At KIT CERVICOS, UNIPESSOAL LDA, a limited liability company with registered office at Rua Zeca Afonso, n.º 10, Loja Esquerda, District: Lisbon County: Loures Parish: Santa Iria de Azoia, São João da Talha e Bobadela, 2690 - 395 Santa Iria de Azóia with Registration Number/NIPC: 518217566, hereinafter referred to as COMPANY or WE53, with connection to WE53CY LIMITED (Republic of Cyprus) and website www.we53.io we respect your privacy and are committed to protecting your personal data. In this Privacy Policy, we will describe how we will use, process and store any personal data that we collect from you or that you provide to us, either through our Website or through our mobile application. We will also inform you of your privacy rights and how the law protects you.
When you use our Services, you are entrusting us with your information. We understand that this is a great responsibility and we work responsibly and committedly to protect your information.
Our website https://we53.io/ ("Site") in accordance with the Terms and Conditions/Public Offering Agreement WE53;
our services accessible through the WE53 mobile application ("Mobile Application") after you have downloaded a copy of the mobile application to your mobile device ("Device");
our services accessible through the Power Bank Rental Station ("Station") – a device that provides the issuance and reception of Power Banks to you
This Policy aims to provide you with information about how we collect and process your personal data through your use of our Website, mobile application or Station, including any data you may provide when you purchase a service, sign up for our newsletter/email, participate in a contest or survey. We may also obtain and use information about you that is provided by third parties. Our website, mobile app or Station are not intended for children and we do not knowingly collect data relating to children.
If you have any further questions, you can contact our Data Protection Officer (DPO) at the following email address: compliance@we53.io
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 on the free movement of such data (General Data Protection Regulation - "GDPR") gives you the right to view, delete or amend the data we hold about you (among other rights). Our support team or DPO can help with any questions you may have regarding your data. Please read the full Privacy Policy for more details on how we use your information.
Our Website and mobile application use cookies to distinguish you from other Users. This helps us to provide you with a good experience when you browse our Website and mobile application and allows us to improve the functionality of our Website and mobile application and the User experience. Please see our Cookie Policy on the Website and mobile app for more details.
In this Privacy Policy, WE53 will sometimes be referred to as "we", "us" or "our". In addition, there are references to "You". In these cases, "You" may be a visitor to our Website, or a User of our mobile application or Station and its services ("User").
Data Controller
For the purposes of the GDPR, the data controller is KIT CERVICOS, UNIPESSOAL LDA, a limited liability company with registered office at Rua Zeca Afonso, n.º 10, Loja Esquerda, District: Lisbon County: Loures Parish: Santa Iria de Azoia, São João da Talha e Bobadela, 2690 - 395 Santa Iria de Azóia with Registration No./NIPC: 518217566.
Data Protection Officer
We have appointed a Data Protection Officer, who has a number of important responsibilities, including:
monitor WE53's compliance with GDPR and other data protection laws;
raising awareness of data protection issues, training WE53 staff and conducting internal audits; and
cooperate with supervisory authorities, such as the National Data Protection Commission (CNPD).
If you have any questions about this Privacy Policy, including any questions or guidance for exercising your legal rights, please email us at compliance@we53.io
Complaints
You have the right to file a complaint at any time with the National Data Protection Commission (CNPD) with a web site https://www.cnpd.pt/. We would, however, like to have the opportunity to analyse your matter beforehand and try to find the best solution, so we suggest that you contact us in the first instance.
To be clear and there are no misunderstandings about how we process your personal data, we will:
Always keep your data safe and private.
Refrain from selling your data.
To enable you to manage and review your marketing choices at any time.
INFORMATION WE COLLECT ABOUT YOU
We may collect, use, store, and transfer different types of personal data about you, which we have grouped together as follows:
Information Submitted – information you provide to us through direct interactions:
This is information that you provide to us about yourself by filling in forms on the mobile app, the Station and/or the Website, or by contacting us (e.g. by email or via the chat functions on the mobile app and/or the Website).
