In accordance with Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR” or “Regulation“), LimoLane S.r.l. provides all the information regarding the processing of personal data of NCC users who use the NCC ride marketplace service “LiMO” (“Driver“) through the “LiMO” App or the WebApp available on the website app.limo.global (“LiMO Service”).
1. Data Controller
1.1 The data controller of personal data is LimoLane S.r.l. (“LimoLane” or “Company“) with registered office in Cornaredo (MI), Via Per Monzoro n. 41/43, 20007, contactable at the email address firstname.lastname@example.org.
2. Collected Personal Data and Data Source
2.1 LimoLane processes the following personal data received from the NCC company (or, in the case of registration by an individual Driver, directly from the Driver) for the registration of the Driver to the LiMO Service and to enable the Driver to use the LiMO Service:
- Driver’s identification and contact details (e.g., name, surname, email address, phone number);
- Data related to the Driver’s NCC license (e.g., driver’s license, license number).
2.2 LimoLane also processes the following personal data received from the Driver to enable the Driver’s regular use of the LiMO Service:
- Geolocation data: Driver’s location data is detected throughout the duration of the ride and subsequently deleted;
- Any data on billing and payment made to the Driver by the passenger of the ride.
3. Purposes and Legal Basis of Processing
3.1 LimoLane will process personal data for the following purposes:
a) Purposes related to the use of the LiMO Service, particularly for:
- registration to the LiMO Service (via App or WebApp);
- managing the provision of the LiMO Service (e.g., ride acceptance and sending related service communications).
The legal basis for processing is the provision of the LiMO Service to Drivers, as regulated by the Terms and Conditions of use of the NCC Ride Marketplace Service contained in the “LiMO Application License Agreement” signed by the NCC company.
Providing the data is mandatory to use the LiMO Service, and refusal to provide the data will make it impossible to register for the LiMO Service and accept rides.
Data relating to each NCC ride performed by the Driver will be retained for 10 years from the termination of the contractual relationship with LimoLane, in compliance with the terms provided by applicable prescription regulations.
b) Sending informative and promotional communications related to the LiMO Service via email.
The legal basis for processing is LimoLane’s legitimate interest in ensuring that Drivers are always informed about commercial and/or promotional initiatives related to the LiMO Service (e.g., promotions related to the use of the marketplace, “refer a friend” initiative).
The data will be retained until the Driver objects.
In any case, Drivers can request to no longer receive these communications (opt-out) at any time by clicking on the appropriate link provided in each communication sent by LimoLane.
c) Marketing activities to promote LimoLane’s new initiatives and business partnerships.
Marketing activities may be carried out through the sending of communications via SMS, email, and/or phone calls with operators.
The legal basis for processing is the explicit and specific consent provided by the Driver at the time of first accessing the LiMO Service or subsequently through their personal area, which can be revoked at any time.
The data will be retained until consent is revoked.
d) Compliance with legal obligations, investigation, exercise, or defense of a right of LimoLane or third parties (e.g., handling of claims, disputes, judicial and/or transactional proceedings).
The data will be retained for 10 years to ensure compliance with LimoLane’s legal, judicial, and administrative obligations, as well as to manage LimoLane’s participation in any administrative and/or judicial proceedings.
e) Processing of aggregated statistical analysis related to the LiMO Service.
The data collected by LimoLane will be processed anonymously for the purpose of generating aggregated statistics related to the activities carried out within the LiMO Service.
The legal basis for processing is LimoLane’s legitimate interest in analyzing the functioning of the LiMO Service to improve its features and characteristics based on its usage.
4. Data Disclosure
4.1 The processing of personal data will be carried out, for the purposes indicated in paragraph 3 above, by LimoLane’s internal staff, expressly authorized to process personal data. Furthermore, personal data may be disclosed for the purposes indicated to the following subjects:
- Subjects who provide services on behalf of LimoLane, such as data processors (e.g., IT service providers);
- Public or private entities (e.g., insurance companies, banks, public authorities, judicial bodies, tax agency) that will process them as autonomous data controllers.
5. Territorial Scope of Processing
5.1 Personal data will not be transferred outside the European Economic Area.
6. Rights of Data Subjects
Drivers may exercise, in the cases provided by the Regulation, the following rights under Articles 15 and onward of the GDPR:
- Right of access: request confirmation of whether or not personal data is being processed and, if so, request access to the information concerning such processing from LimoLane;
- Right to rectification: request the rectification and integration of inaccurate or incomplete data;
- Right to erasure of data: request the erasure of data from LimoLane;
- Right to restriction of processing: request the restriction of processing;
- Right to data portability: request to receive, in a structured, commonly used, and machine-readable format, the data concerning them or to obtain the direct transmission to another controller, where technically feasible;
- Right to object: right to object, in whole or in part, for legitimate reasons and in cases provided by the GDPR, to the processing of data concerning them.
In accordance with Article 7 of the GDPR, Drivers may revoke consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Drivers can exercise the aforementioned rights by sending a communication to the email address email@example.com.
Furthermore, if a Driver believes that their data has been processed unlawfully, they may lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).