ESB

Privacy Policy

This page will describe management of ESB web site and ESB applications as regards of processing the personal data of users that visit us.

We inform you that the personal data you provide and acquired together with the registration to the services of your choice, as well as the data necessary for the provision of these services, will be processed, in compliance with the guarantees of confidentiality and security measures provided by law in force through Information Technology, telematic and manual tools, with logic strictly related to the purposes of treatment.

By using ESB website and/or apps means that you agree to this new privacy statement.

We handle personal data collected during your visits to our websites and/or while using our mobile applications confidentially and entirely in accordance with legal regulations. If you have any questions or comments, please contact our Support team.

This information is provided – in pursuance of Section 13 of Legislative Decree no. 196/2003 – to any entity dealing with the web-based services that are made available by SITAEL S.p.A. via electronic networks as from the following address: www.esb.bike which corresponds to the home page of ESB official web site.

The information provided only applies to ESB web site and ESB applications and does not concern any web sites that may be visited by a user via external links.

  • General Information

The concept of ESB apps and the ESB.bike platform (hereinafter referred to as “ESB Products”) is based in part on the publication of details regarding individual users; such details are accessible to other users via the ESB Products and social networks (e.g. Facebook).

The collection, administration and use of personal data through ESB by SITAEL complies with the Italian applicable data protection laws and ensures that, as a user, you can establish which of your personal details shall be made accessible to other users.

  • Data Controller

The “ESB application” and “ESB.bike platform” are concepts of SITAEL S.p.A., a company duly organized and existing under the laws of Italy.

The data controller is SITAEL S.p.A., with registered office in Mola di Bari (BA) (Italy), Via San Sabino 21 – 70043 (hereinafter referred to as “SITAEL”).

  • Security

SITAEL takes security precautions to ensure that your data managed by us are protected against tampering, loss, destruction, access by unauthorized persons, or unauthorized disclosure. Our security measures are being continuously improved in accordance with the state of technological developments.

  • Personal Data Collected

SITAEL collects and processes Personal Data within the meaning of §4.1 (B) of the PERSONAL DATA PROTECTION CODE (Legislative Decree no. 196 of 30 June 2003) and information from users upon registration on its website (hereinafter “Registration” and “Registered User”) and in connection with the use of any of the ESB Products.

When you register for our services, by logging in with your contact details, you indicate your consent to our collecting, processing and using these data and the master personal data voluntarily provided by you in the context of use of the available services, to the extent necessary for the provision of the contractually stipulated services.

You may revoke your consent hereto at any time. The revocation shall be communicated via e-mail to support@esb.bike. The revocation entails your account removal from the system.

You may also ask us to block or delete the data relating to your user account/s and your personal data, at any time. You can delate your account on our mobile application, which will have the effect of automatically deleting your personal data from our system.  Data which is no longer required will be deleted after 30 days or, at the latest, upon the expiration of the statutory retention period/deadline. Only such personal data required by us for the completion of outstanding tasks or the enforcement of our rights and also any data which we are obligated to retain in accordance with statutory regulations will not be subject to deletion.

The insights gained enable us to further optimize our services and better tailor them to your needs.

2.1 Mandatory Data.

ESB Products require you to provide some Personal Data in order to register and open a user account, such as:

  • E-mail address;
  • First and last name;
  • Password (saved in an encrypted format that will not be visible in plain text, at any point);

Mandatory data are required in order to enable us to undertake the user agreement and any other agreement. Personal data entered in the contact form are collected for the purposes of enabling us to respond appropriately to any enquiries. We will retain your master personal data as long as it is necessary for our purposes. Thereafter, it will be deleted from our system.

  • Optional data.

Other data are optional during the Registration phase and you can edit them by adding or delating information in a second moment, among them:

  • Personal Information:
    • Address (city, country);
    • Profile picture;
    • Height and weight;
  • Contact information:
    • Phone, website;
    • Facebook, Twitter accounts.
    • Additional User Data.

In order to provide our services, after the Registration phase, we collect additional data (hereinafter referred to as “Additional User Data” and, together with the Registration Data, the “User Data”), such as:

  • Activities (e.g. distance, app usage time, travelling time, routes, calories, duration, training days, elevation, workouts,);
  • Location data and maps of activities;
  • Position related data (GPS Data);
  • Photos;
  • Battery data;
  • Speed;
  • Distance;
  • Calories;
  • Travelling Time;
  • Co2 saved;
  • Fuel saved;
  • Browser tracking data (cookies and User’s language);
  • Friendships (followers and people you follow).

The following Personal Data: first name, last name, profile picture, bike model, route or bike shared on ESB social network, as well as the list of followers and people you follow and your address (City, Country) may be visible to all users.

ESB users can also view information shared by other users concerning their routes and their e-bikes.

  • Use and Sharing of Personal Data
    • Confidentiality and Security.

SITAEL deems all user information confidential and does not disclose such information without your express informed consent. SITAEL has implemented reasonable security policies and procedures designed to protect users’ information.

