Provision of the Public Guagua Taxi Service by the Vega de San Mateo City Council approved under Ordinance No. 3,628 of the Illustrious Vega de San Mateo City Council (Official Bulletin of the Province of Las Palmas, Number 116. Friday, September 26, 2025).

Privacy Policy

Privacy Policy for the Simdle Rider Application

This privacy policy describes how personal data is handled when you use the Rider Application and its features.

1. What is Personal Data?

Personal Data includes any information relating to an identified or identifiable natural person, for example, your name, address, email address, or user behavior in connection with the Rider Application.

2. Responsible Body

The Rider Application and the backend system were developed by Losch Digital Lab S.à r.l. with its registered office at 5, rue des Joncs, L-1818 Howald Luxembourg for the entity ALSA GRUPO, S.L.U. (hereinafter Alsa) with tax ID 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 when using the Application.

The Manufacturer and service provider of the Rider Application and the backend system it is connected to, 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 r.l.

5, rue des Joncs

L-1818 Howald

Luxembourg

dpo-ldl@losch.lu

3. What personal data is collected? How is the collected data used? On what legal basis is the use founded?

Application Installation

When you install this Rider Application and register for the service, the following information about you is collected:

  • Email address (used for verification)
  • Mobile phone number (used for verification)
  • First and Last Name
  • City Hall ID number (optional)

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

  • Email address
  • Encrypted credentials

This information is processed for registration and authentication purposes, as well as for user identity verification. The legal basis for this is Art. 6 para. 1 (b) of the GDPR (performance of a contract).

Application Usage

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

1. Location data

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

2. Device information

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

3. Google Firebase

The Manufacturer uses Firebase within the application. Firebase is a development platform for mobile and web applications, which provides tools and infrastructure through a Software Development Kit (SDK). This allows the Manufacturer to make the application's functionalities simpler and 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 handling of user data in the Google™ privacy policy:

The Manufacturer uses Firebase in the following way:

4. Firebase Cloud Messaging

Firebase Cloud Messaging is used to transmit push messages or so-called in-app messages (messages that are only displayed within the respective application). The end device is assigned a pseudonymized push reference, which serves as the destination for push or in-app messages. You can find information about the functionality of Firebase Cloud Messaging here: https://firebase.google.com/products/cloud-messaging

The Manufacturer uses Firebase Cloud Messaging to provide you with information about a new booking or cancellation via a push notification. This allows the Manufacturer to connect passengers with drivers and ensure the application's performance.

5. Anonymous usage logs

Depending on the system settings and the data privacy conditions of your contractual partner, anonymized usage data may be collected to allow us to improve our product and services. Please refer to the specific terms and conditions, as well as the privacy conditions of your contractual partner in the Application for more details.

4. Will data and information about me 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 paragraph 3 above, unless it is necessary for the purpose of contract processing or you have given your express consent for it.

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

The Manufacturer shares personal information in an anonymous or pseudonymized form with processors located in non-EEA countries, 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 ensure that the recipient has an adequate level of data protection (e.g., based on an Adequacy Decision of the EU Commission for the respective country, a self-certification by the recipient for the EU-U.S. Privacy Shield, or an agreement between the recipient and the European Union on Standard Contractual Clauses).

The Manufacturer and your employer or contractual partner can provide you with a summary of recipients in third countries and a copy of the regulations specifically agreed to ensure the adequate level of data protection. Please use the contact information in the contact section for this purpose.

6. How long will my data be stored?

Your data will generally be deleted once the purpose for which it was stored has been fulfilled, unless the deletion is contrary to legal retention periods. After the expiration of a legal retention obligation, the data will be deleted.

7. What rights do I have?

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

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

Your right to lodge a complaint with a supervisory authority: Without prejudice to the rights established above, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, place of work, or the place of the alleged infringement, if you consider that the processing of your personal data infringes the GDPR.

The supervisory authority with which the complaint has been lodged will inform the complainant about the course and outcome of the complaint, including the possibility of a judicial remedy under Article 78 of the GDPR.

