PRIVACY POLICY

1.- Controller of your personal data and representative in the European Union:

a) Controller: FEDA SOLUCIONS, SAU (hereinafter, "FEDA SOLUCIONS"), domiciled at Avenida la Bartra, S/N, AD200 Encamp (Principality of Andorra), with company registration number 18.225, with business registration number 929742J and with tax registration number A-713332-L.

b) Data Protection Officer: You can contact our data protection officer by email [email protected]

2.- File declared in accordance with Andorran legislation at the Andorran Data Protection Agency:

In compliance with what is required by Law 15/2003, of December 18, Qualified on Personal Data Protection (hereinafter, "LQDP"), and with the regulations that develop it, FEDA SOLUCIONS informs you that any personal data that you provide through the Mou-te application (hereinafter, "the App") or the Web-App accessed through the link https://feda.hafas.cloud/?show=homemenu (hereinafter, "the Web-App") will become part of the file of the Intermodal Mobility Platform operated by FEDA SOLUCIONS (hereinafter, "the Platform"), duly registered within the Andorran Data Protection Agency (APDA).

3.- Provisions regarding the processing of personal data of minors and/or third parties:

3.1.- The creation of an account in the App and the electronic contracting of products and services offered through this and the Web-App, can only be carried out by natural persons who meet the age and legal capacity requirements to contract established in the Terms and Conditions of use of the Platform.

3.2.- Personal data that do not belong to the person who facilitates it cannot be provided. However, if it is justifiable that this happens, such as, among other possible assumptions, in the event that it is necessary to assist a third party in the process of creating his/her account in the App, the person who provides the personal data assumes the responsibility of informing the person to whom the data belongs, in advance, of every provision made in this privacy policy.

3.3.- In the cases of processing of personal data of a minor, he/she guarantees to FEDA SOLUCIONS that he/she has the authorization of the holders of their parental authority or guardianships for FEDA SOLUCIONS to treat the referred personal data in accordance with the provisions made in this privacy policy. Similarly, in the cases of processing of personal data of a person who has the right to register and/or to contract products or services limited, he/she guarantees FEDA SOLUCIONS that he/she has the authorization of the holders of his/her guardianship or curatorship for FEDA SOLUCIONS to treat the referred personal data in accordance with the provisions made in this privacy policy.

4.- Purposes of the treatments, legal basis of the treatments and period of conservation of the personal data:

4.1.- Purposes of the treatments:

FEDA SOLUCIONS may process your personal data for the purposes described below:

a)     By downloading the App on your smartphone or by means of your express authorization when using the Web-App, FEDA SOLUCIONS will collect your consents to:

1. Access the location of your device, which will be done exclusively if:

                                                    i.     You decide to use said location as a point of departure or destination in the route search utility offered by the Platform (saving you to manually introduce it), or

                                                  ii.     You consult this location on the map offered by the Platform.

1. Access the contacts stored on your smartphone, which the App will do exclusively for:

                                                    i.     Allow you to select the address of a contact as a point of departure or destination if you start typing their name in the route search utility (saving you from remembering the full address and entering it by hand).

You may revoke these consents at any time through the settings tab of the App or through the smartphone settings (to withdraw the consents you gave in the App), or through the configuration of the web browser from which you access the Platform (to withdraw the consents you gave on the Web-App). Likewise, in the case of mobile devices and as long as your smartphone allows it, you can decide whether to authorize the App and/or the Web-App to access the location only when it is being used (recommended) or at all times;

b)     By creating and managing your user account and your preferences in the App and in the Web-App, FEDA SOLUCIONS will collect and process the personal data that you provide in order to create and maintain a personal account on the platform, which will be used for:

• Maintain our relationship with you, and
• Register the data and favorites that are part of your user profile (contact data, means of transport and other preferences that you want to include in the route search utility to go from point A to B, such as whether the trip can or not include bicycles, how fast you walk, or the minimum time you want to have when you have to make a transfer).

