v1.0 Last updated November 20, 2023

INTRODUCTION – WHO WE ARE?

Kineton S.r.l. –  Società Benefit with registered office in with registered office in Via Gianturco n° 23 – 80146 – Naples (NA), VAT n. IT 08585821211 (Data Controller, hereinafter “we”, “us”, or “our”), respect your privacy and are strongly committed to keeping secure any information we obtain from you or about you. This Privacy Policy describes our practices with respect to Personal Information we collect from or about you when you use our website, applications, and services (collectively, “Services”).

TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. HOW DO WE KEEP YOUR INFORMATION SAFE?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO WE MAKE UPDATES TO THIS NOTICE?
  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

  • email addresses
  • passwords
  • full names
  • user interests
  • voice transcripts

Special categories of personal data. We do not process special categories of personal data.

Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Google, or other social media account. If you choose to register in this way, we will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

  • Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
  • Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s microphone, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

The sole purpose of collecting this information is to ensure we can provide the service our application(s) offer.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information – such as device characteristics – is collected automatically when you download our App.

The information we collect includes:

  • Metrics and Statistics from Google Play and App Stores. Information that is collected from Google Play or App Store and for which user already accepted terms and conditions. This may include information about app downloads, basic device information (e.g. OS version), user ratings and reviews.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

The Services are reserved to subjects over the age of 18 years old. Hereby, we don’t collect personal data pertaining to subjects under the age of 18 years old. At request of the users, we will promptly delete all the personal data, involuntarily collected, pertaining to subjects under the age of 18 years old.

In particular, the personal data of the users will be lawfully processed for the purposes depending on how you interact with our Services, including:

  1. To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.
  2. To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
  3. To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
  4. To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
  5. To comply with legal obligations. This includes adhering with obligations imposed by law, an authority, a regulation or European legislation.
  6. To conclude negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e. legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfil our contractual obligations, to protect your rights, or to fulfil our legitimate business interests.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

  • For the purposes set forth in 1), 2), 3) and 4) as described in the previous paragraph 2, the legal basis is provided by art. 6, paragraph 1, letter b) of the GDPR, i.e. the processing is necessary for the performance of a contract to which the user is a party or for the execution of pre-contractual measures taken at the user’s request.
  • For the purposes set forth in 5) as described in the previous paragraph 2, the legal basis is provided by art. 6, paragraph 1, letter c) of the GDPR, as the processing is necessary for compliance with a legal obligation to which the Data Controller (us) is subject.
  • For the purposes set forth in 6) as described in the previous paragraph 2, the legal basis is provided by art. 6, paragraph 1, letter f) of the GDPR, as the processing is necessary to conclude negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organisation apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The third parties we may share personal information with are as follows:

  • Cloud Computing Services
    We utilize Google Cloud Platform to deliver our services. We have implemented robust measures to safeguard data, ensuring it resides in isolated environments. Furthermore, our data is exclusively hosted on European servers to enhance its security and compliance.
  • AI Services
    Voice transcripts from users are transmitted unfiltered to the OpenAI API for text completion. This API processes the input to detect actions and initiate specific workflows, such as beginning a new trip. Since the API does not pre-filter inputs, users are advised against sharing personal or sensitive information through the voice assistant. Utilizing this functionality does not necessitate the disclosure of private or sensitive user data. Moreover, compliance with GDPR is ensured through OpenAI’s Data Processing Addendum (https://openai.com/policies/data-processing-addendum).

We also may need to share your personal information in the following situations:

  • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs (e.g. Google Maps API, Places API).

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use only technical cookies, aimed at ensuring the proper functioning of our Services.

Maps SDK for Android and Maps SDK for iOS use cookies subject to Google’s Privacy Policy, such as calculating daily and 7-day active users and service abuse prevention. These cookies are not associated with any signed-in Google Account and are not logged with the rest of the information collected from the API calls.

6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?

In Short: If you choose to register or log in to our Services using a social media account, we may have access to certain information about you.

We inform that if you choose to register or log in to our Services using a social media account, the following methods shall be used:

  • Registration through the “Connect with Facebook” or equivalent service, where available. The data that may be communicated by the Facebook’s provider to us through the “Connect with Facebook” service are: name, surname, and email address. We will process such data exclusively for the purposes indicated in this notice, in accordance with the user’s consents given from time to time. For further information about the “Connect with Facebook” service and to modify privacy settings related to this service, please refer to the following links:
  • Registration via the “Connect with Google” or equivalent service, where available. The data that may be communicated by the provider Google to us through the “Connect with Google” service are: name, surname, and email address. We will process such data exclusively for the purposes indicated in this notice, in accordance with the user’s consents given from time to time. For further information about the “Connect with Google” service and to modify privacy settings related to this service, please refer to the following links:
  • Registration via the “Sign in with Apple” or equivalent service, where available. The data that may be communicated by the Apple’s provider to us through the “Sign in with Apple” service are: name and surname (adjustable by the user at the time of registration), and email address (with the possibility of using the “Hide my email” feature and providing a unique and random email address that forwards mail to your personal email address). We will process such data exclusively for the purposes indicated in this notice, in accordance with the user’s consents given from time to time. For further information about the “Sign in with Apple” service and to modify privacy settings related to this service, please refer to the following links:

7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

8. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate and reasonable technical and organisational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorised third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Switzerland, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Switzerland), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you consider that the processing of your personal data is in breach of the Regulation, the right to lodge a complaint with a supervisory authority (in the Member State in which they have their habitual residence, in the Member State in which they work or in the Member State in which the alleged breach has occurred).

The Italian Supervisory Authority is the Garante per la protezione dei dati personali, located in Piazza Venezia n. 11, 00187 – Rome (http://www.garanteprivacy.it/).

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you may exercise their rights granted by the Applicable Law by contacting us as follows:

  • Sending a registered letter with return receipt to the registered offices of Kineton S.r.l. – Società Benefit: in Via Gianturco n° 23 – 80146 – Naples (NA), Italy;
  • Sending an electronic mail message to privacy@kinecity.it.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognising and implementing DNT signals has been finalised. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this notice, you may contact us as follows:

  • Sending a registered letter with return receipt to the registered offices of Kineton S.r.l. – Società Benefit: in Via Gianturco n° 23 – 80146 – Naples (NA), Italy;
  • Sending an electronic mail message to privacy@kinecity.it.

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please send us a request to: privacy@kinecity.it.