1. General

Hoop Solutions SL (with registered office at Calle Bravo Murillo, 231 — Piso 2D, 28020 Madrid, Spain), acting as data controller, is committed to protecting and respecting your privacy on the TRIBBU platform (“TRIBBU”). This document (the “Privacy Policy”) is designed to inform you about our practices regarding the collection, use and disclosure of the information you provide to us through this website www.tribbuapp.com (the “Website”) or our mobile applications (the “App”). This Privacy Policy establishes the framework under which your personal data will be collected and processed. Please read this text carefully so that you understand our position and practices regarding your personal data and how we will treat it.

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2. What information do we collect?

We may collect and process the following data about you:

2.1 Information that you provide to us

You may provide us with information, including information that can identify you (“personal data”), when you use the Website/App to fill out its forms (such as, for example, the registration form), when you enter any of our contests, promotions or surveys or when you contact us by phone, email or in any other way, as well as when you report a problem with our Website/App.
The information you provide to us may contain:
- Required information necessary to register for the service we provide on our Website/App or to access other of our services; this data includes your name, surname, and mobile phone number. All of these fields are required. TRIBBU will not be able to provide you with the services offered on our page and app if you don't give us the necessary information to be able to create a user account on our Website/App
- Your date of birth
- A photograph
- Addresses that you save as favorites on the platform
- Information about your car, such as the license plate or the environmental sticker
- A record of the correspondence you have had with us
- A record of any reservation you make or any travel announcement you publish through our Web/App;
- Details of economic or accounting transactions, including transactions carried out through our Web/App or any other means. This may include information such as, for example, your payment card or bank details, information regarding trips or travel sections that you have booked or offered through our Website/App
- Details of your visits to our Web/App and the content you access
- Your answers to our surveys or questionnaires, such as your reviews about trips you have shared with other members of our community. This information can be used for the purpose of analyzing and studying user behaviors.
- Information that we may request from you when you report a problem with our Website/App or our service, such as the cause of your request for support
- Information about your location, only when the application is open in the foreground, at the time you select the origin or destination of your trip, and provided that you have given your consent to the collection and processing of this data.

2.2 Information that we automatically collect

2.2.1 With respect to each of your visits to our Website/App, we may collect, in accordance with applicable legislation and, when necessary, with your consent, information regarding the devices you use and the networks to which you connect when you use our services. This may include the following information: your IP address, connection information, browser type and version, types and versions of the plugins or add-ons of your browser, operating system and platform, information about your visit including the detailed history of the URL, through and from our Website/App, products you have viewed or searched for, download errors, duration of visits to certain pages, interactions with the page and telephone number from which you called us. We collect this information using a variety of technologies, including cookies.
2.2.2 We also collect global information about your activity on our platform (such as, for example, the number of trips offered, your response time to messages, etc.). This information can be published in your public profile on our platform.
2.2.3. Using Microsoft Clarity. In order to better understand how users interact with our Website/App and thus improve our products and services, we collaborate with Microsoft Clarity. This tool allows us to collect information about the browsing behavior of users through metrics, heat maps and session recordings. This data is collected using our own and third-party cookies, as well as other tracking technologies. This helps us to optimize the site experience and detect potential fraud or security threats. For more information on how Microsoft collects and uses your data, you can see the Microsoft Privacy Statement.

2.3 Data Retention
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2.3.1 Except for the categories of personal data mentioned in clauses 2.3.2 and 2.3.3, your personal data will be kept for the duration of your relationship with us and will no longer be used:
- 5 years after the last use of our platform, if you did not close your account;
- 60 days after the closure of your account, unless you received a negative report or rating, in which case your personal data will be kept for (i) a period of 2 years after the last negative report or rating, or (ii) 1 year after the closure of your account, whichever is longer.
2.3.2 The following categories of personal data may be kept for different periods:
- Financial data (e.g., payments, refunds, etc.) are kept for the time required by applicable accounting and tax legislation;
- All user-generated content is anonymized, although it is still available on our platforms.
2.3.3 In the event that your account is suspended or blocked, we will keep your data for a period of between 2 and 10 years, in order to prevent you from circumventing the rules that apply to our platforms.

