Privacy and Policy - Site

SiWeGO S.r.l. considers of paramount importance the privacy of its users and ensures that the processing of personal data entered, collected and processed through the SiWeGO Application will be fulfilled according to the rights of the person concerned, with particular reference to confidentiality, protection of personal identity and the right to protection of personal data within the meaning and for the purposes of the “Italian Personal Data Protection Code” Legislative Decree no. 196/2003 (hereinafter, the Code), the EU Regulation 2016/679 (GDPR) as amended. In this regard, SiWeGO s.r.l. has adopted and implemented this Privacy Policy, which is valid as information pursuant to art. 13 of the Regulations for all that concerns the management of the Site in relation to the processing of user personal data.

Data Controller

The Data Controller is SiWeGO s.r.l., with legal office and administrative headquarters c/o Trentino Sviluppo S.p.A., Rovereto (TN), P.zza Manifattura no. 1, Tax Code/VAT 02439130226, in the person of its legal representative pro tempore, Dr. Marcello Favalli born in Brescia on 05.06.1978 and resident in Flero (Bs), via Caselle n. 1. By “processing” is meant - as better specified in art. 4 of the Regulation - any operation or set of operations, implemented even without the support of electronic tools, concerning the collection, recording, organization, structuring, storage, consultation, processing, adaptation or modification, selection, extraction, comparison, use, interconnection, blocking, communication by transmission, dissemination or any other form of making available, restriction, erasure and destruction of data, even if not registered in a database. “Personal data” means any information relating to a natural person, identified or identifiable (so-called interested party), even indirectly, by reference to any other information, including a personal identification number. This Privacy Policy applies to the User personal data collected through the application, the same Privacy Policy does not apply to other websites or applications owned by third parties, which may be accessed through a link on the application SiWeGO.

Data Processor

Data ownership, visibility and responsibility

The SiWeGO service is based on a platform shared by users, therefore, it is assumed that, once the data is entered, it remains available to the entire community of users, to the extent necessary for the performance of the service.

The user is responsible for all content, information and data he/she publishes or shares through the Services. In particular, the user is responsible for any new data or information he/she enters, for any change to pre-existing data and/or in general for any operation of creation, publication and sending of a transport request/offer, making in any case any content available through the Services.

When the user uses a third-party application to access the SiWeGO platform (i.e. by signing up for a Facebook or Google+ account) it may request the permission to access the user content, information, and data. The agreement accepted by the user when adding the application governs how the application may use and transfer content, information, and data.

Types of data processed and how they are processed

SiWeGO s.r.l. may collect some User personal data:

personal data such as name, surname, address,
phone or mobile phone number,
tax code,
banking data
tax code or VAT number of legal persons,
car insurance, if required
e-mail,
User ID, password e profile picture generated during platform registration,
information aggregated while browsing the application,
other personal data freely provided by the User during the registration process when requesting goods or services offered by the application or information sent by email; as well as all data better specified in the Terms and Conditions of Use of the Platform, in particular, item 6.

The User’s personal data, therefore, may be processed, by automated means, (i) during browsing, (ii) at the time of registration to the application (necessary to be able to use the services or purchase goods offered by the same), (iii) at the time of the request for the provision of an individual service. Moreover, if the User contacts SiWeGO to request information, all his/her personal data necessary to provide him/her with a response, will be collected.

Connection Data

The computer systems and software procedures used to operate the application 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 due to its nature could, through processing and association with data held by third parties, allow the Users to be identified. This category of data includes IP addresses or the domain names of the computers used by Users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, 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 given by the server (successful, error, etc.) and other parameters relating to the User’s operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information about the use of the SiWeGO application and to check its correct functioning and they are deleted immediately after processing. The data may be used for liability assessment in the event of hypothetical computer crimes against the SiWeGO Application.

Data voluntarily provided by the User

SiWeGO S.r.l. also collects personal data entered on registration or service request forms or sent to SiWeGO S.r.l. by e-mail. This is primarily information needed to provide the User with the requested services, that is to contact the User in response to his/her request for information.

Users have the option to consent to be geolocated using a satellite tracking system (GPS). The geolocation will take place only with the express consent of the user and in accordance with the provisions of the Regulations and the specific circulars of the Italian Data Protection Authority.

Purpose of personal data processing

SiWeGO s.r.l. will process your personal data for the following purposes:

requirements relating to authorisation operations useful for using the platform’s functionalities;
enabling and customising access to the various areas and relative contents of the application;
requirements relating to the entering into and performance of a contract at the request of the User and to perform a service or an operation within the scope of the activities of SiWeGO S.r.l.;
transaction of sums due to users, concerning the fees due/paid by virtue of a transport commissioned through the platform;
for business development, customer relationship analysis and marketing purposes, subject to your prior, optional consent. For example, SiWeGO S.r.l. may send updates and information on products or promotions to your e-mail address.