This includes information you provide when you register to use the mobile application, download or register the mobile application, subscribe to any of our Services, enter into any order or transaction on the mobile application, participate in discussion forums or other social media functions on the mobile application or website, participate in a contest, promotion, or survey, and when you report a problem with a mobile application or the services.
The information you provide to us may include your email address, phone number, transaction information (payment details, payment amount, cardholder name, first 6 and last 4 digits of the card, bank name, payment processing system, identifier of a particular card number, such as card ID, Payment Token, Fingerprint).
Information we collect about you and your Device.
Device information - each time you visit the mobile app or our website, we will automatically collect the following information:
technical information, including the Internet Protocol (IP) address used to connect your Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, Device information, and the type of mobile device you use, a unique identifier of the Device (e.g., the IMEI number of your Device, the MAC address of the Device's wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting, geolocation data;
information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through, and from our website (including date and time), services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse swipes), methods used to navigate away from the page;
transaction information, also collected through a Station (If you pay our fees with a credit or debit card, your credit or debit card information is provided directly to the following third-party payment processors to process payments):
STRIPE
Payment information is transmitted directly over a connection encrypted by you to STRIPE. STRIPE processes and stores your personal data and payment information in accordance with STRIPE's privacy policy available at https://stripe.com/privacy. WE53 does not collect or store your payment information. STRIPE claims that it is PCI compliant, and you can learn more about STRIPE's security measures available at https://stripe.com/docs/security);
details of your use of our mobile application or your visits to our Website.
Third-party information: information to help us provide you with our service.
Third-party providers are not managed or controlled by the Company, and this Privacy Policy does not apply to third-party providers. The Company is not responsible for the content, privacy policy, or actions of third-party providers. You have the right to study and understand the privacy policy of any third-party provider before providing you with any information on or through them. Your interaction with these features is governed by the privacy policy of the third-party provider providing this feature.
Through the website, we use an analytics service provider, such as Google Analytics, which collects cookie information, such as your IP address and browsing information. Please refer to our Cookie Policy on the Website and mobile application for details on how data is collected and processed by these third parties and for instructions on how Users can opt out of using these features.
Through the mobile application, we use analytics, marketing analytics, and ad service providers, which collect mobile identifier information. This is a unique, anonymized, user-resettable ID for advertising and analytics, as an Android Advertising Identifier (provided by Google Play services) and an Identifier for Advertisers (IDFA) provided by Apple):
Amplitude - a service to analyze user behavior in mobile applications (For more information about Amplitude's privacy practices, please see https://amplitude.com/privacy);
To opt in to cross-app tracking and use your device ID:
If your phone uses Google Play services, you can manage your Google apps and services in Google Settings here https://support.google.com/android/answer/3118621?hl=en or within your Device, in the Settings section > Security & Privacy > Privacy > Other privacy settings > Ads, OR
If you use an iPhone, go to Settings > Privacy > Tracking. Here, make sure to enable Allow apps to request to track OFF.
USES MADE OF INFORMATION
Below is a summary of the main types of data we use as part of the WE53 services. For more information about how these types of data are used and for what purposes, see the table below.
We use the information held about you in the following ways:
(a) Information Submitted: We will use this information:
to perform our obligations arising from any transactions you enter into with us and to provide you with the information and services you have requested from us;
to notify you about changes to our services; and
to ensure that content on our Website or mobile application is presented in the most effective manner for you and your Device.
(b) Device Information: We will use this information:
to administer our Website and mobile application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
to improve our Website and mobile application to ensure that content is presented in the most effective manner for you and your Device;
to allow you to participate in interactive features of our service, when you choose to do so;
as part of our efforts to keep our Website and mobile application safe and secure;
to measure or understand the effectiveness of the advertising we display to you and others, and to provide you with relevant advertising.
(c) Information from Third Parties: We will use this information to:
make decisions about whether you agree to approve the application, website, or mobile service.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this policy for as long as it is combined.
