Privacy Policy

1.- IDENTIFICATION

By means of this Privacy Policy, the user (hereinafter, the “User” or, where applicable, the “Users“) is informed that the personal data provided through the application (hereinafter, the “APP“), as well as the data derived from browsing and any other data that may be provided in the future, will be processed by the owner of the APP as the data controller (City Group Co. KSCP ).

Depending on the territory in which the APP is used,City Group Co. KSCP(hereinafter, “CityLink Shuttle“), registered office at Sulaibiya Industrial Area, Block No. 2, Building No. 800100 Kuwait and e-mail care@citylinkmobility.com, will be the CONTROLLER, or another entity on behalf of which City Group Co. KSCP acts. Thus, when City Group Co. KSCP acts on its own behalf in a territory, it shall be CONTROLLER for the User’s personal data, while when it provides the service on behalf of another entity, the latter shall be the CONTROLLER and City Group Co. KSCP shall act as data processor.

In the event that an entity other than City Group Co. KSCP is the data controller, this will be specifically indicated in the Specific Terms of Use.

The User should carefully read this Privacy Policy, which has been drafted in a clear and simple manner, in order to facilitate its understanding, and the User may freely and voluntarily determine whether they wish to provide their personal data to the CONTROLLER and consent, where appropriate, to the processing of their data.

2.- NEED TO PROVIDE THE DATA

The data requested in the APP forms are, in general, obligatory (unless otherwise specified in the required field) in order to fulfil the purposes for which they are being collected.

Therefore, if they are not provided or are not provided correctly, the above mentioned purposes cannot be fulfilled, without prejudice to the fact that the User may freely view the content of the APP at any time.

The CONTROLLER informs the User that it is necessary to process their personal data, such as their telephone number, in order to provide the service and comply with the purposes of the processing listed in the following section. Information on the type of data processed, as well as any other information required by the applicable regulations, can be found throughout this Privacy Policy.

3.- FOR WHAT PURPOSES WILL THE DATA CONTROLLER PROCESS THE USER’S DATA?

The personal data provided through the APP will be processed by the CONTROLLER in accordance with the following purposes:

1. Management of the contractual relationship with the User for the purchase of goods or the contracting of services from the CONTROLLER

• Manage the registration of the User in the APP.
• Manage, process, send and follow up the contracting of goods or services offered by the CONTROLLER(City Group Co. KSCP).
• Manage the collection of the goods or services contracted by the User.
• Contact the User to help him/her to finalise the contracting of goods or services, or when the payment process has not been completed.
• Contact and/or determine the User’s position in order to agree on the place where the services are to be provided.
• Manage, process and respond to the User’s requests, applications, incidents or queries.

2. Internal reporting and analysis to improve the CONTROLLER’s goods, services and PPPs

• Analyse, manage and elaborate internal reports on User behaviour in order to implement improvements in the PPP.

3. Conduct quality and satisfaction surveys

• Conducting queries to Users regarding the quality and their satisfaction with the goods or services provided by the CONTROLLER(City Group Co. KSCP).
• Analysis of reports and statistics obtained from User responses.

4. Sending personalised commercial and promotional communications

• Sending of commercial and promotional communications through telematic or conventional means of goods and services identical or similar to those purchased or contracted from the CONTROLLER (City Group Co. KSCP).

4.- WHAT USER DATA WILL THE DATA CONTROLLER PROCESS?

The CONTROLLER (City Group Co. KSCP) will process the following categories of User data:

1. Management of the contractual relationship with the User for the acquisition of goods or the contracting of services from the CONTROLLER (City Group Co. KSCP).

• Identification data: name, surname and proof of identity.
• Contact details: telephone number, address and email address.
• Personal characteristics data: age.
• Transaction data of goods and services subscribed with the CONTROLLER (City Group Co. KSCP).
• Geolocation data
• Navigation data in the APP

2. Development of internal reports and analysis to improve the goods, services and PPP of the CONTROLLER.

• Identification data: name and surname.
• Contact details: telephone number, address and email address.
• Personal characteristics data: age.
• Transaction data of goods and services in the CONTROLLER(City Group Co. KSCP).
• Geolocation data
• Navigation data in the APP

3. Conducting quality and satisfaction surveys

• Identification data: name and surname.
• Contact data: telephone number and e-mail address.
• Transaction data of goods and services in the CONTROLLER(City Group Co. KSCP).
• Other data provided by the Users themselves in the open fields of the forms provided by the CONTROLLER (City Group Co. KSCP).

4. Sending of personalised commercial communications

• Identification data: name and surname.
• Contact data: telephone number and e-mail address.
• Transaction data of goods and services in the CONTROLLER (City Group Co. KSCP).

In the event that the User provides data of third parties, they declare that they have their consent and undertake to provide them with the information contained in the Privacy Policy, exempting the CONTROLLER from any responsibility in this regard. Nevertheless, the CONTROLLER will be able to carry out periodic verifications to verify this fact, adopting the corresponding due diligence measures, in accordance with the data protection regulations.

5.- WHAT IS THE LEGITIMACY OF THE PROCESSING OF THE USER’S DATA BY THE DATA CONTROLLER?

The legitimacy of the processing of your personal data will be as follows:

1. Management of the contractual relationship with the User for the purchase of goods or the contracting of services from the CONTROLLER:

All processing derived from this purpose will be based on the fulfilment of the contractual relationship.

2. Preparation of reports and internal analysis and implementation of improvements in the goods, services, APP of the CONTROLLER.

All processing derived from this purpose will be based on legitimate interest, recognised to the data controller by the regulations.

