
• -sex, at the time of his first registration, in order to be able to identify him;
• - email address, at the time of his first registration, in order to be able to identify him, verify his order, keep it updated and send him information;
• - postal and billing address, at the time of your first registration, in order to be able to identify you and process your order;
• - contact number, at the time of his first registration and at any other time during the transaction, in order to be able to identify him;
• - payment information, at the time of your first registration and at any other time during registration, in order to complete your order;
• -data for the direct debit and related mandate of the interested party, at the time of his registration and at any other time, in order to complete his order;
• - hourly records relating to calls and vehicle pickup points (including date and time), during a call to Customer Service or when picking up and returning a vehicle, to monitor the safety of our means and to prevent unauthorized use;
• - secure access credentials if the interested party registers to access restricted areas of our platform, eg. to access your Customer Account;
• - geographical location (made anonymous), to record the position of our vehicles, for security reasons and to prevent theft;
• - geographical location, if the Data Subject uses our Platform, in order to provide additional Services such as those based on the location mentioned below.

In case of use of the Platform, we may process additional Personal Data of the interested party, subject to your consent, as specified below (see: Location-based services). In certain circumstances, we may request additional Personal Data from the interested party in order to respond in the most appropriate way to your needs relating to:

• -medical information relating to insurance claims, in order to support the interested party in the management of a claim;
• - Complaints to Judicial Authorities and related documentation;
• - photographic material sent by the User.

Failure to communicate, where required, the Personal Data by the Data Subject could result in a limitation to access to the Service or to additional services such as assistance.
When accessing the Platform through your device, other Personal Data is also automatically collected, including:

• - information about the device or software (e.g. configuration information of mobile devices, Internet browser used, third party applications or platforms used to access our platform);
• - IP addresses, browsing information (e.g. history), URL (Uniform Resource Locator) and other data relating to browsing the Web and related to the use of our Platform and / or our Service;
• - information on accesses to our Platform, i.e. when our Service is used and / or the contents are viewed. These data will be automatically collected and recorded / archived (e.g. data relating to accesses, and the so-called device event information, such as blocking and / or sudden termination);
• -information relating to access and use of other Software and Mobile Applications (so-called Mobile App);
• - information relating to the use of your User Account to access websites, Applications and / or Services of third parties.

Location Based Services

Eagle Etsp may collect, use and share precise location data, including the real-time geographical location of the vehicle rented by the User, to offer the system Services based on location using GPS, Bluetooth, the IP address of the 'User, Hotspot, Wi-Fi, Crowd-Sourced and other technologies to determine the approximate location of the User's device and the distance.

Sensitive Personal Data

We will not ask the interested party to communicate their sensitive Personal Data to us regarding: race or ethnic origin, political opinions, religion or other similar beliefs; membership of trade unions; physical or mental health; sex life or convictions. If the interested party communicates Sensitive Personal Data, Eagle Etsp will request his explicit consent so that such information is used exclusively for the purposes for which it was provided. What are the purposes and legal bases of the collection? In addition to the previous purposes, we can collect this additional information in order to make all the functions available to the interested party, in particular: to verify and process uses; for payments related to the use of the Service; to keep him updated on the activities carried out by him in relation to the Service; to answer your questions; to support him during the recovery of a lost or stolen vehicle and to provide assistance in the event of an accident or mishap. We have the possibility to do so because the interested party has registered to use our Service and therefore authorizes us to process his data to fulfill the obligations of a contract, unless otherwise specified. We may have to share the data of the interested party with local law enforcement agencies, including the police, if we are obliged to do so by law, to satisfy our legitimate interests or to protect the interests of the interested party or other subjects.

Direct Marketing and Promotions

To improve the experience of using our system, we may use the interested party's e-mail address to inform him about the development of the Platform, about special offers and promotions. With your explicit consent, we will be able to share contact data with our Partners, as well as use them for purposes of detecting the degree of consent, analysis of customer consumption habits and market surveys, also through questionnaires that can be carried out by us and / or by third parties, regarding the quality of our Service, including the publication and communication of your feedback. If the interested party no longer wishes to receive this information, he or she can unsubscribe by following the instructions described on the site or in the App. In that case, we will no longer contact him for direct marketing purposes. We may also collect and use your Personal Data to:

• - compliance with contractual obligations, terms and conditions;
• -the management of accounting aspects, risk management and data storage / archiving;
• - research, planning and statistical analysis activities;
• - to prevent, identify and investigate fraudulent or other illegal activities, or in order to reduce the risk of the aforementioned events occurring;
• -the training of our employees;
• - for any other purpose related to the above.

