Privacy Policy and Cookies

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Mister Lavaggio srls (“Mister Lavaggio”) respects privacy regulations and is committed to providing maximum transparency in the subject of data processing, convinced that such transparency is an indispensable aspect of the quality of service we offer to our customers, companies and all those interested in receiving information or staying in touch with our system.

 

Data controller

Any personal data (hereafter also referred to as “data”) you provide or collect through the operations you perform:

  • on the Mister Wash app
  • On the sites www.misterlavaggio.com, partner.misterlavaggio.com and any other site owned by Mister Lavaggio srls on which this statement appears

is processed by Mister Lavaggio Srls in the person of the legal representative p.t., VAT no. 09271400963, headquartered at Gian Carlo Passeroni Street no. 6 – 20135 Milan, pec address: misterlavaggio@pec.it, (hereinafter, “Owner”), as “Owner” of the treatment.

 

Mr. Washers

Mister Washing provides its customers with a car wash service, which can be booked through a mobile app. Operators who physically perform the washing are referred to as washers.

In case several Washers operate in an area, it is possible to choose the one you prefer when booking (also being able to rely on other users’ reviews).

They operate under the Mister Wash brand, using Mister Wash booking management tools, products and protocols.

 

Type of data collected on the app and sites

The personal data we receive from our customers, in addition to enabling the use of the service we provide, helps us to personalize and continuously improve the service. In some cases, upon your express consent or request, they may be accessed or transferred to third parties for the provision of additional services.

Below are the categories of data we collect:

  • Personal data provided by you: We receive and process personal data provided by you only if.
    • are required in order to take advantage of a service you have requested (for example, if you make a reservation you will have to leave your name and phone number in order to be contacted by the operator who will come to wash your car, or if you request to be called to receive information about our system you will have to leave your phone number)
    • Expressly agree to their use for other purposes (e.g., marketing)
  • Mobile device location information: in some cases we collect the GPS location of the device in order to make better usable and/or improve the services offered (e.g., identify areas not yet covered by the service, from which reservation requests arrive). Most mobile devices allow you to turn off location services. Usually to do this you find appropriate configurations within the device’s settings menu. If you have questions about how to disable location services on your device, we recommend that you contact your mobile carrier or the manufacturer of your device.
  • Completely anonymous device technical information and usage events: we may  automatically collect and process some anonymous information for diagnostic, data analysis and fraud prevention purposes. Such data may include: 
    • Data on how the service features are used
    • Data on the installation or removal of the app
    • Internet protocol (IP) address only if not traceable to personal data
    • device technical data such as smartphone model, browser or operating system version, device event information such as crashes, system activity, hardware settings, browser type, language, date and time of requests, and referring URL,
    • during some visits to sites or app use, it is possible that we evaluate and collect session information, including loading and dwell times on screens, download errors, duration of visits to certain screens, screen interaction information (such as scrolling, clicking, and cursor movement on pages), and methods used to exit.
  • Technical device information and usage events not entirely anonymous:

we may use (with your consent) certain technical information, such as the Internet Protocol (IP) address used to connect your device to the Internet or other identifiers, which, although they do not contain direct information about the person, may allow their identification under certain conditions

  • Local storage: In some cases we may collect and store information (including personal information) locally on the device, using mechanisms such as web storage via browsers (including HTML 5) and application data caches.
  • Cookies: better specified below
 

The purposes of personal data processing

To protect your privacy, your personal data will be used, by the Data Controller or authorized third parties, and only after your explicit consent (art. 7 GDPR) for:

  • Inform you of offers, promotions and news regarding services and products offered by the Owner or Washers
  • Satisfaction survey campaigns on the quality of services

Separate consent will be required should the data be used to send you commercial and/or promotional communications from third parties (e.g., business partners, and other companies).

