Privacy Policy "AdriGo Tenerife S.L." & Accessibility Statement  
1. Privacy Policy "AdriGo Tenerife S.L." for users and candidates.  
This Data Protection Statement describes our data protection practices of AdriGo its subsidiaries and affiliated  
entities in European Union (EU) (hereinafter referred to as “AdriGo”, “we,” “us,” or “our”) when HR data is  
processed. The protection of your personal data is important to us. We comply with legal regulations on data  
protection and data security.  
Your use of AdriGo electric scooters services is governed by applicable terms and our general Privacy Policy.  
Below you will find information about which personal data we collect and how we use it for which purposes.  
In addition, we will inform you about the legal bases for the processing of your data as well as about your  
specific rights with regard to data protection.  
“Personal data” means any information relating to an identified or identifiable natural person (‘data subject’);  
an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to  
an identifier such as a name, an identification number, location data, an online identifier or to one or more  
factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that  
natural person.  
Processed Data  
For each and every process and purpose we process different types of data. This policy covers the information  
you share with us and/or which may be acquired or produced by AdriGo during (A) the use of our  
micromobility service (website/mobile app/customer support) and (B) the application or recruitment  
process.  
A) Service Users (Micromobility App Users) – typical categories of personal data:  
Phone number (SMS verification) and email address (if provided).  
Account and profile data (e.g., preferred language, basic settings).  
Trip and rental data (e.g., start/end time, duration, tariffs, scooter ID).  
Location data necessary to provide the service (e.g., pick-up/parking zones).  
Payment and transaction data (e.g., payment status, transaction identifiers; full card details are handled by the  
payment provider).  
AdriGo does not receive or store your actual credit or debit card numbers used with Apple Pay and other  
payment systems. Instead, Apple/other payment systems provide us with a unique Device Account  
Number (token) and a transaction-specific dynamic security code to complete your purchase securely.  
Device and technical data (e.g., device model/OS, app version, IP address, identifiers, security and access logs).  
Customer support communications (e.g., chat/email/Telegram messages related to your account).  
Fraud and safety data (e.g., abuse prevention signals, incident reports), where applicable.  
B) Candidates / Applicants – categories of personal data processed during the application or  
recruitment process:  
First and last name  
Email Address, address, telephone numbers (and other contact information)  
Application documents, including resume or CV, employment history, cover letter, education, transcripts and  
other statements of experience and education.  
Type of employment sought, desired salary, willingness to relocate, or other job preferences.  
Details of how you heard about the position you are applying for.  
Sensitive information (race/ ethnic origin), if you voluntarily submit such information as part of the  
application process  
Information relating to any previous applications you may have made to AdriGo and/ or any previous  
employment history with AdriGo.  
Reference information and/or information received (including names and contact information for referrals)  
from professional and educational checks, including information provided by third parties.  
Information about your educational and professional background from publicly available sources, including  
online, that we believe is relevant to your application or a potential future application (e.g. your LinkedIn  
profile).  
Information related to any assessment you may take as part of the interview screening process.  
Information from interviews and phone-screenings you may have if any.  
Purposes of Data Processing  
AdriGo processes personal data for the following purposes (as applicable to you):  
A) Service Users (Micromobility service):  
Provide and manage the rental service (account setup, unlocking/ending rides, parking rules, tariffs).  
Billing, payments, debt collection for outstanding amounts, and dispute handling.  
Information collected during an Apple Pay transaction is used strictly for order fulfillment, fraud  
prevention, and legal compliance. We do not share this payment-related data with third parties for  
marketing purposes without your express consent.  
Customer support and incident management.  
Safety, fraud prevention, and security of our systems and users.  
Compliance with legal obligations and responding to lawful requests.  
B) Candidates / Applicants (recruitment):  
Recruit, source, select, hire employees including the conduct of professional and educational checks and  
verifying your information.  
Communication with you on the recruitment process and/ or your application, including informing you of  
other potential career opportunities at AdriGo.  
Creating and submitting reports as required by law or other regulations, where applicable.  
Complying with applicable laws, regulations, legal processes or enforceable governmental requests.  
Improving our recruitment process, including by generating analytics using Candidate information.  
If you are offered and accept employment with AdriGo, the candidate information will become part of your  
employment record and will be used for employment purposes.  
Legal basis  
Pursuant to the GDPR, we process your personal data for the following legal bases.  
A) Service Users (Micromobility service): We process personal data primarily on the following legal  
bases (Art. 6 GDPR):  
Performance of a contract (Art. 6(1)(b)) – to provide the rental service and manage your account and rides.  
Legal obligation (Art. 6(1)(c)) – e.g., accounting/tax and compliance requirements.  
Legitimate interests (Art. 6(1)(f)) – e.g., fraud prevention, security, service improvement, and defending legal  
claims.  
