Please read this Policy carefully before using this website because it explains how we will process personal data (the “Data”).
2- INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA
Your Data will be processed to administrate and fulfil your request and for general administration purposes by Company as a controller under the applicable data protection legislation, as follow:
|Data / Data Categories||Purposes||Legal Basis|
|Respective identification and contact details if applicable (name, surname, cell phone, country of residence, company, email address*)||Contacting, communication, and request fulfilment||The processing of this data is necessary in order to carry out the request of the interested party.|
|email address||To send newsletter||This data processing will take place only with your consent. Failure to provide such data will make it impossible to send our newsletter. This will not affect in any way the use of the Web site.|
|email address||To send emails with marketing purposes regarding our products/services which are similar to those purchased||This data processing is in our legitimate interest and is permitted by law only with reference to the email contact details provided, provided that the products / services are similar to those which are the subject of the sale and that the interested party, after being adequately informed, does not object to such use either initially or on the occasion of subsequent communications. You can unsubscribe|
|Information related to the use of the product/service and contact details||To analyse behaviours, habits and propensity to consume, in order to personalize our direct marketing activities as indicated above (profiling for marketing purposes)||This data processing will take place only with your consent. Failure to provide such data will prevent us from personalizing our marketing communications for you. This will in no way affect the access and use of the Website.|
|Identification details and contact||To communicate the Data to subsidiaries or affiliates of the Company, as well as to partner companies belonging to the automotive, financial, insurance and telecommunications sectors, which may process them for sending commercial and / or promotional communications on their products and services, as well as to conduct market research||This data processing will take place only with your consent. Failure to provide such data will prevent us from sending information about you to third parties for their own marketing purposes. This will in no way affect the provision of the services you have purchased.|
|Navigation data such as e.g. IP address, location – country -, information on the pages visited within the website, access time to the website, browsing time on each page, clickstream analysis||Website maintenance and troubleshooting||This data processing is in our legitimate interest for the maintenance of the web site. When you report a problem with our web site, we do not believe that your interests or fundamental rights outweigh (or outweigh) our legitimate interests. Failure to provide such data will make it impossible for us to solve your problem. It is allowed to exercise the right of opposition within the limits established by law.|
The Data elements marked with an asterisk (*) are mandatory and a contractual requirement. You are therefore obliged to provide the Data. In case you do not provide the Data, we cannot fulfil your request. The Data may be processed in hardcopy, by automated or electronic means.
3 – HOW TO PROCESS THE PERSONAL DATA
The data processing carries out with information system and organizational and logical methods strictly related to indicated purposes and are implemented all technical and procedure security measures to ensure the confidentiality, integrity, availability and resilience of data processing, in compliance with the article 32 of GDPR.
The personal data could be transferred to abroad, outside the EU also, in comply with the applicable law.
4 – DATA TRANSFER OUTSIDE OF THE EEA
Within its contractual relations Company may transfer the Data in countries outside of the European Economic Area (EEA), including store them in databases managed by entities acting on behalf of Data Controller. Databases management and Data processing are bound to the purposes of the processing, mentioned above and are carried out according to GDPR and – if applicable – local data protection law.
In case the Data are transferred outside of the EEA, Company will use any appropriate contractual measures to guarantee an adequate protection of the Data including – among the others – agreements based on the standard contractual clauses adopted by the EU Commission, and where required additional measures, to rule the transfer of Data outside of the EEA.
To receive information about our mentioned safeguards and to obtain a copy of respective safeguards please contact us via e-mail email@example.com .
5- COMMUNICATION OF PERSONAL DATA
Company could authorize internal or external parties to perform the data processing. The internal parties are “people in charge of data processing” involved in the business organization like as administrative, commercial and marketing staff, legal department, system administrator etc; while external parties act as “data processors” and must be appointed as such by Company. The Data Processor could be transferred the personal data to:
- technical service suppliers
- postal carriers
- hosting providers
- information technology companies
- communication agencies
In particular, we disclose your personal data for the below listed purposes to the following recipients:
|Email address, contact details if provided||
||Your Data will be disclosed to the following companies and also to their respective Information Technology- service providers to support the administration of the named purposes:
– FCA ITALY S.p.A. – c.so Agnelli, 200 – 10135 Torino, Italy
– NHOA S.A. – Via Anton Francesco Grazzini, 14 – 20158 Milano, Italy
– MailUp S.p.A. – via Pola, 9 – 20124 Milano, Italy
– DigitHub Italia S.r.l. – Corso Monforte, 41 – 20122 Milano, Italy
We disclose your Data to the respective Stellantis Group Companies and ENGIE EPS Group Companies if it is necessary to fulfil your request.
The Data may be disclosed to third parties to comply with legal obligations, to execute Public Authorities orders or to exercise a Company right before judicial authorities.
6 – DATA SUBJECTS RIGHTS
Data Controller shall provide the data subjects the exercise of the following privacy rights:
- confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data, ae required by 15 article of GDPR (Right of access);
- rectification of inaccurate personal data concerning him or her or integration of him or her incomplete personal data (Right to rectification);
- erasure of personal data concerning him or her, in accordance with the reasons described in article 17 of GDPR (Right to be forgotten);
- restriction of processing, when one or more of the cases provided by the article 18 of GDPR (Right to restriction);
- receive the personal data concerning him or her, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (Right to data portability)
Moreover, the user has the right to make opt-out of consent of data processing, anytime, without prejudice to
the lawfulness of the processing based on the consent given before the opt-out.
To exercise your rights, you can send an email with the following subject “PRIVACY”, to firstname.lastname@example.org.
The data subject can claim Privacy Authority, when he believes the Data processing is carried out in violation of the Regulation. Further information is available on the website http://www.garanteprivacy.it.
7 – LINKS TO THIRD PARTY WEBSITES
8 – LINKS TO SOCIAL NETWORKS
Our website does not include links to social networks.
9 – DATA RETENTION
Your Data will be in compliance with applicable laws, for a period of time not exceeding the necessary for the achievement of the purposes for which they are processed. The criteria for determining the data retention period take into account the period of lawfulness of the processing and the applicable legislation (for example, tax or anti-money laundering legislation), the limitation periods and the nature of legitimate interests.
From the moment your Data is stored for the necessary period of time, and the data will no longer be necessary, it will be deleted or made anonymous in a safe way.
10 – AMENDMENTS
11 – CONTACTING US
Free2Move eSolutions S.p.A. – Piazzale Lodi 3 – 20137 – Milan – Italy. You can contact the Company writing to the following email address email@example.com
5 July 2021