LUGGit Partners

Privacy Policy

Last updated: 14/10/2019

This privacy policy contains all the information applicable to the processing of personal data collected by virtue of our WEB page available at or through other alternative channel that you use to contact us (namely: email, phone).

Please note that if you download our mobile application (APP) at this time, you will be provided with our privacy policy as you do so (CUSTOMER user or Keeper user).

This privacy policy does not apply to third-party products and services, or to third-party websites that may be accessed through the links that are in our website for the convenience and/or information for the user. Regarding access to third-party links, you should consult our terms and conditions in advance.


Principles followed by the responsible, security and protection of personal data

  • The processing of personal data is done in accordance with the law and based on the principles of lawfulness, loyalty, justice, transparency, limitation of purposes, minimisation of data and accuracy. Thus, with the intention of protecting your personal data, against unauthorized use and disclosures, LUGGit has implemented several security measures.
  • As a responsible for your data, we proceed to the lawful processing of your personal data, always collecting your free, specific, informed and explicit consent whenever required under the law.
  • We will not use/transmit your personal data for purposes incompatible with the above principles.
  • The purpose (s) for which your personal data are collected is (are) solely and exclusively the one (s) described herein and to that extent. We will not treat your data to any other purpose, unless such treatment is previously consented by you.
  • The collection of personal data is carried out on the basis of the minimisation principle under which LUGGit only collects the data deemed indispensable for the pursuit of the purpose in question.
  • Once the collected data is no longer necessary for the purpose for which it was collected, we will refrain from continuing to proceed to its treatment and shall take all the necessary measures to destroy it.


Settings. It is important that you understand some of the main concepts

  • Personal Data: Any information that identifies you as a user (personal data subject) in our website from which it can be identified directly or indirectly. We may collect your personal data by the usage of our website or during any interaction with LUGGit either through our website (pre-registration on or through any another way you decide to contact us. Regarding the personal data of the Keepers, what we collect at the time of their pre-registration is only the minimum necessary for the creation of their account and the signature of the contract as LUGGit's service provider.
  • User: Owner of personal data that interacts on our Web pages either through a simple visit, or for the pre-registration to apply to be a Keeper on
  • Responsible: person who determines the purposes for which the personal data are collected, before obtaining their consent, and who assumes responsibility for the compliance with the General Data Protection Regulation (GDPR) - identified in point C.
  • Processing of personal data: operations or technical procedures, automatic or not, which allow the collection, registration, organization, structuring, conservation, adaptation or modification, recovery, consultation, use, transmission, dissemination or any other form of disclosure, comparison or interconnection, limitation, erasure or destruction.
  • Consent: Manifestation of free will, without ambiguity, specific and informed of the USER's wishes, through which he authorizes LUGGit's responsible to process his/her personal data.
  • Third parties: Any individual or legal entity that is external to our company. Any other than the user.
  • Subcontractor: Legal entity, public authority, service or other body that provides a service to the responsible for the personal data and treats personal data on its behalf.
  • Transfer of personal data: Any transfer of personal data made to third parties.


Responsible for the personal data:

Bus Terrace Technologies, Lda., collective person number 515274003, with headquarters in Via do Conhecimento, Edifício Central, Parque da Ciência e Inovação, 3830-352 Ílhavo, Aveiro, Portugal.

E-EMAIL: [email protected]

Within our organization the contact person with whom you can clarify your doubts in this field and, as well, exercise the rights that are recognized to you, whenever you feel this need, is João Pedro Pedrosa. You can also send an email to [email protected] or postal mail to the address of our headquarters, always to the care of João Pedro Pedrosa, internal responsible for the application and compliance with the legal provisions of the EU regulation number 2016/679 of the 27th of April of 2016 on the protection of Personal data (GDPR) and other applicable national legislation.


Personal data collected

The personal data we collect depends on the interaction you have on our website. If you only use our page for consultation and if you are interested in receiving the newsletter from LUGGit, we collect a certain group of personal data (contact details); If you are a Keeper user, we will collect the personal data (contact details and other required information) for pre-registration on our website, with subsequent creation of the Keeper account in the APP and its profile and consequent signature of the contract as service provider.

