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Privacy Policy

Last Updated: October 6, 2025

1. Introduction

Fully Technologies OÜ (Spanish NIF: N0382791B) ("we", "our", or "Fully") operates the Fully mobile application and power bank rental service. This Privacy Policy explains how we collect, use, store, and protect your personal data when you use our Service.

Your privacy is important to us. We are committed to protecting your personal data and complying with the General Data Protection Regulation (GDPR) and Spanish data protection laws.

By using our Service, you agree to the collection and use of information in accordance with this Privacy Policy.

Our Contact Details:

  • Company: Fully Technologies OÜ
  • Spanish NIF: N0382791B
  • Address: Calle Lepant 270, 08013 Barcelona, Spain
  • Email: privacy@fullygo.com

2. Data Controller

Fully Technologies OÜ is the data controller responsible for your personal data. This means we determine how and why your data is processed.

3. What Data We Collect

We collect the following types of personal data:

Account Information:

  • Email address
  • First name and last name
  • Phone number
  • Payment information (processed securely by Stripe)

Usage Data:

  • Device information (IP address, device type, operating system, unique device identifiers)
  • Rental history (stations used, rental duration, timestamps)
  • Location data (to show nearby stations on the map)
  • App usage data (pages visited, time spent, interactions)

Camera and Photos:

  • When you scan QR codes to rent power banks
  • When you upload photos for fault declaration forms

Payment Data:

  • Payment card details (stored securely by our payment processor Stripe, not by us)
  • Transaction history

4. Legal Basis for Processing Your Data (GDPR)

We process your personal data based on the following legal grounds:

Contractual Necessity: To provide the power bank rental service you requested (Art. 6(1)(b) GDPR)

Legitimate Interest: To improve our service, prevent fraud, and ensure security (Art. 6(1)(f) GDPR)

Legal Obligation: To comply with tax, accounting, and regulatory requirements (Art. 6(1)(c) GDPR)

Consent: For location tracking and camera access (Art. 6(1)(a) GDPR) - you can withdraw consent at any time in your device settings

5. How We Use Your Data

We use your personal data for:

  • Service Delivery: Processing rentals, managing your account, handling payments
  • Customer Support: Responding to inquiries, resolving issues, processing fault declarations
  • Security: Preventing fraud, ensuring platform security, protecting against misuse
  • Legal Compliance: Meeting tax, accounting, and regulatory obligations
  • Service Improvement: Analyzing usage patterns to improve user experience
  • Communication: Sending service updates, receipts, and important notifications

We do not use your data for automated decision-making or profiling.

6. Data Sharing and Third Parties

We only share your data with trusted third-party service providers who help us operate our Service:

Payment Processing:

Stripe processes all payments securely. For EU customers, Stripe primarily processes data within the EU infrastructure. As Stripe is a US-based company, some data may be transferred to the USA under appropriate GDPR safeguards including Standard Contractual Clauses.

Data Storage:

Our servers are located in the European Union to ensure GDPR compliance.

We never sell your personal data to third parties.

7. International Data Transfers

Your data is primarily stored and processed within the European Union. When we use service providers outside the EU (such as Stripe), we ensure:

  • Standard Contractual Clauses (SCCs) approved by the European Commission are in place
  • Adequate data protection safeguards equivalent to GDPR standards

8. Your GDPR Rights

Under GDPR, you have the following rights:

  • Right to Access: Request a copy of your personal data
  • Right to Rectification: Correct inaccurate or incomplete data
  • Right to Erasure ("Right to be Forgotten"): Request deletion of your data
  • Right to Restrict Processing: Limit how we use your data
  • Right to Data Portability: Receive your data in a machine-readable format
  • Right to Object: Object to processing based on legitimate interests
  • Right to Withdraw Consent: Withdraw consent for location/camera access at any time

To exercise these rights, contact us at: privacy@fullygo.com

We will respond within 30 days of your request.

9. Data Retention

We retain your personal data only as long as necessary:

  • Active accounts: Data retained while your account is active
  • Closed accounts: Data deleted within 90 days unless required for legal/tax purposes
  • Legal requirements: Some data (invoices, transactions) retained for 7 years per Spanish tax law
  • Usage data: Anonymized and aggregated after 24 months

10. Data Security

We implement appropriate technical and organizational measures to protect your data:

  • Encryption of data in transit (SSL/TLS)
  • Secure data centers in the EU
  • Access controls and authentication
  • Regular security assessments

While we take extensive measures to protect your personal data, no method of electronic storage or internet transmission can be guaranteed to be completely secure. We continually work to maintain the highest standards of data security.

11. Children's Privacy

Our Service is not intended for individuals under 14 years old (the age of digital consent in Spain). We do not knowingly collect personal data from children under 14. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at privacy@fullygo.com so we can delete it.

12. Mobile App Permissions and Tracking

Our mobile app requires certain permissions to function:

Location Services: To display nearby power bank stations on the map. You can enable or disable this in your device settings under Location Permissions.

Camera Access: To scan QR codes on stations and upload photos for fault reports. You can enable or disable this in your device settings under Camera Permissions.

Device Analytics: Our app collects technical data (device type, operating system, app performance) to improve functionality. This data is anonymized and cannot be disabled without uninstalling the app.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via:

  • Email notification
  • In-app notification
  • Updated "Last Updated" date at the top of this policy

Continued use of the Service after changes indicates acceptance of the updated policy.

14. Complaints and Supervisory Authority

If you believe we have not handled your data properly, you have the right to lodge a complaint with:

Spanish Data Protection Agency (AEPD)

  • Website: www.aepd.es
  • Phone: +34 901 100 099
  • Address: C/ Jorge Juan, 6, 28001 Madrid, Spain

15. Contact Us

For any questions about this Privacy Policy or to exercise your GDPR rights:

Email: privacy@fullygo.com

Address: Calle Lepant 270, 08013 Barcelona, Spain