At the end of your registration on the Platform, by creating your user account, you will be able to:

• Bring within the App the digital version of your RFID card of the type "free bus" (students), "magna" (retired), "blue" (disabled) and "abonandbus" (high grade students).
• Register your bank card with the Payment Service Provider (hereinafter, "PSP") that uses both the App and the Web-App, so that you can pay with it for the services and products that the Platform offers you.
• Change the data of your user account, including your preferences.
• Manage your consents.
• Manage your preferences on means of transport, presentation of routes, etc.
• Send the operator of the Platform an email with your comments.
• Receive in the email that you have provided the invoices that you request and commercial communications that are considered to be of interest to registered users, related to the services that the Platform offers you, or will offer you soon (the latter, provided that you have not rejected it during the configuration of your user account).

c)     Through the Platform's customer service, FEDA SOLUCIONS will process your request to unsubscribe from the service, to:

• Delete all the data in the App installed on your smartphone (including the route history);
• Anonymize all your data in the backend of the Platform (except those that we have a legal obligation to retain), so that they can never be identified with you again, and
• Delete your user account, so that no one can use it;

d)     Through the service for searching routes to travel between two points in the Principality of Andorra (which includes schedules and combination of means of transport) and the service for purchasing the associated tickets, FEDA SOLUCIONS will allow you to find possible routes to go from point A to B prioritized according to, or limited to, the preferences that you specify in the App and the Web-App, and select the one that seems most appropriate to remember it (for future use) and/or add the tickets to your shopping cart required to make the journey according to the selected route. Additionally, FEDA SOLUCIONS will store the selected route on your smartphone to facilitate your consultation (within your list of routes) and the repurchase of the associated tickets (saving manual re-entry). Likewise, through this service you can define your "favorite" locations or routes, which FEDA SOLUCIONS will store locally within the App or the device with which you access the Web-App (in the latter case, using cookies), so that they always are at your disposal when filling in the departure and destination points of a travel. Additionally, and in this last case, only when you are registered in the App, FEDA SOLUCIONS will use the route you select to offer you the purchase of the bus tickets you require, and in the case you are consulting your past travels, it will offer you to buy again the tickets associated with the route you select (saving manual re-entry).

e)     Through the shopping cart service, FEDA SOLUCIONS will remember the data of the products or services that you select so that, when you already have in the cart all the ones you deem necessary, you can buy them with a single bank transaction;

f)      Through the purchase service, FEDA SOLUCIONS treats the "token" of your means of payment to complete on your behalf the payment of the content of your shopping cart (simple tickets, weekly or monthly subscriptions, etc.). This "token" is nothing other than the anonymous code that the PSP returns the Platform when you have declared your card within the payment system of said PSP, to save you from entering your card for each purchase. The PSP registers in its system (which meets the security standards required by VISA, MasterCard and other entities adhering to the "Payment Card Industry") and sends said "token" to the Platform that the PSP itself links to your card, so that the Platform can use it every time you press the purchase button in your basket. Likewise, through the purchase service, FEDA SOLUCIONS creates the bus tickets or subscriptions that you have purchased, and stores them in digital format in your smartphone to allow you to use it instead of a physical support, to access a national bus and to accredit in front of an inspector that you are in possession of a valid title to use the national bus service;

g)     Through the emails that FEDA SOLUCIONS makes available to you in the App and the Web-App so that you can send comments, make requests for information or assistance, queries or claims, this entity will collect and process your personal data for the purpose to be able to manage your request or comment, as well as to carry out all the formalities and/or procedures necessary to process the aforementioned request;

h)     Through your contact with the FEDA SOLUCIONS user support center, an incident or support ticket is opened, and both the details of the incident or your query and your contact information are stored in the management system of FEDA SOLUCIONS so that the specialists can analyze it and inform you of the result;

i)      Through cookies and other tracking technologies, detailed within the Platform's cookie policy at any time, the Platform manages to optimize the attention to all its simultaneous users and constantly improve the display services on the map.

j)      Likewise, FEDA SOLUCIONS will process your contact information (name, surname, email and contact telephone number) to authenticate, as far as possible, the validity of requests to exercise rights (see section 6 of this policy privacy) and to communicate any security violation that may entail a high risk to your rights and freedoms; and

k)     Finally, FEDA SOLUCIONS will process your personal data to anonymize it for the purpose of using it in research initiatives and improvement of services without chances for anyone being able to link the anonymized data with you.