By Registering, you explicitly agree to this privacy Policy as well as you agree that SITAEL shall have the right to use all the collected personal data for purposes concerning ESB Products.

  • Sharing of Data.

As a general rule, the user will decide which personal data may be accessible to third parties. The disclosure of personal data which may be accessible to third parties will be on a voluntary basis. In order to provide our services, SITAEL will make the data voluntarily disclosed available to those users with access privileges in the designated parts of our website and/or App.

Anonymous position-related data (GPS data) will be transmitted in the context of the tracking function to routing and navigation service provider with a view to extending and improving the cartographical materials.

SITAEL may only transmit a user’s personal data to third parties if and to the extent that: (1) this is necessary in order to enable us to implement the contract concluded with the user; (2) SITAEL is legally obligated to do so as response to lawful requests from federal, state, local, or foreign law and civil enforcement agencies, as required by law; or (3) this is necessary for the enforcement of our rights and claims. In the event that one of your personal data is to be spread for purposes other than those specified herein, SITAEL will ask your consent thereto in each individual case. SITAEL will not disseminate any personal date to third parties without such consent.

ESB website may contain links to third-party websites operated by providers that are not associated with us. After you click the link, SITAEL has no longer influence over the collection, storage, or processing of any personal data transmitted to third parties upon your clicking on the link (such as the IP address or URL of the page that contains the link), as SITAEL naturally does not have any control over the behavior of third parties.

Therefore, SITAEL cannot assume any responsibility for the processing of such personal data by third parties.

SITAEL implements all reasonable measures to prevent the unauthorized access by third parties to saved data.

SITAEL transfers information of Registered Users to vendors, service providers, and other partners such as Amazon Web Services (AWS), Fabric Answers for analytics (https://fabric.io/kits/android/answers) and Fabric Crashlytics for crash reporting (https://fabric.io/kits/android/crashlytics). In this way, SITAEL can provide and improve its services, such as technical infrastructure services or analysis concerning how the services perform or how they are used.

ESB Products use the so-called double opt-in procedure for the distribution of our newsletter (i.e. you will only receive a newsletter once you have confirmed, by clicking on a link contained in our e-mail alert, that the newsletter service can be activated). The user explicitly consents to the storage and use of non-personally identifiable information for purposes of newsletter marketing or on www.esb.bike by SITAEL or its partners. In case you do no longer want to receive newsletters or any other advertising materials from us, you may decline this service at any time. Written notification (e.g. via e-mail) of this revocation will be sufficient. Every newsletter will also contain a link enabling you to cancel your subscription.

SITAEL uses data received to help, operate, provide, improve, understand, customize, support, and market all services.

  • Plug-Ins and Widgets for Social Media

The ESB Products include and use social media plug-ins, such as (i) Facebook.com, which is operated by Facebook Inc., 1601 South California Avenue, Palo Alto, CA 94304, USA, and (ii) Twitter, 1355 Market Street, Suite 900, San Francisco, CA 94103, USA.

The plug-ins are identified with the logo or the suffix of each social media (e.g. “Facebook social plug-in”). Such plug-ins can recognize a user’s IP address and the page visited on the ESB.bike platform and they can store cookies, so that the services offered by ESB work properly. Social media plug-ins and widgets are hosted either by third party providers or directly by us. Your interactions with these plug-ins are subject to this privacy policy or the privacy policy of any third party that offers such feature. SITAEL is not responsible for the use of -or guidelines regarding the use of -personal data by third party providers.

Users may recognize the respective plug-ins, e.g. by the respective logo or other respective characteristic typical for the respective social media-platform on our pages. You can find an overview of Facebook plug-ins here: https://developers.facebook.com/docs/plugins. You can find an overview of Twitter plug-ins here: https://dev.twitter.com/web/overview

When you visit a page on our website that contains such plug-ins, these buttons are initially disabled. The plug-ins will not be enabled until you click on the button displayed. These buttons will only be activated and establish a connection to the social network in question upon their activation by the customer, who thereby indicates their consent to the transmission of their data to the operator of that network. If you are logged in on Facebook, Facebook can link your visit to your Facebook account. If you click on the relevant button, the corresponding information will be transmitted directly to Facebook by your browser and stored there. If you interact with the plug-ins (e. g. by clicking on the Facebook “Like-Button” or entering a comment), while being logged into your Social Media account on Facebook, or on Twitter, you link the contents of the ESB pages to your respective social media profile. Thereby, Facebook/Twitter can associate a user’s visit of the ESB page or use of ESB Products with such user’s social media account. As the provider of the ESB Products, SITAEL does not have any knowledge of the content of the transmitted data or its usage by Facebook, Google+, or Twitter. Users can find more information on the issue of data transmission in the privacy policy of the respective social media-platform:

  1. Facebook: https://developers.facebook.com/policy
  2. Twitter: https://dev.twitter.com/web/overview/privacy

If you do not want to have the respective social media platform associate your visits on our website with your social media accounts, you shall log out from your social media account.