As a Keeper user know that in addition to the contact data, we also obligatorily collect data belonging to the social category, including information about the criminal activity of the candidate and to the financial category as VAT exemption and initiation of activity.

If the candidate for the Keeper is a legal person, data from the individuals who will act under the responsibility of the collective person shall be collected. In such cases it is of the responsibility of the legal person, in the matter of personal data, to comply with all applicable duties in advance, nothing can be required of LUGGit in this matter afterwrods. The failure to complete these duties implies the violation of the duties provided herein and the obligation to refrain from creating a LUGGit account.

In addition to the personal data voluntarily provided by the user, we may also automatically collect information through the use of cookies (see below more about this point).

Thus, the data we collect and treat according to a certain interaction are:


Subscription to receive LUGGit's "Newsletter"

To receive the "Newsletter" about LUGGit products nd services or about our company, we only treat the email contact of the USER in the tab "Stop wasting your time. Be one of the first "that is in the final part of our website. However, we will only do so if we have your free, specific, informed and explicit consent.

The user is responsible for the data he makes available and of its truthfulness, under penalty of providing false declarations with the inherent legal consequences.


Execution of the pre-registration, creation of account and respective profile and contract signature as service provider by the USERS candidate to Keepers

The following data and personal documents are requested for pre-registration on the website:

  • Name, number of identification and validity, tax number, bank account number, email, mobile phone number and photograph;
  • Number, validity and issuing entity of the ID document;
  • Number, validity and issuing authority of the Keeper's license;
  • Criminal record;
  • Copy of the vehicle documents with which the candidate wants to drive;
  • Proof of vehicle insurance and the last inspection carried out on the vehicle identified in accordance with the previews paragraph;
  • Document proving the contract and validity of the civil liability insurance under the terms herein (optional);
  • Proof of VAT exemption;
  • Document proving the declaration of initiation of activity with the competent authority.

The documentation delivered will be analysed and validated by LUGGit, more strictly by a competent team whose elements are aware of the confidentiality rules on the protection of personal data, and may request any clarifications/additional data. Once LUGGit concludes that the applicant, through the information provided, complies with the minimum requirements to advance the application, an email will be sent with a code that will allow them to create the Keeper account. The conclusion of the creation of the Keeper account constitute the signature of the contract for the provision of services between the Keeper and LUGGit, applying to the same the terms and conditions established for that purpose.

If LUGGit concludes that the applicant does not meet the mandatory minimum requirements, it will be informed of the dicision, also by e-mail, and the personal data that has been provided at the time of the pre-registration will be, under security conditions and in accordance with the law, properly destroyed by LUGGit which, from then on, is obliged not to proceed with any type of treatment and appropriation.

For the creation of the Keeper account, LUGGit no longer requests any personal data other than those already mentioned and which are requested for pre-registration.

For the creation of the Keeper account, LUGGit no longer requests any personal data other than those already mentioned and which are requested for pre-registration.


Interaction with our social networks

If you interact with our social networks (by your will), namely, with our Facebook page, Instagram, Twitter, through Linkedin or Youtube, know that we collect personally identifiable data and any other information that you provide when interacting with us. Each of the aforementioned social networks have their own privacy policies which are totally unrelated to us and for that reason the Keeper user since the moment he decides to interact with us through those channels, is the solely responsible, for what we advise the prior consultation of such documents.ite:


Simple Site Navigation

We advise to consult the point regarding our Cookies policies.


Underlying purpose and treatment basis

We only collect personal data voluntarily provided by you, and are characterized by: i) a limited nature, only personal data are requested which are strictly necessary for the purpose in question; II) a specific purpose; iii) A legal basis that makes the treatment lawful (as: consent, signature of a contract, compliance with legal obligations or pursuing the legitimate interests of the data responsible).

Therefore, please be aware that for the purposes referred to in points 4.1, 4.3 and 4.4, the processing of your personal data is justified by virtue of the consent provided by you, and thus with respect to the provisions of article 6 number 1, point (a) EU Regulation 2016/679 (GDPR).