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3. How do we use the information we collect?

We will use the information collected in order to:
‍3.1 to comply with our obligations under the contracts we enter into between you and us and to provide you with the information and services you request from us;
‍3.2 fulfill our obligations under the contract signed with the company or university to which you belong, for the benefit of offering you the best user experience. This data will be used to offer you exclusive benefits because you belong to your company, such as privileged parking spaces in your company or university, rewards for your recurrence, etc.
‍3.3 send you information regarding our services by email and/or text message and/or Whatsapp and/or any other means of communication (e.g. your booking confirmation);
‍3.4 to receive the payments you make or to transfer to you the payments that we have collected on your behalf;
‍3.5 to allow you to customize your user profile on our platform;
‍3.6 to allow you to communicate and interact with other members about our services or about trips that you are going to share or have shared with other members and/or to organize such trips;
‍3.7 to give you access to our support services and to allow you to communicate with our member relations team;
‍3.8 to ensure compliance with (i) applicable legislation, (ii) our Terms and Conditions, (iii) Privacy Policy (iv) and Code of Good Conduct. Certain breaches that we consider to be inappropriate may lead to the suspension of your account;
‍3.9 to send you, in accordance with applicable legislation and, when necessary, with your consent, marketing messages and information necessary to facilitate the service or booking process and to offer you suggestions and recommendations about related goods and services that may interest you. We also share events that you generate on our Website/App with third parties to send you advertising on your social media platforms (more information in point 8 of this page).
‍3.10 to notify you of any changes to our services;
‍3.11 to manage our Web/App and for internal operations, including problem solving, data analysis, testing, research and surveys;
‍3.12 to ensure that content is presented in the most effective way for you and your device;
‍3.13 to allow you to participate in the interactive features of our service, when you request it;
‍3.14 as part of our efforts to keep our Website/App safe and secure;
‍3.15 to measure or understand the effectiveness of the advertising we send to you, both to you and to third parties, and to send you information that may interest you.
‍3.16 to be able to prevent fraud.
‍3.17 to be able to consult your opinion about TRIBBU.
‍3.18 to be able to do a survey regarding the service and your relationship with it.
‍3.19 to improve our service.
‍3.20 for any other question related to the provision of the service.
‍3.21 to verify your eligibility and obtain the Energy Savings Certificates incentive (only in Spain).

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4. Who are the recipients of the Information we collect about you and for what purpose?

4.1 When you make use of our services, certain information about you is shared with relevant members of our community (collaborating entities and users), both in your public profile and in relation to your reservations, only as necessary for the provision of the service and access to benefits that result from it (e.g., we give your telephone number to the members with whom you are going to share a trip, we share your vehicle registration number with the company to which you belong to to to give you access to benefits such as “VAO parking spaces” or we analyze your use of the application to prepare sustainability reports).

‍4.2 In accordance with applicable legislation and, when necessary, with your consent (in this case, by accepting this Privacy Policy, you grant your consent in this regard), we may combine information about you, including your personal data and information obtained through cookies and that we receive or send to our business partners. We may use such information and the combined information for the purposes set out above.

‍4.3 In addition, Hoop Solutions SL may disclose your information when legally required or when we consider in good faith that such access, protection or disclosure is reasonably necessary to (i) respond to a claim against Hoop Solutions SL, (ii) comply with legal procedures, (iii) enforce a contract with our users, in accordance with our Terms and Conditions, our Privacy Policy, our Code of Good Conduct, (iv) in the event of an emergency involving a danger to public health, death or physical harm to a person (v) in the framework of an investigation or (vi) to protect the rights, property or personal safety of Hoop Solutions SL, its members or other individuals.

‍4.4 We also work closely with third parties who may be recipients of your personal data, for example: our business partners who can advertise their services on our Website and Application and to whom you may decide to subscribe. Our business partners, who can advertise our services on their websites and/or applications. Our subcontractors, who include technical services, payment services, or providers of analytical solutions.

