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LUGGit Keeper App - Privacy Policy

This privacy policy contains all the information applicable to the processing of personal data collected through our Keeper Mobile Application. Here you can find all the information applicable to the processing of your personal data following any interaction and commercial transaction established with LUGGit. Any browsing on the LUGGit Keeper app and/or purchasing services provided by LUGGit implies full acceptance of this privacy policy. Acceptance of this privacy policy is a prerequisite for the completion of any interaction and commercial transaction. Therefore, if you do not agree with the provisions herein, you must refrain from making any use of our Mobile Application. If you continue to use it, please be aware that any form of use will be understood, for all legal purposes, as full acceptance of this privacy policy and any updates that may be made to it at any time. This Privacy Policy does not apply to third-party products and services, nor to third-party websites that can be accessed through links on our website and/or mobile applications for the User's convenience and/or information. We do not have any right or control over the content of these pages or materials, so we are not responsible for the content contained therein or for any fact arising from their use or viewing and, therefore, it is your sole and exclusive responsibility to carry out all processing processes. verification needed before deciding to use them or not. To this extent we do not accept any responsibility for any damage or loss arising from its use. Regarding access to third-party links, you must first consult our Terms and Conditions.

1. Responsible for the Processing of Personal Data

Bus Terrace Technologies, SA., legal entity no. 515274003, with registered office at Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal, represented by Ricardo Figueiredo and Diogo Correia, acting as administrators. Email : hello@luggit.app

The contact person with whom you can clarify your doubts in the field of data protection and, as well, exercise your rights whenever you feel the need, is Diogo Correia. You can contact us via the following email: support@luggit.app or by post to the address of our headquarters, in the care of Diogo Correia, internally responsible for the application and compliance with the legal provisions of Regulation (EU) No. 2016 /679 of April 27, 2016 regarding the protection of personal data (GDPR) and other applicable national legislation.

2. Principles followed by the Responsible Person, Security and Protection of Personal Data

The processing of personal data is carried out in accordance with the law and based on the principles of lawfulness, loyalty, justice, transparency, purpose limitation, data minimization and accuracy. Therefore, with a view to protecting your personal data against unauthorized use and disclosure , LUGGit has implemented several security measures. As Data Controller, LUGGit carries out the lawful processing of your personal data, always collecting your free, specific, informed and explicit consent whenever required under the law. LUGGit does not use /transmit your personal data for purposes incompatible with the Principles set out above. The purpose(s) for which your personal data is collected is(are) solely and exclusively those described here and to that extent, your personal data will not be processed for any other purpose, unless such processing is previously consented by you. The collection of personal data is carried out based on the Principle of Minimization under which LUGGit only collects data considered essential for the pursuit of the purpose in question. As soon as the data collected is no longer necessary for the purpose for which it was collected, LUGGit will refrain from further processing it and will take all necessary measures to destroy it.

3. Definitions

For the purposes of this Privacy Policy, the following terms will have the meaning indicated below:

  • User: natural person or legal person who accesses LUGGit’s digital platforms and/or registers, whether the mobile application or the web page;
  • Customer: natural person or legal person who, through access to LUGGit's digital platforms, contracts the merchandise transport service, under the Terms set out here, and must, for this purpose, be the legitimate owner of the merchandise or, if not, be duly authorized and mandated by the owner for this purpose;
  • Service: transport of goods, which takes the form of receiving the goods at the collection location on the date and time of collection; movement, via land transport, of merchandise; and delivery of the goods at the delivery location (located in the same city as the collection location), to the recipient, on the date and time of delivery. This service can be carried out directly by LUGGit or resorting, in whole or in part, to subcontracting, under the terms defined by you.
  • Merchandise : any type of volume and/or personal item; Other services: services other than goods transport services carried out by LUGGit and provided that they are individually and specifically contracted with the Customer;
  • Keeper: natural or legal person who carries out transport and/or storage by previously concluding a service provision contract with LUGGit, for this specific purpose;