For compliance with the purpose referred to in point 4.2, the processing of personal data is necessary for pre-contractual arrangements for the purpose of the admission of the Keeper and consequent execution of the service provider contract to be signed if the user is accepted by LUGGit, in compliance with article 6 number 1, point (b) of the GDPR.

Furthermore, data processing is still necessary to fulfil the legitim interests of LUGGit in accordance with article 6 number 1, point (f) of THE GDPR where this is justified, in particular, to maintain and improve the safety and protection of our Users; to prevent, detect and combat fraudulent activities related to the use of our services; to optimize our services; for purposes of research and analysis of usage trends; to improve user experience and improve security and protection of our services. Furthermore,to fulfil the interests of third parties or the general public in accordance with the article 6 number 1), point (f) of the GDPR, the sharing of information related to judicial actions or claims communications for the protection of rights and security of third parties.

Any of the data specified by the USER shall not be used for any other purpose than those mentioned above unless the collection of prior consent.

The treatment performed by LUGGit does not need from the users any decision made solely on the basis of the automatic treatment, including the definition of profiles, which produces effects on its legal sphere or affects it significantly.


Retention deadline for personal data

  • The data retention period varies according to the purpose for which the information is treated.
  • Personal data collected on the basis of consent shall be retained for a period of five years from the last date on which we obtained your agreement, unless you have previously requested its destruction. If you do not do so during that period of time, we will ask you for a new consent, being your silence perceived as a validation.
  • Data collected on the basis of pre-contractual diligence and execution of the service contract shall be retained for the period of time in which the contract is valid, unless by legal imposition or fulfilment of a judicial obligation to extend the period.
  • At any time you may cancel the subscription and stop receiving our "Newsletter". To do so, you simply need to click on the "unsubscribe" option available at the bottom of the email.
  • In relation to the Keeper account, once the service contract is completed, it will be deactivated immediately.


Processing of minors personal data

As a rule, we do not collect or perform, by any mean, the processing of data of minors under 18 years old. If, by any circumstance, this occurs know that the treatment is lawful only if and to the extent that consent is given or authorised by the holder of the child's parental responsibilities.

In this case, LUGGit will make all the appropriate efforts to verify that the consent has been given or authorized by the holder of parental responsible of the child, taking into account the available technology.


Data transmission to third parties

The personal data collected in the follow-up of its interaction shall not be transmitted to third parties other than LUGGit except by legal imposition, or by investigation by the competent authorities.

Regarding Keeper users data, they may, for the purpose of executing their contract, be transmitted to third parties subcontracted by LUGGit which will be, in a timely manner, of the knowledge of their owners.

Please be aware that LUGGIT is also able to anonymously transmit your users ' personal data to: processors and payment facilitators; Security verification service providers; Cloud storage vendors; Google servers; Data analysis providers; Partners that help LUGGit improve the security of its site.



The confidentiality of all information transmitted by the user is guaranteed.

LUGGit undertakes to protect the information disclosed with all care having, for this purpose, adopted the necessary measures to prevent the use and dissemination of information by anyone other than itself, unless you consent by writing that disclosure which will be done in the agreed terms.

With regard to the data provided by the Keeper candidate in pre-registration, know that the fulfilment of the minimum requirements is assessed by a team of LUGGit whose elements are acknowledged the technical and professional competence to this end and which are aware to confidentiality obligations in compliance with the rules imposed in the context of the protection of personal data.

The information disclosed on the site is the sole and exclusive property of the disclosing entity, or of the property of those who have authorised such disclosure, not possessing our entity any right on any type of information that will be transmitted or to which it had access.