Consent (Art. 6(1)(a)) – where required, e.g., optional marketing communications or non-essential  
cookies/trackers.  
B) Candidates / Applicants (recruitment):  
We process candidate information where it is necessary to take steps, at your request, prior to entering into  
an employment contract (Art. 6(1)(b) GDPR).  
We may also process candidate information on the basis of consent (where applicable), to comply with a legal  
obligation, and/or for our legitimate interests (e.g., to manage and improve recruitment), and for purposes  
connected to legal claims (Art. 6(1)(a), (c), (f) GDPR).  
Disclosure and transfer of personal data  
We may share personal data with other AdriGo entities and with service providers acting on our behalf, to the  
extent necessary and on an applicable legal basis. For service users, this may include payment and billing  
providers, hosting/infrastructure providers, mapping/geo services, customer support tools, IT support, and  
fraud/security vendors.  
Disclosure of Data Shared by Apple Pay  
When you make a purchase using Apple Pay, we receive certain personal information provided by you  
through the Apple Pay interface, such as your name, email address, and shipping address. This information  
is used solely to process your transaction and deliver your order.  
For candidates, this may include external HR entities, payroll/benefit providers, accounting providers,  
auditors, management consultants, health insurers, recruiters, background check providers, and outside  
counsel. Service providers and affiliates receive only the data necessary to perform their tasks and are bound  
by confidentiality and data protection obligations.  
Where personal data is transferred outside the European Economic Area (EEA), we ensure an adequate level  
of protection by relying on (i) adequacy decisions of the European Commission (where applicable, including  
the EU-U.S. Data Privacy Framework for certified U.S. recipients), or (ii) appropriate safeguards such as the  
European Commission’s Standard Contractual Clauses (SCCs), and where required, supplementary measures.  
You may request information about the safeguards applied to international transfers (including a copy of the  
relevant SCCs, where applicable) by contacting us using the contact details provided in this Policy.  
Time period for storage of data  
We retain personal data only for as long as necessary for the purposes described in this Policy and in  
accordance with applicable legal retention obligations. Retention periods may vary depending on the data  
category, legal requirements, and whether the data is needed to establish, exercise, or defend legal claims.  
Retention schedule (summary):  
Data category  
Examples  
Typical retention  
period  
Notes / legal basis  
Account & contact  
data  
Phone number, email,  
profile settings  
While account is  
active + up to 24  
months after closure  
For service provision,  
support, and legal  
claims.  
Trip / rental data  
Ride history, scooter  
ID, start/end time,  
parking information  
Up to 24 months (or  
longer if required for  
disputes/claims);  
Needed for billing,  
customer support,  
and service  
aggregated analytics  
may be kept longer  
improvement.  
Payment / transaction Transaction IDs,  
Typically 6 years  
Full card details are  
handled by the  
payment provider; we  
keep only what is  
necessary.  
data  
amounts, status,  
invoices/receipts  
(business/accounting  
records) or longer if  
required by tax law  
Support  
communications  
Emails,  
Up to 24 months after  
ticket closure  
To resolve issues and  
for quality and legal  
purposes.  
chat/Telegram  
messages linked to  
your account  
Security & access logs  
Login/authorization  
logs, IP address,  
device/app identifiers  
Typically 6–12  
months  
Security, fraud  
prevention, incident  
response.  
Fraud / safety  
incident records  
Abuse reports,  
accident/incident  
notes  
Duration of  
investigation + up to 5  
years (claims)  
Legitimate interests  
and legal claims.  
Recruitment data  
(candidates)  
CV, interview notes,  
assessment results  
Typically 12–24  
To manage  
months after closure  
of the process (unless  
extended by consent)  
recruitment and  
defend against legal  
claims.  
Data protection rights  
Right to rectification  
You have the right to demand that AdriGo immediately corrects personal data relating to you if those data are  
incorrect. Depending on the purposes of the processing, you may have the right to have incomplete personal  
data completed, including by means of providing a supplementary statement.  
Right to erasure (“right to be forgotten”)  
You have the right to demand that AdriGo deletes the personal data relating to you under the prerequisites  
described in Art. 17 GDPR.  
These prerequisites establish especially a right to erasure if the personal data are no longer necessary for the  
purposes for which they were collected or otherwise processed as well as in situations involving illegal  
processing, the existence of a right to object or withdraw a consent, the existence of a duty to delete under the  
law of the European Union or the law of the Member States governing AdriGo or when the data were collected  
with regard to services offered in the information society pursuant to Art. 8 para. 1 GDPR.  
