PRIVACY POLICY

Lucian S.r.l. strives to ensure that the processing of personal data is carried out in compliance with the legislation on the protection of personal data and as described below.

We invite you to carefully read this policy regarding the General Data Protection Regulation (GDPR) EU 2016/679.

OpenMove is a set of software platforms - available for smartphones, web or via APIs with the OpenMove brand or with end customers brands - dedicated to electronic ticketing and passenger information.

The data provided by the user or otherwise acquired in connection with the use of the OpenMove software platforms will be processed in compliance with the legislation on personal data protection.

Data Controller

The data controller is Lucian S.r.l. (hereinafter the Owner), with registered office in Mori (TN), Via della Lasta no. 12, VAT number 02354270221, registered in the Chamber of Commerce of Trento and with registered email luciansrl@legalmail.it. Lucian S.r.l. can also be contacted by email at info@openmove.com and by phone at the number +390464740009.

Types of personal data and purpose of processing

The processing will relate to individual transactions or a series of operations relating to the processing of personal data (such as, for example: collection, registration, organization, storage, processing, communication, modification, selection, use) provided by the user during the phase of establishment of the relationship and subsequently on the occasion of the use of the services offered by the Owner through the use of OpenMove services.

The information requested when registering for the services provided by the Owner, as well as any further information subsequently collected, will be used for the purposes listed below:

It should be noted that the data listed above may also come from third-party platforms listed on the Partners page, on which the user is accredited and whose Terms and Conditions of Use are referred in full. These data are communicated through dedicated IT systems, in full compliance with security requirements.

Nature of data provision - Processing methods

With respect to the purposes referred to in point 2, the provision of data marked as mandatory during registration (or in the event of any further circumstances in which the user is required to provide data) is necessary to use the services offered by the Owner, and any refusal involves the impossibility of registering an account and therefore the use of the services provided. 

The user may, at any time, modify, through the OpenMove platforms, the data of his account, including the preferences regarding the methods of receiving communications based on the different channels made available (email, SMS, MMS).

The data will be processed electronically and using methods designed to ensure confidentiality, integrity and availability, in compliance with what is defined by the General Data Protection Regulation (GDPR) EU 2016/679.

The personal data we process is stored in such a way as to reduce, through the adoption of suitable and preventative security measures: the risk of destruction or loss of data, even by accident, unauthorized access, forbidden processing, and processing of the data that is not in line with the reasons for which it was collected.

Communication and disclosure of personal data

For the correct fulfillment of the aforementioned purposes, the following subjects may have access to the user's personal data: the personnel belonging to the Owner's organization, the person in charge of administration and accounting, the technical representatives of the customer support service, the marketing staff, and the personnel of third-party companies that provide services to the Owner. The Operator who provides the transport or parking service purchased by the user will also have access to the user's personal data and to the ticket purchase and travel data, as well as any entities that have the ownership of the aforementioned data, as reported on the Partners page to which reference is made. The Operator who provides the transport or parking service has full access to this data through dedicated front-end services to control operations, sales, administration and assistance.

With the consent of the user, the data may be transferred to third parties to be used for their own purposes but, in any case, purposes that are strictly connected to the implementation of OpenMove; the data will not be disclosed in any case, except within the limits described above. 

Rights of the Data Subject

The interested party can exercise the rights provided by the General Data Protection Regulation (GDPR) EU 2016/679 by contacting the Data Controller. Specifically, according to the regulation:

the user is entitled to ask for: 

1. the origin of the personal data;
2. the purposes and methods of data processing;
3. the logic applied in case of processing carried out with the aid of electronic devices;
4. the identification details of the Data Controller, of the Data Processors and of the designated representative, in accordance with the law;
5. subjects or categories of subjects to whom the personal data may be communicated, or who can learn about them in their capacity as appointed representatives of the State, as designated managers or as persons in charge.

the user has the right to ask for: 

1. the updating, the modification or, if necessary, the integration of the data;
2. the deletion, transformation into anonymous form or blocking of data which have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
3. the confirmation that those to whom the data are communicated or disclosed are notified of the actions referred to under points a) and b), including their content, unless the fulfilment thereof proves impossible or involves using methods which are clearly disproportionate to the right being protected;
4. the sending in a structured format, unquestionably chosen by Lucian S.r.l., of all the data related to him/her.

the user has the right to oppose, totally or partially: 

1. to the processing of their personal data for legitimate reasons, even if pertinent to the purpose of collection;
2. to the processing of personal data for the purpose of sending advertising materials, for direct sales, or for carrying out market research or commercial communication activities.

These rights can be exercised by sending a request to the email address info@openmove.com, by telephone calling the number +390464740009, or directly through the account.

Updates

The Owner may update this Privacy Policy, also in the event of regulatory changes. In the event of substantial changes to the content of this policy, the Owner will inform the users through the app.

IT services of technical suppliers

The Owner, in order to provide its services, uses the IT services of the following third-party technical suppliers, who take care to operate and maintain the data on the territory of the European Union, in full compliance with the laws in force.

This table shows the details of the documents made available by the suppliers and regarding data processing. Lucian S.r.l. assumes no responsibility for any incompleteness of the documentation of those third parties and invites to make a report in this regard if necessary.

LEGAL NOTE

Lucian S.r.l., while ensuring the maximum commitment in order to guarantee the correctness and completeness of the information provided through the OpenMove platforms, assumes no responsibility for any errors, inaccuracies or omissions.

As a result, the Owner does not assume any responsibility for damages of any nature that may result to users accessing the application and the aforementioned website and for the use of the information provided by them. 

Finally, although Lucian S.r.l. actively works in this regard, it is not able to guarantee that its website is free of viruses or other elements harmful to users. 

All rights relating to OpenMove are reserved. Even partial reproduction is strictly forbidden. 

COMPANY INFORMATION

Lucian S.R.L., registered office in Mori (TN), Via della Lasta no. 12, VAT number 02354270221, registered in the Chamber of Commerce of Trento and with registered email luciansrl@legalmail.it.

In case of discrepancy between the original Italian version of this document and its translation into English (or into any other language), the original Italian version will always and anywhere be considered as prevailing.