Privacy Policy pursuant to Article 13 of the European General Data Protection Regulation (GDPR) 2016/679 (GDPR) for the service of Eagle Electric Transport of Shared Passengers Srl, with registered office at Piazza Giovanni Bovio, 22, 80133, Naples.

This Privacy Policy ("Policy") sets forth how we collect, use, store, disclose, and protect Personal Data through access to our Platform and our service. By providing your Personal Data, you accept the terms of this Policy and consent to its collection, use, and disclosure in accordance with it. The "Eagle Etsp" Policy applies to the Data Subject as a User of the Rental Service of innovative electric vehicles provided by Eagle Etsp. Its purpose is to illustrate the methods, timing, and purposes of processing of Personal Data, as well as the User's rights and how they can exercise them. The Data Controller, pursuant to Article 4, point 7) of the GDPR, is Eagle Electric Transport of Shared Passengers Srl, with registered office at Piazza Giovanni Bovio, 22, 80133, Naples. The Data Protection Officer is its legal representative, whom the data subject may contact by emailing [email protected].

Personal Data

The data subject's personal data is collected at the times and for the purposes specified below:
- first and last name, upon initial registration, for identification purposes;
- gender, upon initial registration, for identification purposes;
- email address, upon initial registration, for identification purposes, to verify your order, keep you updated, and send you information;
- mailing and billing address, upon initial registration, for identification purposes and to process your order;
- contact number, upon initial registration and at any other time during the transaction, for identification purposes;
- payment information, upon initial registration and at any other time during the registration period, for the purpose of completing your order;
- direct debit data and the Data Subject's related mandate, upon registration and at any other time, for the purpose of completing your order;
- timestamps of calls and vehicle pickup locations (including date and time) during a Customer Service call or when picking up and returning a vehicle, to monitor the security of our vehicles and prevent unauthorized use;
- secure login credentials if the Data Subject registers to access restricted areas of our Platform, e.g., to access their Customer Account;
- geolocation (anonymized), to record the location of our vehicles for security purposes and to prevent theft;
- geolocation, if the Data Subject uses our Platform, to provide additional Services such as the location-based Services mentioned below.
 

If you use the Platform, we may process additional Personal Data about you, subject to your consent, as specified below (see: Location-Based Services). In certain circumstances, we may request additional Personal Data from you to best meet your needs regarding:

- medical information related to insurance claims, in order to support you in managing a claim;
- complaints to judicial authorities and related documentation;
- photographic material sent by you.
Failure by you to provide Personal Data, where requested, may result in limited access to the Service or additional services such as support.
When you access the Platform using your device, other Personal Data is also automatically collected, including:

- information about your device or software (e.g., mobile device configuration information, Internet browser used, third-party applications or platforms used to access our Platform);
- IP addresses, browsing information (e.g., history), URLs (Uniform Resource Locators), and other web browsing data related to the use of our Platform and/or our Service;
- information about access to our Platform, i.e., when our Service is used and/or content is viewed. This data will be automatically collected and recorded/stored (e.g., access data and device event information, such as blocking and/or unexpected termination);
- information related to access and use of other software and mobile applications (so-called Mobile Apps);
- information related to the use of your User Account to access third-party websites, applications, and/or services.
 

Location-Based Services

Eagle Etsp may collect, use, and share precise location data, including the real-time geographic location of the User's rental vehicle, to provide the system with location-based services using GPS, Bluetooth, the User's IP address, hotspots, Wi-Fi, crowd-sourced services, and other technologies to determine the approximate location of the User's device and distance.

Sensitive Personal Data

We will not ask the Data Subject to provide us with sensitive personal data regarding: racial or ethnic origin, political opinions, religion or other similar beliefs; trade union membership; physical or mental health; sex life or criminal convictions. If the Data Subject provides sensitive personal data, Eagle Etsp will obtain their explicit consent to use this information solely for the purposes for which it was provided. What are the purposes and legal bases of collection? In addition to the purposes above, we may collect this additional information to provide you with all the features, in particular: to verify and process usage; to process payments related to the use of the Service; to keep you updated on your activities in relation to the Service; to answer your questions; to assist you in recovering a lost or stolen vehicle and to provide assistance in the event of an accident or mishap. We are able to do so because you have registered to use our Service and therefore authorize us to process your data to fulfill the obligations of a contract, unless otherwise specified. We may be required to share your data with local law enforcement agencies, including the police, if we are required to do so by law, to meet our legitimate interests, or to protect the interests of you or others.

Direct Marketing and Promotions

To improve your experience using our system, we may use your email address to inform you about Platform developments, special offers, and promotions. With your explicit consent, we may share your contact information with our Partners and use it for customer satisfaction surveys, customer consumption analysis, and market research, including through questionnaires conducted by us and/or third parties regarding the quality of our Service, including the publication and communication of your feedback. If you no longer wish to receive this information, you may unsubscribe by following the instructions on the website or in the App. In this case, we will no longer contact you for direct marketing purposes. We may also collect and use your Personal Data for:

- compliance with contractual obligations, terms, and conditions;
- accounting, risk management, and data retention/archiving;
- research, planning, and statistical analysis;
- to prevent, detect, and investigate fraudulent or other illegal activities, or to reduce the risk of such occurrences;
- to train our employees;
- for any other purpose related to the above.
 

General Personal Data

The IT systems and software procedures used to operate the App (such as the Apple Store and Google Play) acquire, during their normal operation, certain data relating to the User, the transmission of which is implicit in the use of Internet communication protocols, smartphones, and devices used. This category of data includes, but is not limited to, geographic location, telephone number, User contact information, email address, and credit card information. Users can consult the privacy information available on the following websites: 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

Data is processed electronically and can be deleted at any time using the functions available in the App. Downloading the App is voluntary, and the User can uninstall it at any time, change permissions, and delete documents such as expense reports. The collected Data will be retained on the System for the duration of the subscription and for the period required by Applicable Law and/or for a reasonable period (Eagle Etsp or its third parties will rectify or delete the Data Subject's Personal Data if it is no longer necessary).

Data Subject Rights

The User may exercise their rights by sending an email to [email protected] to request rectification or deletion, or request restriction of processing or object to processing. Furthermore, they have the right to data portability, and any complaints they may lodge with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali). Pursuant to the EU General Data Protection Regulation (GDPR) 2016, the Data Subject has the right to receive information and access to all Personal Data we hold about them. This right may include, for example, requesting modification or deletion of their Personal Data; withdrawing their consent; and knowing the purposes for which their Personal Data is processed and to which recipients it may be disclosed (subject to legal and regulatory requirements). If you do not agree to subject your Personal Data to the processing described in this Policy, please do not submit your data by accessing the platform or by any other means.