1. Who is responsible for the Processing of your Data?

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR) Relating to the Protection of Natural Persons with regard to the Processing of Personal Data and the Free Circulation of this Data and by which Directive 95/46 / CE (General Data Protection Regulation) is repealed, we inform you of the following aspects:

Identity:	SCOOBIC URBAN MOBILITY SL
NIF / CIF:	B90427865
Postal Address:	Avda. de la Libertad 5-7, local 2– 41703 Dos Hermanas
Telephone:	+34 854.523.400
E-mail:	eortiz@scoobic.com

2. What personal data do we collect?

SCOOBIC URBAN MOBILITY SL, hereinafter “the company” or “this company”, informs you that we collect information about you, specifically:

• Identification data such as your name, surname and NIF / DNI,
• Postal or electronic addresses, such as your email address or your postal address;
• Your access data when you access our applications and websites;
• Economic data (billing information).
• Any other information necessary for the provision of our services and to respond to your requests.
• Our organisation does not process specially protected data.

The categories of data that are processed are:

o Identification data.

o Postal or electronic addresses.

o Personal characteristics.

o Social circumstances.

o Data related to health.

o Economic data.

o Payroll, Personnel and Human Resources data.

o Video surveillance.

In THIS COMPANY specially protected data is not processed.

The answering of our questionnaires and delivery of personal data on your part is not compulsory. However, the refusal of this will mean the non-provision or the impossibility of accessing the service for which they were requested. Likewise, data may be provided on a voluntary basis in order that the services offered can be optimally provided.

3. For what purpose do we process your personal data?

Your data will be collected exclusively for specific, explicit, and legitimate purposes, and will not be further processed in a way that is incompatible with those purposes. They will be treated in a lawful, loyal, and transparent manner in relation to the interested party.

In accordance with regulations, we identify the purpose and legal basis applied for the processing of said personal data in the following table:

	Purpose of the Treatment	Legitimation
1	Execute the contracts to which you are a party.	We consider that it is in our legitimate interest that our contracts are executed correctly and in the defense of our rights if necessary
2	Manage your personal account.	This treatment is necessary for the execution of the contract between you and our company.
3	Respond to customer requests for certain products and services.	This treatment is necessary for the execution of the contract between you and our company.
4	Send you commercial information about our products and services.	We believe that it is in our legitimate interest to keep our customers informed about our products and services, as it helps us to ensure the sustainability and development of our activities.
5	Manage promotional offers, contests or other promotional events.	This treatment is necessary for the execution of the contract between you and our company.
6	Respond to requests and complaints from our web pages.	This treatment is based on your consent.
7	Comply with any applicable law, court order, legal process, or the requirements of a regulatory body.	This treatment is necessary to comply with our legal obligations.
8	Enforce our legal rights and obligations and for any judicial procedure that involves it, initiated by or against it.	We consider that it is in our legitimate interest to protect our organization against the breach of a legal obligation incumbent on it and in the defence of our rights, in case of litigation.
9	Protect the rights of third parties.	This treatment is necessary to comply with the legal obligations to which our organization is subject. This treatment is also necessary for the legitimate interests pursued by our company. We believe that it is in our legitimate interest to ensure that our activities do not violate the rights of third parties.
10	In anticipation of and / or in connection with a commercial transaction such as a merger, acquisition, restructuring or sale.	We believe that it is in our interest to be able to make informed decisions about the future of our company in order to preserve and develop our business activities.
11	Comply with the legal obligations with the employees derived from the employment contract.	Compliance with a legal obligation
12	Development of the work activity of our employees.	Execution of a contract
13	Video surveillance	Fulfilment of a mission in the legitimate interest of guaranteeing the safety of people, goods and facilities in the treatment of images.
14	Detection of possible infected people and prevent their access to our facilities and their contact within it with other people.	Compliance with the legal obligation to guarantee the safety and health of workers. Fulfilment of a mission carried out in the public interest in the case of clients, suppliers and / or visitors.

In addition, we inform you in accordance with article 9.f of the GDPR, when specially protected data is processed, explicit consent is not necessary, when the treatment is necessary for the formulation, exercise, or defence of claims or when the courts act in the exercising of their judicial function.

4. How long will we keep your data?

The personal data provided will be kept for the duration of the contractual relationship and the corresponding legal terms according to Regulations expire.