Right to restrict processing  
You have the right to demand that AdriGo restricts the processing in accordance with Art. 18 GDPR. This right  
exists especially if the accuracy of the personal data is disputed between the user and AdriGo for the period  
required for examining the accuracy as well as in the event that the user demands a restriction on processing  
instead of deletion in the event that there is a right to deletion, and also in the event that the data are no  
longer needed for the purposes pursuit by AdriGo when the user, however, needs the data to assert, exercise  
or defend against legal claims, as well as in the situation when the successful exercise of an objection is still  
disputed between AdriGo and the user.  
Right to access  
You have the right to receive from AdriGo at any time upon request information about the personal data  
relating to you which are processed by AdriGo to the extent set forth in Art. 15 GDPR.  
This means that you may have the right to obtain from us confirmation as to whether or not personal data  
concerning you is processed, and, where that is the case, to request access to the personal data. The access  
information includes – inter alia – the purposes of the processing, the categories of personal data concerned,  
and the recipients or categories of recipient to whom the personal data have been or will be disclosed.  
However, this is not an absolute right and the interests of other individuals may restrict your right of access.  
You may have the right to obtain a copy of the personal data undergoing processing. For further copies  
requested by you, we may charge a reasonable fee based on administrative costs.  
How to exercise your data protection rights (including DSAR under Art. 15 GDPR):  
1) Recommended (fastest): submit your request from within the AdriGo mobile app, from the relevant logged-  
in account (Support / Help section).  
2) Alternatively, you may contact us by email at info@adrigo.eu or via our official Telegram support channel. If  
you use these channels, we may need to verify that you are the account holder before disclosing any personal  
data.  
3) Verification: if we have reasonable doubts about the identity of the requester, we may ask for additional  
information necessary to confirm identity (e.g., SMS code to the phone number registered in the account  
and/or specific transaction details). We only request what is necessary and proportionate.  
4) Response time: we respond without undue delay and in principle within one month after we can verify the  
requester’s identity and locate the relevant records. In complex cases, the deadline may be extended as  
permitted by GDPR.  
5) Delivery: we will provide the requested information through a secure channel (preferably in-app) and will  
not disclose personal data to third parties.  
Right to complain  
You also have the right to file a complaint with the relevant supervisory authority.  
Right to object  
You have the right to submit an objection against the processing of personal data relating to you at any time  
for reasons resulting from your specific situation. AdriGo will stop processing your personal data unless  
AdriGo can prove important reasons for the processing which deserve protection which outweigh your  
interests, rights and freedoms or if the processing serves to assert, exercise or defend against legal claims.  
Changes to this Data Protection Statement  
The processing activities of AdriGo can be changed from time to time. and AdriGo accordingly reserves the  
right to amend this Data Protection Statement at any time. We will post any changes to the Policy on this page.  
2. Accessibility Statement  
Commitment to Accessibility  
AdriGo is committed to ensuring digital accessibility for its products and services in compliance with Regulation  
(EU) 2019/882, Spanish Royal Decree 1112/2018, and other relevant national legislation.  
We continuously work to ensure that our digital platforms - including the website, mobile app, customer support  
interfaces, and rental process - are accessible to users with disabilities.  
Scope  
This statement applies to:  
- our official website  
- the mobile application for electric scooter rental  
- the digital map with parking zones and usage rules  
- digital customer support channels (chat, email, Telegram)  
Conformance Level and Current Status  
We are working toward WCAG 2.1 Level AA compliance and conformance with Spanish UNE-EN 301 549.  
Currently:  
Implemented:  
- Proper text contrast and scaling on the website  
- Keyboard navigation and partial screen reader compatibility  
- Alt text for images and buttons  
In development:  
- Full mobile app screen reader support  
- Improved accessibility for users with limited mobility  
- Subtitled and sign-language video instructions  
Not applicable due to the nature of the service:  
Due to the physical risks associated with electric scooter use, this service may not be suitable for persons with  
certain physical, visual, or neuromotor disabilities.  
For safety reasons, we strongly discourage use by individuals who are unable to safely control a personal  
mobility device.  
Technical Limitations and User Responsibility  
While we aim to ensure digital access for all, the physical operation of the service has structural limitations:  
- We cannot verify the physical condition of users.  
- Each user is responsible for ensuring they meet the minimum safety requirements for using our service, as  
outlined in the User Agreement and Terms of Use.  
Feedback and Complaints  
If you encounter accessibility barriers or wish to file a complaint regarding digital access, please contact us:  
Email: info@adrigo.eu  
Telegram Support: Tenerife AdriGo (@adrigo_tfs)  
Complaints may also be submitted to the Accessibility Office of the Ministry of Social Rights and 2030 Agenda, in  
accordance with Royal Decree 1112/2018.  
We will respond within 20 working days, in line with Spanish regulation.  
Ongoing Updates  
This statement will be reviewed regularly. Audit results and user feedback will inform our future updates.  
The AdriGo Team  
Micromobility Service AdriGo