MY FREE HANDS® PRIVACY POLICY FOR USERS

1. What is the purpose of this Policy?



So you can quickly and concisely see how we use the personal data we have about you. You can view additional information about this and the other sections of the Policy by clicking View More.



2. Who are we?



Secure Drive Empire, S.L, treats your personal data as the controller, i.e. we are jointly responsible for how your personal data is used and protected. See more.



3. Where do we get your Data?



(i) From yourself, as you provide us with certain information when you create a user account; (ii) from information we obtain from your use of MY FREE HANDS® and (iii) from social networks. See more.



4. What do we use your Data for?

To (i) provide you with our driver-driven vehicle reservation service (the "Service"); (ii) only if you wish, to send you news and promotions from MY FREE HANDS® based on your profile (if you connect to the WiFi network of the vehicles, also from third parties); to (iii) improve our service; to (iv) prevent fraud and to (v) consult your opinion about MY FREE HANDS®. See more.



5. For how long?



Until you delete your user account or request the cancellation of your personal data. Third party promotions will be sent only while you are using MY FREE HANDS® services. See more.



6. Why is it legal for us to use them?



For various reasons. First, because we need to use them to enforce the Terms and Conditions you agree to with us when you create an account; otherwise, we cannot provide the Service to you. Second, we send you news and promotions about MY FREE HANDS® or third parties only when you authorize us to do so. Finally, we try to improve our Service, prevent fraud and conduct market research because we believe that we have a legitimate interest in doing so and that it is also in your best interest. See more.



7. Do we share your Data with third parties?



Yes, we share your personal data (i) with the companies in which they work, (ii) with other entities of the MY FREE HANDS® group, (iii) with external suppliers who help us with different issues related to the Service and (iv) with public authorities or bodies. In some cases, these third parties are located outside the European Union, but the transfers of your Personal Data are carried out with adequate guarantees: either we have signed with these entities Standard Contract Terms approved by the European Commission or they are adhered to the Privacy Shield. See more.





8. What are your rights?



You can ask us to access, rectify, delete or transfer your personal data. You can also file a complaint with the competent data protection authorities. In some cases, you may also object to our use of your data or ask us to limit its use. Read more.



9. Will we modify this Policy?



We may do so in the future, but we'll let you know before it affects you. See more.







1. What is this Privacy Policy for?



At MY FREE HANDS® group we are committed to providing you with an optimum service, facilitating your urban and interurban journeys in conditions of maximum quality, comfort and respect for the urban environment and the environment. Furthermore, we are also concerned about the privacy of your personal information. We want you to know and always have control over your personal data. To this end, we make this Privacy Policy (the "Privacy Policy") available to you, in which you can consult in detail, but in an easy and transparent manner, the characteristics of the use we make of your personal data in order to provide you with our Service and for other purposes.

You can access this Privacy Policy at any time, as it is available in the "Privacy" section of the MY FREE HANDS® website (www.myfreehands.com ) and the mobile application (MY FREE HANDS®). On the Website, the "Privacy" section is at the bottom, while in the Application it is accessible from the menu that you can display by tapping on the circle at the top left of the screen. When we use the term "Platform", we mean both the Website and the Application.



2. Who is the person responsible for the processing of your Personal Data?



Secure Drive Empire, S.L. is responsible for the processing of your personal data:



Secure Drive Empire, S.L., the Spanish parent company ("MY FREE HANDS® Matriz").



- Postal address: Avda Meridiana 354, 9º C 08027 Barcelona.



In other words, MY FREE HANDS® Matrix is responsible for your Personal Data. This is because we decide how we use and protect your Personal Data. The roles and responsibilities of MY FREE HANDS® Matrix in using and protecting your Personal Data are clearly defined. If you wish, you can ask us to provide you with the essentials of this through the Help Center located on the Website and on the Application.



3. Where do we get your Personal Data? What exactly will we use?



Please note that, in order for you to enjoy the Service we offer you at MY FREE HANDS®, we will use some data about you that we obtain through different ways and at different times. Below, you can see it in detail:



1. We will use the personal information you provide when creating a user account: name and surname, password, e-mail address, telephone number, postal address, country, banking information and date of birth.



2. We will also use other information about you that we learn from your use of the Service: your location; your IP address; the ID code we assign to you internally; your navigation of the Platform (dates and times you access it, clicks you make, etc.) and the hardware, software and browser you use.



3. Finally, we will obtain information from different social networks, which will provide it to us if you have authorized it by accepting their corresponding terms and conditions.



We use the term "Personal Data" to refer to all of the above information and any other information we have about you.



