This policy describes the ways in which our company Qooder SA processes your personal data in relation to browsing on this website (the "Website") to inform you about which personal data are collected how they are used which third parties may have access to such data and how you can exercise your rights regarding this processing.
The processing takes place in full compliance with the Swiss Federal Data Protection Act ("LPD") and with EU Regulation 2016/679 - "Regulation on the protection of individuals with regard to the processing of personal data and the free circulation of such data "(the "Regulation").
Data Controller representative of the Data Controller and data processors
The data controller is Qooder SA with registered office in Vacallo (Switzerland) Via dei Lauri 4 in the person of the legal representatives pro tempore e-mail: firstname.lastname@example.org (the "Controller").
Pursuant to art. 27 of the Regulation we have appointed as the representative established in the EU territory for the purposes of applying the regulations on the processing of personal data Qooder Italia S.r.l. with registered office in Como Via Volta 66 Tax Code VAT number and listing number in the Como Companies Register no. 03434900134. The representative can be contacted at email@example.com.
Some external subjects (natural and legal persons) have also been appointed as data processors who provide specific services or related instrumental or support activities additional to those we provide the complete list of which can be consulted by sending a specific request to firstname.lastname@example.org.
Source of personal data
Personal data is collected directly from you.
Categories of data processed
When you browse the Website some of your personal data are processed:
When you browse the Website the Data Controller receives and collects the identification of the navigation tool the IP address the operating system used and the name of the ISP (Internet Service Provider) of the device itself and the pages visited. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation.
The data could be used to ascertain responsibility in the event of computer crimes: except for this possibility the data are currently not stored for more than 7 days.
In case of the sending of communications through the appropriate form or registration on the Website which allows access to specific areas of the same you will need to provide some personal data (e.g.: first name and surname e-mail).
Furthermore any sending of communications through the Website involves the acquisition of the e-mail address and any additional personal data that you indicate which we may use for our communications with you.
Purpose and legal basis of the processing
The data is processed for the following purposes:
a) Website operation. Legal basis: our legitimate interest;
b) possible access to specific functions of the Website. Legal basis: your consent;
c) management and execution of the contractual relationship and/or the adoption of pre-contractual measures if required (for example: the acquisition of preliminary information for the conclusion of a contract; the execution of operations on the basis of the obligations deriving from the contract concluded with the customer or supplier; etc.). Legal basis: execution of a contract of which you are a party or of pre-contractual measures taken at your request;
d) fulfilment of the obligations established by laws or regulations including accounting tax and administrative ones as well as by provisions issued by authorities legitimated by the law and possibly by supervisory and control bodies. Legal basis: fulfilment of a legal obligation;
e) subject to your consent for commercial promotional and other marketing purposes including the promotion and sale of our products and services carried out through letters telephone advertising material automated communication systems etc.; the sending of informative material as well as ascertaining of the degree of customer satisfaction with the quality of the services provided and the activity carried out and the performing of market surveys (through personal or telephone interviews questionnaires etc..). Legal basis: your consent;
f) subject to your consent profiling activities aimed at improving the services offered according to the needs of customers and in order to obtain information on commercial behaviour and habits in the automotive and financial sector. The profiling activity concerning individuals or groups could be carried out through the processing of customer identification data through a relationship between the data that are used to identify the data subjects and the analytical indications relating to their personal sphere (behaviours habits and propensities to consumption);
g) upon your specific request to provide the "Newsletter" service through a mailing list. Legal basis: your consent.
Personal data are processed lawfully correctly and transparently according to the methods and for the purposes indicated above.
