PRIVACY POLICY
Information document pursuant to art. 13 EU Reg. 2016/679 (GDPR) – Information for the processing of personal data collected from the interested party
- Data Controller (articles 4 and 24 GDPR)
Genova Car Sharing Srl, with registered office in Via Paolo Imperiale n. 4, 16126 Genoa, in the person of the pro-tempore legal representative. You can contact the Data Controller via: fax +39 010.275.60200, email: privacy@genovacarsharing.com, phone number +39 010 275 601.
Data Protection Officer (RPD / DPO – Data Protection Officer), pursuant to art. 37 – 39 of the GDPR, is identified within the organization and the related contact details are tel. number: +39 010 275 601; e-mail dpo@genovacarsharing.com.
- Categories of personal data processed
Personal data: any information relating to an identified or identifiable natural person (“interested party”); the natural person is considered identifiable who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier or one or more characteristic elements of his physical identity, physiological, genetic, psychic, economic, cultural or social (Article 4, paragraph 1 No. 1 – C26, C27, C30 GDPR).
- Purpose of processing / Legal basis – Data retention period and nature of the provision
| Purpose of the treatment | Legal basis | Data retention period | Nature of the provision |
|---|---|---|---|
| A) Provision of car sharing / car rental services provided for by the General Contract Conditions and management of booking and assistance requests via the website, smartphone app or telephone call. | Art. 6 par. 1, lett. b) GDPR Contract | 10 years from the termination of the supply contract. | Necessary to fulfill the obligations deriving from the contract. In case of failure to provide the service, it will not be possible to deliver the service. |
| B) management of current contracts and execution of pre-contractual measures, B) management of current contracts and execution of pre-contractual measures, in particular to fulfill purposes instrumental to the fulfillment of company activities, such as operational, technical and administrative management of the relationship with the Customer connected to the provision of services, archiving, billing, management of payments (with relative treatment – in accordance with the law – of payment data, including identification details of credit cards) for the services requested and for any accessory economic charges, and, in any case, within the limits in which the processing is necessary for execution of the obligations deriving from the contracts themselves; to this end, the Company may use its contact details to send communications of an exclusively informative nature regarding changes to the contractual conditions, updates on the operation of the services and any other information regarding the service that the Company should deem useful knowledge in the interest of the customer. | Art. 6 par. 1, lett. b) GDPR Contract | 10 years from the termination of the supply contract. | Necessary to fulfill the obligations deriving from the contract. In case of failure to provide the service, it will not be possible to deliver the service. |
| C) management of relations with third party authorities and public bodies for purposes related to particular requests, the fulfillment of legal obligations or particular procedures (eg: re-notification to the actual transgressor of the reports of contestation of violations of the rules of the Highway Code) | Art. 6 par. 1, lett. b) GDPR Contract | 10 years from the termination of the supply contract. | Necessary to fulfill the obligations deriving from the contract. In case of failure to provide the service, it will not be possible to deliver the service. |
| D) direct marketing activities of the Owner with your consent for sending promotional material, direct sale of new products and services and / or satisfaction questionnaires by automated means such as e-mail, fax, text messages such as Mms or Sms or other type, as well as through telephone calls via operator and paper mail. To compare and possibly improve the results of communications, the Data Controller uses systems for sending newsletters and promotional communications with reports. Thanks to the reports, the Owner will be able to know, for example: the number of readers, openings, unique “clickers” and clicks; the devices and operating systems used to read the communication; details on the activity of individual users; the details of the emails sent, emails delivered and not, of those forwarded. All these data are used for the purpose of comparing, and possibly improving, the results of communications. | Art. 6 par. 1, lett. a) GDPR Consent of the interested party | Until termination of the contract (or until consent is revoked in case that is earlier) | Optional and free. Failing this, you will still able to use the requested supply service. |
| E) with prior consent, profiling of the interested party on the basis of his preferences and related habits to receive service offers in line with your interests. | Art. 6 par. 1, lett. a) GDPR Consent of the interested party | 24 months (or until consent is revoked) | Optional and free. Failing this, you will still able to use the requested supply service. |
| F) with prior consent and until the Customer’s objection, for direct marketing activities of third parties, sending of advertising / promotional material, direct sale of new products and services and / or satisfaction questionnaires by automated means of e-mail, fax, text (Mms or Sms) or of any other type, as well as by telephone calls through an operator and by mail. The data will be transferred to Duferco Group Companies and Commercial Partners, operating in the energy sector. To obtain privacy information and exercise the rights of the interested party regarding the processing of customer data by third parties, they must contact the same third party, who will send promotional communications as an independent owner. | Art. 6 par. 1, lett. a) GDPR Consent of the interested party | Until termination of the contract (or until consent is revoked in case that is earlier) | Optional and free. Failing this, you will still able to use the requested supply service. |