4. Information and consent

Law No. 58/2019, of August 8, 2019 (which ensures the implementation, in the national legal order, of Regulation (EU) 2016/679 of the Parliament and of the Council, of April 27, 2016) and the Regulation General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, hereinafter “GDPR”) ensure the protection of natural persons with regard to the processing of personal data and the free circulation of these data. In legal terms, "personal data" means any information, of any nature and regardless of its support, including sound and image, relating to an identified or identifiable natural person, meaning that protection does not cover data from legal persons. By accepting this Privacy Policy, the User gives their informed, express, free and unequivocal consent for personal data provided through mobile applications and web pages to be included in a file under the responsibility of LUGGit, whose processing complies with security measures appropriate techniques and organisation. LUGGit maintains a database with records of its Users. The data present in this database are solely the data provided by them at the time of registration (as Customer, Keeper or Partner) or later detailed in their account, being collected and processed automatically, under the terms approved by the National Data Protection Commission by LUGGit , entity responsible for the corresponding file. Under no circumstances will information be requested about philosophical or political beliefs, party or trade union affiliation, religious faith, private life and racial or ethnic origin as well as data relating to health and sexual life, including genetic data. Under no circumstances will any of the following activities be carried out with the personal data provided through this page: Transfer the data to other people or other entities, without the prior consent of the data subject; Transfer data outside the European Economic Area (EEA) without the prior consent of the data subject.

5. Data collected and purposes

LUGGit guarantees the confidentiality of all data provided by Users at any time and whatever the means used for this purpose. However, LUGGit collects and processes data in a secure manner that prevents its loss or manipulation, using the most advanced techniques for this purpose. The data collected on the keeper mobile application depends on the interaction which will be described below.

5.3. General APP navigation

In order to provide a better experience when browsing our APP and thus adapt it to your needs, LUGGit uses third-party metrics collection tools that allows it to carry out statistical analysis; continue with marketing or targeted engagement campaigns; analyze and resolve app issues. The data processed in this way is anonymized without the possibility of reaching its respective owner, however, LUGGit does not have any control over these tools and their respective privacy policies, so it is up to you, the User of the APP, to read their policies and decide whether or not to accept them.

Furthermore, as a result of the use of our APP, we also collect: a) Usage data regarding how you interact with our APP, date and time of access; APP resources used or pages accessed via the APP; APP failures; browser type. In the event of an error/failure in the APP, we may collect the following data: IP address of the device you use, the name of the device, the operating system version, the configuration of the application when using our service, the time and date of access . b) Data about the device you are using, namely the hardware model, device IP address, operating systems and versions, software, preferred language, device movement data, mobile network data.

5.4. Registration on the APP

This section describes the data collected and processed by LUGGit when you register on the APP. Given that the intent of the APP is to facilitate the provision of services, a contract is required to be concluded between LUGGit and the KEEPER professional before you are allowed to register on the APP. Therefore, the data collected and processed by LUGGit described in this section only applies to KEEPER professionals, and not to any other type of user, for compliance with these measure, a valid code is required to be inserted in the APP and validated, which will determine the type of user you are and only then will you be able to register on the APP.

After validating the code, the following data will be collected and processed by LUGGit for the purposes of creating a KEEPER account:

  • Full Name
  • Phone number
  • Email
  • Password
  • Profile photo
  • Vehicle license plate
  • Vehicle brand
  • Vehicle model
  • Vehicle color
  • Vehicle year

The data you provided above when registering on the app will only be visible on our APP and, therefore, accessible to our CUSTOMERS who are registered, your name and photo. All other data will not be disclosed on the APP or any other platform owned by LUGGit.

The data provided above, when registering on the APP, excluding phone number; email; password; will be used by LUGGit to help the KEEPER professional provide the service, namely, the vehicle license plate, brand, model, color and year, will be used to identify the vehicle that will be used to transport the merchandise, and the profile photo and name will be used to identify the KEEPER professional. This data will be visible to the CUSTOMER who is registered on the APP and has an active service where the KEEPER professional is the assigned party. In relation to the phone number and email, will be used to contact the KEEPER professional whenever necessary by the LUGGit.

The KEEPER User is solely responsible for the veracity and ownership of the personal data provided here and is obliged to update it whenever it is no longer up to date. If the KEEPER User, expressly violating this obligation, provides false or inaccurate information, they will be solely responsible for the same, as well as for any losses caused, either to LUGGit or to any third parties.

5.6. Service Provision

This section describes the data collected and processed by LUGGit only when you use the KEEPER app as a registered keeper professional. Given that the KEEPER is a professional, the data collected and processed by LUGGit is strictly necessary for the execution of the service provision contract. This section only applies to KEEPER professionals, whom have a service provision contract with LUGGit, are registered on the APP and are providing services to CUSTOMERS.

