Privacy Policy

May 31, 2017

Kissmybike is an innovative anti-theft system for bicycles that detects theft and tracks the bicycle's location until its successful retrieval developed and provided by KMB Lab srl. Kissmybike is designed to maximise the chances to recover a stolen bicycle, but KMB Lab srl is not responsible for the theft and/or loss of items tracked by Kissmybike. It is a User's responsibility to minimise the chances of her bicycle to be stolen by using chain and/or other type of lock.
Kissmybike tracking services are provided through the website (www.kissmy.bike) (the Kissmybike website) and/or Kissmybike mobile application (the Kissmybike app) by using mobile tracking devices (Kissmybike device(s)) and software (Kissmybike software). The devices, software, website and mobile application are collectively referred to herein as Kissmybike services.
This Privacy Policy (the Privacy Policy) describes the information KMB Lab collects from users, how it uses that information; and the users' rights related to collection and processing of the information.
This Privacy Policy applies to Kissmybike services and is provided pursuant to Article 13 of Italian Legislative Decree (D.Lgs) no. 196/2003 "Data Protection Code" (Codice in materia di protezione dei dati personali) and the European Recommendation 2/2001 (Data Protection Working Party) dated of 17 May 2001.
KMB Lab may occasionally and unilaterally change this Privacy Policy, according to any improvement in Kissmybike services, or to technological and legislative developments. Any changes will become effective only when the new version of this Privacy Policy will be published on the Kissmybike website.

Data controller

The data controller of Personal Information collected, processed, used and stored by the Kissmybike services is: KMB Lab srl, dei Solteri str. 76, 38121 Trento, Italy, a limited liability company incorporated under the laws of Republic of Italy full member of the European Union. KMB Lab can be contacted by email at: info@kissmy.bike

Personal Information collected by Kissmybike

In this Privacy Policy, the term "Personal Information" means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly by reference to a name, an identification number, or, in certain circumstances, location information, an IP address or the user unique identifier allocated to each Kissmybike device and associated with a User's Account.
KMB Lab does not identify a User personally to other users or make a User's Personal Information available to any third parties in any way that could identify a User without her prior consent.

1. Visiting the Kissmybike website

KMB Lab collects data from all Users who visit the Kissmybike website, even if they do not have an Account. When a User visits the Kissmybike website, KMB Lab collects data from industry-standard registers that store information about the visit, such as: the type of browser, the operating system, the URL of the page from which the visit has been redirected, the actions taken and the IP address of the visited pages, and other similar information.
KMB Lab uses all the data collected to enhance the experience of visiting the Kissmybike website and to verify the correct functioning of the Kissmybike website.
KMB Lab also collects cookies data to make it easier for Users to use Kissmybike services. For example, cookies are used to remember a User when she returns to the Kissmybike website, identify a User when signing-in, authenticate a User's access, keep track of User's in-app specified preferences or choices, tailor content to User or her geographic region, display a personalized browsing history, and/or to provide specific technical support.
Cookies can be also used to gauge site usage, conduct research and diagnostics to improve the content, product and services provided by KMB Lab and to analyse general web traffic.
The cookies expire after they have fulfilled their purpose. Some cookies expire when a User closes her browser (i.e., session cookies) or after a set period (i.e., persistent cookies). The expiration time of cookies that are placed by third parties is determined by the third party, not us.

2. Registering for the Kissmybike app

When activating a Kissmybike device, a User must download the Kissmybike app on her smartphone (at least, compatible with iOS 7 and Android 5) and create a User Account by entering her data—full name, email address, date of birth, type of bike owned, city of domicile/residence—and by creating a password. This information will be used by KMB Lab to generate statistics and to identify the bicycle in case of theft.
Users may also be able to create a User Account and interact with the app by using a third-party social networking service (“Social Network”), e.g., Facebook. If a User decides to use a Social Network account for registering for Kissmybike services, KMB Lab is permitted to collect some Personal Information—name, primary email address and photo URL—that a User has provided in her Social Network account. Users can stop sharing this information with KMB Lab at any time, by removing all access authorization to their personal account on the social network.

3. Using Kissmybike services

3.1 Kissmybike services are developed to enable Users to know where their bicycles are. In order to do that, it is necessary to collect Location Information – the location data from a User's smartphone or device, and her Kissmybike device. Kissmybike app and Kissmybike device transfer Location Information directly to the KMB Lab's server. These data are collected, stored and used to provide the Kissmybike services. Still, only the most recent Location Information—several last positions of a User and/or her bicycle—is stored. KMB Lab does not store historical information about a User's and/or her bicycle's movements and/or locations. Each time a sync occurs, the transmission data (e.g., sync time and date, device battery level, IP address) are logged. Similarly to Location Information, only the most recent transmission data are stored.
In order to determine the User bicycle's location, Kissmybike services collect data, including: GPS signals, device sensors, Wi-Fi access points, and the IDs of the cell towers. KMB Lab stores this information together with other User Account data to provide location services. By using a map service, all data about the User bicycles' location are sent to the service in order to display the location on the map; however, map services are not allowed, by contract, to share or use such data for other purposes.