8. Contact

ALSA GRUPO, S.L.U., tax ID 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 for the mobile application

TERMS AND CONDITIONS OF USE FOR THE SIMDLE (OR SIMDLE RIDER) MOBILE APPLICATION

1. INTERVENING PARTIES AND OBJECT

1.1. Parties

These Terms and Conditions regulate the relationship between:

  • The Application Provider: Cube4t8 Sarl, with its registered office at 5, rue de Joncs, L-1818 Howald, Luxembourg, which is the developer and owner of the mobile application SIMDLE (hereinafter, the "Application" or "APP").
  • The Transport Service Operator: The Vega de San Mateo City Council through five Municipal Taxi Licenses (LM2, LM5, LM6, LM7, and LM9) that are holders of the administrative authorization to provide the public passenger transport service called Guagua Taxi regulated in these terms.
LICENSE NAME D.N.I. ADDRESS
LM2ADAY SANTANA SANTANA78489694DC/LA PALMA, 26 VEGA DE SAN MATEO
LM5JUAN WENCESLAO SANTANA CÁRDENES78470001GC/LA YEDRA, 22 VEGA DE SAN MATEO
LM6EZEQUIEL QUINTANA GUTIÉRREZ78474226CCTRA. ARÍÑEZ, 12 VEGA DE SAN MATEO
LM7CARLOS VALIDO MARRERO42841191BEL MESÓN, 62 LA LECHUZA
LM9JOSÉ MIGUEL GUTIÉRREZ RODRÍGUEZ43763745NLAS MESETAS, 5 LA LECHUZA
  • The User: The natural person who downloads, registers, and uses the Application to request the Guagua Taxi transport services.

1.2. Object

These Terms and Conditions have a twofold objective:

  • 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 transport service for passengers on demand in the VCM-103 concession (hereinafter, the "Transport Service") provided by the Operator, which is requested and reserved by the User through the Application:
    • Geographical area covered: Four routes that will operate from the villages to the center of the municipality of La Vega de San Mateo and from the center to the villages for travel between the user's home and the urban center of Vega de San Mateo, or vice versa.
    • Lines Involved: The service will be implemented in the scope of lines Route 1 "Aríñez (Risco Prieto, Galas, Aríñez, Las Sequeras y el Piquillo)", Route 2 “Cruz de Tejeda” (Crus de Tejeda, Las Lagunetas, Cueva Grande, Camaretas, Casa de la Cal, La Asomada, La lechuza), Route 3 “La Hiedra” (La Yedra, Cruz del Herrero, Lomo Carbonero, La Solana, Los Corraletes, Utiacas, La Asomada) and Route 4 “La Bodeguilla” (La Bodeguilla, El Chorrillo, La Lechucilla, La Higuera, Lomo Caballo). The download and use of the Application, as well as the request for a Transport Service, imply 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 the reservation of the service. The transport contract between the User and the Operator will be finalized at the time of accessing the vehicle and paying the ticket directly to the Operator, not through the Application.
  • The download and use of the Application, as well as the request for a reservation, imply the full reading and acceptance of these Terms and Conditions by the User.

2. CONDITIONS OF USE OF THE APPLICATION

  • Acceptance of the Conditions: The installation and use of the Application imply 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 the installation and registration in the Application, the following User information is collected for the purpose of registration, authentication, and identity verification:
    • Email address.
    • Mobile phone number.
    • First and Last Name.
    • City Hall ID number (optional).
  • Access to Device Information: When using the Application, device information is automatically collected, such as the IP address, device type, operating system, manufacturer, model, and version number, as well as unique device identifiers (excluding the IMEI). This information is used by the Manufacturer to diagnose problems and improve the service. The legal basis for this is the performance of a contract (Art. 6 para. 1 (b) of the GDPR).
  • Use of Location Data: Location data is optional and will only be used to autocomplete the User's origin location.
  • Notifications: The Application uses Firebase Cloud Messaging to send push or in-app messages to the User's device. These messages are intended to provide information about new reservations or cancellations, allowing the Manufacturer to connect passengers with drivers and ensure the Application's performance.

3. SPECIFIC CONDITIONS OF THE ON-DEMAND TRANSPORT SERVICE

The Transport Service is provided by five operators of the municipal Taxi licenses of the Vega de San Mateo City Council (LM2, LM5, LM6, LM7, and LM9) under the authorization of the San Mateo City Council in collaboration with the General Directorate of Transport of the Government of the Canary Islands and is governed by the following conditions:

3.1. Specific Characteristics and Operation of the On-Demand Service

This transport system seeks to optimize resources and reduce environmental impact, adapting to the real mobility needs of users.

