PRIVACY POLICY

In BUSUP TECHNOLOGIES, S.L. We recognise the importance of protecting your personal information and are committed to treating it responsibly and in compliance with applicable data protection laws.

For the mere use or navigation on this Website: www.busup.com will be attributed the condition of "User", and you must carefully read the following "Privacy Policy" that is set out below. All this without prejudice to the need to provide your consent when it is collected for the provision of personal data and / or the installation of cookies.

Information about which cookies BUSUP TECHNOLOGIES, S.L. uses. on the Website and how to configure them, as well as more detail on what processing of User information - as a result of the use of the device with which you browse - are carried out, can be found in our Cookies Policy in https://www.busup.com/cookies-policy.

Likewise, it is reported that the Privacy Policy of the BUSUP computer application ("BUSUP App Privacy Policy")), available in the Android (Google Play) and Apple (App Store) application stores or in web environments enabled for this purpose, as well as its "Terms and Conditions of Use", will be governed by the provisions of their own legal texts *.

At the end of this document, in the section "Other legal texts applicable to the service" you can find the list of policies and conditions applicable to each country in which Bus Up operates.

Who is responsible for the processing of your personal data?

In accordance with current regulations, the interested party (hereinafter "User") is informed that the personal data provided will be processed by the owner of the website "www.busup.com" (hereinafter "Website"), BUSUP TECHNOLOGIES S.L. (hereinafter "BUSUP"), whose contact details are as follows:

Tax identification number : B-66864307
Registered office : Gran Via de les Corts Catalanes 133 (CP 08014) Barcelona, Spain

Email address of the Data Protection Officer: info@busup.com

For what purpose and legitimacy will your personal data be processed?

The personal data provided by the User through the forms of the Website or other channels, other than those of the App itself, will be used for the following purposes:

Why do we process your data provided and with what legitimacy?

TREATMENTS COMMON TO ALL THE COUNTRIES IN WHICH WE OPERATE:

Respond to the request, request or consultation of information or documentation made through the contact forms of the Website by a representative of a company, business and / or technology park, university, school or event, a passenger transport service operator, or any other type of User of the Website. In these cases, the processing of personal data is based on the User's consent granted by checking the corresponding box on the form.

Remember that you can withdraw your consent at any time. However, in case of withdrawing consent, this will not affect the legality of the treatments carried out previously. At the end of this section you will find out how to revoke your consent.

To manage the job application submitted to offers published on our Website, LinkedIn or through a recruitment or employment agency. In this case, the processing of your data is based on the application at the request of the interested party of pre-contractual measures or the intention to conclude a contract. More specifically, as applicable, we may receive your resume or your academic and professional experience through LinkedIn or recruitment or employment agency, in order to initiate the appropriate selection process.

We may also process the personal data that you voluntarily provide us by submitting your application, even if there is no specific offer published, based on the legitimate interest of BUSUP in the management of these spontaneous applications, in which case you will be provided with the corresponding information for the processing of your personal data.

Additionally, if you authorize us, we may communicate your curriculum to the rest of the companies of the BUSUP Group to increase your chances of joining the Group (You can access the list of Group companies in section 5. Recipients). You can revoke this consent at any time, without prejudice to the legality of the treatments carried out until that moment.

Register and manage the User's registration in the blog of our Website https://www.busup.com/en/blog for the reception by email of the latest news and articles published. The processing of personal data is based on the User's consent granted by checking the corresponding box on the form.

Manage the User's participation in the comment form of the Website's blog through the publication of their comments. The processing of personal data is based on the User's consent granted by checking the corresponding box on the form.

Please note that the publication of the User's comment is subject to compliance with the provisions of the Legal Notice of the Website.

Send commercial communications about the services and news of BUSUP by email. The processing of personal data is based on the User's consent given by ticking the corresponding box on our Website forms or social networks (e.g. when you use a contact form or download documents free of charge).

Maintain relations of any kind with the legal entity in which the natural person empowered provides his services in cases of representation of the company. For these purposes, based on the legitimate interests of Bus Up we will process the information you provide us (for example, through the delivery of business cards) or lawfully provided to us by third parties (for example, other people who work in your company).

You can put an end to the processing of your personal data for these purposes by exercising your right in the manner indicated in the section relating to the "exercise of rights". Although, in certain cases, the legitimate interest of BUSUP could prevail over this right, in which case, it will be indicated with reasons.

Attend and manage calls made to the BUSUP customer service telephone service (Call Center) based on the execution of the contractual relationship with the users who have contracted the services of BUSUP. The purpose of this treatment is to attend and manage requests, queries or incidents communicated by Users by telephone.

Make recordings of calls made to the BUSUP customer service (Call Center) to properly manage your request, improve the quality of services and defend the interests of BUSUP against possible claims.

This treatment responds to BUSUP's need to ensure the quality of its services to the interested party, as an effective means of resolving possible present and future incidents, allowing BUSUP to verify the information provided by Users at the time of their request. In this sense, the treatment is suitable to satisfy the legitimate interest of BUSUP consisting in being able to face potential claims from the interested parties as a result of the requests made, since such information is necessary for the formulation, exercise and / or defense against possible claims.

