Privacy Policy and Cookies

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Mister Lavaggio srls (“Mister Lavaggio”) respects privacy regulations and is committed to providing maximum transparency in the subject of data processing, convinced that such transparency is an indispensable aspect of the quality of service we offer to our customers, companies and all those interested in receiving information or staying in touch with our system.

 

Data controller

Any personal data (hereafter also referred to as “data”) you provide or collect through the operations you perform:

• on the Mister Wash app
• On the sites www.misterlavaggio.com, partner.misterlavaggio.com and any other site owned by Mister Lavaggio srls on which this statement appears

is processed by Mister Lavaggio Srls in the person of the legal representative p.t., VAT no. 09271400963, headquartered at Gian Carlo Passeroni Street no. 6 – 20135 Milan, pec address: misterlavaggio@pec.it, (hereinafter, “Owner”), as “Owner” of the treatment.

 

Mr. Washers

Mister Washing provides its customers with a car wash service, which can be booked through a mobile app. Operators who physically perform the washing are referred to as washers.

In case several Washers operate in an area, it is possible to choose the one you prefer when booking (also being able to rely on other users’ reviews).

They operate under the Mister Wash brand, using Mister Wash booking management tools, products and protocols.

 

Type of data collected on the app and sites

The personal data we receive from our customers, in addition to enabling the use of the service we provide, helps us to personalize and continuously improve the service. In some cases, upon your express consent or request, they may be accessed or transferred to third parties for the provision of additional services.

Below are the categories of data we collect:

• Personal data provided by you: We receive and process personal data provided by you only if.
  • are required in order to take advantage of a service you have requested (for example, if you make a reservation you will have to leave your name and phone number in order to be contacted by the operator who will come to wash your car, or if you request to be called to receive information about our system you will have to leave your phone number)
  • Expressly agree to their use for other purposes (e.g., marketing)
• Mobile device location information: in some cases we collect the GPS location of the device in order to make better usable and/or improve the services offered (e.g., identify areas not yet covered by the service, from which reservation requests arrive). Most mobile devices allow you to turn off location services. Usually to do this you find appropriate configurations within the device’s settings menu. If you have questions about how to disable location services on your device, we recommend that you contact your mobile carrier or the manufacturer of your device.
• Completely anonymous device technical information and usage events: we may  automatically collect and process some anonymous information for diagnostic, data analysis and fraud prevention purposes. Such data may include: 
  • Data on how the service features are used
  • Data on the installation or removal of the app
  • Internet protocol (IP) address only if not traceable to personal data
  • device technical data such as smartphone model, browser or operating system version, device event information such as crashes, system activity, hardware settings, browser type, language, date and time of requests, and referring URL,
  • during some visits to sites or app use, it is possible that we evaluate and collect session information, including loading and dwell times on screens, download errors, duration of visits to certain screens, screen interaction information (such as scrolling, clicking, and cursor movement on pages), and methods used to exit.
• Technical device information and usage events not entirely anonymous:

we may use (with your consent) certain technical information, such as the Internet Protocol (IP) address used to connect your device to the Internet or other identifiers, which, although they do not contain direct information about the person, may allow their identification under certain conditions

• Local storage: In some cases we may collect and store information (including personal information) locally on the device, using mechanisms such as web storage via browsers (including HTML 5) and application data caches.
• Cookies: better specified below

The purposes of personal data processing

To protect your privacy, your personal data will be used, by the Data Controller or authorized third parties, and only after your explicit consent (art. 7 GDPR) for:

• Inform you of offers, promotions and news regarding services and products offered by the Owner or Washers
• Satisfaction survey campaigns on the quality of services

Separate consent will be required should the data be used to send you commercial and/or promotional communications from third parties (e.g., business partners, and other companies).

The personal data you provide may be processed without consent (Art. 6 GDPR) by the Data Controller or authorized third parties for the purpose of:

• Allow you to access the services you have requested (e.g., booking a wash through the app)
• Contact you at your express request (e.g., for information on how to join the Mister Wash system)
• process payments
• Update our records and generally manage your account
• Post and display content such as reviews on the service
• Contact you via email, text message, telephone contact, push notification, and/or other digital tools, for needs related to the use and management of the services requested, such as confirmation of reservation or other service communications
• Prevent or expose fraud or abuse to the detriment of our system
• Exercise legitimate rights and fulfill obligations under laws, rules or regulations, fulfill pre-contractual, contractual and tax obligations

Mode and duration of treatment

Your personal information is subject to processing (collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction) whether on paper or electronically and/or automatically, for the time strictly necessary to achieve the purposes for which it was collected.

In the event that you have provided us with personal data for the purpose of using our services, we retain that data for as long as we deem necessary to enable you to use the services (e.g., you will not have to enter your contact information into the app for each booking).

In the event that you have provided us with personal data to receive information and/or communications we will retain such data for as long as we deem necessary to enable you to receive the requested information and/or communications (e.g., in the case of subscribing to a newsletter, data will be retained until your specific request to unsubscribe or until such newsletter is deactivated).

In case you have provided us with personal data for profiling and marketing purposes, your data is kept for a commercially appropriate time (e.g., we may send you promotional offers at certain times of the year until you expressly request not to receive any more or until you are no longer interested).

In all cases, the duration will take into account the time necessary to comply with applicable law, to resolve disputes with any party, and if otherwise necessary to enable us to conduct our business, to prevent and disclose fraud or other illegal activities.