The personal data you provide may be processed without consent (Art. 6 GDPR) by the Data Controller or authorized third parties for the purpose of:

  • Allow you to access the services you have requested (e.g., booking a wash through the app)
  • Contact you at your express request (e.g., for information on how to join the Mister Wash system)
  • process payments
  • Update our records and generally manage your account
  • Post and display content such as reviews on the service
  • Contact you via email, text message, telephone contact, push notification, and/or other digital tools, for needs related to the use and management of the services requested, such as confirmation of reservation or other service communications
  • Prevent or expose fraud or abuse to the detriment of our system
  • Exercise legitimate rights and fulfill obligations under laws, rules or regulations, fulfill pre-contractual, contractual and tax obligations
 
 

Mode and duration of treatment

Your personal information is subject to processing (collection, recording, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, deletion and destruction) whether on paper or electronically and/or automatically, for the time strictly necessary to achieve the purposes for which it was collected.

In the event that you have provided us with personal data for the purpose of using our services, we retain that data for as long as we deem necessary to enable you to use the services (e.g., you will not have to enter your contact information into the app for each booking).

In the event that you have provided us with personal data to receive information and/or communications we will retain such data for as long as we deem necessary to enable you to receive the requested information and/or communications (e.g., in the case of subscribing to a newsletter, data will be retained until your specific request to unsubscribe or until such newsletter is deactivated).

In case you have provided us with personal data for profiling and marketing purposes, your data is kept for a commercially appropriate time (e.g., we may send you promotional offers at certain times of the year until you expressly request not to receive any more or until you are no longer interested).

In all cases, the duration will take into account the time necessary to comply with applicable law, to resolve disputes with any party, and if otherwise necessary to enable us to conduct our business, to prevent and disclose fraud or other illegal activities.

 

Data access

Our clients’ personal data is an important component of our work, and it is not part of our business to give it away to others. Your information may be made accessible only to the extent stated in this policy:

  • to employees and collaborators of the Controller (administrative, sales, customer care, marketing, legal, system administrators) in their capacity as internal data processors and/or system administrators;
  • to the Washers with which you booked the services offered by the system. The information is accessed by them in order to make the service usable, send service communications, or allow them, with your consent to send you promotional offers, information and news regarding the services offered. They shall, in carrying out their activities, act in a manner consistent with this Privacy Policy;
  • to other external data controllers, i.e., third-party companies or other entities that perform processing activities on our behalf. For example, to send e-mails, text messages or push notifications, analyze data, provide marketing assistance, and make credit card payments. These providers have access only to personal data that are necessary to carry out their tasks. We assure you that they may not use the same data for any other purpose and are also required to process personal data in accordance with this Privacy Policy, and under applicable data protection regulations.
  • to Supervisory Bodies, Judicial Authorities, insurance companies for the provision of insurance services as well as to those parties to whom disclosure is required by law. These parties will process the data in their capacity as autonomous data controllers.
  • business transfers: Customers’ personal data are part of the company’s assets. Our business is constantly developing, but in the unlikely event that your property or substantially all of your assets are transferred to a third party, your personal data will naturally be among the transferred assets. In any case, they remain subject to the commitments made in any previous Privacy Policy
  • In the event that there emerge other purposes, you will be informed and will have the opportunity to choose whether or not to give your consent to the processing of your personal data for such purposes

The updated list of data processors and processors is kept at our registered office.

 

Data transfer outside the European Community

Some of the external data processors who process information on our behalf have registered offices and/or process data outside the European Community.

Whenever personal data is transferred to companies, entities, or institutions based in countries outside the European Community, we will ensure that the data is transferred in accordance with this Privacy Policy and in compliance with applicable legal provisions, subject to entering into the standard contractual clauses required by the European Commission.

Such external providers are: Google LLC (with its services such as Analytics, Google Plus, adWords, adSense, AdMob, Analytics, Maps, YouTube, Android services, Firebase, Crashlytics, Answers, Gmail, Google Contacts), Zoho Corporation (Zoho Mail), Facebook Inc, Instagram, Mailchimp, DigitalOcean Inc, OneSignal Inc, One-etere S.r.l. a Socio Unico (Trendoo), Stripe Inc, Debitoor UK Ltd, Hotjar Ltd, Active Campaign LLC, PayPal Holdings Inc, Etison LLC (ClickFunnels).

They are located in countries that have been granted an adequacy decision by the European Community (i.e., process personal data in accordance with the principles and standards referred to in this Notice), or guarantee their adherence to the Privacy Shield (the transfer of personal data, in which case, is authorized under specific Decisions of the European Union and the Data Protection Supervisor. , in particular Decision 1250/2016 – Privacy Shield – here the information page of the Italian Garante ).