  • Service Conditionality: If a trip has no reservations, the service will not be carried out, preventing the vehicle from traveling empty.
  • Optimized Routes: If there are reservations, but they do not affect all the locations of the service, the vehicle will only travel the necessary routes, avoiding unnecessary kilometers by not going to locations with no demand.

3.2. Reservation, Validation, and Service Access Process

3.2.1. Nature of the Reservation:

  • The reservation of a trip through the Application is a preparatory and free act that does not imply the contracting of the transport service. Its purpose is to manifest the User's intention to use the service on a specific date and time, allowing the Operator to plan the route efficiently.
  • Users, previously registered, may request the service directly through the SIMDLE app. Upon confirming a reservation, a unique reservation code will be generated and associated with the User's account (identified by their first and last name). This code is the only title that grants the right to access the vehicle to formalize the transport contract.
  • Additionally, the operating company will have a BackOffice application and a telephone service center through which it will also be possible to make reservations.

3.2.2. Process of validation and perfection of the Transport Contract.

To use the service, the User must present themselves at the indicated stop and time and show the reservation code to the driver. The driver will verify the validity of the code.

The transport contract is perfected exclusively on board the vehicle, at the moment the User, once their reservation has been validated, pays the ticket price or validates their transport pass (subscription) directly with the Operator's staff. The confirmation of the reservation in the App does not in any case imply payment for the service or the issuance of a ticket.

3.3. Fares and Payment

The service fares are those officially approved by the Vega de San Mateo City Council by virtue of Municipal Ordinance No. 3,628 published in the Official Bulletin of the Province of Las Palmas, (no. 116, September 26, 2025) stated in its article 6:

“The amount of the patrimonial service will be 1.50 euros per trip and user. This amount will be collected directly by the vehicle owner who performs the service, on behalf of the Vega de San Mateo City Council.”

The transport contract is formalized and the payment of the ticket is made directly to the Operator's staff on board the vehicle, not through the Application. The confirmation of the reservation through the App does not imply the collection of any amount by the Application Provider.

3.4. Cancellation Policy and User Commitment.

Flexibility and Cancellation: Users can make reservations until 13:00 on the day before the day of the requested service, which must be within the following hours: From 09:00 to 13:00 and from 16:00 to 20:00 from Monday to Friday. Users cannot make reservations more than 3 days in advance of the service day. To guarantee the correct planning and sustainability of the service, the User is requested to cancel as far in advance as possible. The User can cancel any reservation made through the Application at no cost before 2 hours from the start of the service.

Users who make three cancellations after 2 hours from the start of the service without justification, or incur three "no-shows" (not showing up at the agreed time and place) in a 90-day period, may have their access to the reservation system temporarily blocked for a period of 15 days, as a measure to protect the efficiency and availability of the service for the rest of the community.

The temporary blocking measure described in the previous section will not be applied when the late cancellation or the "no-show" is due to a justified cause, understood as an unforeseen, unpredictable, inevitable, and external circumstance that prevents the User from using the service.

By way of example and not limitation, the following will be considered justified causes:

A sudden, serious medical emergency of the User or a first-degree family member that requires their indispensable attention.

Fulfillment of an unavoidable public duty notified after the reservation was made (e.g., a member of a polling station, a court summons that cannot be postponed).

A serious accident or breakdown on the way to the pickup point that objectively prevents arriving on time.

Officially declared force majeure situations that directly affect mobility in the area (e.g., extreme weather conditions, road closures).

For the cause to be considered justified, the User must:

Notify the Operator of the cancellation and the reason for it as soon as possible, through the enabled contact channels.

Provide documentary evidence that justifies the alleged circumstance (e.g., medical certificate, official summons, accident report) within 72 hours from the date of the canceled service.

The Operator will evaluate the provided documentation and inform the User if the justification has been accepted. Forgetfulness, errors in personal planning, normal traffic, or any other circumstance that does not have the character of being unpredictable and inevitable will not be considered justified causes.