This treatment responds to the current and real interest of BUSUP to protect itself against potential practices that may cause damage, so that this objective could not be achieved without carrying out the treatment. On the other hand, in accordance with the conditions of the treatment, it is considered that this interest is not neutralized by the rights and freedoms of the interested parties, but on the contrary, since the treatment contributes to increase legal certainty in the relationship that they maintain with the Responsible. In any case, the interested parties may, at any time, communicate their opposition to this treatment, in accordance with the rights contained in this privacy policy.

The Busup Drivers app collects and uses your device's location data to track your real-time location while you are performing a service. This is essential for monitoring and ensuring the efficiency and safety of the service provided to our passengers. Your location will only be accessed and shared during active service times. The location data will not be used for any other purpose and will not be collected when you are not actively providing a service.

SPECIFIC TREATMENTS IN THE COUNTRIES IN WHICH WE OPERATE

BRAZIL:

BUSUP may interact with you through social networks in which BUSUP has a registered profile in Brazil. In these cases, the processing of personal data that BUSUP carries out will be aimed at answering your query and will be based on the application of pre-contractual measures at the request of the interested party.

In any case, remember that the processing of your personal data is ultimately subject to the privacy and security policy or conditions of the social network of which you are a user. For these purposes, you can consult the privacy policies of the social networks in which BUSUP has a profile in Brazil:

Twitter:

@busup_brasil

@BUSUP_es

Instagram:

@busup_es

@busup_pt

@busup_br

Youtube:

@busup1307

TikTok

User: busup_br

Facebook:

busup.es/

busup.br

What categories of personal data will be processed?

The categories of data to be processed will be determined, in each case, according to the collection channel and purpose pursued. Such data may be the following:

TREATMENTS COMMON TO ALL THE COUNTRIES IN WHICH WE OPERATE:

Collection channel/Purpose	Type of data
Contact Form / Attend the request, request or query made	Name and Last name Name of the organization (in case of representative of any of the entities mentioned in the purpose) Country Email Other information provided in comments
Application form / Management of job applications	Name and Last Name Email Teléfono Perfil de LinkedIn, CV Cover letter
Blog registration form / Registration to receive news and articles on the blog	Email
Form comment blog/Participation in the blog through comments	Number Email
Forms on the Website or social networks where consent is requested for the sending of commercial communications	Name and surname E-mail and telephone Professional data as a company and position
Call center	Number Email

SPECIFIC TREATMENTS IN THE COUNTRIES IN WHICH WE OPERATE:

BRAZIL

Chats or direct messages on social networks

Name and surname
E-mail and telephone

Obligation to provide data

The data requested in the forms of the Website or other channels, other than the App, are generally mandatory (unless otherwise specified in the required field) to comply with the established purposes. Therefore, if they are not provided or are not provided correctly, they cannot be attended, without prejudice to the fact that you can perform other actions on the Website.

Sources from which we obtain user data

That provided by the user himself
Obtained from browsing behavior (see Cookies policy in https://www.busup.com/cookies-policy).

How long will we process your personal data?

As a general rule, personal data will be kept as long as you are registered as a User of any of the services of our Website (e.g. registration on the blog) and even afterwards, until the eventual responsibilities derived from it are prescribed.

The criteria of periods for the retention of personal data can be found in the following summary table available at the end of the document.

TREATMENTS COMMON TO ALL THE COUNTRIES IN WHICH WE OPERATE:

Purpose	Retention criteria or period
Respond to the request, request or query made	During the time necessary to process and respond to your request and, once completed, during the limitation period of legal actions arising from such requests.
Management of job applications	The data used to evaluate your job application will be kept for the time strictly necessary to assess whether your application conforms to the profile offered and, at most, one year. If you intend to keep your personal data for a longer period, your consent will be requested.
Sign up to receive news and blog posts	The data used for sending news and articles on the blog based on consent will be processed until the User withdraws his consent.
Participation in the blog through comments	The data used to manage your participation in the blog through your comment based or consent will be processed until the User withdraws his consent.
Sending commercial communications	The data used to send commercial communications based on consent will be processed until the User withdraws his consent.
Attention Rights	Durante the time necessary to carry out the right requested by the User and once fulfilled said right, they will be kept until the prescription of the possible responsibilities derived from this treatment.
Call Center	D during the time necessary to process and respond to your request and, once completed, during the limitation period of legal actions arising from such requests.

SPECIFIC TREATMENTS IN THE COUNTRIES IN WHICH WE OPERATE:

BRAZIL

Chats or direct messages on social networks

During the time in which your request, query or request is managed

In any case, in those cases in which there are specific conservation periods different from the previous ones, they will be informed through other collection and information channels at their disposal.

Data security

BUSUP has implemented the necessary technical and organizational measures to guarantee the security of your personal data and prevent its alteration, loss, treatment or unauthorized access, taking into account the state of the art, the nature of the data and the risks to which they are exposed. However, please note that measures on the Internet, due to their nature and global nature, are not impregnable.

Who are the recipients of your personal data?

