General Conditions of Contract of the SeeMe service

• Legal Notice
• Privacy policy
• General Contracting Conditions
• General Conditions of Contract of the SeeMe service
• TwoNav App Privacy Policy
• Link App Privacy Policy
• Privacy Policy Social Networks
• Clause Acceptance Reception Exclusive Offers
• Cookies policy
• End user license agreement

Pre-contractual information

This website, www.twonav.com, is the property of COMPEGPS TEAM S.L., with tax id number CIF B63123962 and headquartered in C/ Draper 13 08350, ARENYS DE MAR (BARCELONA).

The Terms and Conditions of Sale regulate the relationship for the distance sale between COMPEGPS TEAM S.L. and the user or customer, pursuant to legal stipulations, and in particular Law 7/1998 of 13 April, on General Terms and Conditions of Sale, Law 3/2014 of 27 March, which amends the revised text of the General Law for the Defence of Consumers and Users, Organic Law 15/1999 of 13 December, on the Protection of Personal Information, Law 7/1996 of 15 January, on the Organisation of Retail Commerce, and Law 34/2002 of 11 July, on the Services of the Information Society and Electronic Commerce.

COMPEGPS TEAM S.L. reserves the right to make any changes it deems appropriate to the General Terms and Conditions with no prior notice. These changes may be made through its websites in any legally allowed manner and must be complied with for as long as they are published on the website and until they are validly modified by subsequent modifications. However, COMPEGPS TEAM S.L. reserves the right to apply Specific Terms and Conditions of Sale in certain cases that override these Terms and Conditions when deemed suitable, announcing them when and as appropriate.

The purpose of the website is to broadcast your exact position to track your routes, keep you safe and give your family peace of mind.

The contract duration will be the same as that of the service contracted.

As a user or customer, you expressly state to know, understand and accept the conditions of use and these general terms and conditions of sale. Similarly, you must be of legal age and be legally able to access the websites of COMPEGPS TEAM S.L. and to purchase services on said websites.

To purchase the SeeMe service, you can go to the relevant section in our website.

You must first register as a user on the website before purchasing the service. You can access the registration section on the website itself. Pursuant to Organic Law 15/1999 on the Protection of Personal Information, COMPEGPS TEAM S.L. informs its users that the personal information gathered during the registration and subsequent purchase process will be entered into a file maintained by COMPEGPS TEAM S.L. for the purpose of processing these actions by the user and to manage subsequent activities stemming from them.

Similarly, COMPEGPS TEAM S.L. informs you that you can exercise your rights to access, correct, delete and oppose the processing of your data by writing to C/ Draper 13 08350, ARENYS DE MAR (BARCELONA) or sending an email to .

Unless you tell us otherwise, we will assume that your data are unchanged, that you agree to inform us of any changes and that we have your consent to use them to enhance the relationship between the parties.

During the purchase process, you must log in using the username and password provided. This information will not be made public. You accept responsibility for treating your login credentials responsibly and for not transferring them to anyone else. You can change the information you entered at any time in your customer area. This same area will contain a record of your orders, which you can manage by deleting those entries that you no longer want to keep.

At the end of the order process, the customer will receive an order confirmation via email. It is imperative that the user provide a valid email address during the purchase process. If you do not receive confirmation of your order within 24 orders after placing it, please contact COMPEGPS TEAM S.L. by writing to .

All of the website content is in English.

Prior to providing the service, the customer will receive an email confirming the service requested.

Once the service is provided, the customer will receive the associated invoice (only if the annual payment subscription is acquired).

Characteristics, offer and validity of the services

Our online store details the key features of the services offered.

If a service is discounted, the discounted price and the duration of the discount will always be shown alongside its key features.

In compliance with applicable laws, COMPEGPS TEAM S.L. offers information on all its services, their characteristics and prices. However, COMPEGPS TEAM S.L. reserves the right to withdraw, replace or change the services offered through its website by simply changing the content of said website. As a result, the services offered on the website at any given time shall be governed by the General Terms and Conditions of Sale in effect at the time. The company shall also have the right to stop offering access to the aforementioned products at any time with no prior notice.

Warranties

COMPEGPS TEAM S.L. has a customer service department, accessible by sending an email to , where you can lodge the corresponding complaint if you are dissatisfied.

Pricing

All services indicate the sale price in Euros and include value added tax (VAT).

If applicable, any other taxes will also be indicated.

Costs and provision of services

The SeeMe service can be purchased anywhere in the world (see coverage in the Service Provision section). The associated invoice will detail the expenses for the service purchased (only if the annual payment subscription is acquired).

Payment methods and provision of service

You can pay for an order using any of the methods below. During the purchase process, you must specify:

VISA or MASTERCARD credit card:

Any operation that requires you to provide personal or bank information takes place in a secure environment using a server that relies on SSL (secure socket layer) technology. All the information you send us over the Internet is encrypted.

Similarly, all your credit card information is entered directly into the bank’s POS (point of sale) website and is not entered into or stored on any server belonging to COMPEGPS TEAM S.L.

If you pay by VISA or MASTERCARD, you will always be asked for the following information: credit card number, expiration date and verification code, which is printed in italics on the reverse of your VISA or MASTERCARD credit card and is designed to make for a more secure transaction.

This payment method is only valid on the website.