‍4.5 We will only disclose your personal data to the third parties mentioned in the section 4.4. in the following cases:‍

4.5.1 When we use another service provider to fulfill any contract we enter into with you, in order to facilitate or extend our services (for example, in the framework of payments made on our Platform);
4.5.2 As part of the reservation process and in order to provide the requested services, we may publish on the Platform and/or transmit to another member, certain information, such as your name, identity document, mobile phone number and/or email.
4.5.3 In the event that we sell or acquire any business or asset, in which case we may need to disclose your personal data to the potential seller or buyer, in accordance with applicable regulations
4.5.4 If Hoop Solutions SL or all or part of its assets are acquired by a third party, in which case the personal data we hold will be one of the transferred assets.

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5. How do we treat your personal data for Energy Savings Certificates? (only for Spain)

Within the framework of Energy Savings Certificates (CAE), we process some of the personal data of your profile (name, surname, email, telephone number, identification documents) and the details of your trips (duration, distance, cities of arrival/destination, proof of payment and information about the users with whom you shared the trip) that are necessary to obtain Energy Savings Certificates in accordance with the legal requirements established in the CAE Legal Framework. The data is processed by our partner Delcae, a mandatory delegate, as Data Processors, in order to verify your eligibility and submit an application to the Ministry for Ecological Transition and the Demographic Challenge. In the case of trips eligible for the Energy Savings Certificates incentive (Energy Bonus) made between January 26, 2023 and July 19, 2024, this treatment serves our legitimate interest in benefiting from and making you benefit from Energy Savings Certificates. You have the option to object to this at the time we contact you to transfer your energy savings rights.

You have the right to rectify or delete your data (before requesting the CAE), as well as to access information concerning you and/or, for legitimate reasons, to object to this processing by contacting us.

All documents submitted with the CAE application are kept until at least three years after the validation of the CAE to allow verification by public authorities.

Energy Saving Certificates are governed by Royal Decree 36/2023, of January 24, 2023, which establishes a system of Energy Savings Certificates in Spain and which is partially developed by Order TED/ 815 2023, of July 18, 2023, Order TED/845/2023, of July 18, 2023, approving the catalog of standardized energy efficiency measures, and the TRA030 and TRA040 Sheets in their simplified version validated by the Ministry for the Ecological Transition and the Demographic Challenge (referred to in a way independently or as a whole as a “Legal Framework of the EPAs”).

‍5.1. Your location data. To prevent and detect fraud against the CAeS system, Hoop and/or its users, it is necessary to collect location data in real time. It is a legal requirement of the Ministry of Transport, Mobility and Urban Agenda (MITMA) to obtain CAEs.

When a trip is booked and confirmed, we keep track of the location of the driver and passengers along the way, linking this data to their respective accounts. This allows us to verify that the trip is taking place as scheduled.

Exact location collection begins when the user manually activates tracking using the following actions:
(i) In the case of drivers: by pressing the “Have you started the journey?” button.
(ii) In the case of passengers: by pressing the button “Did the driver pick you up?”

The tracking process ends when the user manually stops the trip with the following actions:
(i) In the case of drivers: by pressing the “Have you finished your journey?” button.
(ii) In the case of passengers: by pressing the “Did your driver leave you?” button.

In addition, if the trip is not completed manually, location collection will automatically stop after twice the estimated travel time has elapsed.

To activate the Energy Bonus and be able to benefit from the CAEs, it is essential to grant permission for the collection of the exact location.

Without this, the bonus cannot be activated and, consequently, the user will not be a beneficiary of the CAEs.

If you have any questions about this process, you can contact us at dataprotection@tribbuapp.com.

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6. How do we use and moderate your messages?

6.1 We may review, scan or analyze the messages you exchange with other members of our community through our Web/App, for the purpose of fraud prevention, service improvement, customer support and compliance with contracts signed with our members (such as our Terms and Conditions). For example, in order to prevent a member from circumventing our online booking system, we may scan and analyze messages sent through our platform to verify that they do not include contact information or references to another website.

6.2 We never scan or analyze your messages with other members of our community for commercial or advertising purposes. We may use automated methods to moderate such messages.

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7. Direct advertising and communications

In accordance with applicable legislation and, if necessary, with your consent, we may use the information you provide on our Website/App for electronic direct marketing purposes (e.g. (i) to receive our newsletters, invitations to our events or other communications that we think may be of interest to you, or (ii) to send you direct advertising on social media platforms or third-party sites and applications). We may also try to contact you for technical support in the event of service incidents.

