WEBSITE PRIVACY POLICY

ALD AUTOMOTIVE Italia S.R.L., a company managed and coordinated by Société Générale S.A., with registered office in Viale Luca Gaurico, 187 - 00143 Rome, Share capital EUR 140,400,000, VAT No: IT 01924961004, registered in the Rome Business Register with R.E.A. [Economic and Administrative Index] No. 636604 (hereinafter “ALD”), provides this privacy policy notice, pursuant to Art. 13 of EU Regulation 679/16 (the “Regulation” or “GDPR”), as the Data Controller which will process the personal data of visitors (hereinafter the “Users”) to its Internet website http://2wsolutions.aldautomotive.it/ (hereinafter the "Website").

Users will find specific privacy policy information in certain areas of the Website, in which personal data is collected for purposes other than those described in this policy notice.

1. Type of data processed and processing procedures

Users’ personal data will be processed using manual and electronic instruments to guarantee data security and confidentiality for the following purposes:

- to allow the User to register on our Website, in compliance with the terms and conditions of use, and to provide the various services/products offered on the Website (Art. 6, para. 1, letter b) of the Regulation);

- to respond to the User’s requests regarding the Website and/or our Services/Products (Art. 6, para. 1, letter b) of the Regulation);

- where required, to fulfil the legal obligations, including tax payments, if a service or product is purchased on the Website (Art. 6, para. 1, letter c) of the Regulation);

- if necessary, to allow ALD to pursue its legitimate interest to guarantee the security and integrity of its Website (Art. 6, para. 1, letter f) of the Regulation);

E-mails sent as an explicit, voluntary option to the addresses given on this Website entail the subsequent acquisition of not only the sender’s address, required to answer the requests, but also any other personal data included in the message. Except for what is specified for browser data, Users are free to provide their personal data on the Website forms to send ALDI their requests. Failure to provide this information can prevent Users from registering on the Website and obtaining the services and/or information requested. If Users freely, explicitly and voluntarily choose to send an e-mail to the address given on the Website, their name, surname, e-mail address, message and any additional information of the sender will be acquired automatically, as this information is required to respond to the requests made. It is completely optional to send data for marketing and/or profiling purposes.

2. Browser data

When the electronic system and software procedures used to run this Website are operating normally, they acquire some personal data, which is implicitly transmitted when using Internet communication protocols. This information is not collected to be associated to specific data subjects. However, its very nature could enable users to be identified via processing and the association with data held by third parties. This category includes IP addresses or domain names of the computers used by Users, who connect to our Website, the URI (Uniform Resource Identifier) coded addresses for the resources requested, the time of the request, the method used to send the request to the server, the size of the file obtained in reply, the numeric code indicating the status of the response given by the server (successful, error, etc) and other parameters regarding the User’s operating system and electronic environment. This data is used only for statistical, anonymous information regarding the use of the Website, to check it is operating correctly and it is deleted immediately after processing. The data could be used to ascertain liability in the event of any hypothetical computer crimes against the Website.

3. Cookies

This Website uses Cookies. Please read the Cookies Policy published on our Website.

4. Marketing

ALD may process the User’s data for direct marketing purposes (e.g. direct sales, to send newsletters and promotional material, market surveys, commercial communications, economic and statistical analyses, loyalty initiatives, invitations to award events, to measure the level of customer satisfaction) only if the User gives express consent (Art. 6, para. 1, letter a) of the Regulation). More specifically, the Company may contact the User via post, e-mail, a land-line or mobile telephone, with or without the service of an operator). If the User fails to consent to this optional sending, this will not affect any right to register and the User is free to give or revoke his consent at any time, by ticking the opt-out box in each promotional e-mail, or by contacting ALD via the contact details given below in point 9.

5. Profiling

ALD may only process some of the personal data for profiling to send customised marketing communications subject to the User’s prior consent. If the User fails to consent to this optional sending, this will not affect any right to register and the User is free to give or revoke his consent at any time, by ticking the opt-out contained in each promotional e-mail, or by contacting ALD via the contact details given below in point 9.

6. Optional communication of the data to third parties

ALD may only communicate some of the personal data subject to the User’s prior consent (i) to all the companies belonging to the Société Générale group and (ii) to third party companies operating in the manufacture and commercialisation of vehicles or the supply of the relevant accessory services, companies operating in the transport and mobility sector, insurance companies and other companies operating in the insurance chain, banks, companies operating in the tourist-hospitality sector, companies operating in the sector of electronic trade, so they may, in turn, process the data for marketing purposes. If the User fails to consent to this optional sending, this will not affect any right to register and the User is free to give or revoke his consent at any time, by ticking the opt-out box contained in each promotional e-mail, or by contacting ALD via the contact details given below in point 9.

7. Data retention

Users’ recorded personal data will be collected and stored throughout the period, in which their account is active. Personal data collected regarding products and/or services purchased will be stored for the time required by tax law. Data collected for marketing, profiling and third party communication purposes will be stored until the User revokes his consent given for the purpose. Browser data will be deleted immediately after it has been processed for operational or statistical purposes. In any event, this data can be used to check any liability for any computer crimes committed against this Website. Apart from this circumstance, browser data will be stored for the minimum period of time required, unless a further period of storage is required for legal obligations.

8. Data communication and diffusion

The User’s personal data may come to the attention of ALD employees and/or collaborators appointed to manage the Website. These individuals are formally appointed by ALD as “appointed data processors”. They will process the Users’ data exclusively for the purposes given in this privacy policy notice and in compliance with the legislation in force on the subject of processing personal data. The User’s personal data may come to the attention of third parties, which may process the data on ALD’s behalf as “external data processors”, e.g. suppliers of electronic services and functional logistics to ensure Website functionality, suppliers of outsourcing or cloud computing services, professionals and consultants, companies appointed to send promotional e-mails on behalf of ALD. The User’s data may be communicated to the judicial authorities only in the event of accidental data loss.

9. Users’ Rights

Pursuant to Articles 15-22 of the Regulation, ALD wishes to inform you that Users have the right to know: (i) the origin of their personal data; (ii) the purposes and procedures of the processing; (iii) the logic applied to process data using electronic instruments; (iv) the identification details of the Data Controller and data processors; (v) the individuals or categories of individuals to whom the personal data may be communicated in their post of data processors or appointed persons. Users also have the right to: a) update, correct or, when they so wish, supplement the data; b) delete, restrict the use, transform into an anonymous form or block any data processed in breach of the law, including data, which does not need to be stored for the purposes for which it was collected or subsequently processed; c) certification that the operations in letters a) and b) have been communicated together with the contents, to those to whom the data has been communicated or diffused, except if this proves impossible or involves the use of disproportionate means compared to the right protected. Users have the right to oppose the processing of their personal data in whole or in part: a) on legitimate grounds, even though the data processed is pertinent to the purpose of the collection; b) in order for advertising material to be sent or for direct sales, or to implement market research or commercial communications. Users also have the right to transfer their data, i.e. to ask ALD for their data in a structured, commonly used format, which can be read by an automatic device and sent to another data controller. Users have the right to revoke the consent given at any time, without prejudice to the validity of the processing carried out before the revocation. ALD informs Users they may exercise the rights above, by contacting ALD Automotive Italia S.r.l., and writing specifically to the Data Protection Officer (DPO) at the e-mail address: privacy.it@aldautomotive.com. The DPO may also be contacted at the following e-mail address: dpoalditalia@aldautomotive.com for any other communication within his remit.

ALD Automotive Italia