PRIVACY POLICY FOR VISITORS TO THE SITE

ALD Automotive Italia S.r.l., a company subject to the direction and coordination of Société Générale S.A., with registered office in Viale Luca Gaurico, 187 - 00143 Rome, share capital EUR 140,400,000, VAT number: IT 01924961004, recorded in the Register of Companies of Rome under No. R.E.A. 636604 - (hereinafter, "ALD") defines here below its privacy policy pursuant to art. 13 of EU Regulation 679/16 (the "Regulation" or "GDPR"), as processing owner of the personal data of visitors (hereinafter, the "Users") to its website http://mobilitysolutions.aldautomotive.it/it/ (hereinafter, the "Site")

Specific privacy policies are provided to Users in particular areas of the Site that require the collection of personal data for purposes other than those described in this policy.

1. Types of data processed and purposes of processing

The processing of the Users' personal data will be carried out by means of manual and computerized instruments, in such a way as to guarantee the security and confidentiality of data, for the following purposes:

- to allow Users to register to the Site, in accordance with the related terms and conditions of use, and to provide the services/products offered on the Site from time to time (art. 6, par. 1, letter b) of the Regulations);

- to respond to the User's requests regarding the Site and/or our Services/Products (art. 6, par. 1, letter b) of the Regulations);

- where required, to comply with legal obligations, including taxes, if a service or product is purchased from the Site (art. 6, par. 1, letter c) of the Regulations);

- if necessary, to allow ALD to pursue its legitimate interest to ensure the security and integrity of the Site (art. 6, par. 1, letter f of the Regulation).

The optional, explicit and voluntary dispatch of electronic mails to the addresses indicated on this Site entails the subsequent acquisition of the sender's address, as necessary to reply to requests, as well as of any other personal data included in the message. Apart from that specified for navigation data, Users are free to provide personal data in the request forms to ALD on the Site.
Failure to provide personal data may make it impossible to be registered to the Site and to obtain the services and/or information requested. The dispatch of e-mails to the addresses mentioned on the Site or the use of the forms on the Site, which Users do on the basis of a free, explicit and voluntary choice, imply the acquisition of the name, surname, e-mail address, text and any additional data of the sender, as necessary in order to reply to requests made.

2. Navigation data

The computer systems and software procedures used to operate this Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected in order to be associated with identified interested parties, but by its very nature it could allow Users to be identified, through processing and association with data held by third parties. This category of data includes IP addresses or domain names of computers used by Users connecting to the Site, URI (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters relating to the operating system and computer environment.
This data is used only to obtain anonymous statistical information on the use of the Site and to check its proper functioning and it is deleted immediately after processing. Data could be used to ascertain liability in the event of computer crimes against the Site.

3. Cookies

Cookies are used on the Site. Please read the Cookies Policy published on the Site.

4. Marketing

The so called "cookies" are used on the Website. Please read our Cookie Policy.

5. Profiling

Pursuant to Section 7 of the Italian Privacy Code, ALD hereby informs that the Users have the right to be informed (i) of the source of the personal data; (ii) of the purposes and methods of the processing; (iii) of the logic applied to the processing, if the latter is carried out with the help of electronic means; (iv) of the identification data concerning data controller and data processors; (v) of the entities or categories of entity to whom or which the personal data may be communicated and who or which may have access to the said data in their capacity as data processor(s) or person(s) in charge of the processing. Furthermore, Users have the right to obtain a) updating, rectification or, where they have an implied interest, integration of the data; b) deletion, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected. Users have the right to object, in whole or in part, a) on legitimate grounds, to the processing of their personal data, even though they are relevant to the purpose of the collection; b) to the processing of their personal data, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys. The above-mentioned rights can be exercised by contacting ALD by (i) registered mail to its registered office (to the attention of the Compliance Department), (ii) by email to the email address privacy.it@aldautomotive.com.

6. Optional disclosure of data to third parties

Only with the Users’ consent, ALD may communicate some of the User’s personal data to: (i) all companies belonging to the Société Générale group and (ii) third-party companies operating in the sectors of construction and marketing of vehicles or provision of related ancillary services, companies in the transport and mobility sector, insurance companies and other entities in the insurance chain, banks, companies in the tourism and hotel sector and e-commerce companies. If Users do not provide their consent to such optional communication, this will not prevent them from registering to the Site, as Users are free to give or revoke their consent at any time, by ticking the opt-out box contained in each promotional e-mail, or by contacting ALD at the addresses indicated at the bottom of item 9.

7. Data Retention

Registered Users’ personal data will be collected and stored as long as their account is active. Personal data collected in relation to products and/or services purchased will be retained for the time required by tax laws. Navigation data will be deleted immediately after being processed for operational or statistical purposes; in any case, such data may be used to verify any liability in the event of computer crimes against the Site. Beyond this case, navigation data will be retained for the least required period, without prejudice to any further period of data retention set out in the law.

8. Scope of communication and dissemination of data

The Users’ personal data may be disclosed to the employees and/or collaborators of ALD in charge of managing the Site. These individuals, who are formally appointed by ALD as "data processors", will process the Users' data exclusively for the purposes specified in this information notice and in compliance with current legislation on the processing of personal data. The Users’ personal data may also be disclosed to third parties who may process it on behalf of ALD as "external data processors", such as, for example, providers of IT and logistics services required to operate the Site, outsourcing or cloud computing service providers, professionals and consultants and companies in charge of sending promotional emails on behalf of ALD. The Users' data may be communicated to judicial authorities only in the event of accidental loss of data.

9. Users' Rights

Pursuant to Articles 15-22 of the Regulation, ALD hereby informs that Users have the right to be informed on (i) the origin of their personal data; (ii) the purposes and methods of processing; (iii) the logic applied if data is processed with the help of electronic means; (iv) the identity of data owners and controllers; (v) the subjects or categories of subjects to whom personal data may be communicated or who can acquire it as controllers or processors.
Users also have the right to obtain: a) the updating, rectification or, when interested, integration of data; b) the cancellation, restriction of use, transformation into anonymous form or blocking of unlawfully processed data, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed; c) a certification that the operations as per items a) and b) above have been notified, including in terms of contents, to those to whom data was communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
Users have the right to object, in whole or in part, to the processing of their personal data: a) for legitimate reasons, even if the data processed falls in the scope of collection, or b) for the purpose of sending advertising materials or direct selling or for carrying out market research or commercial communication activities.
Users have the right to data portability, i.e. the right to receive their data from ALD in a structured, commonly used and readable format from an automatic device, and to transmit such data to another data controller.
Users have the right to revoke at any time the consents given, without prejudice to the validity of the processing carried out before revocation. ALD informs all Users that they may exercise the above rights by contacting ALD Automotive Italia S.r.l. and, in particular, the Data Protection Officer (DPO) by addressing an e-mail to privacy.it@aldautomotive.com.
For any other communication under the DPO's responsibility, the DPO may be contacted at the following e-mail address: dpoalditalia@aldautomotive.com.

ALD Automotive Italia