Information security

We try to minimize the use of personal data, using anonymous data whenever possible so that the user’s identity is not revealed.

In relation to the knowledge gained from technical progress, the nature of the data and the specific characteristics of the processing, we use specific security measures to protect the security of your personal information, its protection from all forms of unauthorized access, alteration, unauthorized disclosure and destruction of such information. For example:

  • We offer users verification when logging into their account, preventing unauthorized access to systems (mandatory password request).
  • We allow access to personal information only to employees, appointees involved in the organization or other external data processors obligated to comply with the obligation of confidentiality
  • when you enter data on our site or application, we use Secure Sockets Layer (SSL) software, which encrypts the information you enter.
 

Misuse of data
We are not, under any circumstances, responsible for illicit use and unlawful behavior you may engage in while using the service. For example, under no circumstances are we responsible for your inclusion of insults, defamation, offensive phrases, videos, photos, and any other multimedia content that infringes on constitutionally relevant personal rights or intellectual property rights (e.g., unlawful use of others’ trademarks, patents, etc.). 
Nonetheless, in the event of complaints of any unlawful use, we reserve the right to expel the perpetrators of the aforementioned behavior. 

Choice of data provision, withdrawal of consent, and request for deletion of data

You can always choose not to provide personal data, with the understanding that providing such data may be necessary to take advantage of certain services.

You may at any time decide to revoke your authorization to process personal data for specific purposes by sending notice to privacy@misterlavaggio.com or through any other procedures made available through the app, sites or emails you receive. If authorization to process data for the purposes of the service is revoked, it will obviously become impossible to access the service itself.

You may at any time request the deletion of your data by sending communication to the address privacy@misterlavaggio.com. 

Your rights

Pursuant to European Regulation 679/2016 (GDPR) and national legislation, you may, in the manner and within the limits provided by the current legislation, exercise the following rights:

  1. confirmation of the existence or non-existence of personal data concerning you
  2. their communication in an intelligible form
  3. The updating, correction and deletion
  4. The transfer of data to another company
  5. the limitation of treatment
  6. opposition to processing
  7. The transformation of data into anonymous form
  8. The revocation of the consent to treatment previously given
  9. indication:
    1. Of the origin of personal data;
    2. Of the purposes and methods of processing;
    3. Of the logic applied in the case of processing carried out with the aid of electronic instruments;
    4. Of the identification details of the data controller and data processors

It is also your right to file complaints with the appropriate supervisory authorities (Privacy Guarantor – link to the Guarantor’s page ).

You may exercise your rights at any time by sending an e-mail with your request to privacy@misterlavaggio.com.

 

Disclosures and reviews

If you still have questions about this privacy policy, please email us at privacy@misterlavaggio.com.

Our activities are constantly evolving and, therefore, this Privacy Policy may also be subject to change.

If substantial changes become necessary we will inform you and, if required by law, we may ask you whether or not you consent to the changes.

Cookies

Cookies

The site uses cd. “cookies” and that are small text strings that sites visited by the user send to a terminal (usually to the browser), where they are stored to be retransmitted to the same sites the next time the same user visits.

The cookies used by sites owned by Mister Lavaggio that refer to the following disclosure are:

  • Technical cookies: are installed directly by the Website Owner and used to provide the service and browsing experience. Specifically, technical cookies on the site include:
    • Browsing cookies : related to activities strictly necessary for the operation of the website and the delivery of the service, aimed at maintaining an adequate browsing experience or increasing the performance of the website.
    • Functional Cookies: related to preference-saving activities, allowing the user to navigate according to a selected set of criteria (such as, for example, language, text characters, browser type, etc.).
  • Profiling cookies: are aimed at creating profiles related to the user and are used for the purpose of sending advertising messages in line with the preferences expressed by the same in the context of web browsing.
  • Third-party cookies: are cookies managed by third parties and not by the Owner that allow to use external services or plugins on the site, such as social buttons (Facebook, Twitter, Google Plus, etc…), Youtube videos, analytics services (Google Analytics).

From the perspective of your privacy, cookies can leave traces that, particularly when combined with unique identifiers and other information received by servers, can be used to create profiles of individuals and identify them.