Data retention period
The retention period of personal data:
- for the purposes referred to in section a) of the previous paragraph it is equal to the duration of the browsing session on the Website and in any case for no more than 7 days (except to ascertain responsibility in the event of computer crimes).After this deadline personal data will be destroyed deleted or made anonymous (if not already collected anonymously);
- for the purposes referred to in section b) it is equal to the period necessary to execute the specific functionality of the Website requested;
- for the purposes referred to in section c) it is equal to the period of completion of the contract and subsequently for the time in which we are subject to retention obligations for fiscal or administrative purposes or as otherwise required by law. Therefore after the definition of the contractual relationship the data will be stored in accordance with the ordinary limitation period equal to 10 years (unless in this case a shorter limitation period is applied);
- for the purposes referred to in section d) it is equal to that established by law. The data will therefore be kept for the period of execution of the contract and after the termination of the contractual relationship in accordance with the provisions of the law (10 years);
- for the purposes referred to in section e) it is equal to no more than 24 months for those persons concerned who are already our customers and no more than 12 months for potential customers
- for the purposes referred to in section f) it is equal to and not more than 12 months;
- for the purposes referred to in section g) it is equal to the entire duration of the "Newsletter" service until the time you unsubscribe from the service itself.
In the case of judicial litigation personal data will be kept for the entire duration of the same until the expiry of the terms to promote any appeals.
Nature of the provision of data and consequences of refusal to provide it
The provision of data can be mandatory or optional.
In relation to the purpose referred to in section a) of the paragraph "Purpose and legal basis of the processing" the provision of data is mandatory. The related processing does not require your consent as it is based on our legitimate interest.
In relation to the purpose referred to in section b) the provision of data is not mandatory but it is necessary to have access to the specific functionality of the Website requested from time to time. Failure to provide the data would make it impossible to have access to this specific functionality. Its processing requires your consent.
In relation to the purpose referred to in section c) the provision of data is not mandatory but it is strictly necessary for the purpose of carrying out pre-contractual and/or contractual activities. Any refusal to provide such data would make it impossible for us to carry out the same contractual relationships and legal obligations. Its processing does not require your consent.
In relation to the purpose referred to in section d) the provision of data is mandatory. Failure to provide the data would make it impossible to proceed with any contractual relationships. Its processing does not require your consent.
Otherwise the provision of data for the purposes referred to in sections e) and f) is optional and failure to release them does not entail any consequences regarding access to the Website but will not allow us to carry out further statistical commercial or profiling activities. This processing requires your prior consent; in any case you can interrupt the processing at any time by requesting deletion of the data by writing to email@example.com.
With reference to the purpose referred to in section g) the provision of personal data is always optional; however failure to provide the data will prevent provision of the "Newsletter" service. The processing of data by us for this purpose requires your prior consent. In any case you can interrupt the processing at any time by requesting deletion of the data using the appropriate "unsubscribe" function contained in each newsletter.
Special categories of data
In relation to specific obligations the data subject could provide particular categories of data such as personal data suitable for detecting the state of health as well as biometric data intended to uniquely identify a natural person. For the processing of such data the explicit consent of the data subject is required expressed in writing. In any case the data will always be used within the limits of the execution of specific services requested and in the absence of consent we will not be able to provide the requested service.
Personal data processing method
The processing will consist of any operation or set of operations carried out with or without the aid of automated processes and applied to personal data or sets of personal data such as the collection recording organisation structuring storage adaptation or modification extraction consultation use communication by transmission or any other form of making available comparison or interconnection limitation deletion or destruction.
In relation to the purposes indicated the processing of personal data takes place using manual IT and electronic tools with logic strictly related to the purposes themselves and in any case in order to guarantee the security and confidentiality of the data.
We guarantee that the security and confidentiality of personal data will be protected by adequate security measures in accordance with the provisions of the LPD and the Regulations in order to reduce the risk of destruction or loss even accidental of data of unauthorised access or processing that is not permitted or does not comply with the purposes of the collection. In any case we assume no responsibility for the data transmitted via Internet. Similarly any and all our liability in the event of opening links or other web pages connected to the Website is excluded.
The data processing will be carried out in compliance with the principle of strict necessity. Therefore the processing will be reduced to a minimum and in such a way as to exclude it when the purposes pursued in individual cases can be achieved through the use of anonymous data.
Scope of communication and dissemination of personal data
The data are processed by the designated personnel who need to have knowledge of them in the execution of their activities duly appointed as the subject authorised for processing by the Data Controller or by external managers. The data may also be communicated or transferred to the Controller's subsidiaries parent companies or associates including abroad as well as to our sales and service network.