‍With regard to emails: you can withdraw your consent at any time (i) by clicking on the unsubscribe link that we provide in each of the communications that Hoop sends you or (ii) by contacting us using the contact information provided in section 13 below.

‍With regard to SMS communications: you can withdraw your consent at any time by contacting us using the contact information provided in section 13 below.

‍With regard to communications via WhatsApp: you can withdraw your consent at any time (i) by sending us a message in the same chat you have with us or (ii) by contacting us using the contact information provided in section 13 below.

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8. Information on the use of behavioral events for statistical and advertising purposes

On our Website/App, we use analysis and advertising tools provided by third parties, such as Google and Meta, in order to improve our services and optimize our marketing campaigns.

These tools allow us to record certain behavioral events anonymously (for example, making a reservation or visiting a specific screen of our Website/App). These events do not contain personal data or any identifier that allows direct or indirect identification of the user, such as email addresses, telephone numbers, IP addresses or advertising identifiers of the device.

The information transmitted to these platforms is strictly limited to the event itself. Hoop has no way of individually identifying users or of associating such activity with a specific person. Any possible link between registered behavior and a user on third-party platforms is made in accordance with their own terms and privacy policies, without intervention or responsibility on the part of TRIBBU.

This treatment is carried out exclusively for statistical and advertising purposes, and does not involve the transfer of personal data to third parties or the use of individualized profiling techniques by TRIBBU.

9. What rights can you exercise with respect to your personal data?

9.1 You have the right to receive a copy of the personal data we hold about you (your right to access the data).

‍9.2 You can request the deletion of personal data or the correction of personal data that is inaccurate (your right to deletion and rectification). Please note that we may keep certain information about you, as required by law, or when we have a legal basis for doing so (e.g., our legitimate interest in maintaining the security and protection of the platform for other users).

‍9.3 You have the right to object, at any time, to (i) the processing of your personal data for direct marketing purposes, or (ii) to the processing of your personal data for other purposes, for reasons related to your particular situation (your right to object to the processing). Please note that, in the latter case, this right applies only if the processing of your personal data is based on our legitimate interest.

‍9.4 You have the right to limit the processing of your personal data (your right to limit the processing). Please note that this only applies if (i) you have questioned the accuracy of your personal data and we are verifying that accuracy; (ii) you have exercised your right to object and we continue to assess, as provided for by applicable law, whether our legitimate reasons for processing your personal data in that case override your interests, rights and freedoms; or (iii) we have processed your personal data illegally, but you object to the deletion of personal data or want us to keep it in order to establish, exercise or defend a legal right.

‍9.5 You have the right to receive and/or to have us transfer to another data controller a subset of personal data, related to you and that you have provided to us, and that we process to fulfill our contract or because you have previously given your consent to do so, in a structured, machine-readable and commonly used format (your right to data portability).

‍9.6 To exercise your rights, contact the Data Protection Officer (dataprotection@hoopcarpool.com).

‍9.7 You also have the right to file a complaint with the relevant data protection supervisory authority, or to request compensation through the courts, if you believe that your rights have been violated.9.8 You also have the right to establish policies regarding the destination of your Personal Data after your death.

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10. Confidentiality of your password

When you decide to set a password to access certain parts of our Web/App, it will be your responsibility to keep it secret. Please don't reveal your password to anyone.

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11. Links to other websites, applications and social networks

Our Platform (web and/or application) may contain, at certain times, links to and from web pages and/or applications of our partner networks, advertisers and partners. If you follow a link to any of these websites or applications, keep in mind that they have their own privacy policies and that we are not responsible for them. Always check these policies before providing them with any personal information.

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12. Amendments to our Privacy Policy

Any changes we make to our Privacy Policy will be posted on this page. When appropriate, we will notify you or ask for your consent. Please check back frequently for any updates or changes to our Privacy Policy.

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‍13. Contact

If at any time you want to contact us to tell us your opinion regarding our privacy practices, or in relation to any questions about your personal data, you can do so through our email dataprotection@tribbuapp.com.