Privacy Policy

Welcome to E-GAP S.r.l. – “GAP” – we are excited to work with you and offer you our services. As you can imagine, in order to carry out our work properly, we collect and use information about you.

E-GAP is committed to protecting and respecting your privacy. For this reason, this Policy describes your rights regarding the information collected that we process and the measures we adopt to protect your privacy.

Even if it is a lengthy document, we ask you to take the time to read this Statement very carefully.

Below is a list of contents indicating the issues covered to make reading of the Policy easier.

 

Table of Contents

 

Some useful definitions for informed reading

Which personal data are collected by E-GAP

How we use personal information

Legal basis for processing

Sharing with third parties

IP addresses and cookies

Data security Where personal information is stored and processed

Do we transfer data outside the European Union?

For how long do we keep your data?

Consequences of any failure to provide data

Do we process your data through an automated process?

Do we treat children’s data?

What are your rights?

Changes to this Privacy Policy

Contacts

 

Some useful definitions for informed reading

First you must know that when we talk about us or about GAP we are referring to E-GAP S.r.l. (Tax Code and VAT No. 14253861000), in the person of the legal representative pro tempore, with registered office in Rome – 00185, Via Parigi n.11. We are a company that deals with the development, production and marketing of innovative products or services of high technological value for electric mobility in cities.

 

E-GAP will be the “Data controller”.

 

When we talk about “Customer” or “User“, we are referring to you as the recipient of our services.

 

By the term “Services” and/or “Products“, we mean all the products and services offered by us that you can purchase through the E-GAP application, or through the web platforms that we put at your disposal to offer you our services whenever you want.

 

When we refer to “Devices” or “Computer“, we mean your smartphone or your personal computer or laptop through which you interact with us.

 

Finally, when we talk about “Personal Data“, we are referring to both the data you provide us directly for the use of our services and the data that are automatically collected in connection with your interaction with our website and with our App.

 

Which personal data are collected by GAP

• We receive and store any information you provide to us in relation to the services we offer. You may choose not to provide certain information, but then you may not be able to use many of our services.
• You provide us with your data voluntarily when you download and use our App on your device and provide your details in the “My profile” section (My account). When configuring the settings of your device providing permissions to access your data, such as your geolocation, you can communicate with us by phone, e-mail or chat within the App, and you can fill out a form to request our help.

The data you provide to us through interaction with your device on our website or on our App are:  your name; your address and phone number; information related to payment; your age; information about your location, e-mail addresses of your friends and others; the content of reviews and e-mails sent to us, information and documents relating to identity and your status; corporate and financial information; information related to your creditworthiness; VAT number; and log files and device configurations, including Wi-Fi credentials, if you choose to synchronise them automatically with other devices.

We collect some of your data automatically

• The data that we collect and use automatically are: your internet protocol (IP) address when you connect to the internet; your e-mail address and password chosen by you to access our services; the information on your computer, device and connection, such as device applications or type and version of browser, operating system or time zone set; the location of your device or your computer; the phone numbers you use to call us; and your interaction with the contents of our App or our website.

• We use personal information for the sending of direct marketing via e-mail if this option has been accepted in the relevant contact form. You can decide not to receive marketing communications when you want. To find out more go to the section dedicated to Cookie Policy, by clicking here.

How we use personal information

Personal information will be collected and processed by us for the following purposes:

• We use your personal information to receive and manage your orders, provide our products and services, process payments and communicate with you regarding your orders, products, services and promotional offers;
• to provide those of our services you have subscribed to and which you have requested by registering on the website and/or App and creating your account;
• to provide assistance when you request it by contacting our customer service via e-mail, chat or phone;
• to adapt content and resources to user preferences;
• to communicate with you, respond to your requests or questions via phone, chat, SMS or e-mail;
• to send other information and communications via e-mail that may be of interest to you;
• to create, publish and improve the most relevant content for you;
• to ensure that the content provided through the site is presented in the most effective way for you depending on your device;
• to allow you to participate in the interactive features of the website and App, if you wish to do so;
• to develop and further improve the website, App and systems in order to provide you with a better service.

You are not obliged, either by law or by contract, to provide your personal data. However, since the communication of your data for the aforementioned purposes is necessary for the provision of all our services, failure to communicate some of your data makes it impossible to provide the services, because their provision depends on knowledge of some of your personal data, such as your name and surname, payment method, location and vehicle and its location.

