SMART TD PRIVACY POLICY

The respect of the users privacy, and protection and security of their personal data, is a compromise of INTERFACOM, S.A.U., which is the company that develops and maintains the SMARTTD application. The names INTERFACOM S.A.U. and SMARTTD can be henceforth be used indistinctively for the purposes of this privacy policy.

This privacy policy informs the user on the way in which SMARTTD gathers, treats and protects the personal data which are provided through the application. The user must read this privacy policy carefully, and determine freely and voluntarily if they accept the SmartTD policy on the usage of their personal data.

The user also guarantees that they are older than eighteen years of age, and that the data provided are true, exact, complete and updated, being the user responsible for any damage, direct or indirect, which may result as a consequence of the lack of compliance of that obligation.

  1. Data protection and Responsability

SMART TD implements the measures and data protection security levels required by the EU General Data Protection Regulation 2016/679, of 27 April 2016, and other applicable normatives. Personal data gathered through this application are treated automatically and are incorporated into a file which is responsability of INTERFACOM, S.A.U., society constitued according to Spanish legislation, with C.I.F. A-58225137 and company address in Alejandro Sánchez 109, 28019 – Madrid, Spain.

For any reason related to the present SMARTTD privacy policy, you can contact INTERFACOM, S.A.U. through its postal address in ALEJANDRO SANCHEZ, 109, 28019 – Madrid, or by email at privacidad@flexitrongroup.com

  1. Personal data gathering and finality

SMARTTD uses the following personal data of its user:

  • SMARTTD application user identification
  • Position of the vehicle on which SMARTTD is being used. The position can be sent to the server both when the application is on the front, as when the application is on the background
  • Phone number of the driver (optional)

SMART TD will utilize the user data for the following specific finalities:

  • User code to access the application. The main finalities of this personal data are:
    • Manage and control the access to the application
    • Manage and control access to services provided by server applications to the SMARTTD app
    • Register logs for diagnostic
  • Position of the vehicle in which the application is installed. The position of the vehicle is sent to the fleet management central as long as the user keeps the application active, whether it is on foreground or on the background. The main use cases of the vehicle position are:
    • Feeding the calculation algorithm that determines which is the most adequate taxi for each trip, in function of its proximity to the position of the pickup address.
    • Once the trip has been accepted, allow for the customer to see the position of the taxi as it is approaching the pickup address.
    • Georeferencing the position at the beginning and/or end of the taxi trip if it has not been received from the fleet management central, to obtain the trip pickup and dropoff address, in order to print it on the taxi trip receipt for the customer.
    • Register the position of the taxi for its supervision in case of emergency, accident or dispute with the customer, or if it’s required by any local regulator or the police.
    • Register logs for diagnostic and improvement of the quality of service
  • Personal phone number of the driver (optional). The main finality of this personal data is the following:
    • When the taxi receives a trip, if the driver is outside of the taxi and at that moment does not have access to the device on which SMARTTD is installed, the SMARTTD application can start an automatic phone call to the driver’s personal phone number. This way the driver will know that they have to come back to the taxi to accept and perform the trip.
  1. Sensitive App Permissions

SMARTTD uses the following permissions to access personal data on the user device:

  • Permission to access background location.
    • The main application is to send the position to the radiotaxi central, which uses this data to feed the algorithm that determines which is the most adequate taxi for each trip, in function of its proximity to the position of the pickup address.
    • The location is necessary both when the application is on the foreground and on the background, as the taxi sends its position to be elligible for taxi trips on the central, even if the driver is using a different application on the foreground, or if the device’s screen is locked
    • SMARTTD uses the fine location, in order to assure the maximum possible accuracy of the position of the taxi when calculating the optimal trips assignment.
  • Permission to make a phone call automatically:
    • When the taxi receives a trip, if the driver is outside of the taxi and at that moment does not have access to the device on which SMARTTD is installed, the SMARTTD application can start an automatic phone call to the driver’s personal phone number. This way the driver will know that they have to come back to the taxi to accept and perform the trip.
  1. Legitimacy

The legal base for the treatment of your data is based on your consent, and on the need to perform the services for which you contracted SMARTTD.

  1. Professional secret

The User ID and password of a user are strictly personal, and must not be given to third users. It is the sole and exclusive responsibility of the user to maintain the confidentiality and security of his/her access data to the application.

  1. Sharing data with third parties

SMART TD does not sell, rent or share personal data of its customers or users to any third party. Some data like vehicle positions may be processed for anonimyzation and to build statistics, and the information derived from this process may be provided to regulators where required. SMART TD may disclose personal data collected by legal mandate, in the framework of a judicial process or in the case of a request from a public authority.

  1. User Rights

At any moment the user will be able to exercise their rights to access, rectification, cancellation, opposition,  and limit usage of their data, through the postal address or the SMARTTD email previously stated, in the terms established in the current regulation.

In any case, the user is informet that, in case they consider that SMARTTD has infringed the rights which are recognized by the applicable regulation on data protection, they will be able to place a complaint before the adequate Control Authority, which is the Spanish Data Protection Agency.

  1. Withdrawal of consent

The user has the right to withdraw their consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. To withdraw their consent, users can contact with SMARTTD through the previously stated postal address or email.

  1. Data storage time

SMART TD shall keep the data of their users stored only during the time necessary to perform the services for which it has been contracted. Unless it is required by law to keep them for a longer period of time.

  1. Changes in the Security and Data protection Policy

SMART TD has the right to modify its security and data protection policy, at any moment and without previous warning, while always being in compliance with the Spanish legislation on data protection.

In case of such modification, SMART TD will inform the user of the changes if they are significant for his/her privacy, so that the user can review the changes introduced in order to assess the opposition to the processing of personal data or unsubscribe from the service or from any functionality. However, if consent is required for purposes other than those set out in this privacy policy, the user’s consent will be requested in accordance with the provisions of the data protection regulations current at any given time.