Type of Data	Duration
Video surveillance	1 month
Fiscal and tax	4 years
Personal actions without special terms (Art. 1964, Civil Code)	5 years
Accounting books, Invoices (Art. 30, Commercial Code)	6 years
Prevención de Blanqueo de Capitales y Financiación del Terr.	10 años

5. What are your rights when you provide us with your data?

Current privacy regulations grant you the following rights in relation to your personal data. Below, we provide you with information about each of these rights:

• Withdrawal of consent. You can withdraw your consent to any processing of personal data based on your consent at any time. In no case, the legality of the processing prior to the withdrawal of your consent may affect such processing.
• Access. You can ask us to confirm whether we process your personal data and, as the case may be, inform you about the characteristics of such processing, allow you to access such data and give you a copy of it.
• Rectification. You can ask us to rectify or complete inaccurate or incomplete personal data.
• Cancellation (right to be forgotten). You can ask us to erase your personal data in the following cases: when it is no longer necessary for the purposes for which it was collected; you withdrew your consent; you objected to the processing of your personal data; your personal data has been unlawfully processed; or to comply with a legal obligation. We inform you that in some cases, we are not obliged to comply with your request, especially if the processing of your Personal Data is necessary to comply with a legal obligation or for the establishment, exercise or defense of our interests against legal claims.
• Limitation. You can ask us to limit the processing of your Personal Data (i.e. retain, but not use your Personal Data) when the accuracy of your Personal Data is questioned; the processing may be illegal, but you do not want it erased; it is still necessary to establish, exercise or defend legal claims; to verify the existence of compelling reasons after exercising your right of objection. We may continue to use your personal data after a request for limitation, in cases where: we have your consent; to establish, exercise or defend legal claims; or to protect the rights of another natural or legal person.
• Portability. You can request that we provide your Personal Data in a structured, commonly used, and machine-readable format, or you can request that it be ‘transferred’ directly to another controller. This right may be carried out in those cases in which the treatment is based on your consent or the execution of a contract with you, and in addition, the treatment has been carried out by automated means or methods.
• Right to object to processing justified on grounds of legitimate interest. When the processing is based on a legitimate interest (see section 3), you have the right to object to such processing. If you object, we must stop that processing unless we can demonstrate compelling legitimate reasons for the processing that override your interests, rights, and freedoms or where we need to process the data for the establishment, exercise or defense of legal claims.
• Right to object to treatment of data for the purpose of marketing. When we process your personal data for direct marketing purposes, you have the right to object to that processing at any time.

You also have the right to file a complaint with the Spanish Agency for Data Protection if you consider that the processing of your Personal Data violates applicable law.

To exercise the rights listed above, complete the form, and send it to the email address eortiz@scoobic.com, indicating in the subject field which right you wish to exercise. To verify the ownership of the data of the applicant, it will be necessary to attach a copy of the DNI of the person concerned in the exercising of their rights.

In accordance with article 12.5 of the RGPD, in case the requests are manifestly unfounded or excessive, especially due to their repetitive nature, we may charge a reasonable fee based on the administrative costs incurred to facilitate the information or communication or carry out the action that has been requested.

6. To which recipients will your data be communicated?

We can share your personal data with different types of companies in charge of the treatment, depending on our needs:

• Third party providers of other services (maintenance, hosting, payments, logistics, marketing services, etc.), for the purposes described in section 2;
• Our professional advisers such as lawyers and managers, auditors;
• Government or regulatory authorities with competence in the matters dealt with;
• Professional insurers or any other type of relevant insurers;
• Regulatory entities, AEAT and TGSS, Company Registry; and
• Bank entities.

Please note that this list is not exhaustive and that there may be other cases in which we share your data with third parties, when this is in the legitimate interest of our company, permitted by applicable law, or when it is necessary to comply with a legal obligation to which we are subject.

In this context, your personal data may be transferred outside the European Economic Area (EEA) to countries declared as having a suitable level and / or others that do not offer a level of protection of your personal data equivalent to that enjoyed in the EEA, such as the United States. In the absence of a decision on the suitability of the European Commission, the transfer of your personal data to these countries will be governed by clauses used in standard contractual agreements adopted by the European Commission.

In this way, we inform you that, in specific situations, your data could be transferred to countries that do not offer an adequate level of protection (China). This transfer will be made when necessary for the conclusion or execution of a contract, in the interest of the interested party, between the person responsible for the treatment and another natural or legal person (RGPD, Art. 49.c).

7. How have we obtained your data?

The personal data that we treat in THIS COMPANY have been obtained by various means of communication:

• Forms on this website, Google Forms, or on paper,
• phone calls,
• e-mail,
• Postal or electronic messaging,
• personal interview process,
• Public access sources,
• They have been delivered by hand by you yourself in various media.
• CCTV.

8. What security measures do we apply to your personal data?

We are committed to keeping your personal data safe. We have implemented appropriate security policies, technical and organisational measures to protect your information against: unauthorised access, improper use or disclosure, unauthorised modification, and unlawful destruction or accidental loss.

All our partners, employees, consultants, workers, and data processors, who have access and / or carry out processing of your personal data, are obliged to respect its confidentiality.

9. Contact information for the exercise of your rights

If you have any questions, comments, or concerns about the management of your Personal Data or about this Policy, please contact eortiz@scoobic.com.

10. Changes to this privacy policy

The terms of this Privacy Policy may be modified at any time. For example, to comply with new requirements that may be determined by reference laws, technical requirements, or good business practices. We will notify you in the event of significant changes to this policy.