4. What will we use your Personal Data for?



We will use your Personal Data for the following purposes:



1. Providing you with service



The processing of your Personal Data is necessary for us to provide you with our Automatic Instant Messaging Service and its reply. Otherwise, you will not be able to enjoy it. The provision of the Service includes the following issues:



- Manage the creation of your user account and allow you to use or modify it. To enjoy the Service, you must create an account and identify yourself as a user. You can modify the Personal Data you have provided at any time through the "My Account" section included in the drop-down menu.

- Allow you to listen to and reply to messages you receive via instant messaging.

- Provide you with the email address that you have given us with the invoices for the subscriptions that you have made.

- To offer you the best care and assistance. Through our Help Center we offer you assistance at any time for any doubts, comments, suggestions or incidents related to the Service you want to ask us. This help can only be provided if we have your Personal Data.

- Any other matter related to the provision of the Service.



2. Carrying out marketing actions



We will use your Personal Data to send you news, products and promotions related to MY FREE HANDS® and to third parties related to the product and consumption sectors. To this end, we will analyze the frequency with which you use the Service, your sociological profile and your personal interests and we will create a profile about you so that the promotions we send you are personalized, so that they are adapted at all times to your personal needs and preferences. Please note that you can ask us at any time to stop analysing your profile, although this will mean that you will not receive any more news, offers and promotions. The profile we create about you will not be used for any purpose other than to customize our promotions.

We will also send you communications from third parties on sectors related to products and consumption that we believe may be of interest to you according to your profile if you specifically consent to it. We will only send you these communications if you also use the MY FREE HANDS® WiFi service. Please note that you can use the WiFi service without accepting to receive communications from third parties.

In any case, please note that you can unsubscribe from such communications at any time. To do so, you will simply have to click on the "Unsubscribe" link contained in any of the communications.



3. Improve our service



In MY FREE HANDS® we work permanently on the improvement of the Application and the Website and, for that reason, we carry out tests, investigations and analytical studies and develop new products that end up improving the quality of the Service. They allow us to optimize it, make it more functional and adapt it to your needs (by offering you, for example, the option to enter your preferences, the chosen configuration or your frequent places). Such tasks often require the use of some of your Personal Data.



4. Preventing fraud



To prevent potential fraud against you and MY FREE HANDS®, we have implemented measures that make our Platform a safe place. For example, we will ask you to validate your account by entering a code that you will receive by SMS and, in some cases, we will ask you to send us a picture of your ID. Also, when we detect irregular charges or information, we will contact you to make sure everything is correct. In some cases, we may need to disclose information about your travels to your payment provider(s) in order to resolve possible disputes.



5. Offering you third party products or services



In the event that you connect to the MY FREE HANDS® network through the Platform, we may offer you products or services from third parties that are close to you, if you consent to this.



6. Ask your opinion about MY FREE HANDS®



It is very useful for us to know what your opinion is about MY FREE HANDS® in order to make strategic decisions that make us a company aligned with the interests and concerns of our users. Therefore, at some points we may ask you to respond to a simple survey to find out what your perception of us is.

Please note that we are interested in knowing the opinion of our users in a statistical way. Therefore, when we receive your opinion we will proceed to pseudonymize it, that is, your answers will only be associated with a code. Later, we will give the pseudonymized information to the entity that helps us to carry out these studies so that they can analyze it together with the opinions of many other users and can elaborate a statistical study about the image and perception that you have about MY FREE HANDS®.

Of course, you won't have to give us your opinion if you don't want to.



7. Corporate client users



In cases where you use the Service through your company's corporate account with MY FREE HANDS®, we will share your payment information with your employer.



5. How long will we keep your Personal Data?



The period of conservation of your Personal Data depends on each of the purposes for which they are used. You can consult them in detail in section 4. In the following table we indicate for how long or until when we will keep your data in relation to each of the purposes:



1. Providing you with service

We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to treat your Personal Data for this purpose. Please note that if there are any unresolved issues relating to the Service, we will attempt to resolve them before you can unsubscribe.



2. Carrying out marketing actions

We will use your Personal Data until you ask us to stop, regardless of whether you continue to use our Service or have unsubscribed. Please note that you can ask us to stop sending you news, offers and personalized promotions at any time by simply clicking on the "Unsubscribe" link contained in any of our communications.



3. Improve our service

We will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to treat your Personal Data for this purpose.



4. Preventing fraud

As above, we will use your Personal Data until you decide to stop using our Service, for which you must delete your user account. As long as you do not unsubscribe, we will continue to treat your Personal Data for this purpose.



5. Offering you third party products or services

We will use your Personal Data for this purpose for as long as you use the MY FREE HANDS® network.



6. Ask your opinion about MY FREE HANDS®

We will use your Personal Data until the entity that helps us carry out the statistical studies sends us the corresponding study.

