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Privacy Policy

This Privacy Policy is a document related to the Port Terms of Service (“Terms of Service”). Definitions of the terms used in this Privacy Policy have been included in the Terms of Service. The provisions of the Terms of Service are applied accordingly.

The Policy is for information purposes and serves satisfaction of the information obligations imposed on the data controller under GDPR, i.e. Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC and in case of personal data of UK citizens: UK General Data Protection Regulation and Data Protection Act 2018 (“UK GDPR”).

DATA CONTROLLER

  1. The Controller of personal data, in particular Users’ personal data, is the Service Provider, i.e. Micromobility Solutions sp. z o. o. with its registered office in Kraków, ul. Wadowicka 7, Poland entered in the register of entrepreneurs of the National Court Register (KRS) maintained by the District Court for the capital city of Kraków under number KRS: 0000851205, Tax Identification Number NIP: 7123404649, share capital: PLN 100,100. In accordance with the UK GDPR UK representative is: Port Global Ltd. 1st Floor, Ealing Cross,85 Uxbridge Road, Ealing London UK W5 5BW, Company number: 14104373, UTR 8848722572, VAT Registration Number: 483 2576 67
  2. You may contact Port in particular via email at contact@port.city.

DATA WE COLLECT

  1. We process your personal data (“Data”), in particular from you, which you provided when creating an Account or when you are using Services.
  2. Our Application or Website collects certain Data automatically when you use it. We may obtain information through automated means, such as browser cookies, pixels, web server logs, web beacons and other technologies. These technologies, among other things, help us (1) remember your information so you don’t have to re-enter it, (2) track and understand how you use and interact with the Platform, (3) tailor the Platform to your preferences, (4) manage and measure the usability of the Platform, (5) understand the effectiveness of our communications, and (6) otherwise improve Services..

PURPOSES AND LEGAL BASES OF DATA PROCESSING

We may process your Data for the following purposes:

  1. performance of Agreements and Rentals and provision of services by electronic means through the Application—the legal basis is the statutory authorization to process data which are necessary to perform an agreement if the data subject is a party to such agreement, or if it is essential for undertaking certain actions prior to conclusion of an agreement upon request of the data subject (Article 6.1(b) of the GDPR). For this purpose Port uses Google Analytics;
  2. consideration of filed claims and complaints and optimisation of performances of Port—the legal basis for processing is a legally legitimate interest executed by Port (Article 6.1.(f) of the GDPR) which consists in due conduct of business activity;
  3. promotional and commercial actions carried out by Port—the legal basis is a legitimate interest executed by us Port (Article 6.1.(f) of the GDPR) This legitimate interest is the provision of commercial information by us about our projects and services;
  4. responses to queries or acceptance of complaints—the legal basis for processing is a legally legitimate interest executed by Port (Article 6.1.(f) of the GDPR) which consists in due conduct of business activity;
  5. cooperation with business counterparties—the legal basis is the statutory authorization to process data which are necessary to perform an agreement if the data subject is a party to such agreement, or if it is essential for undertaking certain actions prior to conclusion of an agreement upon request of the data subject (Article 6.1(b) of the GDPR);
  6. pursuing or defending our claims or interests. The legal basis for such processing is Article 6.1.(f) of the GDPR (legitimate interest of the controller). This legitimate interest is to keep records related to your interactions with us in connection with our services or the fulfilment of your requests, as well as to protect our reputation or our rights.
  7. fulfilling obligations arising from legal provisions. An example of such processing would be processing for your orders or settlements related to those orders to comply with tax and accounting obligations. The legal basis for data processing is Article 6.1(c) of the GDPR (compliance with a legal obligation).

VOLUNTARY PROVISION OF DATA

Providing Data is voluntary. However, without receiving the necessary Data, we may not be able to perform some of the activities commissioned by you - their provision is therefore a condition for concluding a contract with Us and providing our services.

PERIODS OF PROCESSING

Data are processed for the following periods:

  1. a period sufficient for Service Provider to prove the appropriate performance of its obligations, whereby such term corresponds to the period of limitation of claims. Usually the period of such processing of such Data is 5 years counted from the end of the year in which the event occurred;
  2. in the case of Services provided against charge—for the time resulting from accounting provisions. The period of such processing of such Data is 5 years counted from the end of the year in which the event occurred;
  3. and in the case of marketing actions, Data are processed until the concerned person objects to further processing of his/her Data for marketing purposes or until he/she revokes the consent to be sent messages with such content. Upon the lapse of the above mentioned period, Data are deleted, unless their processing is necessary under another legal basis.

TRANSFER DATA TO COUNTRIES OUTSIDE THE EEA OR UK

The Service Provider We do not and do not plan to transfer Data from the European Economic Area and/or UK to countries outside the European Economic Area.. If, in connection with the provision of our services, it is necessary to transfer the Data to service providers or other third parties outside the European Economic Area or UK, we will only transfer such data to: (a) entities located in countries where the EU Commission has found an adequate level of protection within the meaning of Article 45(3) of the GDPR or (in case of Data of UK citizens) UK British adequacy decisions ; (b) in the absence of such a decision, the legal basis for the transfer of the Data is a contract based on standard contractual clauses constituting a set of principles adopted by the European Commission, which, in accordance with Article 46 of the GDPR or (in case of Data of UK citizens) International Data Transfer Agreement, ensure the security of the transfer of the Data; (c) on the basis of your consent (Article 49(1)(a) of the GDPR). You will then be informed by us of such data transfer.