Processing methods

Data processing shall be carried out by means of the operations or set of operations indicated in Article 4, paragraph 1 of Regulation (EU) 2016/679: any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, by reference in particular to an identifier such as a name, an identification number, location data, an online identifier or to one or more features of his/her physical, physiological, genetic, mental, economic, cultural or social identity.

Nature of data provision and consequences of refusal to provide data

The processing of data by SiWeGO s.r.l. is based on the fulfilment of the contract between the company and the user, as this is the legal basis on which the contract is based. Consequently, the consent to the data processing is mandatory and fully implies access to the platform.

The provision of data for marketing, profiling and market research purposes is, on the other hand, optional and, for the processing of such data, it is necessary to provide express consent and failure to do it will not affect the user’s request for the service.

The user may revoke his/her consent at any time according to the provisions of the paragraph in this policy.

Minors under 16 years of age may not authorise the processing of their personal data, unless express consent is given by the person exercising parental responsibility or by the person acting on their behalf.

Transmission and/or dissemination of personal data

The personal data collected by SiWeGO S.r.l. through the Application shall be accessible to bodies and employees of SiWeGO S.r.l. that have been formally designated as data processors or persons in charge of the processing. Moreover, user personal data may be disclosed to companies that provide the goods or services available on the Application in performance of their obligations under contracts entered into, upon user request, or in order to provide the service requested by the User. The data is collected and stored on servers owned by SiWeGO s.r.l. or by companies with which SiWeGO s.r.l. has a contract. Some information may be disclosed in anonymous and aggregate form to companies in the group or third parties for statistical purposes. For example, the average age of users, the number of visitors from different geographical areas may be disclosed. In any case, this data does not allow Users to be identified. Moreover, data may be disclosed to third parties in the event of sale, merger or acquisition operations. As part of such reorganization activities, User personal data may be shared with current or prospective purchasers. In such cases, SiWeGO s.r.l. will obtain written assurances that personal data will be processed with an adequate level of protection and in accordance with applicable law. Except what expressly permitted by law, or as provided in this Privacy Policy, personal data will not be disclosed or shared without the user’s consent.

The Company may make use of its own collaborators and third-party companies that carry out call- centre activities that will act exclusively as external data processors pursuant to Article 28 of Regulation (EU) 2016/679. In this case, the user’s personal data may be disclosed exclusively for the achievement of the purposes set out in this policy.

Only with the prior consent, free and optional withdrawal at any time, SiWeGO S.r.l. may carry out promotional and marketing activities on behalf of third parties with whom it has entered into trade agreements, concerning products and/or services even different from those relating to services offered by SiWeGO. Moreover, only with the prior consent, free and optional, withdrawable at any time, the user data may be transmitted and/or transferred by SiWeGO S.r.l. to business partners located in countries outside the European Union and operating in different product sectors, having as their object products and/or services other than those relating to services offered by SiWeGO, in accordance with the provisions of art. 44 et seq. of Regulation (EU) 2016/679.

Therefore, these subjects will process the user personal data as independent data controllers under the Regulation (EU) 2016/679 and will be required to provide the user with their own information. The complete and updated list of entities that process the user personal data as autonomous controllers is available at SiWeGO s.r.l. at the following e-mail address: privacy@siwego.com.

The user personal data may be disclosed, solely for the purposes set out above, to service companies that SiWeGO S.r.l. uses, to supervisory and monitoring bodies, to public authorities and to other entities or bodies that own and operate databases to which disclosure of personal data is mandatory. The subjects belonging to these categories operate as autonomous data controllers unless they have been designated as data processors pursuant to and for the purposes of Article 28 of Regulation (EU) 2016/679. The personal data of users are in no way subject to disclosure

Personal data protection

SiWeGO S.r.l. protects the personal data processed by adopting the security measures provided for in European Regulation (EU) 2016/679, the details of which are contained in a specific technical document that can be consulted on the express request of the person concerned at the address: privacy@siwego.com. Measures to prevent unauthorised access by third parties to personal data and the application, or the unauthorised recording or use of personal data are in place. User Ids, passwords and credit card numbers are protected by an encryption system (Secure Sockets Layer – “SSL/TLS”).

SiWeGO s.r.l. will not be aware of or store your credit card number and codes, relying on the external platform Lemon Way that guarantees security and confidentiality in the transaction, whose Privacy Policy please refer to, for appropriate knowledge.

SiWeGO may provide links to third party websites, the functionality of whose content SiWeGO is aware of and ensures the security of the data provided to them.

Data provided by Users will be disclosed to Users of the Platform itself only as necessary for the performance of SiWeGO services.

The user may choose to disclose his/her data in various ways, such as accessing the Platform through social networks (e.g. Google, Facebook, etc.) or by using third-party services that allow him/her to post reviews or other information, thereby allowing third parties to use it.

Access via social networks and the use of these are subject to the terms and conditions and the privacy and cookie policies of the same social networks.