When you use the KEEPER app as a registered KEEPER professional, the following data will be collected and processed by LUGGit for the purposes of providing the service:

App Permissions and Data Collected

When setting up the Keeper app all of the following data and permissions are asked for before the app can be used and only collected when you, as a KEEPER, consent and allow these permissions on your device.

Location Information

The LUGGit Keeper App may collect, whenever you mark on the app that you are online or are performing a service, your precise or approximate location information as determined through data such as GPS, IP address, and WiFi. We collect this information when the app is running in the foreground (app open and on-screen) or background (app open but not on screen) of your device, only if you mark you status as online or are actively performing a service. We use this information to provide and improve the safety and security of our services. Given that the KEEPER is a professional, the data collected and processed by LUGGit is mandatory for the execution of the service provision given the signed contract. This location data is used to determine the location of the KEEPER and the merchandise being transported; to calculate routes and assignment of services; to calculate estimated times of arrival; to prevent, detect and combat fraudulent activities related to the use of our services; to optimize our services;

Device Information

The app may collect information about your device, including the hardware model, operating system and version, software, preferred language, unique device identifiers, advertising identifiers, serial number, device motion information, and mobile network information. We use this information to provide the service and improve the safety and security of our services.

Audio

The app may collect audio data when you use the app's voice communication feature. This data is used to allow you to communicate with the customer or with the LUGGit team. The microphone is only used whenever you, as a KEEPER, consent and allow this permission on your device and only when you are using the voice communication feature on the app, when requesting a call to the customer or to the LUGGit team and during the call.

Camera and Photos

The app may collect photos and videos when you use the app's camera feature. This data is used to allow you to take photos or videos of the merchandise to be transported. The camera is only used whenever you, as a KEEPER, consent and allow this permission on your device and only when you are using the camera feature on the app, when taking photos or videos of the merchandise to be transported.

Bluetooth

The app may collect information about nearby Bluetooth signals when you use the app's Bluetooth devices integration feature. This data is used to allow you to communicate available device integrations, such as printers, scanners, or other Bluetooth devices. The Bluetooth is only used whenever you, as a KEEPER, consent and allow this permission on your device and only when you are using the Bluetooth devices integration feature on the app.

6. Underlying purpose and basis of processing

The personal data processed by LUGGit is characterized by being: i) limited in nature, in that only personal data that is strictly necessary for the purpose in question is requested; ii) a specific purpose; iii) a legal basis/foundation that makes the processing lawful (such as: consent, conclusion of a contract, compliance with legal obligations or pursuit of the legitimate interests of the Data Controller).

The processing of data collected for account creation and any interaction, namely simple navigation on the Website or Mobile Applications, is necessary for the execution of a contract to which the data subject is party, from the moment the service is requested until to its conclusion and LUGGit may use the data collected for anything it deems appropriate for the correct execution of the same and, also, for the pursuit of the legitimate interests pursued by the controller or third parties, thus complying with the provisions of article 6 .º, no. 1, al. b) and f) of Regulation (EU) 2016/679 (“GDPR”), namely to maintain and improve the security and protection of our Users; to prevent, detect and combat fraudulent activities related to the use of our services; to optimize our services; for the purposes of research and analyzing usage trends to improve the User experience and improve the safety and security of our services, sharing information regarding legal actions or claim communications to protect the rights and safety of third parties

The processing of payment data, when implementing the purchased service, is justified under the terms of article 6, paragraph 1, al. b) GDPR.

The data provided by the User may not be used for any purpose other than those mentioned here unless the prior consent of the Holder is obtained.

The processing carried out by LUGGit does not subject Users to any decision taken exclusively based on automated processing, including profiling, which produces legal effects or significantly affects it.

