PRIVACY POLICY OF DRIVESMART

1. What is the company responsible for processing your data?

The company responsible for processing your data (the “data controller”) is DRIVESMART TECNHOLOGIES S.L., of Spanish nationality, domiciled in Calle del Príncipe de Vergara, 57, Esc. A, piso 1ºB, 28006 Madrid, with Tax I.D. B-84755743 and registered with the Commercial Register of Madrid in Volume 22952, Page 100, Section 8, Sheet M-411087, Entry 1 (hereinafter, “DriveSmart”).

DriveSmart takes the protection of your privacy and personal data very seriously. Therefore, order to secure your data, DriveSmart complies fully with applicable law regulating the protection of personal data.

This Data Protection Policy governs the access to and use of the services provided by DriveSmart to Internet users (hereinafter, the “Users”) interested in the services (the “Services”) and content (the “Content”) hosted in the mobile application :DriveSmart and the Website http://drive-smart.com (hereinafter, the “Websites”).

2. Why is :DriveSmart legitimized to process your data?

The User data provided through online registration forms available on the Websites are collected by DriveSmart with the purpose of providing the Services offered on each Website.

Under the provisions of applicable privacy law and its implementing regulations, :DriveSmart, as holder of the Websites, hereby informs the User of the existence of an automated personal data file which has been duly registered with the General Register of the Spanish Data Protection Agency (Registro General de la Agencia Española de Protección de Datos). Said data file has been created by DriveSmart under its own responsibility.

3. What is the purpose of the processing of your personal data by DriveSmart?

DriveSmart may collect personal data of the Users by means of registration forms. The personal data collected by

DriveSmart may be used for the following purposes:

i. To provide the services offered on the Website.

ii. To deliver commercial communications to the Users by post, telephone, email, SMS/MMS, instant messaging or other equivalent means of communications in connection with the services of DriveSmart, provided that the User has previously consented thereto.

Furthermore, Users consent to the processing of their data for the purpose of making profiles (by using profiling techniques such as Geolocation, among others), as well as for the automated segmentation of their data. The purpose of said processing may be both the review and preparation of statistics of the traffic in and use of the Website by Users and the determination of the tastes and preferences of Users with a view to providing them with promotional communications which are in accordance with their interests.

4. Compulsory or optional nature of the information provided by the User and veracity of the data supplied

The User hereby guarantees the veracity of the personal data supplied and undertakes to communicate to DriveSmart any changes in said data. The User shall be responsible, in any event, for the veracity of the data supplied, and DriveSmart reserves the right to exclude from the services any Users who may have supplied false data, without prejudice to any other actions which may be brought under the law.

It is recommended that Users protect their data with utmost diligence by using appropriate security tools. DriveSmart will not be liable for any unlawful theft, amendment or loss of data.

5. Forbidden practices and data preservation

DriveSmart will cancel the registration of any Users who may:

(i) include or promote unlawful, immoral, obscene or harmful materials;

(ii) promote any form of discrimination;

(iii) send bulk, junk or spam e-mail or unsolicited newsgroup communications;

(iv) infringe any third-party intellectual or industrial property rights.

Furthermore, the User undertakes not to use or collect data from distribution lists obtained through the information and services included on the Website for the purposes of carrying out promotional or advertising activities, and not to send commercial communications of any type through any unsolicited media, unless said communications have been previously approved by DriveSmart and/or the users of the Website.

Personal data supplied by the Users will be retained by DriveSmart with the purpose of providing them with information about the company’s products insofar as the they do not state their wish to unsubscribe from DriveSmart’s services.

6. Rights of the Users in connection with their data

Users are entitled to:

(i) access their personal data;

(ii) request the rectification of any inaccurate data;

(iii) request the erasure of their data;

(iv) request that the processing of their data be limited;

(v) object to the processing of their data;

(vi) exercise their right to be forgotten;

(vii) request the portability of their data.

In order to exercise said rights, Users must provide proof of their identity by sending a photocopy of their Spanish I.D. or any other documents approved by law for this purpose.

Users may exercise these rights by writing to the following email address info@drive-smart.com and stating the reasons for their request.

Alternatively, they may send their request by mail to the following address:
DRIVESMART TECNHOLOGIES S.L.
Calle del Príncipe de Vergara, 57, Esc. A, piso 1ºB. CP: 28006, Madrid.

Without prejudice to any other administrative and/or judicial actions which may be at their disposal, Users shall be entitled to file a claim before the Supervisory Authority, in the Member State where they have their usual residence or their workplace or in the place where any alleged infringement has taken place, if they consider that their personal data has not been processed in accordance with applicable regulations and/or if they have been prevented from exercising any of their rights. The Supervisory Authority receiving the claim shall inform the claimant of the situation and result of the same.

7. Data security

The protection of the privacy and personal data of its clients is very important to DriveSmart. Therefore, DriveSmart uses all its best efforts to prevent your data from being used inadequately. Only authorized personnel have access to your data.

DriveSmart keeps personal data protection security levels as provided by applicable regulations and has implemented all technical means at its disposal to prevent any loss, misuse, alteration, unauthorized access to and/or theft of the data provided by the Users through its Website, without prejudice to informing Users that security measures on the Internet are not impregnable.

DriveSmart undertakes to comply with its duty to maintain the secrecy and confidentiality of personal data as provided by applicable law, and to keep the security of any international data assignments and/or transfers which may take place, if applicable.

8. Further information

Should you need any further information about this privacy policy, do not hesitate to contact us by email at info@drive-smart.com

9. Acceptance and consent

The User hereby declares that he/she has been informed of the terms and conditions applicable to the protection of personal data, and accepts and consents to the automated processing of said data by DriveSmart as and for the purposes stated herein.