 

Data access

Our clients’ personal data is an important component of our work, and it is not part of our business to give it away to others. Your information may be made accessible only to the extent stated in this policy:

• to employees and collaborators of the Controller (administrative, sales, customer care, marketing, legal, system administrators) in their capacity as internal data processors and/or system administrators;

• to the Washers with which you booked the services offered by the system. The information is accessed by them in order to make the service usable, send service communications, or allow them, with your consent to send you promotional offers, information and news regarding the services offered. They shall, in carrying out their activities, act in a manner consistent with this Privacy Policy;
• to other external data controllers, i.e., third-party companies or other entities that perform processing activities on our behalf. For example, to send e-mails, text messages or push notifications, analyze data, provide marketing assistance, and make credit card payments. These providers have access only to personal data that are necessary to carry out their tasks. We assure you that they may not use the same data for any other purpose and are also required to process personal data in accordance with this Privacy Policy, and under applicable data protection regulations.
• to Supervisory Bodies, Judicial Authorities, insurance companies for the provision of insurance services as well as to those parties to whom disclosure is required by law. These parties will process the data in their capacity as autonomous data controllers.
• business transfers: Customers’ personal data are part of the company’s assets. Our business is constantly developing, but in the unlikely event that your property or substantially all of your assets are transferred to a third party, your personal data will naturally be among the transferred assets. In any case, they remain subject to the commitments made in any previous Privacy Policy
• In the event that there emerge other purposes, you will be informed and will have the opportunity to choose whether or not to give your consent to the processing of your personal data for such purposes

The updated list of data processors and processors is kept at our registered office.

 

Data transfer outside the European Community

Some of the external data processors who process information on our behalf have registered offices and/or process data outside the European Community.

Whenever personal data is transferred to companies, entities, or institutions based in countries outside the European Community, we will ensure that the data is transferred in accordance with this Privacy Policy and in compliance with applicable legal provisions, subject to entering into the standard contractual clauses required by the European Commission.

Such external providers are: Google LLC (with its services such as Analytics, Google Plus, adWords, adSense, AdMob, Analytics, Maps, YouTube, Android services, Firebase, Crashlytics, Answers, Gmail, Google Contacts), Zoho Corporation (Zoho Mail), Facebook Inc, Instagram, Mailchimp, DigitalOcean Inc, OneSignal Inc, One-etere S.r.l. a Socio Unico (Trendoo), Stripe Inc, Debitoor UK Ltd, Hotjar Ltd, Active Campaign LLC, PayPal Holdings Inc, Etison LLC (ClickFunnels).

They are located in countries that have been granted an adequacy decision by the European Community (i.e., process personal data in accordance with the principles and standards referred to in this Notice), or guarantee their adherence to the Privacy Shield (the transfer of personal data, in which case, is authorized under specific Decisions of the European Union and the Data Protection Supervisor. , in particular Decision 1250/2016 – Privacy Shield – here the information page of the Italian Garante ).

Information security

We try to minimize the use of personal data, using anonymous data whenever possible so that the user’s identity is not revealed.

In relation to the knowledge gained from technical progress, the nature of the data and the specific characteristics of the processing, we use specific security measures to protect the security of your personal information, its protection from all forms of unauthorized access, alteration, unauthorized disclosure and destruction of such information. For example:

• We offer users verification when logging into their account, preventing unauthorized access to systems (mandatory password request).
• We allow access to personal information only to employees, appointees involved in the organization or other external data processors obligated to comply with the obligation of confidentiality
• when you enter data on our site or application, we use Secure Sockets Layer (SSL) software, which encrypts the information you enter.

Misuse of data
We are not, under any circumstances, responsible for illicit use and unlawful behavior you may engage in while using the service. For example, under no circumstances are we responsible for your inclusion of insults, defamation, offensive phrases, videos, photos, and any other multimedia content that infringes on constitutionally relevant personal rights or intellectual property rights (e.g., unlawful use of others’ trademarks, patents, etc.). 
Nonetheless, in the event of complaints of any unlawful use, we reserve the right to expel the perpetrators of the aforementioned behavior. 

Choice of data provision, withdrawal of consent, and request for deletion of data

You can always choose not to provide personal data, with the understanding that providing such data may be necessary to take advantage of certain services.

You may at any time decide to revoke your authorization to process personal data for specific purposes by sending notice to privacy@misterlavaggio.com or through any other procedures made available through the app, sites or emails you receive. If authorization to process data for the purposes of the service is revoked, it will obviously become impossible to access the service itself.

You may at any time request the deletion of your data by sending communication to the address privacy@misterlavaggio.com. 

Your rights

Pursuant to European Regulation 679/2016 (GDPR) and national legislation, you may, in the manner and within the limits provided by the current legislation, exercise the following rights:

1. confirmation of the existence or non-existence of personal data concerning you
2. their communication in an intelligible form
3. The updating, correction and deletion
4. The transfer of data to another company
5. the limitation of treatment
6. opposition to processing
7. The transformation of data into anonymous form
8. The revocation of the consent to treatment previously given
9. indication:
   1. Of the origin of personal data;
   2. Of the purposes and methods of processing;
   3. Of the logic applied in the case of processing carried out with the aid of electronic instruments;
   4. Of the identification details of the data controller and data processors

It is also your right to file complaints with the appropriate supervisory authorities (Privacy Guarantor – link to the Guarantor’s page ).

You may exercise your rights at any time by sending an e-mail with your request to privacy@misterlavaggio.com.

 

Disclosures and reviews

If you still have questions about this privacy policy, please email us at privacy@misterlavaggio.com.

Our activities are constantly evolving and, therefore, this Privacy Policy may also be subject to change.

If substantial changes become necessary we will inform you and, if required by law, we may ask you whether or not you consent to the changes.