Privacy Statement

Rev. April 2024

CoDrive S.r.l., as the Data Controller, pursuant to Article 13 of the EU Regulation 2016/679, wishes to provide you with some information about the processing of data acquired using the APP.

CoDrive S.r.l. has its registered office at Viale D. Bramante, 43 Terni – Italy email: info@codrive.it

Data collected by CoDrive

CoDrive, collects user data that allows direct or indirect identification depending on whether the user completes the registration or remains anonymous and collects information on how the services offered are used.

Data shared by the User

The user can decide whether to share their trips in the CoDrive Community by setting the choice by default or they can modify it for each individual trip.

Personal data of account, profile, activity, and usage

CoDrive collects personal data such as name, surname, language, country, gender, email address, in order to allow access to the services.
It collects the Primary Account of the provider used to log in (Google, Apple). Information available on the Primary Account (such as name, surname, e-mail address, URL of the profile picture used for the account) are collected and stored on CoDrive servers which are exposed on the codrive.it domain.
It optionally collects personal data on a voluntary basis from the user that we use to optimize the reporting we provide to the user.

Location Information

The user freely consents, upon explicit consent, to CoDrive’s acquisition of location information when the APP is in navigation mode.

If the User wishes to stop sharing the device’s location, they can do so at any time by changing the device’s settings, the APP will no longer be able to guarantee the services provided.

Payment Information

CoDrive uses certified third-party payment services and does not have access to credit card data.

Third-Party Accounts

CoDrive allows the User to register and access the Services using accounts created with third parties, such as Meta, Google, or Apple (collectively referred to as “Third-Party Accounts”). If the User accesses the Services with Third-Party Accounts, we will collect the information that they have agreed to make available, for example, name, email address. The information is collected by the providers of the Third-Party Accounts and is provided to CoDrive according to their privacy policies.

Technical Information

CoDrive collects technical information related to the access and use of the Services, such as: IP addresses, browser type, ISPs, visited pages, platform type, date and time, and the number of clicks. This information allows analyzing the type of usage, administering and protecting the Services, monitoring user movements as a whole, and collecting general data, such as the country of residence and overall usage.

Legal Bases

  • The processing of personal data is essential to enable the user to use the provided services and falls under the case referred to in Article 6(1)(b) of the GDPR: execution of an agreement of which the data subject is a party;
  • For data sharing, such as routes, driving modes, vehicle type, consent is freely given by the user according to Article 6(1)(a) of the GDPR by the user in the general settings or in the individual trip. Data shared by the user.
  • For data processing in cases of legal disputes, the processing of personal data is indispensable to comply with a legal proceeding or a court order or to exercise and defend legal rights.
  • To protect the vital interests of the User or others, for example, in case of an emergency.

How CoDrive Uses the Information

Provision of Services

  • Recording activities and analyzing performance, for example, to compare past performances, to analyze training. CoDrive might also match the User’s GPS activities to specific segments or routes to analyze the User’s efforts compared to those of other users and to compile rankings.
  • Interaction with other users to participate in the CoDrive Communities, follow other users, search for friends.
  • Training management, for example, to set goals and use the control panel for workouts.
  • Exploring new places to go, for example, to discover routes or segments where one can carry out their activities. Similarly, if multiple users run along a certain route, this information could be used to suggest that route to other users.
  • Sharing information with the CoDrive Community, for example, by sharing the User’s public reviews and photos of specific routes or segments.

To Propose Targeted Promotions

CoDrive uses the collected and received information to propose promotions that may interest the User, based on their notification preferences and email sending. For example, if we notice that a User has been active for a long time with a monthly subscription plan, we might offer them a promotion to switch to a discounted annual plan. Or, if a User is active but has never subscribed, we might send an offer for a free trial subscription.

Protection of the User and the Services

CoDrive uses the collected and received information to protect users, identifies and removes content that violates correctness, such as forms of hate incitement or spam, suspending the concerned accounts.