The use of your information described above is permitted by the applicable law on the protection of personal data, insofar as:

• necessary for our legitimate interests in pursuing the aforementioned purposes; in any case, these interests do not conflict with the right of users to privacy;
• in some cases, necessary to fulfil our legal or regulatory responsibilities, for example in the case of communication to authorities and government or regulatory bodies;
• in some cases, necessary for carrying out an action of public interest and, when we use particular categories of personal data, necessary for initiating, bringing forward or defending ourselves in legal actions, or when the processing concerns personally information that is clearly in the public domain;
• in limited circumstances, and subject to consent from you from time to time, for sending news and marketing communications via e-mail.

If you wish and, therefore, subject to your explicit consent, your data may be used for advertising purposes in relation to our business activity or that of a third party, in the following ways:

• market research, economic and statistical analyse;
• evaluation of usage data and preferences through the use of analytical tools in order to adapt contents to the interests of users and in this way improve our offer;
• sending of information and newsletters;
• creation of user profiles, also including location and payment data;
• marketing of our services and/or those of a third party, sending of advertising/information/promotional material and participation in initiatives and offers for rewarding our customers;
• for the purpose of carrying out and accounting for any commercial transactions;
• surveys of the degree of customer satisfaction with the quality of services provided.

 

Legal basis for processing

The legal basis that legitimises the processing of Personal Data voluntarily provided by you or that we collect even automatically when we send you e-mail or communications is the execution of a contract to which you are party or the execution of pre-contractual measures taken on your request, or to fulfil legal obligations.

In particular, we process your personal data for the following purposes:

• to provide you with the assistance you wish to receive, in fulfilment of the obligations arising from the General Conditions, Regulations and/or the provision of ancillary services and/or services related to such contracts. In such cases, we inform you that under the current legislation on personal data, the acquisition of your consent is not required if the processing is necessary for fulfilment of the obligations arising from the contract to which you are party; in the negotiating phase, it is also not mandatory to acquire consent if the processing is necessary to fulfil – before conclusion of the contract – your specific requests or for the execution of pre-contractual measures.
• When you register on our website and our App, creating your profile (your account) will allow us to process your requests and provide you with our services and communicate with you via chat, SMS, e-mail or phone to perform those services meeting your requests;
• in some cases, necessary for carrying out an action of public interest and, when we use particular categories of personal data, necessary for initiating, bringing forward or defending ourselves in legal actions, or when the processing concerns personally information that is clearly in the public domain;
• because our business is in continuous development, we may sell or buy other companies or services. Generally speaking, in such transactions the data related to customers are part of the corporate assets that are transferred, but remain subject to the content of the previous applicable Privacy Policy (unless, of course, the customer does not consent otherwise). If our corporate assets were to be acquired by third parties, the personal data related to customers would naturally be part of the transferred assets.

Sharing with third parties

We never sell your personal information to third parties. However, GAP may communicate your personal data to the companies of our group or controlled by it, which are subject either to this Privacy Policy or in any case to procedures that provide safeguards similar to those described in this Privacy Policy.

To facilitate the efficient use of information and provide users with content and/or resources, the information is disclosed to third parties. However, such disclosure will occur only in the following circumstances:

• we make use of other companies and individuals to perform certain activities on our behalf. For example, to process your orders, send paper mail and e-mail, remove recurring information from customer lists, analyse data, provide marketing assistance, provide search results and links;
• we also use third-party suppliers to process payments, transmit content, calculate credit risks and provide customer support services;
• we communicate data related to the account and other personal data when we believe that such communication complies with legal obligations; to enforce or apply our General Conditions of Use and Sale and other agreements; or to protect the rights, assets and security of GAP, our customers or others. The foregoing includes the exchange of information with other companies and organisations that provide for the prevention of fraud or reduction of credit risk;
• on our web pages we have bound the use of the so-called “social plugins” of social networks such as Facebook, Twitter and Google+ to the conditions set out below. While browsing our website, social plug-ins are disabled, meaning that they do not send any data to the operators of their respective social networks. If you wish to use one of the social networks, you must click on the respective social plugin to establish a connection with the corresponding server. If you have a user account with the social network and when you activate the social plugin you have logged in to, the social network can associate your visiting of our web pages to your user account. If you wish to avoid this occurring, you must log out of the social network before activating the social plugin. If you activate a social plugin, the social network transmits the contents made available directly to your browser which links them to our web pages. In this situation, transmission of data initiated and managed by the respective social network may also occur. When you connect to a social network, only the data protection rules of the respective social network apply to data transmissions between the social network and your system and to your interactions on this platform. The social plugin remains active until you disable it or delete your cookies.

