Privacy Policy
INFORMATION ON THE PROCESSING OF PERSONAL DATA: USERS
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PRIVACY POLICY
1. INFORMATION ON THE PROCESSING OF PERSONAL DATA pursuant to EU Regulation no. 679/2016 and Legislative Decree no. 196/2003
Autostrada Pedemontana Lombarda SpA (also "APL"), in compliance with the principles enshrined in EU Regulation no. 679/2016 - General Regulations on the Protection of Personal Data (the "Regulations") and the applicable national legislation (Legislative Decree 196/2003, "Privacy Code"), offers users the opportunity to interact with its portal at www.pedemontana.com corresponding to the home page of the official website of Autostrada Pedemontana Lombarda SpA. In addition to describing how the website and its Reserved Area are managed, this page is intended to inform users of Autostrada Pedemontana Lombarda SpA, in its capacity as Data Controller, about the processing of personal data carried out through the same and the related guarantees recognised by the Regulations and the Privacy Code.
This information is provided exclusively for the website of Autostrada Pedemontana Lombarda SpA and does not extend to processing performed by third parties that may be consulted by users through links. Autostrada Pedemontana Lombarda SpA is not responsible for such further processing, users having to refer to the individual privacy policies of third-party websites.
2. PURPOSE OF PROCESSING
Autostrada Pedemontana Lombarda SpA may collect and process the user's data through the website, for the following purposes:
a) Sending newsletters and communications, including marketing ones, by e-mail to the address provided by the User, regarding services offered by Autostrada Pedemontana Lombarda SpA similar to those already provided to the User. In these cases, the users’ consent is not necessary, and they can object to the processing at any time. In order to allow the user to easily object to the submission, any communication on these services will give the user the possibility to refuse further similar communications.
The legal basis for the processing of the User's personal data for such purposes is represented by the legitimate interest of Autostrada Pedemontana Lombarda SpA in sending the User communications and updates relating to services similar to those used by the User, pursuant to recital 47 of the Regulation.
b) with the user's consent, for marketing activities through newsletters, invitations to surveys and market research, the sending of promotional material and commercial communications on services and/or offers from Autostrada Pedemontana Lombarda SpA, including co-marketing initiatives concerning the joint offer of services from Autostrada Pedemontana Lombarda SpA and its commercial partners (operating in sectors related to and connected with toll collection services). These communications will be sent using both automated and non-automated methods (e.g. email, sms, ordinary mail, etc.). Consent will be requested at the bottom of the registration forms and may be revoked at any time, even partially; to this end, communications sent by email will give the user the option of refusing further mailings. Consent is optional, failure to provide it will preclude the user from receiving communications, invitations, promotions or offers from Autostrada Pedemontana Lombarda SpA, without prejudice to the possibility of using the services and functions accessible through the website.
In this case, the legal basis for the processing of the User's personal data is represented by his or her express, free and optional consent - which will be requested at the bottom of the relevant data collection form - which the User may revoke at any time, as indicated above, without, however, affecting the possibility of using the services offered by the website and by Autostrada Pedemontana Lombarda SpA.
c) Pursuit of the legitimate interests of Autostrada Pedemontana Lombarda SpA and/or third parties (e.g. the right of defence in court, the correct billing and charging of payments, the management of complaints and litigation, any judicial and extrajudicial debt recovery, the prevention of fraud and/or illegal activities), which in the opinion of the Data Controller do not prevail over the fundamental rights and freedoms of the User and which represent the legal basis of the processing.
d) Purposes connected with the fulfilment of legal obligations, regulations, national and Community rules as well as deriving from provisions issued by legitimated authorities, which constitute the legal basis for the processing.
3. PLACE AND MANNER OF PROCESSING
Processing related to the website and web services of the Reserved Area is carried out at the head office of Autostrada Pedemontana Lombarda SpA as well as at external subjects, provider and site manager, appointed as Data Processors, and is carried out, for the time strictly necessary to achieve the purposes, also through the use of automated tools observing the security measures aimed at preventing the loss of data, illicit or incorrect use and unauthorised access.
The data are processed by Company staff authorised to process them or by external parties charged with occasional maintenance operations, which will ensure data processing is correct, lawful, transparent, relevant and not excessive with respect to the purposes of collection and subsequent processing.
4.TYPE AND NATURE OF DATA PROCESSED
Autostrada Pedemontana Lombarda SpA receives and collects, via its website www.pedemontana.com and via the "pedemontana lombarda" mobile application, information relating to users who visit the pages of the website and use the web services available in the Reserved Area of the site and the services available on the mobile application. In particular, Autostrada Pedemontana Lombarda SpA acquires and processes the following information.
Browsing data
Access to the website involves the collection of data used solely for the purpose of obtaining statistical information or ensuring proper functioning.
