PRIVACY POLICY

Confidentiality and security are paramount values for us and, consequently, we assume the commitment to guarantee privacy at all times and not to collect unnecessary information.

This Privacy Policy is applicable to users of the RAY App and/or Website and to buyers of products manufactured by RAY and purchased through the RAY dealer network (the “User(s)”).

The contents of the Web are exclusively aimed at adults, therefore, when the User provides their personal data, they declare that they are of that age. For this purpose, RAY reserves the option to request the User, at any time, documentation proving their age. In the event that RAY verifies that the User does not have the required age or does not correctly meet RAY's requirement, RAY may implement technical measures to terminate him and/or prevent his access to the Web.

1. RESPONSIBLE FOR THE TREATMENT

Company name: WIN LIFE ELECTRIC VEHICLES, S.L. ("RAY")
NIF number: B-67486639
Registered office: C/ Vallespir, 22 08970 Sant Joan Despí (Barcelona)
email: rgpd@ray.eco

2. PERSONAL DATA SUBJECT TO PROCESSING

2.1. Data that Users provide us directly:

• Through the configuration and reservation of products manufactured by RAY and sold by authorized distributors/dealers: name and surname, email, telephone number, registration number assigned to the vehicle, postal address and ID number.
• Through the sending of emails: email and any additional personal data provided to answer your questions or concerns.
• Through any contact form on the Web: name and surname and email.
• Through the use of the vehicle and access to the functionalities of the App: identification and geolocation data.
• By registering in the App as a Guest User: name and surname, email, password and geolocation data.
• Through the configuration of the "charging settings" section in the App: geolocation data (usual charging point address).
• Through the configuration of the "route history" section in the App: Geolocation data (Route start address and route end address)
• Through the use of the "map and navigation" section in the App: geolocation data and IP address

2.2. User data provided to us by third parties:

Sometimes, the personal data of the Users related to name and surname, address, telephone number, email, identity document, VIN and registration number of their vehicle may come from distributors or dealers.

3. PURPOSES OF THE PROCESSING OF YOUR PERSONAL DATA

The personal data provided through the Web and/or the App may be processed for the following purposes:

• Configure the vehicle model to be purchased from the distributor or dealer and choose the vehicle purchase options and deliver it to dealer and/or distributor establishments or stores, at the User's request.
• Allow the correct use and enjoyment of all the functions of the vehicle (“connectivity services”), as well as the activation and operation of the App and link the personal data of the user to the vehicle and the RAY App.
• Identify you as a User and be able to give you access to the different functionalities that are available to you as the owner of the vehicle and registered user of the App and/or the Web.
• Allow RAY to provide after-sales services or other services linked to products manufactured by RAY.
• Keep a record or history of updated routes, so that the User can access it at all times.
• Determine the geographical location of the vehicle so that the User can locate it, recognize its routes, location and the usual charging point.
• Notify the User in case of theft or unrecognized movement of the vehicle.
• Provide an additional account to the invited Users, so that the User (owner of the vehicle) can track and know the location and movements of the vehicle at all times.
• The sending of promotions and publicity from RAY or distributors/dealers about products and services that may be of interest to you (newsletter sending).

4. LEGITIMATION FOR THE PROCESSING OF PERSONAL DATA

The legal basis for the different data processing may be the application of pre-contractual measures at the request of the User, the execution of the contractual relationship with the distributor or dealership and the express consent of the User.

5. RECIPIENTS OF PERSONAL DATA

The User's personal data may be communicated to RAY distributors or dealers in order to manage test rides or promotional or test actions for the requested vehicles and, where appropriate, their own marketing. Distributors or dealers may be domiciled outside the European Union, although in countries that offer a comparable level of protection according to decisions of the European Commission.

Likewise, personal data may be hosted by RAY providers based outside the European Union, under conditions of security and confidentiality, in accordance with the corresponding legal guarantees.

6. PRESERVATION OF YOUR PERSONAL DATA

The User's personal data will be kept by RAY until the purpose for which they have been provided through the App and/or the Web is carried out, or until its deletion is requested.

When you delete your account, we remove the content posted to your account. However, we will keep certain information in anonymized form for statistical purposes and to improve our products and services, in such a way that re-identification of the user is not possible.

7. RIGHTS

The User can revoke their consent at any time, when it has been granted for the processing of their data, without retroactively affecting the processing of personal data carried out up to that moment.

Likewise, the User can exercise the following rights:

• Request access to their personal data or its rectification when it is inaccurate or incomplete.
• Request its deletion when, among other reasons, the data is no longer necessary for the purposes for which it was collected.
• Request the limitation of its treatment in certain circumstances.
• Request opposition to the processing of their data for reasons related to their particular situation.
• Request the portability of the data in the cases provided for in the regulations.
• Where appropriate, the right not to be subject to automated individual decisions.

Where and how to request your Rights:: By means of a letter addressed to RAY at its postal or electronic address (indicated in section 1), specifying the right that you want to exercise and with respect to what personal data.

In the event of disagreements with the company in relation to the processing of your data, you can file a claim. In the event that the User does not obtain a satisfactory response or wishes more information regarding any of these rights, you may go to the Data Protection Control Authority.

8. SECURITY OF YOUR PERSONAL DATA

RAY has implemented the necessary technical and organizational security measures that guarantee the security of your personal data and prevent its alteration, loss, treatment and/or unauthorized access, taking into account the state of technology, the nature of the stored data and the risks to which they are exposed, whether they come from human action or from the physical or natural environment.

9. UPDATE OF YOUR PERSONAL DATA

The User guarantees that all personal data provided to RAY through the Web or when using the App is true, exact and complete. Likewise, you agree to keep your data updated. In the event that the User provides any false, inaccurate or incomplete information or if RAY considers that there are well-founded reasons to doubt the veracity, accuracy and integrity of the same, RAY may deny access and present or future use of the Web and / or the App or any of its contents and / or services.

Similarly, the User must keep the identification password to use the services provided in the App and on the Web and agrees not to assign its use to third parties.

10. CONTACT

If you have any questions or concerns about the way we treat and use your personal data or wish to exercise any of the rights described above, please contact rgpd@ray.eco.

Publication date: June 28, 2022