4.2.- Legal basis of the treatments:

Your personal data may be processed in accordance with one or more of the following legal bases:

a)     The treatment is necessary for the execution of the contract signed with users registered on the Platform;

b)     The treatment is carried out in accordance with the eventual consent that you have granted according each case. The aforementioned consent can be withdrawn at any time you wish, although, likewise, this withdrawal will limit the services provided by the App and/or the Web-App;

c)     The unequivocal consent that you express when contacting the user support center, together with our legitimate interest in attending your query or notification;

d)     The treatment is necessary for the achievement of legal obligations; and

e)     Respecting your interests, your freedoms and your fundamental rights, the treatment is necessary for the achievement of a legitimate interests of FEDA SOLUCIONS; such as, among others, to promote the products and services related to the Platform, or to fight against fraud and to ensure the defense of FEDA SOLUCIONS in case of litigation.

4.3.- Term of conservation of personal data:

In general, your personal data will be kept for the period necessary to achieve the purposes established in this privacy policy. Afterwards, your personal data will be kept for as long as it takes to prescribe the legal responsibilities derived from the treatment in question, in accordance with the applicable legislation.

By way of example, your data may be kept for the following periods:

-        5 years for accounting documentation;

-        As long as it is possible that they are required for eventual litigation and until all eventual remedies are exhausted; and

-        In the case of commercial communications, your personal data will be kept indefinitely, until you oppose the legitimate interest of FEDA SOLUCIONS in sending you information or promotions related to the Platform.

If your personal data are used for various purposes that oblige FEDA SOLUCIONS to keep them for different periods, this entity will apply the longest conservation periods among the applicable ones, and will maintain at all times the security measures that the most demanding treatment needs.

5.- Categories of recipients, including service providers, and transfers to third countries or international organizations (international transfers):

5.1.- If it is necessary to achieve the aforementioned purposes, your personal data may be communicated to the following categories of recipients:

a)     FEDA SOLUCIONS service providers that must process your personal data in relation to the purpose in question, which they will do according to the instructions of FEDA SOLUCIONS and in accordance with this privacy policy and any appropriate security and confidentiality measures established by this entity;

b)     Third parties that are not related to FEDA SOLUCIONS, if we identify, in good faith, the need to carry out the communication in question to: (1) comply with any law, regulation, legal procedure or governmental requirement with applicable executive force; (2) enforce the terms and conditions of the product and/or service purchased, including the investigation of possible violations; and/or (3) detect, prevent, or otherwise address fraud, security, or technical issues;

c)     Competent Public Administrations, in the cases provided for in the Law and for the purposes defined therein.

5.2.- FEDA SOLUCIONS only carries out international transfers of personal data to countries of the European Union, in accordance with the provisions of article 36.a of the LQPD and 44 of the General Data Protection Regulation of the European Union (hereinafter, "the GDPR").

6.- Rights in relation to your personal data:

In compliance with the LQPD, and the regulations that develop it, FEDA SOLUCIONS informs you that, to exercise your rights of access, rectification and deletion of your personal data, recognized in the aforementioned regulations, you must send a written and signed communication to the email address [email protected], to which a copy of your passport or other national identity document must be attached.

On the other hand, in accordance with the GDPR, if you are in the European Union, in addition to the above rights, you may also exercise the following:

-        Right to limitation of treatment, right to data portability, right to object to the treatment;

-        In cases in which the treatment is based on your consent, your right to withdraw your consent without affecting the legality of the treatment of said data based on the consent prior to its withdrawal; and

-        Right to file a claim in a data protection control authority of the European Union.

You may exercise the above rights by sending a written and signed communication to the email address [email protected], to which a copy of your passport or other national identity document must be attached.

Likewise, you can obtain additional information about your rights by contacting a data protection control authority.

We remind you that, if you are not registered on the Platform, FEDA SOLUCIONS is not able to identify you. However, in this case you can exercise the above rights, provided that, for the purpose of exercising them and under article 11 of the GDPR, you provide FEDA SOLUCIONS with additional information that allows you to identify them.

7.- Security:

FEDA SOLUCIONS guarantees you that the treatment that it will carry out of your personal data is subject to the strictest confidentiality, and that the necessary technical and organizational measures have been established to guarantee the security of your personal data and prevent its alteration, misuse, loss, theft and unauthorized treatment and/or access.

8.- Changes to the Privacy Policy:

This privacy policy is subject to periodic modifications in accordance with the applicable legislation at any time; Therefore, we recommend you to consult this privacy policy frequently.

Last Update: November 16, 2020