To Assist a User Submitting a Support Request

CoDrive uses the information collected and received to respond to support requests and User comments. Depending on the request, it may be necessary to access the User’s account, for example, to resolve or replicate a reported issue.

Improvement of Services

CoDrive may also use the information collected and received to conduct research and to analyze, develop, and improve the Services and resolve issues.

Subscription Processing

We use the information collected to process the subscription, including using location data to determine the price in that country.

Sharing Data with Service Providers

CoDrive may share User information with providers that supply services, such as support, improvement, promotion, and protection of the Services, processing payments, or fulfilling orders.

Publicly Available Information

The profile and activities of users who join the CoDrive community are set to be visible to everyone by default. The name and other information in the profile can be viewed by other CoDrive users and the public, and based on the User’s privacy settings, additional information and content shared by the User may be visible. For example, multimedia content and routes could be accessible to other CoDrive users and external parties or visible on publicly accessible CoDrive pages or appearing in search results.

Legal Requirements

CoDrive may retain and share User information with third parties, including law enforcement, public or governmental agencies, or private litigants, within or outside the country of residence, if it decides that such disclosure is permitted by law or is reasonably necessary to comply with the law, for example, to respond to orders, injunctions, subpoenas, or other legal or regulatory processes.

Configuration of Notification and Email Preferences

CoDrive offers various ways to manage the notifications received. It is possible to choose not to receive certain notifications via email by setting preferences. It is also possible to unsubscribe from these emails by following the instructions contained at the bottom of such messages. In our app, it is possible to access “Push Notifications” in the settings menu. Where permitted by local regulations, CoDrive may send marketing communications to users who interact a lot with the Services or who purchase a subscription. CoDrive may also send periodic communications to ask the User if they wish to receive marketing communications.

All administrative or service-related emails (confirmation of a purchase, notification of price changes, provision of a requested training plan, or disclosure of a significant update to our policies, and so on) may not include an option to block their receipt, as they are necessary to provide the requested Services. The User is required to provide us with a valid email address and to keep it updated to ensure receipt of notifications via email.

Account Information Update

You can correct, modify, or update your account or profile information at any time by changing the information in the account settings. For further assistance on modifying inaccurate information, contact CoDrive.

Deletion of Information, Account, and Data Download

You can delete your account or download your data.

After you have requested the deletion of an account, we permanently and irreversibly delete personal data from our systems, including backups. After deletion, your data, including your account, activities, and ranking positions, cannot be restored. It may take up to 45 days from the deletion of your account before all records and personal data are deleted from our systems. Additionally, we may retain information whose deletion has been requested to comply with the law and undertake other actions permitted by law.

CoDrive is not responsible for content that you have shared directly with others, such as photos or videos on other social media platforms, or that others may have copied. Your public profile may appear in search results until the search engine’s cache is updated.

CoDrive also offers you the option to remove individual published activities without deleting your account. Once removed, the activities may remain in the systems until you delete the account.

Privacy of Minors

Our services are not directed or intended for individuals under the age of 18 and who do not have a driver’s license. Users under the age of 18 should not use the Services.

Protection of Information

CoDrive adopts technical, physical, and organizational measures to protect the transmission and storage of collected data. You can take additional measures to protect your account and your information, such as creating a strong password, using letters and numbers, symbols, special characters, not sharing your password with others, and promptly reporting suspicious activities or unauthorized access to your account.

Rights of Data Subjects

Users have the right to access, correct, download, and delete their information, as well as the right to place restrictions and object to certain processing of such information.

Cross-Border Data Transfers

Data is managed within the territory of the EEA, and no cross-border transfers are planned.

In the event of a transfer, CoDrive Srl will adopt standard contractual clauses to ensure that data transfers comply with applicable laws.

Retention of Information

Information is retained for the time necessary to provide the services and, in the case of deletion or deactivation of the account, for the times required for legal, administrative, and dispute management purposes.

However, it is possible to delete certain information such as photos, articles, etc.