Personal Data security

LUGGit uses various technical and organisational measures to protect the personal data of the Customers, depending on what is appropriate to the specific case: i) pseudonymization and the encryption of personal data; (ii) the ability to ensure the confidentiality of the integrity, availability and resilience of treatment systems and services; (iii) the ability to re- establish availability and access to personal data in a timely manner in case of a physical or technical incident; (iv) Implementation of a process to test, assess and evaluate regularly the effectiveness of technical and organisational measures to ensure the safety of treatment, among other measures which are deemed to be appropriate and relevant casuistically. Infringement, or attempt of infringement, of the personal data for which LUGGit is responsible will be communicated to the authorities. If the breach is a high risk for the holders of the personal data, they will be informed of the incident.


Cookie Policy

a) LUGGit and its partners use cookies and other identification technologies on the websites, emails and online advertisements for the purposes described in this policy, namely:

  • Authenticate users
  • Remember users preferences and settings
  • Determine the popularity of a content
  • Disseminate and measure the effectiveness of marketing campaigns
  • Analyse trends and traffic to get a general understanding of online behaviors and the interests of people who interact with our services. We may also allow others to provide measurement and analysis services to us, who show advertisements on the Internet on our behalf and that monitor and report the performance of those advertisements. These entities may use cookies, web beacons, SDKs and other technologies to identify your device when you visit our site and use our services, as well as when you visit other websites and online services.

b) Cookies are files with a small amount of data that are typically used as unique anonymous identifiers. These are sent to your browser from the sites that the user visits and are stored in the internal memory of your device.

c) This service does not use "cookies" explicitly. However, the application may use third-party code and libraries that use "cookies" to collect information and improve its services.

d) The user has the option to accept or decline these cookies and to know when a cookie is being sent to the device. If you choose to decline our cookies, you may not be able to use parts of our service.

e) This cookie policy is periodically revised, so your content may suffer some updates.


Rights of data subjects

The exercise of rights and freedoms to the Customers is guaranteed through the contacts

present below in this privacy policy, which are:

a) right of information: Consists of the right of the user to obtain clear and accurate information concerning the way in which his/her personal data are processed and,furthermore, of which rights they assist, which are provided by this privacy policy.

b) right of Access: It is the right of the user to access the personal data at any time and free of charge with the exception of some cases where we may ask for administrative costs under the law. Any repetitive, unfounded or excessive requests will not be satisfied.

c) right of rectification: Consists of the right of the user to request the rectification, completion or updating of the personal data that is incorrect, incomplete or outdated, respectively and to any issue.

d) right to deletion: It is the right of the user to obtain the deletion of his/her personal data, when LUGGit has no legal or legitimate reasons to continue to treat them.

e) right to limitation of treatment: Consists of the user's right to request the limitation of the treatment that is made of his/her personal data, when any of the following conditions are found: 1) The verification of the accuracy of personal data, 2) The user has objected to the processing of personal data, 3) The processing of the data has become unnecessary or 4) the treatment is illegal.

f) right to portability: It consists of the user's right, whenever possible, to request the transfer of his/her personal data to another responsible for the treatment of his/her data.

g) right to withdraw consent: It consists in the right to withdraw, at any time, the consent that was once granted to LUGGit, making unlawful the processing of data that it is carried out. In this case, the channel used to withdraw consent is the same as that used to give consent.

h) right to file a complaint to the National Data Protection Commission (NDPC): If you consider that you do not exercise your rights, you may present a complaint to NDPC ( The exercise of any of the above rights must be made through one of the following ways: a) Please email João Pedro Pedrosa to [email protected]

i) Write to us: The address of our headquarters in the care of the person identified in the preceding paragraph.


Changes to the privacy Policy and applicable law

This privacy policy will be updated whenever justified without notice, giving you knowledge of the date of the last update, that is why we advise the periodic reading. Use of the website assumes that you know and accept this privacy policy, as well as the terms and conditions of use. Our Privacy policy was created in accordance with the provisions of the Regulation (EU) 2016/679 of the European Parliament and of the Council of the 27th of April of 2016 on the protection of individuals with regard to the processing of data and the free movement of such data and repealing Directive 95/46/EC, which constitutes our framework and also the Law no. 67/98 of 26the of October, the Personal Data Protection Law which remains in force in our legal order as it is not approved, promulgated and published any other law to revoke it.

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