This is a general document that gives information about the correct processing of personal data carried out on or through the Website. Users can find a detailed explanation of such criteria in the Disclosures published - pursuant to Article 13 of Legislative Decree No. 196 of 30 June 2003 (hereinafter “Privacy Code”) - in the various sections of the Website designed to specify the methods and purposes of processing linked to specific services and/or various kinds of information.
1) Data Processing Controller (Article 28 of the Privacy Code)
Data on persons identified or identifiable may be processed as a result of consulting this Website.
The Data Processing Controller is LeasePlan Italia S.p.A., with offices in Rome, Viale Alessandro Marchetti 105 - postcode 00148, email: firstname.lastname@example.org.
2) Place where personal data is processed
Processing relating to Internet services on this Website take place at the above offices of LeasePlan Italia S.p.A. and/or at the headquarters of the Company’s electronic communications service providers and data are only handled by technical staff specially appointed as persons in charge of processing pursuant to Article 30 of the Privacy Code, or by other persons in charge of occasional maintenance operations.
The disclosure and possible dissemination of personal data only takes place in accordance with the provisions of the Privacy Code: with the consent of the data subjects or, more generally, without their consent, according to the rules contained in Articles 24 and 25 of the Code.
Categories and types of personal data being processed.
3) Navigation Data
The computer systems and software procedures used for the operation of the Website, during normal operations, acquire some personal data whose forwarding is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified data subjects, but by its very nature it could, through processing and associations with data held by third parties, lead to the identification of users.
This category of data includes IP addresses or domain names of computers used by users that connect to the Website, URIs (Uniform Resource Identifier) of requested resources, the time of request, method used to submit the request to the server, size of the file obtained in reply, numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters regarding the operating system and IT environment of the user.
The data are only used to obtain anonymous statistical information on the use of the Website and to check its correct operation and are immediately deleted after processing. The data could be used to ascertain responsibilities in case of hypothetical IT crimes committed against the Website. Except for such eventuality, currently data on web contacts are not stored permanently, except in case of any the user requests (e.g. access to one’s pages on the Website that summarize the services used, information requested, etc.).
5) Data provided voluntarily by the User
The optional, explicit and voluntary sending of email messages to the addresses listed on the Website will result in the subsequent acquisition of the sender’s address, necessary to reply to any requests, as well as any other personal data included in the message.
Specific summary information will be reported or displayed in due time on Website pages dedicated to particular services on request.
6) Sensitive Data
LeasePlan Italia Spa does not request or collect sensitive personal data through the Website (such as information that could reveal racial or ethnic origin, political, philosophical or religious beliefs, sexual habits or health data). Otherwise, the prior written consent or equivalent statement will be required to the user.
7) Providing data is optional
Apart from what is specified above in regard of navigation data, the user is always free to provide personal data for the purposes with which he/she connects to the Website (e.g. request for information by filling out forms, registration for particular services, purchase of goods or services, etc.). However, failing to provide some data may in some cases make it impossible for the Company to fulfill the request.
8) Purpose of Processing
LeasePlan Italia Spa collects and processes the personal data of customers and users of the Website to carry out its activities and business by making available information, products and services that may be of interest to the User and for the purpose of statistical surveys on the use of the same Website. The information provided by users may be used to contact them when necessary, e.g. to notify changes in the features of the Website or communicate service offerings (with their prior consent, as appropriate) that may be of interest to them.
Pursuant to Article 24 , paragraph 1, lett . b) of the Privacy Code, such data may be processed without the need to obtain the prior consent of the User in all cases where the processing is necessary to fulfill requests made directly from the User (as in the case of a request for a quote through the special form of our Site ) .
The processing of personal data for commercial or marketing purposes will be based on the acquisition of their prior specific consent. The related communications will be sent either through automated (such as email , SMS , MMS , fax, pre - recorded phone calls ) or traditional means (such as paper mail and phone calls with operator). Given that the consent possibly given by the User to be contacted for advertising and marketing purposes through automated means also extends to the traditional ones, the User can at any time contact us to the email address further indicated to exercise the right to object, even only partially , with reference to each of the modalities just specified.
9) Secondary profiling purposes
The processing of personal data for profiling purposes will be based on the acquisition of a prior specific consent from the user. With the prior consent of the user, relevant data and non-excessive data on individuals may be collected and stored for profiling purposes or in order to improve the services being offered according to the users’ needs and derive information on their behavior and habits in the field of long-term rental.
Profiling may relate to “individual” personal data. Such processing can be carried out by using personal data that are also aggregated according to predefined parameters depending on business needs and may include the collection of information on the opening of emails and links contained in them sent by LeasePlan Italia Spa to the user in order to measure the effectiveness of our email messages and assign specific scores to users including to improve the match between the email messages and the actual tastes / preferences of the users themselves.
The provision of personal data for the purposes outlined above is optional and failure to provide them will not determine consequences other than the impossibility for LeasePlan Italia Spa to proceed to the aforementioned profiling.
Even in case the user has provided consent to authorize LeasePlan Italia Spa to pursue profiling purposes, the same will remain free at any time to withdraw it by sending a specific notice to the following e-mail address email@example.com.
Any data processed for profiling purposes will be stored in an appropriate manner to minimize data dissemination to what is strictly necessary, restricting to a minimum the number of working staff with possible access to the information.
10) Processing Method
Personal data are processed by automated tools for the time strictly necessary to achieve the purposes for which they were collected.
Specific security measures are observed to prevent the loss of data, illegal or incorrect use and unauthorized access.
11) Rights of Data Subjects
The persons to whom the personal data belong will at all times have the right to obtain confirmation of the existence or otherwise of such data and to know the content and origin thereof, verify their accuracy or request their supplementation or updating, or correction (Article 7 of the Privacy Code).
Pursuant to the same Article, Users will have the right to request the cancellation, transformation into anonymous form or blocking of data processed unlawfully, and in any case to object to their processing for legitimate reasons.
Requests should be addressed to the Data Controller, without specific formalities, by sending an email to: firstname.lastname@example.org.
Last update: September 2016