Information pursuant to articles 13 and 14 of the GDPR – REGULATION 2016/679/EU – Privacy Policy

Privacy

Wecity s.r.l., a limited liability company under Italian law with its registered office at Via Contrada 309 in Modena and VAT number 03475130369 – (hereinafter “wecity”), pursuant to the GDPR, is the Data Controller of the data collected in the course of its activities, and co-controller or external manager of that of any Clients, as specified below.

Any Data Controllers or Co-Controllers (generally the Clients) will be specified in the Co-Controller Agreement made known to the Data Subjects pursuant to Art. 26 paragraph 2, of Regulation 2016/679/EU.

The “Privacy Policy” described below, i.e., the practice we adopt in the Processing of personal data, intends to clarify how Wecity collects and uses certain personal information that may concern You, and the rights and options that, in relation to this, you can exercise: it is an integral part of the Terms of Use (hereinafter “Terms”) and is fully reported on the website www.wecity.it (hereinafter the “Site”).

Attention: by using the mobile application named “wecity” (hereinafter the “App”) as well as the website (hereinafter, Site and App are collectively referred to as the “Services”), that is, by registering and accessing the Site, installing, using the App on Your devices, and, in general, the Services or participating in initiatives of wecity or related to its activities, Your consent to the Processing, full acceptance of this “Privacy Policy” as well as its subsequent modifications is considered acquired.

The personal data provided is subject to electronic and/or manual processing, which is always carried out in compliance with the legal measures for the security and protection of the data itself, and only for the purposes described below.

As per Communication no. 102322 sent for confirmation of the notification made by the Guarantor for the Protection of Personal Data, Wecity has, in compliance with the regulations, filed a notification for the processing carried out in the course of its activities that involve:

  • Georeferencing, geolocation, and data related to movements, i.e., the collection of data indicating the geographical position of people or objects and their movements through an electronic communication network;
  • Profiling, i.e., processing carried out with the aid of electronic tools aimed at defining the profile or personality of the data subject, monitoring their movements, or analyzing habits or consumption choices, or monitoring the use of electronic communication services, excluding processing technically indispensable for providing the same services.

The list of Data Processors and Appointed/Authorized persons designated for the processing of personal data is available at the registered office of wecity s.r.l..

Personal Data of the Data Subject

When installing the App on your device, Wecity will ask you to provide some personal and contact data, indicating which data is mandatory to allow authentication, access to the Services, and their use.

In the case of registration with email and password, wecity collects the following data of Users:

  • Name
  • Surname
  • Email address
  • Password

In the case of registration via Facebook or AppleID, wecity collects the following data of Users:

  • Email address

In the case of User participation in a “Mission” (like BIKE TO WORK), wecity may collect the following data of Users, based on the requests and needs of the clients:

  • Acceptance of terms & conditions
  • Name (or confirmation of name, see above)
  • Surname (or confirmation of surname, see above)
  • Date of birth (optional)
  • Place of birth (optional)
  • Gender (optional)
  • Phone number (optional)
  • Home address (optional)
  • Work address (optional)
  • Company (optional)
  • Work position (optional)
  • IBAN (optional)
  • Tax code (optional)

During the use of the app, the following are also recorded:

  • Usage Data,
  • Cookies,
  • Mobility Data (latitude, longitude, altitude, direction of travel, time of position recording) which allow tracking the User’s movements by identifying the geographical location of the smartphone on which the app is installed.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the collection of the data itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, Cookies, and Mobility Data, be automatically collected via the app during the use of wecity.

If not specified otherwise, all Data requested by wecity are mandatory. If the User refuses to communicate them, it may be impossible for wecity to provide the Service.

In cases where Wecity indicates some Data as optional, Users are free not to communicate such Data, without this having any consequence on the availability of the Service or its operability.

Users who have doubts about which Data are mandatory are encouraged to contact the Owner.

wecity may conduct checks on the information provided: where false, incorrect, or not updated, this could lead to the deletion – after communication – of Your account, making it impossible to access the Services or use them correctly.

The email you choose will be used to identify you during Authentication and use of the Services and will be associated with every piece of information you provide and choose to make visible or not to other Users.

In-app, you will only be visible to other users through the nickname and profile picture you uploaded.

Any additional information beyond those indicated above, such as the amount of CO2 saved to the environment, that emitted, and the routes traveled, may be used and shared with other Co-Controllers even after the use of the Application, made available to the latter on the Platform, and also from here be made accessible to the Co-Controllers of the processing.