This legitimate interest is based on being able to offer Users both the goods and services of the CONTROLLER, as well as its APP with the highest quality and best possible experience.

3. Conducting quality and satisfaction surveys:

The processing derived from the carrying out of quality and satisfaction surveys will be based on the legitimate interest, recognised to the data controller by the regulations.

This legitimate interest is based on being able to offer Users both the goods and services of the CONTROLLER and its APP with the highest quality and best possible experience.

4. Sending personalised commercial and promotional communications

The processing derived from this purpose will be based on the legitimate interest, recognised to the data controller by the regulations, when the User registers in the CONTROLLER’s application.

This legitimate interest is based on the consideration of the interest of the Users as customers of the CONTROLLER to offer them goods and services through direct marketing.

On the other hand, the sending of commercial communications to non-registered Users, i.e. Users who provide their data through “Contact”, “Request a demo”, etc. forms, are based on the consent that is requested and can be withdrawn at any time.

The consents obtained for the aforementioned purposes are independent so that the User may revoke only one of them without affecting the others.

To revoke said consent, the User may contact the CONTROLLER via the corresponding email address depending on the territory in which they use the APP, as indicated in the Specific Terms of Use.

6.- WITH WHICH RECIPIENTS WILL THE USER’S DATA BE SHARED?

The User’s data may be communicated to:

• Public Administrations in the cases provided for by law.
• Courts and Tribunals in the cases provided for by law.
• The entities providing the service (City Group Co. KSCP, that form part of its business group) in each of the locations where the User requests the service, taking as a legitimate basis the execution of the contract.

7.- INTERNATIONAL DATA TRANSFERS

The CONTROLLER MAY carry out international data transfers. However, if the CONTROLLER starts to carry out international data transfers, it will regulate the international transfer in accordance with the provisions of the applicable regulations. For more information regarding possible international data transfers depending on the territory from which the User uses the APP, please consult the Specific Terms of Use.

8.- DATA RETENTION

The User’s data will be kept for the time necessary to fulfil the purposes set out in this Privacy Policy (unless a longer retention period is required by applicable law). In this sense, personal data will be kept for as long as the User has an account with the CONTROLLER. The personal data provided for the provision of the service will be retained for the time necessary to comply with legal obligations and until the prescription of the liabilities arising from them.

9.- GEOLOCATION

Some of the functionalities of the CONTROLLER APP allow the geolocation of the device from which it is accessed or on which it is installed (Tablet, Smartphone, etc.).

The User may disable this option directly on the device or browser itself, however, disabling this option may prevent the use of some of the functionalities of the APP.

For their part, the vehicles have a geolocation system aimed at providing Users with necessary and relevant information relating to the provision of services. The geolocation system integrated in the vehicle cannot be disconnected as it is necessary for the effective provision of the services, as well as for security reasons and to avoid illicit activities related to the vehicle.

10.- COMMERCIAL AND PROMOTIONAL COMMUNICATIONS

One of the purposes for which the CONTROLLER processes the personal data provided by the Users is to send them commercial communications with information relating to products, services, promotions, offers, events or news (their own and, where appropriate, those of third parties), relevant to the Users.

In the event that the User wishes to stop receiving commercial or promotional communications from the CONTROLLER, they can request cancellation of the service by sending an email to the corresponding email address depending on the territory in which they use the APP, as indicated in section Customer Service of the Specific Terms of Use, or by clicking on the link that will appear at the bottom of the commercial communications sent.

Under no circumstances will the CONTROLLER assume the consequences derived from third party promotions offered to the User (who has so consented) through its own means.

11.- RESPONSIBILITY OF THE USER

The User:

• Guarantees that they are over sixteen (16) years of age and that the data they provide to the CONTROLLER are true, accurate, complete and up to date. To this effect, the User is responsible for the veracity of all the data provided and will keep the information provided suitably updated, in such a way that it corresponds to their real situation. If the User is under sixteen (16) years of age, they will require the authorisation of their parents or legal guardian in order to use the APP. The CONTROLLER reserves the right to request additional information necessary to ensure compliance with this requirement.
• They guarantee that they have informed the third parties from whom they provide their data, if they do so, of the aspects contained in this document. Likewise, they guarantee that they have obtained their authorisation to provide their data to the CONTROLLER for the aforementioned purposes.
• The USER will be liable for any false or inaccurate information that they provide through the APP and for any damages, direct or indirect, that this may cause to the CONTROLLER or to third parties.

12.- EXERCISE OF RIGHTS

The User may send an email to the corresponding address depending on the territory in which they use the APP as indicated in section Customer Service of the Specific Terms of Use, attaching a photocopy of their identity document, at any time and free of charge, in order to:

• Revoke the consents given.
• Obtain confirmation as to whether or not the CONTROLLER is processing personal data concerning the User.
• Access their personal data.
• Rectify inaccurate or incomplete data.
• Request the deletion of their data when, among other reasons, the data are no longer necessary for the purposes for which they were collected.
• Obtain from the CONTROLLER the limitation of the processing of the data when any of the conditions provided for in the data protection regulations are met.
• Request the portability of the data provided by the User in those cases provided for in the regulations.

13.- SECURITY MEASURES

The CONTROLLER will treat the User’s data at all times in an absolutely confidential manner and will keep the mandatory duty of secrecy with regard to the same, in accordance with the provisions of the applicable regulations, adopting for this purpose the necessary technical and organisational measures that guarantee the security of the data and prevent its alteration, loss, processing or unauthorised access, taking into account the state of the technology, the nature of the data stored and the risks to which they are exposed.