CODE ON PERSONAL DATA PROCESSING AND CONSENT
Pursuant to art.13 of European regulation 679/2016
ELLEGI S.R.L. ,(which operates under CarMotion brand) with registered office located in Via Francesco Crispi, 250 – 90139 Palermo (PA), CF e P.IVA 04147860821 (from now on referred as “the Holder”) as direct holder of data processing, informs the Customer, pursuant to the national regulation appliable, and to art.13 of European regulation 679/2016 (from now on referred as “GDPR”), that his data will be processed with the methods and for the purposes that follow:
By choosing to use our car rental services, it will be necessary to share with us some informations that we need to provide You our services, to send quotes, to book reservations and to make fiscal invoices for these services.
In this document, we wish to explain:
1. Processing Subject
The Holder will process the following personal data, which are identifying and not sensible (in particular: name, surname, identity card or passport, VAT number, fiscal code, business name, address, phone number, e-mail address, bank account coordinates and payment invoices) – later, he will eventually process also “personal data” and “data” which the Customer provided at the moment of ending the rental agreement for the car rental services offered by the Holder.
2. Purpose and Legal basis of Data Processing
Customer’s personal Data, arbitrarily communicated and acquired by the Holder to provide the service, will be processed following the law and with honesty, only for the following purposes:
-Without Customer explicit consent to:
-Start and end the agreement for the rental service;
– Fullfill the pre-contractual, contractual and fiscal obbligations related to the current relationship;
– Fullfill the obbligation provided for by the law, by a code, by European regulations or by an authority order;
– Fullfill to billing of our services, to manage claims and contentious issues, to send service communications, to recover credit, to prevent any fraudulent or illicit activity;
– Exert Holder’s rights (f.e. right of defense in court)
b) Only with Customer explicit consent, for Marketing purposes:
Send by e-mail, sms, mail and/or phone call newsletters, any commercial communication and/or advertising material oon products and services offered by the Holder, and inquiry on the degree of satisfaction with the quality of his services;
Customer data are up to date, relevant, complete and not exceeding the purposes listed above for which data is collected and processed.
3.Data Processing Modalities
Customer data will be processed, respecting the needed security and privacy, trough these modalities: data collection from the interested party, data collection in any of the agencies of the Holder, collected and recorded for specific purposes, which are legal and explicit, processed trought electronic and automated devices (customer data collection trough telematic communications, directly with the customer) and stored for such purposes.
4. Data Access
Customer data could be shared for the purposes pursuant to art 2.A) and 2.B) of this code, to: Holder employees and collaborators, in their role of responsibles and internal processing managers, as well as system administrators; to third party companies and other subjects (f.e. credit institutions, professional firms, consultants, insurance companies for the provision of insurance services, computer systems companies for the operation of management software, etc.) which carry out outsourced activities for the Holder, in their role of responsibles of external data processing.
Without the need of an explicit consent (art. 6 b) and c) GDPR) the Holder can share Customer’s data for the purposes of art 2.A) to: Supervisory and judicial authorities, insurance companies for the provision of insurance services, as well as to any other subject to which is mandatory by law to provide all the needed data to fulfill the aforementioned purposes. These subjects will process data as indipendent data managers. Customer’s data will not be widespread, nor subject to any decisional process fully automated, including profiling.
6.Nature of data collection and consequences of refusal to provide them
It is mandatory to provide all the needed data for the purposes listed in art. 2.A). If any of those is lacking, it will be not possible to guarantee the services of art. 2.A).
To provide data for the purposes listed in art 2.B) is optional. The Customer can choose to not provide his data, or to deny the authorization to process the already collected data: if he chooses to do so, he will not be able to receive newsletter, marketing communications and advertising material related to the services offered by the Holder. Anyway, The customer will still be entitled to the services of art. 2.A)
In his role of interested party, the Customer is entitled for the rights pursuant to art.15 GDPR, and in detail:
1) To receive confimation about the existence of his personal data, even if not yet recorded, and to eventually receive a communication about this data; 2) to receive informations about: a) The source of personal data; b) Of the purposes for which data was collected, and details about its processing; c) the method adopted in case of data processing by electronic instruments; d) Identification details of the holder, of the managers, and any designated representative, pursuant to art.3 comma 1 GDPR; e) of subjects and third parties with which the data was shared, or who has the possibility to access the data in the role of national representative, or in charge. 3) To obtain without unjustified delay: a) the update and/or the amend of wrong data or, if interested, incomplete data integration; b) the cancellation, modification in anonymous form or the block of any data processed against the law rules, including data for which storage is not necessary related to the purposes for which the data s collected and processed; c) A proof that actions described in point a) and b) were effectively brought to knowledge of the subject to which the data was communicated, excluding the case in which such an opetation would result impossible, or needs an use of disproportionate means related to the protected right; 4) To deny, partially or totally: a) the processing of any personal data of the Customer, even if relevant to the purpose of its collection, only for legitimate reasons; b) the processing and sharing of any personal data of the Customer with the purpose of sending any commercial communication and/or advertising material on products and services offered by the Holder, or for detection of market researches, trough phone and/or mail. Please note that the right of opposition of the interested party, exposed in the previous point b), for purposes of direct marketing through automated methods, extends also to traditional ones, and that anyway the Customer still has the right to deny his authorization even partially. For this reason, the Customer can decide to receive communications only trough traditional communication methods (phone/mail), only trough automatic ones (sms/email) or none. Where those applies, the Customer also has the right pursuant to art. 16-21 GDPR (right of rectification, right to be forgotten, right to limitation of treatment, right to data portability, right of opposition), as well as the right to claim directly to a control authority (guarantor authority for the processing of personal data)
8. Data Storage
Customer’s personal data, collected and processed for the purposes listed above, will be stored until the end of the rental agreement and, thereafter, for as long as the Holder is subject to retention obligations for tax or other purposes, as foreseen by law.
9.How to exercise Customer’s Rights
The Customer will be able to exercise his rights by sending:
- a Registered Letter to ELLEGI Srl (CarMotion) Via Francesco Crispi, 250 – 90139 Palermo (PA)
- an email to firstname.lastname@example.org
10.Holder, Manager and Responsibles
The Holder of Data processing is ELLEGI S.r.l., with registered office in Via Francesco Crispi, 250 – 90139 Palermo (PA), in the person of Mr. Termini Mario. The Holder can be contacted by email, to the address email@example.com .
The updated list of Managers and responsibles of data processing is stored in the registered office of the Holder.
This INFORMATION NOTICE may be subject to changes. Each update will be visible on the website www.carmotion.it.