Below, in table format, we provide a description of all the ways in which we use your personal data, as set out above, and what legal bases we rely on to do so. We also identify what our legitimate interests are, where appropriate.
Please note that we may process your personal data for more than one lawful reason, depending on the specific purpose for which we are using your data.
What we use your information for
Type of Information
Our reasons
Our legitimate interests
To provide the WE53 services:
To fulfill our obligations in any contract you have entered into or will enter into with us. Including:
To provide you with access to WE53 platform and to enable your interaction with WE53;
To provide customer service;
Processing and delivering your order; and
Collecting and recovering money owed to us.
Submitted Information
Fulfilling contracts
Our legitimate interests
Consent
Legal obligation
Being efficient about how we fulfill our legal and contractual duties.
Our commercial interest in providing you with a good service.
To keep the WE53 services up and running:
To administer our Website and the Mobile application for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; to ensure that content from our site is presented in the most effective manner for you and for your Device;
To allow you to participate in interactive features of our service (such as prize draw, competition or completing a survey), when you choose to do so;
To notify you about changes to our service and legal binding documents; and as part of our efforts to keep our Website and the Mobile application safe and secure.
Submitted Information,
Device Information,
Third Party Information
Fulfilling contracts
Our legitimate interests
Consent
Being efficient about how we fulfill our legal and contractual duties.
Our commercial interest in providing you with a good service.
What do we mean when we say:
Legitimate interest: means our interest as a company in conducting and managing the WE53 platform to enable us to provide you with the WE53 services. We make sure that we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted by law).
Performance of a Contract: means processing your data where this is necessary for the performance of a contract to which you are a party or to take steps at your request prior to entering into such a contract.
Consent: This means that we will only process your personal data for certain specific purposes if we have obtained your consent prior to such processing, for example, to collect and process your location data and/or to send you notifications. We usually ask for your consent to the use of your personal data to provide you with our services when you download the mobile app. Please note that if you do not provide your consent to do so, or withdraw it at a later stage, we may not be able to provide you with our services.
Opt-out. You can follow the opt-out links in any marketing message sent to you. In the case of Third-Party Information collected through cookies, you have the right to opt-out through the opt-out options provided by the relevant third party. For more information, please see the Cookie Policy.
Change of purpose. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in accordance with the rules above, where required or permitted by law.
RETENTION OF YOUR INFORMATION
We retain your information for as long as necessary for the performance of the contract we have with you. If you no longer want us to use your information, you can send a request to compliance@we53.io. Please note that in this case, we may not be able to provide you with our services or may be limited in providing our services.
STORAGE SECURITY
The hosting facilities for our website, mobile application and station infrastructure are located in the EU.
The data we collect about you will be transferred to and stored at a destination within the European Economic Area (EEA).
All information you provide to us is stored on our secure servers. Any transmission of information is encrypted using TLS technology, the current standard in secure communications over the Internet. Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our website; Any transmission is at your own risk.
Once we receive your information, we will use strict procedures and security features to try to prevent unauthorized access.
YOUR LEGAL RIGHTS
You have rights under data protection laws in relation to your personal data. For more information on these rights, please see below:
Right of access – You have the right to request copies of your personal data from us.
The right to rectification – You have the right to request that the Company correct any information that you consider to be inaccurate. It includes the right to request the Company to complete information that it considers to be incomplete.
The right to erasure – You have the right to request that the Company erase your personal data, under certain conditions.
The right to restrict processing – You have the right to request that the Company restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to the processing of your personal data by the Company, under certain conditions.
The right to data portability – You have the right to request that the Company transfer the data we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you.
INFORMATION FOR CHILDREN
WE53 does not knowingly collect any personal data from children under the age of 16. If you think that your child has provided this type of information to the Company, we strongly encourage you to contact us immediately and we will make our best efforts to promptly remove this information from our records.
CHANGES TO THE PRIVACY POLICY
Any changes we may make to our Privacy Policy in the future will be posted on our Website or mobile application and, where appropriate, notified by email.
Please check back frequently to see any updates or changes to our Privacy Policy.