Generic Personal Data

The computer systems and software procedures used to operate the App (such as Apple store, Google Play) acquire, during their normal operation, some data referable to the User whose transmission is implicit in the use of internet communication protocols, smartphones and devices used. This category of data includes, by way of example but not limited to, the geographic location, the identity of the telephone, the User's contacts, email, credit card data. The User can consult the privacy information available on the following Sites: Apple http://www.Apple.com/legal/Privacy/it/ play https://www.google.it/intl/it/policies/Privacy/; Windows Store: https://Privacy.microsoft.com/it-IT/Privacystatement/

Methods of processing and retention period of Personal Data

The treatments take place in electronic format and can be canceled at any time using the functions in the App. Downloading the App is voluntary and at any time the User can uninstall it or change permissions and authorizations, so that Personal Data such as geolocation are no longer recorded, or delete documents produced such as expense reports. The collected Data will be stored on the System for the duration of the subscription and for the period of time provided for by the Applicable Regulations and / or for a reasonable period (Eagle Etsp or its third parties will rectify or delete the Personal Data of the interested party if are no longer needed).

Rights of the interested parties

The User may exercise his rights by sending an email to supporto@Eagleetsp.it to request rectification or cancellation, or may request the limitation of processing or oppose the processing. Furthermore, you will have the right to data portability and if you wish to lodge a complaint, you can also submit it to the Authority for the Protection of Personal Data. Pursuant to the EU General Data Protection Regulation of 2016, the interested party has the right to receive information and access to all Personal Data concerning him in our possession, and this right may include, by way of example, the request for modification o the elimination of your Personal Data; the withdrawal of your consent; the right to know the purposes for which your Personal Data are processed and to which recipients they can be communicated (subject to legal and regulatory requirements). If the user does not agree to submit their Personal Data to the processing described in this Notice, please do not send your data by accessing the platform or by any other means.

Right to rectify Personal Data

If the interested party informs us that their data is no longer correct, we will modify or update them by contacting our Customer Service at support@Eagleetsp.it.

Right to obtain copies of Personal Data and Right to transfer

Where permitted by law, the interested party has the right to request a copy of the personal data concerning him or her and which are being processed. Before responding to your request, we may ask the interested party to allow us to verify his identity and provide further details in order to better respond to his request. Furthermore, the interested party may request that his data be transferred to another entity by sending an email to supporto@Eagleetsp.it.

Right to withdraw consent and to delete Personal Data

The User, at any time, may cancel his registration and request the deletion of his Personal Data if he revokes his consent (if consent is applicable) and / or no longer uses the service. If we have shared your data with third parties, where possible, we will notify them of this cancellation decision.

Personal data of minors

Our Platform is not intended for individuals under the age of 18. Therefore, we will not intentionally undertake any processing of their Personal Data through these Platforms.

Third Party Websites

The presence on our Platform of links to Websites not belonging to Eagle Etsp does not imply any responsibility or approval on our part. Third party websites are governed by different conditions of use (including privacy policies) and the User is solely responsible for viewing and using each of these sites in accordance with the applicable conditions of use. Eagle Etsp disclaims any liability arising from the methods of handling Personal Information by third party websites that are excluded from this Notice.

Security of Personal Data

The personal data of the interested party (including commercial information) will be processed ensuring the highest level of confidentiality and security. Eagle Etsp implements appropriate technical and organizational measures that comply with legal obligations, as well as with consolidated industry practices. Furthermore, in compliance with the provisions of the European General Data Protection Regulation of 2016, it complies with the standard security procedures for the storage and disclosure of the Data provided by the Data Subject, in order to avoid any unauthorized access. The personal data of the interested party are treated as an asset to be protected from loss, alteration, destruction and unauthorized access. It is impossible, however, to guarantee total security, however we undertake to take the appropriate measures in case of violation.