When the times indicated in the above table arrive, we will not directly delete your Personal Data; we will keep them duly blocked and protected during the time in which responsibilities may arise from the processing or during the periods required by any applicable regulations. During that time, your Personal Data will not be processed for any purpose other than to meet such possible liabilities or to comply with such legal obligations. Consequently, only the same members with special capacity of MY FREE HANDS® and the members of the computer department will be able to access to attend such responsibilities or legal obligations. Once these possible actions are prescribed and the legal obligations mentioned expire, we will proceed to remove your Personal Data definitively without further delay.



6. Why is it legal for us to use your Personal Data?



At MY FREE HANDS® we only use your Personal Data in a legal way, as required by the applicable regulations. To do so, we need to have a sufficient legal basis. Next, we indicate you which is the legal base, that is to say, for what reason it is licit, that we use your Personal Data for each one of the purposes described in the previous section.



1. Providing you with service

The use of your Personal Data is necessary in order to execute the contract that links us to you from the moment you accept our Terms and Conditions. Otherwise, you will not be able to enjoy the Service.



2. Carrying out marketing actions

We will use your Personal Data to send you news, offers and promotions based on your profile only if you have given us your consent to do so. The communications we send to you may be via email, SMS or even through push notifications. Please note that you can ask us at any time to stop sending you these personalized communications.



3. Improve our service

We consider that in MY FREE HANDS® we have a legitimate interest to carry out tests, investigations and analytical studies that improve the quality of our Service, allowing us to make it more functional and to adapt it to your needs. In our opinion, this treatment also benefits you directly, since you will be able to enjoy a Service that solves your needs with greater precision.



4. Preventing fraud

We also understand that we at MY FREE HANDS® have a legitimate interest in trying to prevent potential fraud related to the Service. This treatment is positive for MY FREE HANDS® and also for you, as it will allow us to use procedures that try to prevent fraudulent use of the Service. For example, a third party trying to use your bank details or making charges unrelated to your subscriptions, etc.



5. Offering you third party services and products

We will only process your data for this purpose if you give us your consent before using the MY FREE HANDS® network by accepting the Terms of Use of the MY FREE HANDS® service. This MY FREE HANDS® network service is an extra that aims to make your trips more comfortable. However, the use of the MY FREE HANDS® network is completely voluntary, so you can always use the Service without connecting to it.



6. Ask your opinion about MY FREE HANDS®

We believe that we have a legitimate interest in knowing the perception you have about MY FREE HANDS®, as it will allow us to make strategic decisions that fit the needs and concerns of all our users. Furthermore, we understand that the use of your Personal Data for this purpose is compatible with the provision of the Service.



7. Will we share your Personal Data with third parties?



Yes, in order to provide you with the Service with the highest quality, we need to share your Personal Data with the entities in which we work, with other entities of the MY FREE HANDS® group, with external suppliers that help us with different issues related to the Service and with third parties. Below, we indicate who these entities are:



1. Entities of the MY FREE HANDS® group. We need to give or allow access to your Personal Data to different entities of the MY FREE HANDS® group in order to correctly develop the Service. The entities that make up the MY FREE HANDS® group are listed below:

- Empire External Services, S.L.

- Secure Drive Empire, S.L.

- Empire Influex Center, S.L.



2. Entities that help us with different issues related to the Service. We ensure that all our suppliers who may have access to your Personal Data act in a confidential, loyal manner and scrupulously comply with applicable data protection regulations. To this end, we require them to enter into specific agreements with us governing their use of your Personal Data. Some of our main suppliers are the following:

- Entities providing data processing services. At MY FREE HANDS® we use third parties to execute and process payments you make in connection with the Service. These parties collect your credit or debit card information (such as card type and expiration date) and other financial information that we need to process your payment. We may also collect information such as your zip code, mobile phone number and details of your transaction history. Processing of all of these is necessary to process the payment. Finally, you provide us with other information about you such as a unique token that allows you to make additional purchases using previously stored information.

- Storage service provider. This entity helps us to store your Personal Data and other information related to the Service safely.

- Entity providing services for carrying out surveys or market research. We rely on this entity to carry out statistical and market studies on the valuation of MY FREE HANDS®. As we told you in section IV, all the Personal Data we can share with you are pseudonymized, so when you make your analysis you will not know who is behind each opinion.

3. Public authorities or bodies for the development of their functions. On some occasions, the regulations oblige us to transfer your Personal Data to public authorities or bodies so that they can carry out their functions. For example, tax authorities or judicial authorities. In this way, they will use them for their own purposes.