The User's data may be communicated to:

The AEAT for the fulfillment of the fiscal obligations of BUSUP, as well as any other public administration with competence in the matter.
In the event that the services of a BUSUP group company operating in a specific territory are explicitly or implicitly requested in the request, query or request made, your personal data may be communicated to said company based on the execution of the contractual relationship.
Judges and Courts in the cases provided for by law.
Other companies of the BUSUP Group, with your consent, to evaluate your candidacy.

In these cases, only your personal data will be forwarded to the company located in the country in which the vacancy is open.

BUSUP Group companies and location:

Enterprise	Location
BUSUP Technologies, S.L.,	Spain
BUSUP España Mobility, S.L.,	Spain
BUSUP Portugal Mobility LDA	Portugal
busUp do Brasil Tecnología LTDA	Brazil
BUSUP USA Mobility Inc.	United States
BUSUP Mobility Mexico S.A. de C.V.	Mexico

Likewise, BUSUP's suppliers may access the data if such access is necessary for the proper fulfillment of legal obligations and/or for the purposes indicated above. These providers will not process your data for their own purposes, being among these data processors the following categories:

Operators of collective transport services that are going to carry out the transport service
Hosting and cloud service providers.
Computer maintenance services , suppliers of analytical tools and CRM systems.
Candidate recruitment agencies.
Companies of the BUSUP Group for the administrative and technological support of the companies of the Group.
Mail service providers.

Some of the recipients mentioned are in Europe and others outside the European Economic Area (EEA). We ensure, through contractual clauses, that these service providers treat personal data in accordance with European data protection rules to ensure a high level of protection, even if personal data is transferred to a country where there is a good level of data protection and for which there is no adequacy decision of the EU Commission. No other transfer of personal data to other recipients takes place, except where we are required to do so by law. For more information on the appropriate safeguards for international data transfers or a copy thereof, please contact our data protection officer by email at info@busup.com.

What rights do Users have?

Users have the right, for all countries in which BUSUP operates, to:

Access your personal data.
Rectify inaccurate or incomplete data.
Request the deletion of your data when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
Obtain from BUSUP the limitation of data processing when any of the conditions established in the data protection regulations are met.
Request the portability of your data.
Oppose the processing of your data.
File a complaint with the competent authority of the country in which BusUP has its main establishment when the interested party considers that BUSUP has violated the rights recognized by the applicable data protection regulations. In this sense, you can file a claim with the Spanish Agency for Data Protection (http://www.aepd.es).

In those cases in which rights other than those indicated apply in the country of residence of the User, Bus Up will proceed to inform you about them at the time of collection. You can contact BUSUP by sending a request accompanied by a photocopy of your identity document or proving your identity otherwise admitted by law to the address info@busup.com.

Responsibility of the User

The User:

You guarantee that you are over 14 years old at the time of registering on the Website and / or Application and that the data you provide to BUSUP are true, accurate, complete and updated. In this sense, the User is responsible for the veracity of all the data communicated and will provide updated information, so that it responds to their real situation.
It guarantees that it has informed the third parties whose data it has already provided, where appropriate, of the aspects contained in this document. Likewise, you guarantee that you have obtained your authorization to provide your data to BUSUP for the purposes indicated.
Guard those access data and / or passwords, committing not to transfer their use, assuming the responsibility that may arise from improper use of these.
It will be responsible for false or inaccurate information provided through the Application and / or Website and for direct or indirect damages that may be caused to BUSUP or third parties.

Changes to this Privacy Policy

Ifyou have any questions about privacy at BUSUP, please contactus at our address with a detailed description of your query, and we will try to resolve it.

Our business and technology are constantly changing, and our Privacy Policy will change as well. In the event that BUSUP modifies this Privacy Policy, BUSUP will publish a notification on the Website so that Users may be aware of any change in the conditions of processing of their personal data. However, if at any time, BUSUP decides to use the personal data of the Users in a manner other than that established at the time of collection and the User's consent is required to carry out such further processing, it will notify the Users by email requesting such consent.

Other legal texts applicable to the service

The following list of legal texts is classified by applicable jurisdiction and User category

SPAIN

Passengers:

Terms and Conditions BusUP App Service-Spain-
Privacy Policy App BusUP

Drivers:

Privacy Policy App BusUP Drivers

Monitors:

Privacy Policy App BusUP Schools

PORTUGAL

Passengers

Terms and Conditions App BusUP-Portugal-
Privacy Policy App BusUP

Drivers:

Privacy Policy App BusUP Drivers

Monitors:

Privacy Policy App BusUP Schools

BRAZIL

Passengers

Terms and Conditions App BusUP-Brasil-
Privacy Policy App BusUP

Drivers:

Privacy Policy App BusUP Drivers

Monitors:

Privacy Policy App BusUP Schools

UNITED STATES

Passengers

Terms and Conditions App BusUP-USA-
Privacy Policy App BusUP

Drivers:

Privacy Policy App BusUP Drivers

Monitors:

Privacy Policy App BusUP Schools

PERU

Terms and Conditions App BusUP-Peru-
Privacy Policy App BusUP

Drivers:

Privacy Policy App BusUP Drivers

Monitors:

Privacy Policy App BusUP Schools

Last modified: March, 2023.