  • Cookies

The ESB Products use ‘cookies’ ─ small text files that are placed on the user’s computer and stored by the browser. They are used by SITAEL to provide a more user-friendly, effective and secure service. Cookies also enable SITAEL to identify a user’s browser and offer services to such user. Cookies do not contain any personally identifiable information.

The use of cookies during the registration process and in the course of the provision of our services first of all enables us to identify users who return as customers to our website after an initial visit. Furthermore, we can use cookies to optimize our range of services in line with users’ individual requirements.

We also use cookies as a means of chronicling both the statistical frequency of visits to the various parts of our website and general navigation-related aspects, and also for the creation of pseudonymous profiles, where applicable.

You can prevent the installation of cookies by entering the corresponding settings in your browser software. However, please note that in this case you may not be able to use the complete range of functions of the ESB.bike platform to its full extent. If you want it, you can delete the cookies at any time. However, this can result in some functions no longer being available. For information on deleting the cookies, please consult your browser’s help function.

  • Use of Google Analytics and App Analytics

The ESB Products use Google Analytics, a web analysis service provided by Google Inc. (“Google”). Google Analytics uses ‘cookies’ (see the Section above). The information about your use of this website collected by the cookies, including your IP address, is generally transferred to a Google server in the USA where is stored. To the extent that the ESB Products have activated IP anonymization, Google first abbreviates your IP address within member states of the European Union or in other signatory states of the Agreement on the European Economic Area before this transmission occurs. Only in exceptional cases, will the full IP address be transferred to a Google server in the USA or Asia and abbreviated there. Google will use the information collected on behalf of the website operator in order to evaluate your use of the ESB Products, to compile reports about your activities within the ESB Products, and to provide further services connected with the use of the ESB Products and Internet use to the website operator. Google will under no circumstances associate the IP address transmitted by your browser within the operations of Google Analytics with other Google data.

However, we wish to point out that, if you do so, you may not be able to fully use all of the functions of this website.

You can prevent the data related to your use of the ESB platform, including your IP address, generated by the cookies from being recorded by Google and Google’s processing of this data by selecting corresponding settings of your browser’s software.

Furthermore, you can prevent the future data capture by setting an Opt Out-Cookie via the following link: Deactivate Google Analytics Further information regarding terms of use and privacy provisions may be found on the websites http://www.google.com/analytics/terms/us.html and https://www.google.de/intl/en/policies/.

The ESB Products use Google DoubleClick for Publishers (“DFP”). DFP uses Cookies to provide the user with user-relevant advertisements – further information may be found at https://support.google.com/dfp_premium/answer/2839090?hl=en. The user may disable the DFP’s cookie placement and the placement of user-relevant advertisements for use of the ESB platform via the website: http://www.google.com/ads/preferences.

  • Changes to Privacy Policy

Changes to this Privacy Policy require the consent of the respective user, to whom the changed Privacy Policy shall apply. If SITAEL intends to implement such changes, it will give the user as much prior notice of such changes as possible. Such notice shall be made on the relevant pages of the ESB.bike platform or on any other device through which the user accesses the ESB Products. Any such modifications will take effect within thirty days of publication. This policy was last modified on 10 February, 2018.

  • Revocation of Consent and Deletion of User’s Data

You are entitled at any time to obtain confirmation of the existence of personal data concerning them and be informed of their contents and origin, verify their accuracy, or else request that such data be supplemented, updated or rectified (Section 7 of Legislative Decree no. 196/2003).

You can also revoke the consent to the collection, processing, and use of your personal data for the future. In case of a termination of the Registered User’s account, all personal data provided by the user upon Registration shall be deleted. Any details made public by the user (e.g. routes, notes on other Registered Users’ walls) will be (i) anonymized within thirty days (i.e. it will be made clear that such details were provided by a deleted user), and (ii) deleted irrevocably, at the end of the period;

Upon the Registered User’s request to revoke their consent to the retention of all data and Information where knowledge thereof is no longer required for ESB’s performance of contractual obligations or compliance with statutory retention obligations, they shall be irrevocably deleted. This will not affect data which are required for billing and accounting purposes or which are subject to statutory retention obligations. You shall request such deletion by sending an e-mail to support@esb.bike, which shall include the e-mail address provided to the ESB platform during your registration, or via the website. SITAEL will comply with such requests within ten days and maintain a record of the deletion for one year after the deletion.

All requests should be emailed to support@esb.bike .

  • Your Consent

By using our ESB Products as a non-registered user, you agree to our privacy policy only for those areas not subject to Registration. Please visit also our Terms and Conditions section establishing the use, disclaimers, and limitations of liability regulating the use of our website and apps. http://www.esb.bike/terms-and-conditions/

  • Contacts

To obtain more information or to submit suggestions or complaints regarding the processing of your personal data, please contact us at support@esb.bike. If incorrect information has been stored despite our efforts to maintain correct and up-to-date data, we will correct this upon your request.

Thank you for being part of the ESB community.