PART A: Introduction and Description of the Monitoring System Tool

Introduction

The  terms of this Policy are applicable  to all the individuals / clients (hereinafter referred to as “Vehicle Holders” or “Users” or “Lessees”) who have entered into a contractual agreement with NOVICHENTO LIMITED (hereinafter referred to as “we” or “Company“), or the rental or use or leasing  of the Company’s vehicles (hereinafter referred to as the “Company’s Vehicles“).

The tracking covers Company’s Vehicles, i.e., cars and/or other vehicles owned by the Company, and/or which the Company has and/or may lease or obtain for long-term lease in the future.

These terms constitute an integral part of the Terms of the Vehicle Rental Contract co-signed by the Lessees and the Company for the Vehicle Rental purposes and: 

• Set out the Company’s responsibilities towards the data that may be processed by the Company through the provision / rental of the Company’s Vehicle;
• Define the responsibilities that the User assumes with respect to the Company when the User accepts delivery and return of a Company’s Vehicle; and
• Define the Data Processing Policy for Users of Company Vehicles. 

The Terms and Conditions are available to all people subject to monitoring by using a GPS tracking device installed in the Company’s Vehicles.

These terms meet the requirements of Article 13(1) and (2) of Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016 on the protection of natural people with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC, known as the General Data Protection Regulation (hereinafter the “GDPR“).

Any questions regarding the processing of personal data resulting from GPS tracking in company vehicles should be submitted to the following email address: info@novichento.com 

Description of the Monitoring System Tool

The Company and / or its partner has installed a vehicle tracking tool on all Company’s Vehicles assigned from time to time to employees and/or partners or Users / Lessee. The purpose of using the GPS (Global Positioning System) Tracker vehicle tracking tool (hereinafter referred to as “GPS“) is both to ensure the proper and lawful use of Company’s ehicles in the course of the rental of the Company’s Vehicles and to ensure that Lessees assume responsibility for entrusted property and prevent incidents that violate the interests of the Company (hereinafter referred to as the ‘purpose of installation’).

GPS is a technology that uses satellite signals to accurately determine the position of a vehicle. We use GPS to track the location and movements of company-owned vehicles for a variety of purposes, including optimizing vehicle routes, improving safety, monitoring vehicle maintenance and tracking driver behavior.

Tracking is carried out through the use of a tool – GPS Tracker which is understood as a set of devices used to track vehicles. The tracking is carried out only during the time when a Company’s Vehicle is used.

All Company’s Vehicles are delivered with information on the monitoring and processing of the resulting data, which is posted inside the vehicle, in a place visible to the user (hereinafter “Vehicle Use Policy“).

The monitoring is based on a computer system (hereinafter referred to as “GPS system”) that allows the collection and storage of data transmitted by GPS trackers in the framework:

1. the identification of a company vehicle on a digital map online;
2. the real-time tracking of the company vehicle;
3. routing and destinations;
4. vehicle kilometers history and location;
5. determination of the driver’s travel areas;
6. extensive reporting system;
7. analysis of company vehicle operating parameters.

The surveillance duties are performed only by employees designated for this purpose by the Company and/or its partners. 

The personnel carrying out the monitoring are obliged to keep the results of the monitoring confidential and are bound by confidentiality and non-disclosure agreements.

The Company is responsible for any monitoring tasks and its contact details is:

Kato Zodias 7, Mesa Geitonia, 4007 Limassol Cyprus 

Tel:   +357 94043290

Mob: +357 95197929

Email: info@novichento.com

Any assignment of monitoring tasks to people other than those initially appointed to access the information covered by the monitoring does not require a revision of the present rules. Such assignment in any case requires the conclusion of a confidentiality and non-disclosure agreement between the respective person and the Company.

PART B:  Data Controller, Processor and purposes of processing:

Data Controller 

NOVICHENTO LIMITED, a Cyprus private company, with registered office address at Kato Zodias 7, Mesa Geitonia, 4007 Limassol Cyprus and registration number with the Registrar of Companies HE444366 is the Data Controller.

Processor

For the purposes of GPS tracking, INTELLSYS LTD – as the owner of the computer system that allows the collection and storage of the data provided by PLEASE INSERT – is the provider of the tracking technology and is acting as the Data Processor. Information on how the Processor processes the data can be found PLEASE INSERT LINK

Purposes of processing:

Personal data are processed for the following purposes:

Legal basis for processing:

Personal data are processed on the basis of Article 6(1)(f) of the GDPR (legitimate interests pursued by the Data Controller).

Categories and types of data that may be processed

(a) General personal data: name and surname, identity card/passport number, mobile phone number, date of birth, driving license details, insurance details.

(c) Sensitive data: gender, origin, driving behavior, driving routes, locations

Categories of data which may be disclosed to third parties:

In addition, the Company assigns to the Data Processor the following personal data and/or allows access to the following personal data:

1. a) in relation to the Users or employees or partners using a vehicle: information on the location and travel history of the entrusted vehicle (this data may be directly and/or indirectly linked to other personal data), 

(c) in relation to the persons designated as contact persons on the company’s side: first name, surname, mobile phone number, landline phone number, mailing address, e-mail address.

Note: Personal data will not be transferred by the Processor to a third country.

Transfer of data to third parties:

Personal data may be transferred to the following data recipients: 

1. Public Authorities (where and when required by Cyprus and/or European legislation); 
2. The Company’s legal advisers, where necessary to legally act for and/or defend the Company’s legitimate interests against any claims; and
3. Partners, such as the vehicles’ insurance company.

Your rights:

1. Under the General Data Protection Regulation (GDPR), Users have certain rights with regard to their personal data:
2. Request to access and ask for the rectification or deletion of their data,
3. Object to the processing; and 
4. Request the transfer of their data (the right to data portability).
5. A monitored person has the right to lodge a complaint with the Data Protection Authority if he or she considers that the processing of his/her personal data breaches the provisions of the GDPR and the provisions of the relevant national legislation.

If you wish to exercise your rights, you should contact Company directly.

Note: some of your rights may be subject to restrictions. In this case, you will be informed by the Company in writing of the reasons why your request cannot be satisfied or cannot be fully satisfied. 

Personal data will not be processed in an automated manner, including in the form of profiling.

Technical and organisational measures:

The Company shall make every effort to ensure all physical, technical and organisational protection measures against accidental or malicious destruction, accidental loss, alteration, unauthorised disclosure, use or access, in accordance with all applicable Regulations.

In the event of an incident or suspicious situation that violates the interests of the Company, in the context of monitoring activities, including those that violate the security of information, the privacy of the monitored persons – any person who has obtained such information is obliged to report it to the Company.

Data Retention and Data Deletion

Personal data obtained during monitoring are stored in the GPS file for up to 12 months from the date of collection of the information. At the end of 12 months the data shall be destroyed.

Information relating to the Company’s Vehicle such as kilometres travelled, fuel consumed, hours of vehicle use etc. is stored for a period of time beyond 12 months for the purposes of recorded vehicle history, ensuring vehicle maintenance and analysis of the Company’s expenses. 

The results of the monitoring are subject to analysis only for the purposes set out above, after being pseudonymised so as to ensure that they do not directly identify any individuals. 

Update Policy

This policy was drafted in September 2023. 

The Company reserves the right to amend this policy at any time it considers necessary to comply with any legal obligations arising from relevant legislation and regulations with respect to which it is bound to comply. In such case, the Users will be informed in writing by means of an e-mail to the e-mail address provided to them by the Company and/or by uploading the revised Policy on the intranet.