Transfer of Personal Data to Third Parties

It is possible that there is a need to communicate your Personal Data to our affiliated companies, our affiliates, partners, the Public Administration, contractors and collaborators for the purposes indicated. Should it happen that your data are processed for purposes other than those indicated in this Notice, we will request your explicit consent before their processing. Eagle Etsp may receive and transmit information relating to the User using the platform, including his Personal Data, to its partners for various reasons. Data is generally shared with third parties in the following cases: - if it is necessary to involve an external service provider for the purpose of fulfilling our contractual obligations (for example: payment processing when the costs of the Service are charged to the User); - on the basis of legitimate commercial interests, for example in the context of the use process, computer applications can be used to provide the Service. - with a Service provider in charge of maintaining our Platform; - with analytics and search engine providers to improve and optimize our Platform. In addition, information relating to the User may be disclosed if required by law or if it is reasonably necessary to respond to any complaints and / or in the context of legal proceedings.

Sale or merger

It is possible that extraordinary or share capital operations may be carried out (e.g. mergers, acquisitions, demergers). In such circumstances, there may be a need to transfer and / or communicate your Personal Data in order to facilitate the completion of these operations. In this case, we will ensure that the acquiring company uses any Personal Data transferred in compliance with the applicable legislation and this Notice.

Cookies

A Cookie is a small text file, generally composed of letters and numbers (with an ID tag), which can be installed on the User's computer or mobile device while accessing our Platform. Cookies usually allow a website to recognize the device and browsing activities when the user visits that site again or another site that recognizes the same cookies. Different cookies perform different functions. Some facilitate navigation between pages, memorizing preferences and generally facilitating the use of the Site, while others identify the products, goods or services to which the User may be interested and transmit personalized advertising content. During the visit on our platform, session cookies are active only for the duration of the current visit while the browser is open, they are not stored on the hard disk and disappear when the browser is closed. For general information on Cookies, please refer to the Authority for the Protection of Personal Data of your jurisdiction garanteprivacy.it.

Example of a list of cookies: Google Analytics

We use this type of Cookies to understand how to use our Site in order to improve the User experience. User data are all anonymous

• Persistent cookie: [dataset]
• Session cookies: [dataset]
• Social Buttons

The "Social Buttons" allow the User to share the pages of our Site or to save them as a favorite. Social media sites such as Twitter, Google, Facebook and LinkedIn may collect information relating to the User's activity on the Internet, for example they could record visits to our Platform and to the specific pages consulted if the User has connected to the related Services, even without clicking on the button. It is recommended that you consult the Privacy and Cookies policies adopted by each of these sites to understand exactly how they use personal information and find out how to withdraw your consent or delete this information.

Manual management of cookies

The User has the ability to manually manage cookies on their computer or mobile device in various ways. For more information, consult the About Cookies website. In case of Internet access from multiple computers and / or mobile devices, it is important to ensure that each browser is configured according to your preferences on Cookies.

Do Not Track

If the User wishes to block all cookies every time, he can set his browser with the appropriate function. It is important to keep in mind that blocking cookies could compromise the proper functioning of some parts of our site, affecting the user's browsing experience.

How is consent required for the use of Cookies?

Eagle Etsp abides by the Applicable Cookie Law. On the first access to the Platform, a Pop-up will be displayed asking the User if he wishes to consent to the use of Cookies. If the User denies his consent, the Cookies will be disabled on his behalf. Furthermore, the User has the possibility to disable cookies at any time through the browser settings (for more information on how to proceed, consult the local equivalent of the tag "how to delete cookies" (on allaboutcookies.org/cookies). 'User that the deactivation of Cookies could compromise the correct functioning of some parts of our Platform, therefore we will not be able to take into account the User's actions to improve the Service.

Changes Made to the Information

In case of changes to this Notice, we will communicate the publication of the updated Notice. The notification and acceptance of the new information will result in the immediate effectiveness of the same and will replace the previous version and will also apply to previously collected data. If the user does not accept the communication of the new Information, he will have to suspend the use of the Platform and the Service. However, if you continue to access and use the platform and our Service, this behavior will be considered equal to the acceptance of the information.

Contacts and Data Protection Officer

In the event of any comments, complaints, requests or questions regarding this Notice, the rights of the Data Subject, the Platform, our advertising and promotional material or the Services provided, you can contact the Personal Data Protection Officer at Pandora Srl by sending an email to: supporto@eagleetsp.it. The data manager is the legal representative of Pandora Srl based in Via Vittoria Colonna, 14, 80121 Naples. Telephone +39 3206611345