3.2 Users' Location Information can be used to provide the Kissmybike services, to promote the Kissmybike services or provide Users with offers. However, Users' Location Information is not shared with other users or third parties unless a User chooses to share it through Kissmybike services.

3.3 KMB Lab tracks how, and how often Users use Kissmybike services - certain information about User's mobile device used for Kissmybike services (e.g., model, operating system type and version, the dates and times of User's requests) - are collected. KMB Lab uses this information to provide Users with optimal services and support, and to collect anonymous statistics to understand better the Users base.

4. Requests for information and/or assistance

When KMB Lab receives a request for information and/or assistance, the data shown in the request (i.e., name, email address and any additional data) are stored on the KMB Lab's servers, in order to provide the requested information and/or assistance.
KMB Lab collects and stores any Personal Information a User may choose to provide to the customer care team in the process.

Use of Personal Information collected by Kissmybike

KMB Lab processes all personal data collected by using electronic or automated systems, assuring security and confidentiality of all data collected, in accordance with the provisions of the Data Protection Code. KMB Lab may use the Users' Personal Information for the following purposes:

1. Kissmybike products and services improvement. KMB Lab may use Personal information and Location Information for: (a) statistical or marketing purposes, including measurement and understanding of the common trends to the customers; (b) operational purposes to improve Kissmybike services; (c) alerting Users about any changes to the Privacy Policy, and (d) any other purpose described in this Privacy Policy or required by regulations or lawsuits.

2. Customer support. When Users interact with Kissmybike customer service by e-mail, phone or in person, KMB Lab may collect: personal information pertinent to the situation, including: name, mailing address, telephone number and contact preferences; information about Kissmybike device, including: serial numbers, purchase date and (if applicable) event logs useful for diagnosing performance problems for products or applications; information relating to a support or a service issue. KMB Lab will use this information to provide customer service and product support.

Personal Information shared with Third Parties

KMB Lab does not share data with third parties that allow Users' identification; however, KMB Lab may share such data with its partners, which are obliged by contract to protect all personal data received from KMB Lab, for the sole purpose of providing Kissmybike services. For instance, KMB Lab may share Personal information with (a) law enforcement agencies in case of a User's bicycle theft, (b) companies engaged in providing services to KMB lab (e.g., emails management).
KMB Lab may also use and process Users' Personal Information including Location Information to prevent fraud, misappropriation, infringements, identity theft, and other illegal activities and misuse of our Services. KMB Lab may disclose Personal Information to government or law enforcement officials or private parties as it, in its sole discretion, believes is necessary to (a) comply with a law, regulation, or legal request; (b) protect the safety of any person; (c) address potential violations of our Privacy Policy or terms of service; (iv) investigate fraud, security, or technical issues; or (d) protect KMB Lab's rights or property, its employees, users and the public.
In addition, if KMB Lab is acquired by a third party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a third party, in the event KMB Lab goes out of business or enter bankruptcy, some or all of our assets – including any information collected from or about Users – may be disclosed or transferred to a third-party acquirer in connection with the transaction.
KMB Lab may sell or share with third parties, including advertisers and service providers, anonymized, aggregated data about Users, such as de-identified demographic information, de-identified location information, and information about computers or devices from which Users access the Kissmybike services.

Personal Information retention

KMB Lab stores Users' Personal Information only for the period necessary for providing Kissmybike services, unless a longer period of storage is required by law.
After this period, Users' Personal Information will be processed anonymously.

Personal Information modification

Users can access and modify their Personal Information, such as name, email address or phone number, within the Kissmybike services, or by contacting KMB Lab at info@kissmy.bike. The Location Information associated with a User's Account is a core part of the Kissmybike services and it will be not possible to modify it.  However, if a User does not want KMB Lab to use her Location Information, she can delete it by deleting the Account using the process set below.

Kissmybike Account deactivation

Users can deactivate the Kissmybike Account by contacting KMB Lab's customer service at info@kissmy.bike. In this case, the Personal Information will be removed from the Kissmybike services. Backup copies of these data will be removed from KMB Lab server based upon an automated schedule, which means it may persist in KMB Lab's archive for a short period of time. KMB Lab may continue to use Users' aggregated and de-identified Personal Information.

Communications

KMB lab may periodically send Users promotional newsletters and emails. Users have the opportunity to opt-out of these by following the unsubscribe instructions provided in the emails. Certain communications, like billing information and Service updates are necessary for to be received, so Users will not be able to opt out of those communications.

KMB Lab policy with respect to children

Our services are not intended for persons under 13 years. In compliance with the Italian laws and the UN Convention on the Rights (Convention on the Rights of the Child – CRC) of 11.20.1989, If we learn that we have collected the Personal Information from a child under 13, we will take steps to delete such information as soon as possible. Users who eventually are aware of a User under the age of 13 using the Kissmybike website or Kissmybike app are invited to contact us at info@kissmy.bike.

© 2016 KMB Lab srl All rights reserved.
Via dei Solteri 76, 38121 Trento, Italia
C.F./P.IVA 02403940220

The project is co-funded by the European Union under Grant agreement №632838.
The project is a part of Finodex (FIWARE Accelerate programme). The project is co-funded by the European Union.