Each User is solely responsible for complying with current regulations, obligations, or rules relating to the means used for movements: wecity assumes no responsibility for any loss, damage, cost, or expense that may arise to You as a result or in connection with participation in any activity or event initiated, conducted, or organized by wecity or a “Mission”, nor in relation to any agreement between Users and/or third parties including any activity or event connected in any way, directly or indirectly, with the use of wecity’s Services.

Information Regarding the Georeferencing of Users

Wecity allows you to use the app individually or to participate in a “Mission” where one or more types of transportation means (bicycle, public transport, etc.) and one or more types of routes (home-to-work commutes, home-to-school trips, etc.) are rewarded. Therefore, Wecity collects data and information related to Your location to determine your means of transport. The data related to the movements made and their mode remain segregated from other Users but can be used by Wecity, its clients in the case of Missions, and other Co-Controllers and Data Processors, also in aggregated and pseudonymized form for research and statistical purposes, as well as for other purposes specified in this Privacy Policy.

The primary purpose of Wecity is to use this information to gather important data regarding smart mobility and the amount of CO2 that can be saved for the environment with it. The anonymous or pseudonymized aggregation and study of these data will make it possible to monitor the progress and your results in the Missions you participate in, as well as to conduct scientific research that would otherwise be difficult to carry out.

By adhering to the Services, you therefore authorize Wecity to use without limits and indefinitely the information collected related to your location and the respective routes, without making them public but instead using them to create databases of anonymous or pseudonymized and aggregated data and use them in accordance with this Privacy Policy.

In any case, the only data with which you will be visible to other users is your nickname and your profile photo.

Username and Password

To access, you will always need to use the username and password with which you registered. With the advancement of technology, further or different means of identification and authentication (possibly, for example, biometric data, which will not be collected by Wecity) may also be used for accessing the Services.

Maintaining the secrecy of authentication data is your responsibility. You are fully responsible for any use or misuse of your account and personal data that may result from the disclosure of authentication data to someone else. Ensure that you adopt virtuous behaviors in this regard, for example, never choosing simple passwords made up of only numbers or words, and remember to change the password frequently and at least once every six months.

Use of Aggregated Information

Wecity may use anonymous information, statistical data, or aggregated data to properly operate the Services, to improve their quality or your experience, to create new services and features, including personalized services, modify or cancel existing content or services also for commercial and statistical purposes. Wecity may also use them by sending, disseminating, transmitting, or otherwise communicating or making available such information to Co-Controllers, Users of the services, service providers, partners, and other entities.

Information Security

Wecity considers information security an absolute priority. Wecity requires that its developers and the hosting providers it uses implement systems, applications, and procedures to protect your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information, in compliance with what Italian legislation imposes: in fact, the servers on which said information resides are located in an Italian server farm and the company that manages them has been designated as the Data Processor.

While doing everything to ensure compliance with the above, naturally Wecity cannot guarantee, and it is not reasonable to expect, that the databases are immune from any malfunction, illegal interception, access, or other types of abuse or misuse and therefore cannot assume any responsibility: in case of any malfunction or unauthorized access, you will be informed and everything will be done to restore the situation, ensuring that any illegal behaviors are prosecuted by the competent Authorities.

Data Retention, Deletion, and Opt-Out Policy

If you believe that the information on your account is not accurate, complete, or up-to-date, you are required to make all necessary changes to correct it, and where you are unable to intervene in this regard, you can ask Wecity to do so. Please note that false, incorrect, or obsolete information can prevent registration, lead to the deletion of the profile, and reduce Wecity’s ability to provide the Services.

However, you can exercise your rights under the GDPR at any time by writing a simple letter, registered mail to Wecity’s registered office at Via Contrada 309 in Modena, or an email to info@wecity.it.

Uninstalling the Application does not constitute an explicit choice of opting out regarding this Privacy Policy: if you wish that all your personal data collected by Wecity (except for those now made anonymous and aggregated into databases) be deleted, you must explicitly request their deletion. Following the uninstallation, Wecity will no longer be able to collect any further data, movements, or georeferencing information about you, nor data related to your position and your routes.

Changes to the Privacy Policy

Wecity may modify the terms of this Privacy Policy. Substantial changes will come into effect 30 days after the publication of a notification via the app and/or direct communication to registered Users. Other changes will take effect seven days after their initial publication on the website. Where Wecity modifies the Privacy Policy to comply with legal requirements, the changes will take effect immediately upon their initial publication or within the times required by law.

Using the Services after the communication of changes will in any case imply acceptance by conclusive behavior. If you do not agree with any of the modified conditions, you must refrain from any further use of the Services and are invited to cancel your registration.

Updated 10.05.2021