Privacy Policy

Privacy Policy of the Simdle Rider Application

This privacy policy describes how personal data is processed when using the Rider application and its functions.

1. What is Personal Data?

Personal Data includes any information related to an identified or identifiable natural person, for example, their name, address, email address, or user behavior in relation to the Rider Application.

2. Responsible Body

The Rider Application and its backend system have been developed by Losch Digital Lab S. à rl with fiscal domicile at 5, rue des Joncs, L-1818 Howald Luxembourg for the entity ALSA GRUPO, SLU (hereinafter Alsa) with CIF B-82059478 and registered office at Calle Josefa Valcárcel, 20, 28027, Madrid, who acts as the Data Controller for the personal data provided by users while using the Application.

The manufacturer and service provider of the Rider application and the backend system to which it is connected, Cube4t8 Sarl, uses state-of-the-art technology and procedures to protect data in the aforementioned systems.

Contact details of the manufacturer and service provider:

Losch Digital Lab S.à rl

5, rue des Joncs

L-1818 Howald

Luxembourg

dpo-ldl@losch.lu

3. What personal data is collected? How is it used? What is the basis for its use?

App Installation

By installing this Rider application and registering for the service, the following information is collected:

• Email address (used for verification)
• Mobile phone number (used for verification)
• First Name
• Last Name (optional)

When you install this Rider application and log in, the following information is collected:

• Email address
• Encrypted credentials

This information is used for registration and authentication, as well as to verify the user's identity. The legal basis for this is Article 6, paragraph 1, point (b) of the GDPR (performance of a contract).

Use of the Application

When using the Application, the following personal data may be collected:

1. Location data

Location is optional and will only be used to automatically complete the origin location.

2. Device Information

IP address, device type, operating system, manufacturer, model number and version, and unique device identifiers such as your device ID, but not the IMEI. The Manufacturer collects this information automatically when you use its Services to diagnose problems and improve the Service. The legal basis for this is Article 6, paragraph 1 (b) of the GDPR (performance of a contract).

Google Firebase

The Manufacturer uses Firebase in the application. Firebase is a development platform for mobile and web applications that provides tools and infrastructure via a Software Development Kit (SDK). This allows the Manufacturer to simplify and make application functionalities more efficient. Firebase is a service of Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Firebase collects and processes your data. You can find more information about the management of user data in the Google™ privacy policy :

The manufacturer uses Firebase as follows:

4. Firebase Cloud Messaging

Firebase Cloud Messaging is used to transmit push messages, also known as in-app messages (messages only shown within the corresponding application). The end device is assigned a unique push reference, which serves as the destination for push messages within the application. Information on the functionality of Firebase Cloud Messaging can be found here: https://firebase.google.com/products/cloud-messaging

The Manufacturer uses Firebase Cloud Messaging to inform you about new bookings or cancellations via push notifications. This allows passengers to be connected with drivers and ensures the correct functioning of the application.

5. Anonymous usage logs

Depending on the system settings and the privacy conditions of your contractual partner, anonymous usage data may be collected so that we can improve our products and services. For more information, please refer to the specific terms and conditions as well as the privacy conditions of your contractual partner in the Application.

4. Will my data and information be shared with others?

Your personal data will not be transferred, sold, or otherwise passed on to third parties, except in the cases described in section 3 above, unless necessary for the purpose of processing the contract or if you have given your express consent to do so.

5. Is data also transmitted to recipients outside the European Union or outside the European Economic Area (EEA)?

The Manufacturer shares personal information anonymously with data controllers located in countries outside the EEA, in particular, data shared through Google Firebase with Google LLC and with Mapbox, both in the USA. In this case, the Manufacturer and your employer or contractual partner guarantee that the recipient has an adequate level of data protection (e.g., based on an Adequacy Decision by the European Commission, a self-certification by the recipient for the EU-US Privacy Shield, or standard contractual clauses of the EU).

The Manufacturer and your employer or contractual partner can provide you with a summary of the recipients in third countries and a copy of the regulations specifically agreed upon to ensure an adequate level of data protection. To do so, please use the contact information section.

6. How long will my data be kept?

Generally, your data will be deleted once the purpose for which it was stored has been fulfilled, unless deletion contravenes legal retention periods. Once the legal retention period has expired, the data will be deleted.

7. What rights do I have?

Under the GDPR, you have the right to information, rectification, portability, and erasure of your data.

If data processing is justified by the legitimate interests of the Manufacturer, you have the right to object to future data processing unless the data is absolutely necessary for the performance of your contract or the operation of the Application.

You have the right to lodge a complaint with a supervisory authority:

Without prejudice to the rights set out above, you have the right to lodge a complaint with a supervisory authority, in particular in the State where you reside, work, or where the alleged infringement occurs, if you consider that the processing of your personal data infringes the GDPR.

The supervisory authority, before filing the complaint, will inform the complainant about the course and outcome of the same, including the possibility of judicial appeal according to Article 78 of the GDPR.

