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Notice on the processing of personal data of users of the PitStop platform

pursuant to Article 13 of Regulation (EU) 2016/679 (the "GDPR")

This is an English translation provided for convenience. In case of discrepancy, the Italian version prevails.

Version 1.0 of 29 October 2026

1. Controller and data protection officer

The controller is Sokom S.r.l. ("Sokom"), with registered office at Via Camporcioni Est 18, int. 1-2-3, 51019 Ponte Buggianese (PT), VAT number 01798020473, certified email (PEC) sokom@pec.it.

Sokom has designated a data protection officer, who may be contacted at dpo@sokom.it.

2. Scope of this notice

The PitStop platform (pitstop.interporti.it, the "Platform") allows drivers (the "Users") to book parking services at the interports that use it. The processing of personal data is divided between two controllers:

Section 11 concerns the interport staff who access the management panel and the contact persons of Sokom's customers.

3. Categories of personal data processed

CategoryDataSource
Account dataFirst name, last name, email address, telephone number (optional), driver code, password (stored exclusively in hashed form), preference regarding email notificationsThe User, at registration and when updating the profile
Two-factor authentication dataSelected method (code sent by email or authenticator application) and the related secret, stored in encrypted formThe User, during configuration
Vehicle listNumber plates and any descriptions of the vehicles usedThe User, directly or when making a booking with a new number plate
Billing dataType of invoice holder (natural person or entity holding a VAT number), first name and last name or company name, tax code (codice fiscale), VAT number, address, country, certified email (PEC), recipient code (codice destinatario)The User, in the profile
Technical and security dataIP address, date and time of operations on the account and of login attempts, session tokens and the date of their last useThe User's device, during use of the Platform

The Platform does not require special categories of personal data referred to in Article 9 GDPR or personal data relating to criminal convictions and offences. The User shall not enter such data, or unnecessary data of third parties, in free-text fields.

4. Purposes and legal bases of the processing

PurposeLegal basisCategories of data
a) Registration and management of the account, two-factor authentication, recovery of credentialsPerformance of a contract to which the User is party (Terms of Use of the Platform), Article 6(1)(b) GDPRAccount, authentication and technical data
b) Keeping the vehicle list and the billing data, for their use at each interportPerformance of a contract, Article 6(1)(b) GDPRVehicle list, billing data
c) Making available to the selected interport, at the time of booking, the data necessary for the parking servicePerformance of a contract, at the User's request, Article 6(1)(b) GDPRFirst name, last name, email, telephone, driver code, number plates indicated in the booking, billing data
d) Sending service communications relating to the account (verification codes, recovery links, security alerts)Performance of a contract, Article 6(1)(b) GDPREmail, first name
e) Security of the Platform: prevention of unauthorised access and fraud, limitation of attempts, reconstruction of eventsLegitimate interest of the controller in the security of its systems, Article 6(1)(f) and Recital 49 GDPRTechnical and security data
f) Handling of support requests and of requests to exercise rightsPerformance of a contract and compliance with legal obligations, Article 6(1)(b) and (c) GDPRContact data and content of the request

The data are not processed for marketing or profiling purposes and are not disclosed to third parties.

5. Nature of the provision of data

The provision of first name, last name, email address and password is necessary for registration. Two-factor authentication is mandatory for all accounts and, without it, the Platform does not allow bookings to be made. The provision of billing data is necessary in order to book, as every parking service is invoiced. The telephone number is optional.

6. Automated individual decision-making

For the purposes described, Sokom does not take decisions based solely on automated processing within the meaning of Article 22 GDPR. The automatic assignment of the parking space and the decision to open the barrier are carried out on behalf of the interport and are described in its privacy notice.

7. Recipients of the data

The data may be disclosed:

The Platform, including the email service, is hosted on infrastructure operated directly by Sokom in Italy. Sokom does not engage external providers that process account data on its behalf.

Payments are made on the page of the interport's payment service provider; Sokom does not collect payment instrument data.

8. Transfer of data to third countries

Account data are processed in Italy and are not transferred outside the European Economic Area.

To display the car park map, the User's browser downloads resources from a third party, which receives the IP address of the device, as with any web request, without any account data:

ResourcePartyLocation and safeguards
Map tiles of the car park mapOpenStreetMap FoundationUnited Kingdom, a country covered by an adequacy decision of the European Commission

This party does not set cookies on behalf of Sokom. Reference is made to the cookie policy.

9. Retention period

DataPeriod
Account data, vehicle list, billing dataFor the duration of the account. Upon closure at the User's request, or automatically after 24 months without logins or bookings following 30 days' prior notice by email, the data are erased within 30 days
Session tokens30 days from creation, or until logout
Verification codes and recovery linksFrom 15 minutes to 1 hour, then erased
Log of operations and login attempts12 months
Server technical logs12 weeks, on a rolling basis
Backup copies30 days, on a rolling basis; erased data are also deleted from backups within that period
Support requests24 months from the closure of the request

The closure of the account does not entail the erasure of data relating to bookings already made, including invoices, which remain retained by the interports in accordance with their respective privacy notices and legal obligations.

10. Rights of the data subject

The User may at any time exercise the rights under Articles 15 to 22 GDPR: access, rectification, erasure, restriction of processing, data portability and objection to processing based on legitimate interest. Part of the data can be modified directly in the profile; for other requests the User may write to dpo@sokom.it from the email address associated with the account. Sokom responds within one month of receipt of the request, which may be extended in the cases provided for by Article 12(3) GDPR.

Requests concerning data on bookings and access through the gates are to be addressed to the interport concerned; if received by Sokom, they are forwarded to the interport.

The User also has the right to lodge a complaint with the Garante per la protezione dei dati personali (Italian Data Protection Authority) (www.garanteprivacy.it) or with the supervisory authority of the Member State in which the User resides or works.

11. Interport staff and contact persons of customers

12. Changes

Material changes to this notice are communicated to Users by email or through the Platform before they take effect. The current version is always available on the Platform.


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