Notwithstanding the fact that the country in which you are located is outside the European Economic Area, we wish to inform you that some of the above entities are located in or can access your Personal Data from countries which, in the opinion of the European Commission, do not provide a level of protection for them similar to that which exists in the European Union. We are aware that these countries do not provide a comparable level of protection because the European Commission has not approved an "adequacy finding". In these cases, transfers of your Personal Data are in any case carried out with adequate guarantees to protect their security:

- We have sometimes signed Standard Contract Clauses approved by the European Commission. You can consult its contents in the following link

- On other occasions, our suppliers have adhered to the Privacy Shield, about which you can find more information at the following link



8. What are your rights in terms of data protection?



As a user of MY FREE HANDS®, you have a number of rights so that you can decide and control how we use your Personal Data at all times. You can exercise these rights at any time and free of charge (unless your request is excessive or unfounded - it will be unfounded, for example, if you have just exercised the same right before MY FREE HANDS® very recently; in that case we may reject your request or charge you, always with prior notice, a fee). To exercise one of your rights, you must simply do so through the Website Help Center and on the Application. In order for us to process your request, we need to be sure that it is really you, so you will need to provide us with a copy of your identity document, and we would also appreciate it if you could tell us which right you wish to exercise. If your application does not meet the above requirements, we will ask you to correct it.

In particular, you have the following rights



1. Access. You may ask us to tell you whether or not we are using your Personal Information; if we are, we will also provide you with additional information such as what Personal Information we have about you, what we are using it for, the entities with which we share it, the period for which we will retain your information, or whether we are profiling, among other things.



2. Rectification. You can ask us to modify some of the Personal Data we have about you so that they are accurate and up to date. In fact, please note that you should always keep the Personal Information in your user account up to date. You can do this in the "My Account" section accessible from the drop-down menu.



3. Suppression. You may request that we delete Personal Data held about you (i) when it is no longer needed for the purpose for which we use it, (ii) when you withdraw your consent, in the event that we only process it for purposes based on it.



4. Limitation. You may ask us to temporarily restrict the use of your Personal Data (i) where you believe that your data is inaccurate, until we verify or update it (please note that in the meantime you will not be able to enjoy the Service); (ii) when we no longer need it to carry out the purposes set out in paragraph 4 above but you prefer that we keep it so that you can exercise or defend yourself against claims and (iii) when you object to us using your data for any of the purposes set out in paragraph 4, number 2 of this Privacy Policy, while we assess whether the legitimate interest we have in MY FREE HANDS® outweighs your right to object to us using it.



5. Portability. You may request that we deliver directly to you or to another entity, whenever technically possible, a structured file, of common use and legible by a computer system, containing the Personal Data related to the trips you have made with the limit indicated in section 4 of this Policy, as well as any other information related to the provision of the Service.



6. Claim. You can file a complaint with the competent data protection supervisory authority. In your case, the competent authorities are the following: - Spanish Data Protection Agency:



7. Opposition. You may object to us using your data for any of the purposes set out in number 2 of section 4 of this Privacy Policy. We would especially like to remind you that you can ask us to stop analyzing your profile in order to send you promotional communications.



9. Will we be updating this Privacy Policy?



It's possible. Please note that if for any reason we decide to make any changes to our Privacy Policy, we will inform you promptly before the changes become applicable. This way you will know how we intend to use your Personal Information before we begin to do so.



10. What are Cookies?



Cookies are small text files that are stored locally in the memory of web browsers. This helps us to offer a better service to our users. By way of example, the use of cookies allows us to understand how a user navigates our site, what interactions he or she is carrying out, remember access details and store navigation preferences. The following paragraphs explain how we use cookies to ensure that our services work properly, improve the user experience, analyse data and prevent fraud.



1. How we use Cookies

Cookies are an important element in our website, as they help us to offer a better and closer service. We modify the cookies over time as we improve our service. These are the main cases of use:

- Accreditation. Thanks to the use of cookies we can remember your credentials and login status, to facilitate navigation and quick access to your account.

- Security. Through the specifications of the equipment and browsers used to access our website we can provide you with a safer experience.

- Services and features of the website. We use cookies to remember your preferences when browsing and using our services. This means that you do not have to specify these preferences and settings every time you visit our site. For example, if you have set English as your preferred language, we will always display content in that language to better serve you.

- Analyze and improve the user experience. Through the use of cookies we can better understand how our users arrive at our site and provide us with information on general site usage and behavior. This allows us to analyse which areas we can improve, to provide a more complete service and a better user experience.



2. Use of other technologies

- Pixel tags. Pixel tags (also known as beacons) are used in conjunction with other services to, among other things, measure the success of our marketing campaigns and collect statistics about the use of our services, conversion and response rates.

- Web analysis tools. We use Google Analytics and other third party tools, which employ cookies and similar technologies, to collect and analyze information about the use of our services. This allows us to identify trends and changes to improve the user experience and service.



3. Managing Cookies

You can manage the use of cookies directly from your web browser settings. This includes deleting and/or disabling MY FREE HANDS® cookies. The following links may serve as a reference for this:



• Chrome

• Explorer

• Safari

• Firefox

• Opera



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