The data collected include the IP addresses and/or domain names of the computers used by users connecting to the website, the URI (Uniform Resource Identifier) notation 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.
This data is not collected for the purpose of associating it with identified persons; however, it could enable users to be identified through processing and association with data held by third parties, especially when it is necessary to ascertain liability in the event of hypothetical computer crimes to the detriment of the website.
The data are used to obtain anonymous statistical information on the use of the website and check its correct operation, and are kept for the time necessary to carry out analysis and comparative statistical processing activities, in pursuit of the legitimate interests of Autostrada Pedemontana Lombarda SpA.
Data voluntarily provided by the user or acquired by the Company
Autostrada Pedemontana Lombarda SpA limits the collection of information relating to users exclusively in relation to the pursuit of the purposes set out in paragraph 2 above and the services expressly requested such as:
a) Payment of reminders: in order to pay the reminders for the expired tolls, the user can use the special web service that only requires the provision of the reminder number. After entering the aforementioned number, payment of the reminder can be made by credit card. Alternatively, the user can use the web payment method that requires the provision of the following personal data: email address and password. At the time of registration, the user shall read the Privacy Policy and optionally express consent to marketing activities. After registering, the user may proceed with the payment of the reminders for tolls that have already expired, after providing the reminder number, by credit card. For both payment methods described above, the credit card details are stored on a special portal operated by the provider bank and are not known to APL. The payment process is handled by the financial institutions.
b) Sending of newsletters, surveys and market research, informative and marketing material: both when the user registers on the website and when he/she registers for the Conto Targa Service, the user may freely express his/her consent, by selecting the appropriate boxes, to the use of his/her personal and contact data for the purposes of sending informative and marketing communications by Autostrada Pedemontana Lombarda SpA as illustrated in paragraph 2, letter e above. The provision of such consent by the user is entirely optional and will not preclude the registration to the website or the possibility of using the services offered by the Company.
c) Other data provided voluntarily by the user: as part of the services offered by the website, the user may provide Autostrada Pedemontana Lombarda SpA with other data, in addition to those indicated for the above purposes, in order to receive further information and services (e.g. requesting information, sending notices of "non-payment toll reports" as well as complaints and toll and reminders, reporting inefficiencies or malfunctions, etc.). Such data will be processed by Autostrada Pedemontana Lombarda SpA solely for the purposes strictly related to the user's request or communication. Failure to provide them may result in the impossibility of obtaining the requested service.
5. COOKIES
A cookie is a small text string that a website sends to your browser and saves on your computer when you visit a website. Cookies are used by Autostrada Pedemontana Lombarda SpA to operate the website or to improve its performance, but also to provide information about the website or the users' browsing. As a general rule, the website uses cookies both for technical and additional purposes: while technical cookies are used because they are strictly necessary for the technical operation of the site as well as to provide the service expressly requested by users (e.g. authentication, language setting, etc.), cookies for additional purposes (e.g. analytical cookies) are used to analyse users’ behaviours in order to improve its contents.
Technical Cookies
Technical cookies are essential to allow the user to move around the website and to use its functions, such as accessing the Reserved Area (e.g. registration, authentication). These cookies are strictly necessary and are used to store a unique identifier in order to manage and identify the user as unique with respect to other users who are visiting the website at that time, so as to provide the user with a consistent and precise service. In addition, these cookies allow the website to remember user choices (e.g. user name, language, country of origin, etc.), to distribute requests across multiple servers, to store when the user gives their consent to certain options (e.g. by accepting the use of certain cookies by passing the information banner), to allow the user to view content and videos via Adobe Flash Player.
Analytical Cookies
These cookies may be session or persistent, installed by the website or by third parties such as WAI (Web Analitics Italia), and their use is limited to the performance and improvement of the website. These cookies collect aggregate statistics on how users surf the website, such as the most visited pages. In addition, analytical cookies allow the number of visitors to the website, thus allowing the website to be improved and refined, for example by establishing whether users can easily find the information they want, or identifying which aspects of the website are of most interest. These cookies are used by Autostrada Pedemontana Lombarda SpA to perform statistical and aggregate analyses of how users navigate the website, the number of pages visited or the number of clicks made, anonymously by adopting mechanisms to mask the users' IP address and without WAI (Web Analitics Italia) being able to cross-reference this information with others in its possession in order to identify users.
Disabling cookies via the browser
If you wish, you may delete cookies placed by the website through your browser settings.
Most browsers are set to accept cookies. However, you can configure your browser to restrict the number of cookies accepted or block all cookies by changing your browser settings as follows:
Microsoft Internet Explorer
Click the “Tools” icon in the top right-hand corner and select 'Internet Options'. In the pop-up window, select “Privacy”. Here the user can change the cookie settings.
Google Chrome
Click the “spanner” icon in the top right corner and select “Settings”. Then select “Show advanced settings” and change the “Privacy” settings.
