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Privacy policy

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This policy explains how SOFTGENIO, S.L. processes personal data on the Dropium platform: on the website, in the control centre and in the field mobile applications. It is written to be readable in full without signing in.

1. Two distinct roles, depending on whose data it is

This comes first because it determines who each person should contact to exercise their rights.

For drivers, warehouse operators and platform users, SOFTGENIO is the data controller.
It decides what their data is used for and answers to them directly. The rest of this policy is addressed to these people.
For the recipients of shipments, SOFTGENIO is a data processor (Article 28 GDPR).
It processes their data solely on behalf of, and following the instructions of, the company that commissioned the shipment — which is the controller and already informed them at the time of purchase.

If you are the recipient of a shipment and wish to exercise your rights, you must contact the company that sold you the product or commissioned the transport. If you write to us, we will redirect you to them and inform them.

2. Data controller

Legal name
SOFTGENIO, S.L.
CIF
B21778881
Registered office
Calle Milán 2, 28850 Torrejón de Ardoz, Madrid, Spain
Telephone
+34 627 60 33 36
Exercising your rights
[email protected]
Data protection contact
[email protected]

3. What we process, why, on what legal basis and for how long

Each processing activity with its specific legal basis and retention period, as required by Articles 13(1)(c) and 13(2)(a) GDPR.

Data subjectDataPurposeLegal basisRetention
Driver / operatorName, email, identifier, password, permissionsAccount and authenticationPerformance of a contractFor the duration of the relationship, plus applicable limitation periods
Driver / operatorLatitude and longitude when each event is recordedTraceability of goodsLegitimate interest (Art. 6(1)(f))2 months
Driver / operatorIP address, installation identifier, notification token, approximate location at sign-inAccess security and traceabilityLegitimate interest (Art. 6(1)(f))6 months
Driver / operatorCrash and diagnostic reportsFixing application errorsLegitimate interest (Art. 6(1)(f))90 days
Driver / operatorAggregated usage statisticsImproving the applicationConsent, revocable at any time2 months
Shipment recipientName, address, phone, signature, delivery photo, cash-on-delivery amountCarrying out and evidencing the deliveryOn behalf of the shipper — SOFTGENIO acts as processorAs instructed by the controlling shipper
Anyone contacting usName, email or phone and the content of the messageReplying to your enquiryLegitimate interest (Art. 6(1)(f))1 year from the last communication

Worker consent is not used as the legal basis for geolocation or traceability: in an employment relationship it is not considered freely given, because saying no means saying no to the person who pays you. In exchange, the right to object is effective and immediate, as set out in the next section.

4. Geolocation of drivers and operators

What the device does: when an event is recorded — a delivery, a pickup, an incident, a scan — the approximate latitude and longitude at that moment may be stored, in order to know where the movement took place.

What it does NOT do — these are limits, not nuances:

  • Position is read only when an event is recorded. There is no continuous tracking, none in the background and none with the app closed.
  • It is not used to assess an individual driver’s performance.
  • It is not used to monitor break times or to verify compliance with working hours.
  • It is not consulted outside working time.
  • Accuracy is moderate: it tells one warehouse from another, not a position inside one.

How to object: from “Profile > Privacy” in the application, at any time and without having to give a reason. Records keep working normally, they are simply stored without location. The last position held on the device is erased when it is switched off.

Location points are kept for 2 months, in line with the CNIL reference framework, unless they are evidence in ongoing litigation.

In France this arrangement is additionally subject to prior consultation of the works council (Art. L2312-38 of the Labour Code) and prior individual information of the worker (Art. L1222-4). That obligation falls on the employer deploying the application.

5. Recipients and processors

We do not sell personal data, we do not disclose it for advertising purposes and no advertising networks are involved: the applications contain no advertising and no advertising identifier. The following providers process data on our behalf, as processors within the meaning of Article 28 GDPR:

Google Ireland Ltd. / Google LLC
Push notifications (Firebase Cloud Messaging), crash reports (Crashlytics) and usage statistics (Analytics) in the mobile applications.
CARTO
Map tiles. Receives the device IP address when the map loads.
Amazon Web Services EMEA SARL
Server and database infrastructure. Region: Ireland (European Union).
Cloudflare, Inc.
Hosting and content delivery for this website. Processes the IP address of visitors in order to serve pages.
Apple Inc. / Google Ireland Ltd.
Distribution of the mobile applications in their stores.
Authorised staff of the logistics operator
Coordinators and managers of the company that grants you access to the platform, within their permissions.

6. International transfers

Firebase services involve processing by Google LLC in the United States. Hosting of this website is provided by Cloudflare, Inc., also a US entity.

These transfers rely on the EU–US Data Privacy Framework where the provider is certified under it and, alternatively, on the standard contractual clauses approved by the European Commission.

The server infrastructure and the operational database remain in the European Union.

7. Security

  • Communications with the server are encrypted over HTTPS.
  • Session identifiers are stored encrypted in the operating system’s secure store, never in plain text.
  • Access is restricted by permission profiles and protected with two-factor authentication.
  • Local device data is erased on sign-out or when another operator signs in, which allows devices to be shared across shifts without carrying over information from the previous one.

8. Your rights

You may exercise the rights of access, rectification, erasure, restriction of processing, objection and portability.

To exercise them, write to [email protected]. We will respond within one month of receiving the request.

You may also lodge a complaint with the supervisory authority of your country of residence:

  • Spain: Agencia Española de Protección de Datos (AEPD) — www.aepd.es
  • France: Commission Nationale de l’Informatique et des Libertés (CNIL) — www.cnil.fr

9. This website

Processing on this website is different from, and far more limited than, that of the applications. This site has no forms, no accounts, no analytics and no advertising cookies. The detail is in the cookie policy.

10. Changes to this policy

Any substantial change to processing triggers fresh information: the applications display the privacy notice again when the version of the text changes, before recording any new event.