Privacy Policy

TopCycle (P.IVA 03786490122), with registered office in Italy ("we," "us," or "our"), operates the Smart Commute mobile application (the "App"). This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our App.

By downloading or using Smart Commute, you agree to the collection and use of information in accordance with this policy. If you do not agree, please do not use the App.

2.1 Information You Provide

• Account information: name, email address, and profile details when you create an account.
• Commute preferences: home and work locations, preferred transportation modes, and schedule preferences.
• Communications: messages you send to us through in-app support or email.

2.2 Information Collected Automatically

• Location data: with your permission, we collect location information to provide route planning and commute tracking features.
• Usage data: app interactions, features used, session duration, and crash reports.
• Device information: device model, operating system version, unique device identifiers, and network information.

2.3 Information from Third Parties

We may receive information from third-party services you connect to Smart Commute, such as calendar integrations or transit data providers.

We use the information we collect to:

• Provide, maintain, and improve the App's features and functionality.
• Calculate and suggest optimal commuting routes based on your preferences and real-time conditions.
• Track and analyze your commuting patterns over time.
• Send you service-related notifications, updates, and security alerts.
• Respond to your inquiries and provide customer support.
• Detect, prevent, and address technical issues and security threats.
• Generate aggregated, anonymized analytics to improve our services.

We do not sell your personal information. We may share your information in the following circumstances:

• Service providers: trusted third parties that help us operate the App (e.g., cloud hosting, analytics, crash reporting).
• Legal requirements: when required by law, regulation, legal process, or governmental request.
• Safety: to protect the rights, property, or safety of TopCycle, our users, or the public.
• Business transfers: in connection with a merger, acquisition, or sale of assets.

We retain your personal information for as long as your account is active or as needed to provide services. You may request deletion of your data at any time by contacting us at info@topcycle.it. We will delete your data within 30 days of a verified request, unless retention is required by law.

We implement industry-standard security measures to protect your data, including encryption in transit and at rest, access controls, and regular security assessments. However, no method of electronic storage or transmission is 100% secure, and we cannot guarantee absolute security.

Depending on your jurisdiction, you may have the following rights regarding your personal data:

• Access: request a copy of the personal data we hold about you.
• Correction: request correction of inaccurate or incomplete data.
• Deletion: request deletion of your personal data.
• Portability: request a machine-readable copy of your data.
• Objection: object to certain processing of your data.

To exercise any of these rights, contact us at info@topcycle.it. Under the EU General Data Protection Regulation (GDPR), you also have the right to lodge a complaint with your local data protection authority.

Smart Commute is not intended for children under the age of 16. We do not knowingly collect personal information from children. If we become aware that we have collected data from a child under 16, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us at info@topcycle.it.

The App may contain links to or integrate with third-party services that are not operated by us. We are not responsible for the privacy practices of these services. We encourage you to review their privacy policies before providing any personal information.

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy within the App and updating the "Effective Date" above. Your continued use of the App after changes constitutes acceptance of the revised policy.

If you have questions or concerns about this Privacy Policy or our data practices, please contact us:

• Email: info@topcycle.it
• Company: TopCycle — P.IVA 03786490122