RECIPIENTS OF DATA

  1. The Service Provider may transfer Data to third parties for processing for the purpose of execution of the activities indicated in the Terms of Service and service of the User and cooperation with other entities. In such a case, data recipients may include: the hosting provider, the CRM service provider, the CDI service provider, email operator, the provider of a system for invoice management, payment operator, accounting firm, insurer, tax firm and legal firm.
  2. Data collected by the Service Provider may also be disclosed to: competent state bodies upon their request on the basis of relevant provisions of the law or other persons and entities—in the cases prescribed in the provisions of the law.
  3. Each entity to which the Service Provider transfers Data for processing on the basis of a Data Processing Agreement (“DPA”) guarantees an adequate level of security and confidentiality of the processing of Data. The entity processing Data on the basis of the DPA may process Data through another entity only upon prior written consent of the Service Provider.
  4. Disclosing Data to unauthorized entities under this Privacy Policy may take place only upon prior consent of the data subject.

RIGHTS OF DATA SUBJECT

Each User has the right to: (a) delete the collected Data referring to him/her both from the system belonging to the Service Provider as well as from bases of entities which have cooperated with the Service Provider, (b) restrict the processing of data, (c) portability of the Data collected by the Service Provider and referring to the User, in this to receive them in a structured form, (d) request the Service Provider to enable him/her access to his/her Data and to rectify them, (e) object to processing, (f) withdraw the consent towards the Service Provider at any time without affecting the legality of the processing carried out on the basis of the consent before it is withdrawn, (g) lodge a complaint about the Service Provider to the supervisory authority (for EU: President of the Personal Data Protection Office or for UK: Information Commissioner’s Office).

OTHER DATA

The Service Provider may store http enquiries, therefore the files containing web server logs may store certain data, including the IP address of the computer sending the enquiry, the name of User’s station—identification through http protocol, if possible, date and system time of registration on the Website and receipt of the enquiry, number of bytes sent by the server, the URL address of the site visited by the User before if the User has entered the service through a link, information concerning User’s browser, information concerning errors occurred by realization of the http transaction, information on the User’s device, identifiers of mobile devices (i.e. Apple Advertising Identifier). Web server logs may be collected for the purposes of proper administration of the Website. Only persons authorized to administer the IT system have access to data. Files containing web server logs may be analyzed for the purposes of preparing statistics concerning traffic on the Website and occurring errors. Summary of such details does not identify the User.

SECURITY

  1. The Service Provider applies technological and organizational means in order to secure the processing of Data adequate to the threats and category of data to be secured, in particular, through technical and organizational means the Service Provider secures data against being disclosed to unauthorized persons, taken over by an unauthorized person, processed in violation of the law, and changed, lost, damaged or destroyed. ata are collected and stored on a secured server, moreover, the data are secured by internal procedures of Port related to the processing of Data and information security policy.
  2. The Service Provider has also implemented appropriate technical and organizational measures, such as pseudonymisation, designed to effectively enforce the data protection principles, such as data minimisation, and for the purpose of providing the processing with necessary safeguards, so as to meet the GDPR requirements and protect the rights of data subjects. The Service Provider implements all necessary technical measures as specified in Articles 25, 30, 32-34, 35-39 of GDPR, providing for enhanced protection and security of the processing of Data.
  3. At the same time, the Service Provider states that using the Internet and services provided by electronic means may pose a threat of malware breaking into User’s teleinformatic system and device, as well as any other unauthorized access to the User’s data, including personal details, by third parties. In order to minimize such threats, the User should use appropriate technical security means, e.g. using updated antivirus programs or programs securing identification of the User in the Internet. In order to obtain detailed and professional information related to the security of the Internet, the Service Provider recommends taking advice from entities specializing in such IT services.

COOKIES AND USER IDENTIFIERS

  1. For the purposes of correct operation of the Website, the Service Provider uses the cookie support technology. Cookies are packages of information stored on the User’s device through the Website, usually containing information corresponding to the intended use of a particular file, by means of which the User uses the Website—these are usually: address of the Internet service, date of publishing, lifetime of a cookie, unique number, and additional information corresponding to the intended use of a particular file.
  2. The Website uses two types of cookies: (a) session cookies, which are permanently deleted upon closing the session of the User’s browser; (b) permanent cookies, which remain on the User’s device after closing the session until they are deleted.
  3. It is not possible to identify the User on the basis of cookie files, whether session or permanent. The cookie mechanism prevents collection of any Data.
  4. Cookies used on the Website are safe for the User’s device, in particular they prevent viruses or other software from breaking into the device.
  5. Files generated directly by the Service Provider may not be read by other websites. Third-party cookies (i.e. cookies provided by entities cooperating with Port) may be read by an external server.
  6. The User may individually change the cookie settings at any time, stating the conditions of their storage, through the Internet browser settings or configuration of the service.
  7. First of all, the User may disable storing cookies on his/her device in accordance with the instructions of the browser producer, but this may disable certain parts of or the entire operation of the Website.
  8. The User may also individually remove cookies stored on his/her device at any time in accordance with the instructions of the browser producer.
  9. The Service Provider uses own cookies for the following purposes: configuration of the Website and adjustment of page content to the preferences or conduct of the User; analysis and research of views, click number and path taken on the website to improve the appearance and organization of content on the website, time spent on the website, number and frequency of visits on the Website.
  10. The Service Provider uses third-party cookies for the following purposes: Google Analytics: collecting general or anonymous statistical data by means of analytical tools. Google Adwords: promotional and marketing actions within the retargeting process. Apple Search Ads: promotional and marketing actions within the retargeting process in the Apple AppStore. Facebook Ads: promotional and marketing actions within the retargeting process.
  11. Details concerning cookie support are available in the settings of the browser used by the User.

FINAL PROVISIONS

This Privacy Policy comes into effect as of 23.03.2026.