| G) Navigating on this website (https://www.elettracarsharing.com/) and APP of the Data Controller | Art. 6 par. 1, lett. f) GDPR Legitimate interest | For the duration of the browsing session | Necessary to use the contents of the Genova Car Sharing website / APP. |
| H) Evasion any request for assistance or information via dedicated forums or online chat (eg. assistance form on line present in the FAQ area or interactive chat on the site), or by calling one of the toll-free numbers / contacts present online and subsequent contact by a Genoa Car Sharing representative, at the addresses provided. | Art. 6 par. 1, lett. f) GDPR Legitimate interest | For the time necessary to process the request you forwarded | Necessary to respond to your request. In the event of failure to provide it, you will not provided with assistance and/or the information requested, but you can continue browsing the website / APP. |
Furthermore, we would like inform you that the data acquired by the fleet management system installed on board the vehicles collects and sends data on the geographical position of the car, on its average speed, on fuel consumption and on the mileage. These data are processed exclusively to meet logistical and billing needs, to ensure more efficient management and maintenance of the vehicle fleet, to ensure safety and finally to prevent and counter criminal events and damage to company assets. The personal data acquired by the localization system are processed with the aid of automated IT tools and protected with appropriate security measures.
- Specific areas / sections
On this site you will find some specific areas / sections that will be governed by specific information on the processing of personal data, to which full reference is made.
- Cookies
For more information on the cookies used by this website, consult our cookie policy.
- Recipients / categories of recipients of the data
The personal data provided by the Customer may be disclosed to recipients, who will process the data as managers (art.28 GDPR) and / or as natural persons acting under the authority of the owner and manager (art. 29 GDPR), or who operate in total autonomy as separate Data Controllers, in order to comply with the purposes pursued by Duferco as indicated above. The list of designated data processors is constantly updated and available by contacting the Data Controller at the addresses indicated in the introduction.
The data may be disclosed to recipients belonging to the following categories: – Parent / subsidiary and / or associated companies of Genova Car Sharing Srl; – companies and / or entities that perform functional and / or ancillary systems to the management of the Car Sharing activity with which the Company has various types of agreements; – suppliers of software, technologies and management systems for fleet vehicles, invoicing and payment, necessary for the provision of the services covered by the agreement; – persons in charge of credit recovery activities and insurance companies competent for the settlement of claims; – Institutional bodies, authorities and bodies, as well as experts, consultants and lawyers, police forces and other public administrations, for the fulfillment of obligations under the law, regulations or community legislation.
- Data transfer to a third country
The personal data provided will not be transferred to countries outside the European Union. Should this need arise, such data will be transferred within the limits and under the conditions set out in Articles 44 and ss. of EU Regulation 2016/679, in order to comply with purposes related to the transfer itself. In this case, the Data Controller will update this information and the interested party can obtain a copy of the conditions underlying the transfer by contacting the Data Controller.
- Rights of the interested parties
You can assert your rights as expressed by EU Regulation 2016/679, by contacting the Data Controller at the email address privacy@genovacarsharing.com or by sending an email to DPO: dpo@genovacarsharing.com. You have the right, at any time, to ask the Data Controller for access to your personal data (Article 15), the rectification (Article 16) or cancellation (Article 17) of the same and the limitation of processing (Article 18). You are also recognized the right to data portability, where provided (Article 20): in this case, the Data Controller will provide you with the personal data concerning you in a structured format, commonly used and readable by an automatic device. Furthermore, you have the right to object to the processing of your data at any time (including automated processing, e.g. profiling). Specifically, to oppose profiling, you can write an e-mail at any time to privacy@genovacarsharing.com with the subject “no profiling”. To stop receiving direct marketing communications, you can use our automatic cancellation systems and you will no longer be disturbed.
Without prejudice to any other administrative and judicial appeal, if you believe that the processing of your data violates EU Reg. 2016/679, pursuant to art. 15 letter f), you have the right to lodge a complaint with the Supervisory Authority, or the Italian Guarantor for the protection of personal data (https://www.garanteprivacy.it/) and, with reference to art. 6 paragraph 1, letter a), you have the right to revoke the consent given at any time by writing to the Data Controller and / or the DPO as described above.
Last Update: February 26th 2021