Mozilla Firefox
From the drop-down menu in the top left corner, select “Options”. In the pop-up window select 'Privacy'. Here the user can adjust the cookie settings.
Safari
From the drop-down setting menu in the top right-hand corner, select “Preferences”. Select “Security” and here the user can adjust the cookie settings.
However, it should be noted that disabling the use of all cookies on the website will compromise certain functions (e.g. authentication possibilities).
More information on cookies
The website www.allaboutcookies.org contains instructions on how to manage cookies on the most popular browsers; alternatively, you can consult the documentation attached to the software used on your device.
6. DATA COMMUNICATION
The data provided by the users as well as those collected by the site as part of its services (e.g. IP address) will not be disclosed and may be communicated by Autostrada Pedemontana Lombarda SpA, even abroad in non-EU countries, exclusively for the purposes and methods described above, to the categories of subjects indicated below:
a. collaborators, consultants or freelancers that Autostrada Pedemontana Lombarda SpA employs to perform technical or organisational tasks (such as suppliers of IT services such as Autostrade per L'Italia S.p.A. for website management and maintenance), or with which Autostrada Pedemontana Lombarda SpA collaborates, for the purposes of providing and operating its services and activities;
b. persons, companies or professional firms providing assistance and consultancy to Autostrada Pedemontana Lombarda SpA, with particular but not exclusive reference to accounting, administrative, legal, tax and financial matters, as well as services relating to toll collection;
c. associated companies, for administrative-accounting purposes and for the service purposes described in paragraph 2 above;
d. subjects whose right to access the data is recognised by law or by orders of the authorities.
The subjects belonging to the above--mentioned categories will use the data as autonomous data controllers according to the law or as data processors regularly appointed by Autostrada Pedemontana Lombarda SpA. The names of the subjects to whom the data are or may be communicated may be requested from Autostrada Pedemontana Lombarda SpA by contacting the addresses indicated in the section "RIGHTS OF THE DATA SUBJECT".
7. DATA RETENTION
Data are processed for the time necessary to provide the services requested by the User and to perform the related activities, as illustrated in paragraph 2 above, and are deleted when the purposes for which they were collected and processed no longer apply. Finally, data collected for marketing purposes will be kept until the User unsubscribes, after which they may be kept anonymously for analysis and statistical purposes.
8. RIGHTS OF THE DATA SUBJECT
By contacting the Data Controller Autostrada Pedemontana Lombarda SpA, data subjects (subjects to whom the data refer) may exercise the rights listed in Articles 15 to 21 of the Regulation at any time, and in particular:
- to obtain confirmation that personal data are being processed and, if so, to ask the Data Controller to access information relating to such processing (e.g. purposes, categories of data processed, recipients or categories of recipients of the data, storage period, etc.);
- to request the correction of inaccurate or incomplete data;
- to ask the data controller to delete the data (e.g. if the personal data are no longer necessary for the purposes for which they were collected, if the consent on which the processing is based is withdrawn, etc.)
- to request the restriction of processing (e.g. if the User disputes the accuracy of the data; if the processing is unlawful and the User objects to the deletion of the personal data; if the data are necessary for the exercise or defence in court of a right of the User, even if the Controller no longer needs them; if the User exercises the right to object, for the time necessary to verify the existence of legitimate reasons).
- to receive in a commonly used and machine-readable format (e.g. pdf) personal data concerning the User and to transmit them to another data controller, or to obtain direct transmission from one data controller to another, if technically feasible (so-called data portability).
The User also has the right to oppose the processing of personal data concerning him/her, in whole or in part, for legitimate reasons, as well as the right to oppose, even in part with respect to the various means of communication, the processing of personal data for the purposes of commercial information, marketing advertising or market research by Autostrada Pedemontana Lombarda SpA.
These rights may be exercised directly by Users by contacting Autostrada Pedemontana Lombarda SpA, with registered office at Via Pola 12-14, 20124 Milan (MI), or by contacting the following email address privacy@pedemontana.com.
Finally, if the User considers that the processing of the data provided violates data protection legislation, he/she has the right to lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it).
9. CHANGES TO THE PRIVACY POLICY
Autostrada Pedemontana Lombarda SpA reserves the right to make changes to this Privacy Policy at any time, giving notice by publication on the website. Users are invited to check the website for any updates.
If the changes are particularly significant and/or have a major impact on users' rights, Autostrada Pedemontana Lombarda SpA may also communicate them by different means (e.g. email).
Data controller
The Data Controller of the personal data processed through the website is Autostrada Pedemontana Lombarda SpA, with registered office in Via Pola 12-14, 20124 Milan (MI).
Data Protection Officer
The Data Protection Officer ('DPO') is Mr. Matteo Colombo, tel. 0267741550, email dpo@pedemontana.com.