7. Retention period

The data retention period varies according to the purpose for which the information is processed. Please know that you can delete all your personal data at any time and we will delete it in accordance with security and confidentiality rules. The personal data collected is kept for a period of five years from the date of obtaining your data , if at an earlier time, its deletion is not requested by the respective holder. Data collected based on pre-contractual measures and execution of the service provision contract will be kept for the period of time that the contract is in force, unless, due to legal imposition or compliance with a legal obligation, processing is necessary for a period of time. wider. As for payment data, these will be processed only for the purpose of issuing an invoice for the service provided, being destroyed after the legal obligation to maintain them ends (10 years), and transmitted to the competent legal authorities, due to legal obligation (Example: AT - SAFT ). No credit card data or payment data is stored directly, these are processed by stripe and paypal entities. As for the data for payment of remuneration to KEEPER, these will be destroyed after the legal obligation to maintain them ends (10 years), and transmitted to the competent legal authorities, due to legal obligation (Example: AT - SAFT). Regarding the KEEPER account, as soon as the service provision contract ends, it will be immediately deactivated. At any time you may cancel periodic direct communications , previously consented, from LUG Git and stop receiving them. To do so, simply click on the “unsubscribe” option in the communications you receive, which is generally available there. The option is available in all automated communications made via email. There is also the possibility for the user in the LUGGit app to configure and decide what types of communications they can receive on their profile. In relation to SMS and WhatsApp messages, there is also the possibility for the user to respond with STOP to numbers belonging to LUGGit and will no longer receive all types of communication made via SMS or WhatsApp.

9. Processing of Personal Data of Minors

The use of LUGGit's digital platforms, mobile application and website, is reserved for legal entities, when duly represented, and natural persons, over 18 years of age and with legal capacity to enter into contracts. As a rule, data from minors under 18 years of age is not collected or processed by any means. If, for any reason, this occurs, please be aware that the processing is only lawful if and to the extent that consent is given or authorized by the holders of parental responsibilities. In this case, LUGGit will make all appropriate efforts to verify that consent was given or authorized by the holder of parental responsibilities, taking into account available technology.

10. Transmission of Data to Third Parties

LUGGit uses third-party entities (subcontractors) that provide sufficient guarantees for the execution of appropriate technical and organizational measures in such a way that the processing meets the requirements of the GDPR and ensures the defense of the data subject's rights, namely:

  • Accounting office based at Parque da Ciência e Inovação, 3830-352 Ílhavo to execute the contractual terms from an accounting point of view.

The data may be transmitted to third parties due to legal requirements, or due to investigation by the competent authorities. We may have to transmit your data to third parties with inspection or other powers if, under the terms of the law, we are obliged to do so. In that case, we will inform you whenever we do so and on what terms.

With regard to the data of Users, considered as Customers, Keepers or Partners, these, for the purposes of executing the respective contract, may be transmitted to third parties subcontracted by LUGGit which will be, in a timely manner, known by the respective holders. Please be aware that LUGGit may also, anonymously, transmit personal data of its Users to:

  • Payment and invoicing processors and facilitators;
  • Security verification service providers;
  • Cloud storage providers;
  • Google and/or AWS servers;
  • data analysis providers;
  • Service providers encrypted communication, to be used during the provision of services;
  • Partners who help LUGGit improve the security of our website.

Some of the contact details made available by the CLIENT User on the APP and Website and accessible to KEEPER, may be used by them for the purposes of sending SMS or establishing telephone contact to confirm the place or time of departure and/or delivery or, even , to request more information about the required service.

11. Confidentiality

The confidentiality of all information transmitted by the User is guaranteed. LUGGit undertakes to protect the Information disclosed with great care and, for this purpose, has adopted necessary measures to prevent the use and dissemination of the Information by anyone other than itself, unless that person consents in writing to said disclosure, which will be carried out under the agreed terms. With regard to the data provided by Users, who wish to collaborate as Keepers or Partners, please be aware that compliance with the minimum requirements is assessed by a LUGGit team whose members are recognized as having high technical and professional competence for this purpose and who are committed to confidentiality obligations in compliance with the rules imposed in the context of the protection of personal data. The information disclosed on the website is the sole and exclusive property of the disclosing entity, or the property of whoever has authorized such disclosure, and LUGGit does not have any rights over any type of information that may be transmitted to it or to which it had access.