8. Contact

ALSA GRUPO, SLU, CIF B-82059478 and registered office Calle Josefa Valcárcel, 20, 28027, Madrid; contact email address asesoria@alsa.es , contact details of the Data Protection Officer dpo@alsa.es

Terms and Conditions of Use of the Simdle Mobile Application (The Simdle Rider)

1. INTERVENING PARTIES AND PURPOSE

1.1. Parties

These Terms and Conditions regulate the relationship between:

• Application Provider: Cube4t8 Sarl, with domicile at 5, rue de Joncs, L-1818 Howald, Luxembourg, who is the developer and owner of the SIMDLE mobile application (hereinafter, the "Application" or "APP").
• The Transport Service Operator: S.A.U. ALSINA GRAELLS DE AUTOTRANSPORTES, with domicile in Barcelona, Calle Ali Bei, 80 -Bus Station- and NIF A25000050 (under the name, the “Operator”), which is the company holding the administrative authorization to provide the on-demand passenger transport service regulated in these conditions.
• The User: The natural person who downloads, registers, and uses the Application to request transport services.

1.2. Purpose

These Terms and Conditions have a dual purpose:

• To regulate the conditions for downloading, registering, and using the technological application owned by Cube4t8 Sarl, a technological platform that acts as a channel for managing seat reservations in the Transport Service.
• To inform about the general conditions of the public passenger transport service on demand in concession V-6480 (the “Transport Service”) provided by the Operator, which is requested and reserved by the User through the Application:

·  Geographic scope including: municipalities of Vinaixa, Tarrés, Fulleda, l’Espluga Calba, Els Omellons, La Floresta, Puiggrós, Miralcamp, La Pobla de Cérvoles, Vilosell, L’Albi, Cervià de les Garrigues, on journeys to Les Borges Blanques, capital of the Les Garrigues region, and Bovera, Bellaguarda, La Granadella, and Torrebesses, with journeys to Lleida.

·  Lines Involved: The service will be implemented within the scope of lines TAD1, TAD2, TAD3, and TAD4 of the Clic.cat les Garrigues system. Downloading and using the Application, as well as requesting a Transport Service, implies the full reading and acceptance of these Terms and Conditions by the User.

• The function of the Application is limited to connecting Users with the Operator to facilitate service booking. The transport contract between the User and the Operator will be perfected at the time of accessing the vehicle and paying the invoice directly to the Operator, not through the Application.

• Downloading and using the Application, as well as the reservation request, implies the full reading and acceptance of these Terms and Conditions by the User.

2. CONDITIONS OF USE OF THE APPLICATION

• Acceptance of Conditions: The installation and use of the Application implies that the User has read and fully accepts these Conditions.

• User registration and authentication: To use the service through the Application, users must register beforehand. During installation and registration, the following user information is collected for registration, authentication, and identity verification:

· Email address.

· Mobile phone number.

·  First Name.

·  Last Name (optional).

• Access to device information: When using the Application, device information such as IP address, device type, operating system, and unique identifiers is automatically collected to diagnose problems and improve the service (Art. 6.1.b GDPR).

• Use of location data: Location data is optional and only used to automatically complete the User's origin location.

•  Notifications:  The app uses Firebase Cloud Messaging to send push messages regarding bookings or cancellations.

3. SPECIFIC CONDITIONS OF THE ON-DEMAND TRANSPORT SERVICE

The Transport Service is provided by the Operator (S.A.U., ALSINA GRAELLS DE AUTOTRANSPORTES), contractor of the Generalitat de Catalunya concession V-6480.

3.1. Specific characteristics and operation of the Service on Demand

• Service Condition: If a trip has no reservations, the service will not be performed, preventing the vehicle from traveling empty.

• Optimized Routes: The vehicle will only follow the necessary routes based on demand.

3.2. Booking process, validation, and access to the service

3.2.1. Nature of the Reservation:

• Booking a trip through the Application is a preparatory and free act. Its purpose is to manifest the User's intention to use the service.

• Upon confirming a booking, a unique code will be generated. this code is the only title that entitles access to the vehicle to formalize the transport contract.

3.3. Rates and payments

Rates are the integrated fares officially approved by ATM Lleida, which can be consulted here .

Payment is made directly to the Operator's staff on board, not through the App.

3.4. Cancellation Policy and User Commitment

Flexibility:  Users can cancel at no cost. Please cancel at least 2 hours in advance. "No shows" cause serious harm to the service and the environment.

3.5. General Conditions

General conditions and user rights can be found here: https://atmlleida.cat/en/descripcion-y-funcionamiento-sti/

4. Intellectual Property

Developed by Losch Digital Lab S.à rl. Cube4t8 Sarl acts as the manufacturer and service provider.

5. PERSONAL DATA PROTECTION

For more information, see our Privacy Policy here .

6. LIABILITY

App Provider (Cube4t8 Sarl):  Limited to the correct functioning of the App platform.

Transport Operator (ALSINA GRAELLS):  Solely responsible for the correct provision of the Transport Service.

7. COMPLAINTS

•  App Issues:  soporte-drt@alsa.es.

•  Transport Issues:  https://www.alsa.es/en/help or ATM Lleida website.