Commitment to the Sustainability of the Service: The on-demand transport service is based on the optimization of routes from confirmed reservations. The User's non-presentation at the agreed place and time without having canceled the reservation ("no-show") or the cancellation without the recommended notice, causes a serious prejudice to the Operator and the rest of the users, since:

  1. It prevents other passengers from using the seat.
  2. It forces the vehicle to make unnecessary trips, increasing the environmental impact and operational costs.

Therefore, by accepting these Terms and Conditions, the User understands the collaborative nature of the service and commits to making responsible use of the reservation system, canceling those they will not use as soon as possible. The use of the platform is based on the principle of good faith contractual.

3.5. General conditions for the use of the Transport Service

The general conditions for the use of the Transport Service, as well as the rights and obligations of interurban transport users can be consulted here: https://www.crtm.es/normativa

4. INTELLECTUAL PROPERTY

The Simdle Rider Application and the backend system were developed by Losch Digital Lab S.à r.l.. Cube4t8 Sarl acts as the Manufacturer and service provider of the Application and the backend system it is connected to.

5. PERSONAL DATA PROTECTION

Personal Data Collected and its Use:

  • During installation and registration: The User's email address, mobile phone number, first name, and last name (optional) are collected for registration, authentication, and identity verification purposes. Upon logging in, encrypted credentials are collected.
  • During Application use:
    • Location data: This is optional and is used solely to autocomplete the origin location.
    • Device information: This includes the IP address, device type, operating system, manufacturer, model, version number, and unique device identifiers (excluding IMEI). This information is collected automatically to diagnose problems and improve the Service.
    • Google Firebase: The Manufacturer uses Firebase, a development platform for mobile and web applications, which collects and processes User data to make the application's functionalities simpler and more efficient. More information on data handling by Google™ is available in its privacy policy.
    • Firebase Cloud Messaging: It is used to transmit push or in-app messages (messages that are only shown within the application) to inform the User about new reservations or cancellations.
    • Anonymous usage logs: Depending on the system settings and the contractual partner's privacy conditions, anonymized usage data may be collected to allow for product and service improvement.
  • Data Retention: Data will generally be deleted once the purpose for which it was stored has been fulfilled, unless the deletion is contrary to legal retention periods.
  • User Rights (GDPR): The User has the right to information, rectification, portability, and erasure of their data. If the data processing is justified by the Manufacturer's legitimate interests, the User has the right to object to the data processing for the future, unless the data is absolutely necessary for the performance of the contract or the operation of the Application. Furthermore, the User has the right to lodge a complaint with a supervisory authority, especially in the Member State of their residence, place of work, or the place of the alleged infringement, if they consider that the processing of their personal data infringes the GDPR.
  • Additional information: For more information on the use of your data, please consult our Privacy Policy "Here”.

6. RESPONSIBILITY OF THE PARTIES

Responsibility of the Application Provider (Cube4t8 Sarl): Cube4t8 Sarl's responsibility is strictly and exclusively limited to the proper functioning of the Application as a technological intermediation platform for managing reservations. This includes the availability of the APP service, the security in the processing of personal data in accordance with data protection regulations, and the correct transmission of service requests to the Operator. Cube4t8 Sarl will not be responsible for any incidents related to the provision of the Transport Service (delays, accidents, driver behavior, vehicle condition, etc.), as it is not the provider of said service.

Responsibility of the Transport Service Operator (Municipal Taxi Licenses (LM2, LM5, LM6, LM7, and LM9): The Operator is solely and fully responsible for the proper provision of the Transport Service. Their responsibility covers all obligations arising from the transport contract formalized with the User.

7. COMPLAINTS

The User may file their complaints and claims through the following channels, depending on their nature:

  • Incidents with the Application: For any technical or operational problem with the APP, the User should contact the following email address: soporte-drt@alsa.es
  • Incidents with the Transport Service: For any complaint or claim about the transport service (delay, cancellation, improper charge, loss of objects, driver's treatment, etc.), the User should contact the Operator via the following email address: fundacionnosmovemos.canarias@alsa.es
  • The Operator will respond to complaints within a maximum of 30 days. This is without prejudice to the User's right to appeal to the Transport Arbitration Boards or the competent consumer authorities.