In order to protect your privacy, we use without your consent only cookies that do not allow identification, in particular technical cookies and third-party analytical cookies, i.e., cookies that allow us to analyze behavior on sites or in apps completely anonymously and consequently improve the services offered.

Your consent is also not required for technical cookies that serve to identify you for browsing purposes (session cookies) after you have registered or logged in to our sites.

Other Cookies that allow identification (e.g., for profiling and marketing purposes), will not be used unless after your explicit consent.

Consent can be expressed by interacting with the short information banner on the landing page of the site, in the manner indicated in that banner.

A record of this consent is kept on subsequent visits; however, the user always has the option of revoking consent already given.
You can, however, disable cookies by denying consent to the installation of any cookies or by deselecting cookies individually through your browser or device as well. You can also delete, at any time, any cookies already on your device.

Most browsers accept cookies automatically. If you prefer to restrict, block or delete cookies from the site in question, you can change the configuration of the browser used (although the parameterization of each browser is different, it is normal to configure cookies from the “Preferences” or “Tools” menu).

It is possible to browse the site without cookies; however, if you disable cookies, you may no longer be able to access certain features of the site.
Please note that the Owner does not store sensitive personally identifiable information (such as address, password) in the cookies it uses.


Below is a table showing the profiling and third-party cookies used by this site along with the purpose of each:

Cookie Name Description Type
Google tag manager Used by Google to distinguish users anonymously for statistical purposes




https://policies.google.com/privacy?hl=it

Technician

Third party

GoogleAnalytics Used by Google to analyze traffic on the site




https://policies.google.com/privacy?hl=it

Technician

Third party

GoogleAdwords Used in order to propose personalized adv to users




https://policies.google.com/privacy?hl=it

Technician

Third party

Active campaign Used to recognize the user and perform personalized actions based on the user’s actions on the site. These functions are currently disabled by servers.
https://www.activecampaign.com/privacy-policy/

Technician

Third party

Hotjar Used to anonymously track user behavior on individual site pages




https://www.hotjar.com/privacy

Technician

Third party

Facebook and Instagram Cookies used to identify facebook users who browsed the domain and related App in order to propose offers related to the visited section




https://www.facebook.com/policies/cookies/

Technician

Third party

The above-mentioned list will be updated, as soon as possible, in case of changes in the services offered by the Holder. During said update, certain cookies may therefore be excluded from the list, although they are always cookies with identical purposes to those contained in the above table.
Since the Owner does not have any agreements for the installation of cookies through its site and therefore the Owner itself has only indirect contacts with third parties, the names of the third parties that manage them are given and for each of them the link to the page where you can receive information about the processing and express your consent.

Changing cookie settings and deactivation

If you wish to delete cookies residing on your computer, follow the directions of the browser you are using:

Firefox:

  • Open Firefox
  • Press the “Alt” button on the keyboard
  • In the toolbar located at the top of the browser, select “Tools” and then “Options”
  • Then select the “Privacy” tab
  • Go to “History Settings:” and then to “Use Custom Settings.”
  • Uncheck “Accept cookies from sites” and save your preferences.

Internet Explorer:

  • Open Internet Explorer
  • Click on the “Tools” button and then on “Internet Options”
  • Select the “Privacy” tab and move the slider to the level of privacy you wish to set (upward to block all cookies or downward to allow all cookies)
  • Then click OK

Google Chrome:

  • Open Google Chrome
  • Click on the “Tools” icon
  • Select “Settings” and then “Advanced Settings”
  • Select “Content Settings” under “Privacy”
  • Under the “Cookies” tab, you can uncheck cookies and save your preferences

Safari:

  • Open Safari
  • Choose “Preferences” in the toolbar, then select the “Security” panel in the dialog box that follows
  • In the “Accept Cookies” section, you can specify whether and when Safari should save cookies from websites. For more information click on the Help button ( marked with a question mark)
  • For more information about the cookies that are stored on your computer, click on “Show Cookies”

If you want to request deletion of the data associated with your email. Enter the email here:

If you would like confirmation as to whether or not your personal information is being processed and/or would like to obtain access to it, enter your email here.

You will receive an email response that, if any, will list the data processed and give you the option of requesting its modification, deletion, or revocation of consent for processing.