These third-party service providers only have access to the personal data that are necessary for the performance of their activities, but they will not be able to process the data they become aware of for further purposes. In addition, such third parties are required to process the personal data they become aware of in accordance with this Privacy Policy and applicable data protection regulations..

In cases other than those listed above, you will be informed whenever your personal data are shared with third parties and you will have the opportunity to choose whether or not to allow such communication to third parties.

IP addresses and cookies

We collect information about your computer and device – including (where available) the IP address, operating system and browser version – for system administration. These are statistical data on the actions and browsing behaviour of our users.

For the same reason, we can obtain information on the use that users make of internet in general, through a cookie file that is stored in the device. Cookies help us improve the site and provide better, more targeted content. For more information on the use we make of cookies on the site, see our Cookie Policy, by clicking here.

Data security. Where personal information is stored and processed.

As explained in the “Sharing with third parties” section, we share personal information with:

• Suppliers, contractors or third-party agents: when we use suppliers, contractors or third-party agents, personal information remains under our control and we have systems to ensure that personal information is adequately protected.

We undertake to adopt all measures reasonably necessary to ensure that your personal data are treated securely and in accordance with this Policy.

GAP has designed all the systems through which your personal data are collected, stored and processed according to the highest security standards, to ensure that your privacy is respected.

All individuals who participate in data processing on our behalf have been instructed, appointed and nominated by us to ensure that your privacy is respected.

The software we use is Salesforce and as regards the methods and payment of our services and, therefore, the management of data related to your credit card, we use the Stripe system.

From time to time, we may ask you to confirm your identity and payment methods again in order to implement our physical, electronic and internal organisational security measures.

Do we transfer data outside the European Union?

Your personal data may be transferred and processed in one or more countries within or outside the European Union. Whenever personal data are transferred outside the European Economic Area we will ensure that such data are transferred in accordance with this Privacy Policy and applicable data protection regulations.

For how long do we keep your data?

We store your personal data to allow you to use GAP services continuously for as long as necessary to provide the services requested and to comply with what is set out in this Policy, for example for tax and accounting purposes or, subject to your consent, for our commercial purposes.

In addition, we keep the history of your transactions so that you can review your purchases and in which places you asked for our service to be delivered.

Consequences of any failure to provide data

The provision of data is optional. Nevertheless, failure to provide data marked as mandatory will make it impossible to provide the Service.

However, failure to provide the remaining data not marked as mandatory will still allow provision of the Service, but will not allow us to send you our updates and promotional communications.

Do we process your data through an automated process?

GAP may process your data through automated systems/processes and a decision procedure that is also automated (such as profiling) to offer you and our customers the services requested. For example, to implement our services in areas with greater demand for our intervention, we may perform an automated profiling process to identify the areas where we can improve and implement our services.

Do we process children’s data?

On the basis of the services we offer, we can process your data only if you have reached the age of 16.

What are your rights?

Under the applicable law on the protection of personal data, the user is entitled to:

• access and obtain a copy of your personal data: you are entitled to request confirmation of the fact that we are processing any of your personal data whatsoever. In this case, you will have access to your personal data and some information on how they are processed. In some cases you can ask us to provide an electronic copy of your data;

• right of rectification of personal data: if you are able to demonstrate the inaccuracy of the personal data in our possession concerning you, you have the possibility to request the updating or correction of such data;

• right to be forgotten/data deletion: under certain circumstances, you have the right to have your personal data deleted.  The request can be presented at any time; GAP will evaluate if it can be granted. However, this right is subject to legal rights or obligations that could impose data retention.  For situations in which, in compliance with the law, it is established that the request for deletion of personal data must be granted, GAP will proceed without delay.

To exercise your rights, you can write to us at any time at the following e-mail address: privacy@e-gap.com

To the extent that the processing of personal data is based on your consent, you also have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legitimacy of any processing based on consent given before such withdrawal.

It is also possible to file a complaint regarding the processing of personal data with the local Data Protection Authority.

Changes to this Privacy Policy

The conditions of this Privacy Policy may change from time to time. We will publish any substantial changes to this Policy by means of suitable notice on this website or by contacting the user via other channels.

Contacts

Questions, comments and requests related to this Policy are welcome and should be addressed to E-GAP S.r.l., at the following e-mail address: privacy@e-gap.com

Data Controller: E-GAP S.r.l. (Tax Code and VAT No. 14253861000), in the person of the pro tempore legal representative, with registered office in Rome – 00185, Via Parigi 11.

Data Processor: Filippo de Michelis, who can be contacted via the address: privacy@e-gap.com

Last update: February 2019