Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“Regulation” or “GDPR”), Urban Emotions S.r.l. provides the following information regarding the processing of personal data of the following subjects (“Data Subjects”):

• Users of the GIMBUS service for booking services (“Service”), whether registered on the website gimbus.it (“Registered Users”) or not (“Unregistered Users”)(collectively, “Users”), who use the Service either for themselves or to book services for others;

• Passengers who benefit from the Service, following a booking made either directly as Users or by other Users on their behalf (“Passengers”).

The personal data of the Data Subjects will be processed by Urban Emotions for the purposes set out in this privacy notice. Additionally, Passengers’ data will be shared with the individual driver assigned to them.

1. Data Controller

The Data Controller of the personal data is Urban Emotions S.r.l. (“Urban Emotions” or the “Company”), with its registered office at Via Campagna, 11, Como, Italy, and contactable via email at info@urbanemotions.it

2. Personal Data Collected and Source of Data

2.1 Urban Emotions will process the following User data to enable registration for and/or use of the Service for bookings, either for themselves or others:

• Identification data (first and last name);

• Contact details (e.g., email address and phone number).

2.2 Urban Emotions will also process the following data of the Passenger:

• Identification data (first and last name);

• Contact details (e.g., email address and phone number);

• Information related to the booked service (e.g., pick-up and drop-off addresses).
  If the booking is made by a User other than the Passenger, Urban Emotions will receive the Passenger’s personal data from the booking User.

3. Purpose and Legal Basis of Processing

Personal data will be processed by Urban Emotions for the following purposes:

A) Purposes related to the use of the Service by all Users, specifically for:

• Registration to the GIMBUS services (via the website);

• Managing the delivery of the Service (e.g., verifying the passenger’s name at the start of the service).

Legal basis: the provision of the Service as governed by the relevant Terms and Conditions of use of Urban Emotions.
Providing this data is mandatory; refusal to do so will make it impossible to register for and/or use the Service.

Data retention: data related to each ride will be stored for 10 years from the end of the ride, in accordance with applicable limitation periods.

 

B) Sending of informational and promotional communications via email related to the Urban Emotions Service to all Users

Legal basis: the legitimate interest of Urban Emotions in keeping Users informed about commercial and/or promotional initiatives related to the Service (e.g., promotional discounts near holidays, location-based promotions).

Data retention: until Users request to stop receiving such communications, which can be done at any time by clicking the unsubscribe link included in each message sent by Urban Emotions.

 

C) Marketing activities to promote new initiatives and commercial partnerships of Urban Emotions, addressed to both Registered and Unregistered Users

Marketing activities may include sending communications via SMS, email, and/or phone calls with an operator.

Legal basis: the specific and explicit consent provided by the User at registration or later via their personal account area. Consent may be revoked at any time.

Data retention: until consent is withdrawn, or for two years after the User’s last activity on their account.

 

D) Compliance with legal obligations, and for the establishment, exercise, or defense of legal claims by Urban Emotions or third parties (e.g., managing complaints, disputes, legal proceedings, and/or settlements)

Data retention: 10 years to ensure compliance with legal, judicial, and administrative obligations, as well as for the participation of Urban Emotions in any administrative and/or legal proceedings.

 

E) Aggregated statistical analysis regarding the Urban Emotions service

The data collected will be processed anonymously for the creation of aggregated statistics on the activity carried out within the Urban Emotions service.

Legal basis: the legitimate interest of the Company in analyzing the performance of the Urban Emotions service in order to improve its functionalities and features based on usage patterns.

4. Payment Data

4.1 In order to receive payment for the service, Urban Emotions uses the payment services provided by Fareharbor.com and Nexi Srl.
Urban Emotions is not responsible for the collection or processing of payment data by Nexi. Urban Emotions does not collect or process any payment-related data; it only processes information related to the outcome of the transaction, which is necessary to deliver the Service.

4.2 For more information on how Nexi or Fareharbor process personal data, please refer to the privacy policies available on their respective websites.

 

5. Data Disclosure

5.1 The processing of personal data will be carried out, for the purposes indicated in paragraph 3, by the internal staff of Urban Emotions, who are expressly authorized to process personal data. Additionally, personal data may be disclosed, for the same purposes, to the following parties:

• The individual driver who will handle the booked service, acting as an independent data controller;

• Third parties providing services on behalf of Urban Emotions, acting as data processors (e.g., IT service providers or other support services);

• Public or private entities (e.g., insurance companies, banks, public authorities, judicial bodies, tax agencies), which will process the data as independent data controllers.

 

6. Territorial Scope of the Processing

Personal data will not be transferred outside the European Economic Area.

 

7. Data Subjects’ Rights

Data Subjects may exercise, in the cases provided for by the Regulation, the rights referred to in Articles 15 and following of the GDPR:

• Right of access: to request confirmation as to whether or not personal data concerning them is being processed, and, if so, to request access to such data and information regarding the processing;

• Right to rectification: to request correction or completion of inaccurate or incomplete data;

• Right to erasure: to request the deletion of their personal data by Urban Emotions;

• Right to restriction of processing: to request the restriction of processing under certain conditions;

• Right to data portability: to receive the personal data concerning them in a structured, commonly used, and machine-readable format, or to request the transmission of such data to another data controller, where technically feasible;

• Right to object: to object, wholly or in part, on legitimate grounds and in the cases provided for by the GDPR, to the processing of their personal data.

Pursuant to Article 7 of the GDPR, Registered Users may withdraw their consent at any time, without affecting the lawfulness of the processing based on consent before its withdrawal.

Data Subjects may exercise the above-mentioned rights by sending a request to the following email address: info@UrbanEmotions.it

Furthermore, if a Data Subject believes that their personal data has been unlawfully processed, they may lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).