12. Personal Data Security

LUGGit uses several technical and organizational measures to protect the personal data of data subjects, depending on what is appropriate in the specific case: Pseudonymization and encryption of personal data; Ability to ensure the confidentiality, integrity, availability and permanent resilience of processing systems and services; Ability to restore availability and access to personal data in a timely manner in the event of a physical or technical incident; Implementation of a process to regularly test, assess and evaluate the effectiveness of technical and organizational measures to ensure the security of processing, among other measures that are considered appropriate and relevant on a case-by-case basis. If service providers are subcontracted, they will have to guarantee the same level of protection. The violation, or attempted violation, of personal data for which LUGGit is responsible will be reported to the judicial authorities, as well as control and supervision. If the breach poses a high risk to the holders of personal data, they will be informed of the incident.

13. Cookies Policy

LUGGit uses cookies and other identification technologies on the website for the following purposes:

  • Authenticate Users;
  • Remember User preferences and settings;
  • Determine the popularity of content;
  • Publicize and measure the effectiveness of marketing campaigns;
  • Analyze trends and traffic to gain a general understanding of the online behaviors and interests of people interacting with the Services. It may also allow other entities to provide measurement and analysis services to LUGGit, showing advertisements on the Internet on behalf of the brand and monitoring the performance of these advertisements. These entities may use cookies, web beacons, SDKs and other technologies to identify your device when you visit the website and use LUGGit services, as well as when the User visits other websites and online services.

Cookies are files with a small amount of data that are typically used as anonymous unique identifiers. These are sent to your browser from the websites you visit and are stored in your device's internal memory. This service does not explicitly use “cookies”. However, the page may use third-party code and libraries that use “cookies” to collect information and improve its services. The User has the option to accept or reject these cookies and know when a cookie is being sent to their device. If you choose to refuse LUGGit cookies, you may not be able to use some parts of the proposed service. This Cookies Policy is periodically reviewed, so its content may be updated.

14. Rights of Data Subjects

The exercise of rights and freedoms to data subjects is guaranteed, through the contacts set out below in this Privacy Policy, namely:

a) Right to information : consists of the User’s right to obtain clear and precise information regarding the way in which their personal data is processed and, also, what rights they have, which are, from now on, provided by this policy of privacy.

b) Right of access : consists of the User's right to access their personal data at any time and free of charge, with the exception of some cases in which we may charge administrative costs in accordance with the law. Any repetitive, unfounded or excessive requests will not be honored.

c) Right to rectification : consists of the User's right to request the rectification, completion or updating of personal data that is incorrect, incomplete or out of date, respectively and at any time.

d) Right to Erasure : consists of the User's right to have their personal data erased, as long as it is possible and LUGGit has no legal or legitimate reasons to continue processing them.

e) Right to limitation of processing : consists of the User's right to request limitation of the processing carried out on their personal data, when any of the following circumstances occur: 1) verification of the accuracy of personal data has been requested, 2) the User has objected to the processing of personal data, 3) the processing of their data has become unnecessary or 4) the processing is illegal.

f) Right to portability : consists of the User’s right, whenever possible, to request the transfer of their personal data to another Data Controller.

g) Right to withdraw consent : consists of the right to withdraw, at any time, the consent that was previously granted to LUGGit, making the processing of personal data carried out by it lawful. In this case, the method used to withdraw consent is the same as that used to give consent.

h) Right to lodge a complaint with the National Data Protection Commission (CNPD): If you consider that your rights have not been exercised, you can lodge a complaint with the CNPD (www.cnpd.pt).

15. Exercise of rights

In accordance with the provisions of Law No. 58/2019 and the GDPR, the User may exercise their rights of access, rectification, erasure, limitation, opposition and portability at any time, by requesting any of the following means:

Mail: Via do Knowledge, Central Building, Science and Innovation Park, 3830-352 Ílhavo, Aveiro, Portugal Email: dataprotection@luggit.app

If the User wishes, at any time, to stop being part of the LUGGit database, they may exercise this right through these contacts, providing their identification for this purpose.

16. Changes to the Privacy Policy and applicable legislation

This privacy policy may be frequently updated whenever justified by LUGGit and without prior notice, making you aware of the date of the last update, so you are advised to read it periodically. Our Privacy Policy was created in accordance with the provisions contained in REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free circulation of this data and which repeals Directive 95/46 / EC, which constitutes our reference framework and, also, Law no. 67/98, of 26 October, Personal Data Protection Law which continues to be in force in the our legal system until a law repealing it is approved, promulgated and published. Using the website and mobile applications assumes that you know and accept this Privacy Policy, as well as its Terms and Conditions of Use.

Last updated date: November 14, 2023