If a purchase amount is fraudulently or incorrectly charged using your credit card number, you can demand that the charge be immediately cancelled. In this case, the amount will be refunded to your account as quickly as possible. However, if the purchase was in fact made by you, as the owner of the card, and the return is not demanded as a consequence of exercising your right of withdrawal or of termination, then your request to cancel the charge will be deemed to be improper, and as a result you will be liable to COMPEGPS TEAM S.L. for any damages and harm caused as a result of said cancellation.

How the SeeMe service works

Methods

To use the SeeMe service, you must have previously purchased a compatible device on our website.

SeeMe service has 2 modalities:

• Free trial. The duration varies depending on the GPS purchased. Applicable from the date the device is registered (basic commercial offer)

• Permanent service based on an annual fee. The collection is made automatically once a year through the same payment system that the user has used to pay the first installment. The charge will be applied automatically and without prior notification once a year unless the user decides to terminate their subscription from their client area (they can do so at any time). Applicable from the date the device is registered (extended commercial offer)

Storing of recordings

Recordings made through the SeeMe service are stored using all the security measures specified in Regulation (EU) 2016/679, the European Regulation on Data Protection.

Below are the links to the privacy policies of the COMPEGPS TEAM S.L. service providers:

https://www.salesforce.com/company/privacy/

https://www.heroku.com/policy/security

Images will be stored for one year unless a request is filed earlier to have them deleted.

Watching the recordings

The user of the SeeMe service will be able to select who can see his/her images.

• Position data in real time:
• The contacts selected by the user.
• Alerts
• The user can add a limited number of contacts
• The contacts added will receive an email (for broadcasts) or an email and an SMS (in case of an emergency).

Bear in mind that contacts may disseminate the recordings to third parties, an action for which COMPEGPS TEAM S.L. cannot be held responsible.

Users are reminded that because we do not have the contact’s prior consent, when said contact receives the email, he/she must expressly Accept being the user’s contact.

Likewise, on each electronic communication with the contact (via email), the contact will be instructed how to unregister in the event that he/she no longer wants to be the user’s contact, in which case he/she will no longer receive any messages.

Minors

The SeeMe service can only be used by those 16 or older; therefore, when accepting the conditions, the user states that he/she is 16 or older.

If the user is under the age of 16, his/her parents or legal guardians will be responsible for the use of the service, in which case COMPEGPS TEAM S.L. accepts no responsibility for the dissemination of any recordings.

Recordings

The purpose of the SeeMe service is solely to record the position and other readings (speed, altitude, heart rate, calories burned, power and cadence) taken during the activities performed. No other content of any type is recorded. Likewise, only data collected with a TwoNav device are accepted.

Service provision

COMPEGPS TEAM S.L. guarantees that the service will be accessible immediately after it is activated/purchased, or once the trial period is activated and after the set-up steps prior to its use are carried out.

The availability of this service is limited by the 2G coverage of our provider and by its agreements with providers around the world. COMPEGPS TEAM S.L. reserves the right to limit the service in any non-EU country without prior notice.

The availability of services offered by COMPEGPS TEAM S.L. may vary depending on the service. If a service is not available, COMPEGPS TEAM S.L. will inform users via email as soon as it becomes aware of this situation. This information will be sent no later than 30 days. COMPEGPS TEAM S.L. may then offer to 1) provide the customer with another service of similar or better characteristics at no extra charge, or 2) unless COMPEGPS TEAM S.L. provides justifiable and provable reasons, refund the payment made for the cancelled order. In the event that COMPEGPS TEAM S.L. does not refund the amount within the period stipulated, the buyer may demand to be paid twice the amount owed, without prejudice to his/her right to other compensation.

Right of withdrawal, returns and claims

The customer can cancel an order for any reason and with no penalty within fourteen calendar days of receiving the product. To exercise this right of withdrawal, the customer must send an email to , or write to C/ Draper 13 08350, Arenys de Mar, Barcelona (Spain). Or he/she can fill out the withdrawal form, available from https://support.twonav.com.

Pursuant to Article 103 of Law 2/2014 of 27 March, which amends the revised text of the General Law for the Defence of Consumers and Users, any services or goods made to the consumer’s specifications or that are clearly personalised, or that, due to their nature, cannot be returned or may quickly deteriorate or expire, are not eligible for withdrawal.

If a client notifies up to 14 days after a renewal, the cancellation of the subscription is accepted and 100% of the money is returned. No cancellation costs are applied.

Once the withdrawal period has passed, the user can terminate the collection of their annual subscription from their client area at any time.

Partial cancellations of an annual subscription are not accepted.

Refunds

Any amounts received from you will be refunded using the same method of payment employed by you, unless otherwise stipulated. COMPEGPS TEAM S.L. will refund the amount paid by the customer within 14 calendar days from receipt of the customer’s withdrawal request.

In the event of an unjustified delay by COMPEGPS TEAM S.L. in issuing a refund, the customer may claim twice the amount paid, without prejudice to be compensated for any damages claimed in excess of said amount.

Claims

If a customer wishes to file a claim, the facilities of COMPEGPS TEAM S.L. are located at C/ Draper 13 08350, Arenys de Mar, Barcelona (Spain), or he/she can also write to .

Jurisdiction

COMPEGPS TEAM S.L. reserves the right to file those civil or criminal suits it deems appropriate for the improper use of its website and content or for any violation of these conditions.

The relationship between the user and the provider shall be governed by the applicable law in Spain. Any dispute between the parties may be subjected to arbitration or to the regular courts, in compliance with the relevant regulations on jurisdiction. COMPEGPS TEAM S.L. is headquartered in BARCELONA, Spain.

Date: 15 December 2017