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.
Cookies are used on the Site. Please read the Cookies Policy published on the Site.
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 email@example.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 firstname.lastname@example.org.
For any other communication under the DPO's responsibility, the DPO may be contacted at the following e-mail address: email@example.com.
ALD Automotive Italia s.r.l. (hereinafter “ALD“ or the “Owner“) provides below the privacy information pursuant to art. 13 of EU Regulation 679/2018 (the “GDPR“), of Legislative Decree 196/03 - as amended by Legislative Decree 101 / 2018- (“Privacy Code“) and of the current privacy legislation, as owner of the personal data of the third-party user of the vehicle (hereinafter the “Third User“). Specific privacy information can be consulted on the institutional websites of ALD and has been provided to participants in the ALD Connect initiative who have entered into any rental contracts or other contracts with ALD.
- Object of treatment: In relation to the purposes of the following paragraph, the subject of this treatment will be the personal data of the Third User, including the geolocation data.
- Purposes and legal bases of the treatment: Personal data related to this initiative will be processed for purposes related to the protection of corporate assets, for example in case of accidents or thefts involving the leased vehicle (these purposes include those related to the collection of geolocation data); the legal basis of the described treatment has to be found in the pursuit of a legitimate order by the Owner pursuant to art. 6, paragraph 1, lett. f) of the GDPR.
- Method of treatment: Personal data will be processed in Italy through electronic and manual tools, in compliance with the legislation mentioned above, and according to principles of correctness, lawfulness, transparency and protection of confidentiality.
- Subjects who may become aware of the data and the sphere of communication and dissemination of the data: Who may become aware of personal data of the third-party user: the participants of the ALD Connect initiative, through the application dedicated to service management; subjects entitled to access the data by virtue of legal requirements, regulations or community regulations, or on the basis of provisions of the judicial authority, within the limits set by these laws or measures; 3. ALD employees, collaborators and consultants who may become aware of personal data, as “Managers“ or persons authorized to process; 4. all the companies of the Société Générale Group or companies that legitimately use the ALD Automotive brand 5. companies specialized in: management of fines; vehicle recovery; management of administrative or legal practices affecting vehicles; 6. companies that install and manage on their own, but on behalf of ALD, satellite and/or radio frequency systems with geolocation and/or position detector; 7. in general, subjects who need to access the data for purposes auxiliary to the existing contractual relationship, and/or for the provision of personalized and value-added services or for statistical purposes. The data can be transferred, for the above purposes, to other European Union countries to the same categories previously indicated. The subjects belonging to the categories referred to in points 2, 3, 4, 5 6 and 7 process the data as independent “Data Controllers“, unless they are appointed as external Data Processors by ALD.
- Third User Rights: ALD informs that, for the exercise of the same rights recognized by articles 15 and following of the GDPR, the Third User can contact the Data Controller by writing to the e-mail address firstname.lastname@example.org or to the Data Protection Officer (DPO) by writing to the e-mail address email@example.com. The Participant and the Third User can exercise the following rights:
- the confirmation that personal data concerning him or her is being processed and the access to the data and the following information (processing purposes, categories of personal data, recipients and/or categories of recipients to whom the data have been and/or will be communicated, retention period);
- the correction of inaccurate personal data concerning him or her and/or the integration of incomplete personal data, also by providing an additional declaration;
- the cancellation of personal data, in the cases provided by the current privacy legislation;
- the limitation to the data processing in the cases provided by the current privacy legislation;
- the portability of the data concerning him or her, and in particular to request the personal data provided to the owner and/or to request the direct transmission of the data to another data controller;
- the opposition to the data processing at any time, for reasons connected to a particular situation, and/or to the processing of personal data concerning him or her in full compliance with current privacy legislation.
Interested parties who believe that the processing of personal data referred to them occurs in violation of the GDPR provisions have the right to lodge a complaint to the Guarantor of the Protection of Personal Data as required by art. 77 of the GDPR itself, or to apply to appropriate judicial offices (art.79 of the GDPR).
- Data retention: ALD informs the Third User that its data will be stored for the time strictly necessary to fulfill the purposes mentioned above.
ALD Automotive Italia