1. Who is responsible
The controller of the data processing described in this policy is Slipstack Sagl, with its seat in Lugano and its postal address c/o Stefano Vojinovic, Via al Chioso 11a, 6900 Lugano, Switzerland, UID CHE-233.011.431 ("Slipstack", "we"). For any question about data protection: info [at] limoflit.ch.
We process personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, Regulation (EU) 2016/679 (GDPR).
2. Two different roles
- Controller, for the data of people who visit the website, write to us through the contact form or have a Limoflit account (sections 3 and 4).
- Processor, for the data that customer companies enter into the Service: their customers, passengers, chauffeurs, collaborators, services, invoices and expenses. The company that enters this data is its controller and must inform the data subjects. Slipstack processes it only to provide the Service, in accordance with Annex A of the Terms of Use. If you are a customer, a passenger or a chauffeur of a company that uses Limoflit and you want to exercise your rights over this data, please contact that company first. If you contact us, we will refer you to it.
3. What data we process, why and on what basis
3.1 Website
- Visiting the website. Like any web server, our server records technical data about the request (for example IP address, date and time, page requested). This is needed to run the website and to protect it from abuse. Basis: legitimate interest.
- Cookies. The website uses a single, functional cookie called "locale", which remembers the language you chose for one year. We do not use analytics or advertising cookies. If we introduced them in the future, we would update this policy and ask for your consent first.
3.2 Contact form
If you write to us through the form, we process your name, your company's name, your email, and your telephone number and fleet size (if you provide them), your message, the language of the website, and the date and version of the policy you accepted. We do not store your IP address with the request. We use this data to reply, to present the Service to you and to guide you through getting started, if you wish. Basis: your consent and the performance of pre-contractual measures at your request. A person on our team reads the request; we receive it by email through an email delivery provider.
3.3 Limoflit account
If you have an account (as a company administrator, chauffeur or other user), we process your first and last name, your email, your telephone number (if you provide it), your role and company, your password (stored only in encrypted form), your last access and, if you turn them on, the technical data that allow us to send you push notifications on your device. We also process the access data needed to keep you signed in (a session code stored in your browser). We use this data to create and protect the account, to let you use the Service and to send you the emails and notifications related to your use (for example password recovery, an invitation, a requested confirmation). Basis: performance of the contractual relationship and legitimate interest in the security of the Service.
3.4 Security and improvement of the Service
To detect errors we use a monitoring service configured restrictively: it receives the technical details of the error, the internal identification number of the user, their role and the company number. It does not receive IP address, name, email, content entered or session recordings. Basis: legitimate interest.
3.5 Functions that use external services
Some functions, which the customer uses at its discretion, send data to providers (section 5): the reading of expense documents from a photograph, the search for addresses and the calculation of the route, the optional bank connection, the sending of invoice and reminder emails, push notifications. In these cases we act as the customer's processor (section 2).
3.6 Automated processing
We do not take decisions with legal effect on you based solely on automated processing. Functions that suggest a result (for example the reading of a document or the matching of a payment to an invoice) are always checked or confirmed by a person at the customer.
4. Who sees your data
Within Slipstack, only the people who need it to provide the Service and for support have access. The other users of your company see the data according to their role. A company linked to yours sees only the neutral data of the services that have been handed over to it, as provided in the Terms. We do not sell personal data and we do not use it for advertising.
5. Recipients and providers
We rely on selected providers, each for the task indicated. We have, or undertake to have, agreements with them that require data protection. We indicate the categories of recipients and the country or region in which they process the data.
| Category of provider | Task | Data | Country or region |
|---|---|---|---|
| Hosting and cloud storage | Servers, database, storage of expense documents | All data of the Service | European Union |
| Email delivery | Sending emails (invitations, password recovery, invoices, reminders, contact requests) | Recipient, subject, text and attachments of the emails, delivery status | European Union |
| Error monitoring | Detecting and fixing errors | Technical details of the error, user id, role, company id; no contact data | European Union |
| Processing of expense documents | Cleaning the photograph and automatic reading (supplier, date, amount, VAT), including with artificial intelligence | Image of the document. The cleaning provider deletes it immediately after processing. The reading provider generally keeps it for a limited period, up to 30 days, and does not use it to train its own models | European Union (cleaning) and United States (reading) |
| Addresses, maps and routes | Address suggestions and calculation of the road route, used for splitting VAT in cross-border services | The text typed in the departure, destination and stops fields; coordinates and addresses of the route | United States and European Union |
| Bank connection chosen by the customer | Reading accounts and transactions, only if the customer activates the connection | The customer's accounts and transactions | Switzerland |
| Browser and system notifications | Delivering push notifications, only if you turn them on | The text of the notification | Variable |
| Public exchange rates | The day's exchange rate | Only two currency codes and a date | European Union |
The list with the names and locations of the providers is provided on written request to info [at] limoflit.ch.
We may also disclose data to authorities or third parties when the law requires it or to defend a right of ours, and to a buyer in the event of a sale of the business, with the same safeguards.
6. Transfers abroad
Some providers process data outside Switzerland and the European Economic Area, in particular in the United States. We ensure that an adequate level of protection is guaranteed. For providers based in the United States we rely, depending on the provider, on the European Union's standard contractual clauses supplemented by the Swiss addendum, or on the provider's certification under the Swiss-US Data Privacy Framework. On request we will provide you with a copy of the safeguards.
7. How long we keep data
- Contact requests: 24 months from the last contact, after which we delete them, unless a contractual relationship is established.
- Account and Service data: for the duration of the relationship. After the account is closed we delete it within 90 days, unless the law requires otherwise. Daily backups are overwritten within 14 days.
- Technical server logs: up to 90 days.
- Accounting documents: the law requires companies to keep accounting documents, for example invoices, for ten years. This is the customer's responsibility, and the customer must keep a copy outside the Service.
8. Security
We adopt appropriate technical and organisational measures: encrypted communications, passwords stored only in encrypted form, encrypted bank credentials, separation of data between customer companies, restricted access, error monitoring without personal data and periodic backups. No system is one hundred per cent secure; in the event of a data breach we inform the persons concerned and the authorities as required by law.
9. Your rights
You have the right to request access to your data, rectification, deletion, restriction of processing and the delivery of your data in a commonly used format, and to object to the processing. If you have given us consent, you may withdraw it at any time without affecting the processing that has already taken place. To exercise your rights, write to info [at] limoflit.ch; we may ask you to identify yourself. We generally reply within 30 days.
You also have the right to lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC) or, if you live in the European Union, with the supervisory authority of your country.
10. Obligation to provide data
To use the Service you must provide the data needed to create the account. Without it we cannot provide the Service. The contact form data marked as optional is not mandatory.
11. Changes
We may update this policy at any time, for example for new functions or providers. The version in force is the one published on this website, with the date of entry into force shown at the top of the page. We invite you to consult it regularly; we are not obliged to inform you of every change.
12. Language
Only the Italian version of this policy is legally binding. This English text is a courtesy translation provided for convenience; in the event of any discrepancy, the Italian text prevails.