Retention of Personal Data

SiWeGO S.r.l. keeps your personal data for the period of time strictly necessary for users to take advantage of the services of the application, therefore, the data provided will be processed by the company in order to carry out the Services offered by the same. If the user deletes his/her account from the platform, the result will be the cessation of processing, while storage will be extended for the 10-year period necessary to fulfil the obligations and controls required by law (anti-fraud, anti-money laundering, identity theft, etc.).

If the user has given specific consent for the purposes of marketing and profiling, the data provided by the same will be processed for a time that is relevant, proportional and not excessive for this purpose, without prejudice to the right to withdraw this consent, withdrawal of which will result in the cessation of the retention of data relating to the same.

International transfer of data

SiWeGO S.r.l. may need to transfer user personal data to other companies or service providers in countries outside of the European Economic Area (EEA), composed of countries of the European Union and Switzerland, Iceland, Liechtenstein, and Norway that are considered countries with equivalent data protection and privacy laws and have been granted an adequacy decision by the European Commission. This type of data transfer may occur if the servers on which the data will be stored by SiWeGO S.r.l. or by other suppliers are located outside of the EEA or if the user uses application services while in countries outside of the EEA. In such case, SiWeGO S.r.l. will ensure that the transferred data is properly and adequately protected.

If your country does not have equivalent data protection and privacy laws, you will be required to enter into an EEA-standard contract that complies with EU law.

Information entered by the users

As User Generated Content, SiWeGO S.r.l. shall not be liable for any infringement of third-party rights and in any case, by submitting data, the User agrees to grant SiWeGO S.r.l. non-exclusive ownership of such content.

Changes to the policy

SiWeGO S.r.l. reserves the right to make changes to this privacy policy in order to incorporate changes in legislation or to adapt to technological innovations. Any changes will be adequately notified to the owners. In any case, users are required to view and consult this Privacy Policy periodically to check for any updates or reviews that may be necessary.

Supplementary information for the processing of data collected pursuant to Regulation (EU) 2016/679 and rights of the Data Subjects

Pursuant to article of the EU Regulation No 2016/679 (hereinafter “GDPR 2016/679”), bearing provisions for the protection of persons and other subjects regarding the processing of personal data, we wish to inform you that the personal data you provide will be processed in compliance with the above-mentioned regulation and the obligations of confidentiality which is required SiWeGO Srl.

Processing and retention method

The processing will be carried out automatically and/or manually, in compliance with the provisions of Article 32 of GDPR 2016/679 on security measures, by specially appointed persons and in accordance with the provisions of Article 29 GDPR 2016/679. Please note that, in accordance with the principles of lawfulness, purpose limitation and data minimization, pursuant to article 5 GDPR 2016/679, subject to your free and explicit consent expressed at the bottom of this statement, your personal data will be kept for the period of time necessary to achieve the purposes for which they were collected and processed. The retention period for personal data relating to the identiˋcation of your clients and their transactions is set at 10 years from the end of the business relationship in accordance with Art. 31 of the D.lgs 21 novembre 2007 n. 231.

Scope of transmission and dissemination

We would also like to inform you that the data collected will never be disseminated and will not be disclosed without your explicit consent, except for necessary communications that may involve the transfer of data to public bodies, consultants or other parties for the fulfilment of legal obligations.

Transfer of personal data

Since the storage of personal data may also take place on servers located in countries outside the European Union, your data will in such cases be transferred to such locations in accordance with the provisions of Articles 44 and followings of the Regulation, as better stated in the Privacy Policy you could refer to. The transfer of personal data outside the European Union ("EU”) is strictly governed by the provisions of Chapter 5 of Regulation (EU) 2016/679 of 27 April 2016 on personal data protection.

Special categories of personal data

Pursuant to articles 9 and 10 of EU Regulation no. 2016/679, you could give SiWeGO Srl data that can be qualified as “special categories of personal data”, that is, data that reveal “racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership , as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the health or sexual life or sexual orientation of the person”. These categories of data may be processed only with your free and explicit consent, expressed in writing at the bottom of this information.

Data subject rights

At any time, you are entitled to exercise, pursuant to Articles 15 to 22 of EU Regulation No. 2016/679, the right to:

obtain confirmation as to the existence of your personal data;
obtain information on the purposes of the processing, the categories of personal data, the recipients or categories the personal data have been or will be disclosed to and, where possible, the storage period;
obtain that your data will be rectified or cancelled;
obtain the processing restriction;
obtain the portability of the data, i.e. receive them from a data controller, in a structured, commonly used and machine-readable format, and transmit them to another data controller without hindrance;
object to the processing at any time, also in the case of processing for direct marketing purposes;
object to automated-decision making concerning individuals, including profiling;
require the data controller access to and rectification or deletion of personal data or restriction of processing concerning him/her or to object to the processing of personal data, in addition to the right to data portability;
withdraw consent at any time without prejudice to the lawfulness of the processing based on the consent given before withdrawal;

j) filing a complaint with a supervisory authority

You can exercise your rights by sending a written request to SiWeGO Srl, at the postal address of its legal office o to the email privacy@siwego.com.

I, the undersigned, declare that I have received the above information.