Furthermore in carrying out our business for the execution of contractual or legal obligations or to fulfil your specific requests we may communicate your personal data to subjects whose intervention is strictly functional to the execution of the contractual relationship.
To carry out the activities indicated above we can therefore communicate personal data to the following subjects or categories of subjects:
- banking institutions (in the cases envisaged) for the management of collections and payments;
- subjects who carry out activities connected and instrumental to the execution of the contractual relationship (for example: service providers and technical assistance; delivery of products; transmission enveloping transportation and sorting of communications to customers or suppliers; archiving services of documentation relating to relationships with customers or suppliers);
- public administrations and third parties in fulfilment of legal obligations.
Your consent is not required for this type of communication as the processing is aimed at fulfilling the contractual relationship or at complying with legal or regulatory obligations.
The subjects listed operate in some cases as external data processors appointed for this purpose and in other cases as independent data controllers issuing in this case a specific policy. Should you wish to know in detail the subjects to whom the data may be communicated you can write to firstname.lastname@example.org.
In no case will personal data be disclosed by us.
Transfer of data abroad
Personal data may be transferred outside Switzerland or to countries outside the European Union provided that the European Commission has established that these countries outside the European Union guarantee an adequate level of protection for the data being transferred or by providing suitable and appropriate protection measures to protect personal data and the transfer of the same in accordance with the applicable laws such as for example the adoption of standard contractual clauses adopted by the European Commission pursuant to art. 45 and 46 of the Regulation.
Social plug-ins of third parties
The Website may use social plug-ins provided and managed by third parties such as Facebook.
As a result of this you may send these third parties the information you are viewing on a certain part of the Website. If you are not logged into your account with these third parties they cannot know your identity. Otherwise the latter may be able to link the information relating to your visit to the Website to your account. Similarly your interactions with the social plug-ins could be recorded by the latter.
Rights of the data subject
You can ask us at any time about the following:
- confirmation as to whether or not personal data concerning you is being processed and in this case to obtain access to the following information:(i) the purposes of the processing (ii) the categories of personal data processed (iii) the recipients or categories of recipients to whom the personal data have been or will be communicated in particular if recipients of third countries or international organisations (iv) whenever possible the retention period of the personal data provided or if not possible the criteria used to determine the period (v) the existence of an automated decision-making process including profiling the logic used the importance and consequences expected (right of access);
- the correction of inaccurate personal data or the integration of incomplete data (right of correction);
- the deletion of personal data in the event of (i) revocation of the consent on which the processing is based in the absence of a different legal basis that allows the processing itself by us; (ii) objection to the processing in the absence of any other legitimate prevailing reason to proceed with the processing itself; (iii) unlawful processing; (iv) fulfilment of a legal obligation; except in cases where the processing is necessary for exercising of the right to freedom of expression and information for the fulfilment of a legal obligation for reasons of public interest in the health sector for statistical purposes for archiving in the public interest scientific or historical research or for the ascertaining exercise or defence of a right in court (right to be forgotten);
- the limitation of the processing of personal data (right of limitation).
Furthermore you have the right to:
- receive in a structured format commonly used and readable by an automatic device the personal data provided and transmit such data to another owner without impediments on our part if the processing is based on consent and is carried out by electronic means (right to portability);
- object to the processing including the related profiling possibly based on our legitimate interest if the data are processed for the purpose of direct marketing (right to object);
- withdraw consent to the processing at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation;
- submit complaints to the competent supervisory authorities if you believe that the processing violates the privacy law.
To exercise your rights as well as for any information you can write to email@example.com. Furthermore if you are in the EU territory and the processing activities concern the offer of goods or the provision of services you can also contact the representative of the Data Controller. in the EU at the addresses indicated above.
We reserve the right to update this information. Any changes will be communicated to users on the home page of the Website as soon as they are adopted and will be binding upon its publication.
If you do not intend to accept the changes made you will have to stop using the Website and you can ask us to delete your personal data. Unless otherwise specified the previous information will continue to apply to personal data collected up to that time.