PRIVACY POLICY
PURPOSES AND METHODS OF PROCESSING OF PERSONAL DATA

The personal data provided by the data subject (the “Data”) will be processed by Free2Move eSolutions S.p.A. (“eSolutions” or the “Company”) for the purposes set out below:
To send newsletters (“Newsletter Service”),
with the consent of the data subject, to send commercial and/or promotional communications about your Company products and services, as well as to conduct market research (“Marketing”);
with the consent of the data subject, to analyse behaviours, habits and propensity to consume, in order to improve products and services provided by the Company, as well as to meet the specific needs of customers (“Profiling”);
with the consent of the data subject, to communicate the Data to subsidiaries or affiliates of the Company, as well as to partner companies thereof belonging to the automotive, financial, insurance and telecommunications sectors, which may process them to send commercial and/or promotional communications on the products and services of the aforementioned companies, as well as to conduct market research (“Third-party Marketing”);
with the consent of the data subject, to communicate the Data to subsidiaries or affiliates of the Company, as well as to partner companies thereof, belonging for example to the automotive, financial, insurance and telecommunications sectors. The said Data may be processed to analyse the behaviours, habits and propensities to consume of the data subject, in order to predict the preferences of the data subject with respect to the products and services of the aforementioned companies (“Third-party profiling”).

The processing of the Data for each of the aforementioned purposes will take place on paper and by automated and telematic means, specifically by post or electronic mail, telephone (e.g. automated calls, SMS, MMS, etc.), facsimile and any other computerised channel (e.g. websites, mobile apps).
CONSEQUENCES OF ANY FAILURE TO PROVIDE DATA
The provision of the Data is optional. However, failure to provide Data marked as mandatory will result in the impossibility of the delivery of the Service.
It will however be possible to provide the Service in the event of failure to provide remaining Data not marked as mandatory.

OTHER SUBJECTS THAT MAY PROCESS THE DATA
The Data may be processed by subjects operating on behalf of the Company and under specific contractual obligations, in Member States of the European Union or non-EU countries.
The Data may be communicated to third parties to fulfil legal obligations, to comply with orders issued by government authorities or to exercise a Company right in court.

TRANSFER OF THE DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)
As part of the Company’s contractual relationships, the Data may be transferred outside the territory of the European Economic Area (EEA), including by means of the addition thereof to databases managed by third-party companies operating on behalf of the Company. The management of databases and the processing of data are restricted to the purposes for which they have been gathered, and take place in the utmost compliance with the applicable law on the protection of personal data.
Whenever data is transferred outside the EEA, the Company will take any appropriate and necessary contractual measures to ensure an adequate level of data protection, including but not limited to agreements based on standard contractual clauses for the transfer of data outside the EEA, as approved by the European Commission.

DATA CONTROLLER
The Data Controller is Free2Move eSolutions S.p.A. (“eSolutions” or the “Company”), with its registered office in Milan at Via Privata Anton Francesco Grazzini, 14 – 20158.
Data subjects may contact the Company via the e-mail address privacy@f2m-esolutions.com.

RETENTION OF THE DATA
The Data processed to provide the Newsletter Service will be retained by the Company for two years from the date of withdrawal from the service. However, the Data processed to provide the Service may be retained for a longer period, in order to handle any disputes related to the provision of the Service.

The Data processed for marketing and profiling purposes will be retained by the Company as of the data subject providing their consent and until the said consent is revoked. In the event that the consent is revoked, the Data can no longer be processed for the aforementioned marketing and profiling purposes but may still be retained in order to handle any disputes and/or litigation. The period of data retention for marketing and profiling purposes provided by the Company complies with local regulations as well as with the measures of the Personal Data Protection Authority.

RIGHTS OF THE DATA SUBJECT
Data subjects are entitled to:

  • a right of access, i.e. the right to obtain confirmation from the Company whether or not the Data is being processed and, in this case, to obtain access thereto;
  • a right of rectification and deletion, i.e. the right to obtain the rectification of inaccurate Data and/or to add to incomplete Data or delete the Data on legitimate grounds;
  • a right to limit the processing, i.e. the right to request the suspension of the processing in the event of legitimate grounds;
  • a right to data portability, i.e. the right to receive the Data in a structured, commonly used and readable format, and the right to transmit the Data to another Data Controller;
  • a right of objection, i.e. the right to object to the processing of data in the event of legitimate grounds, including the processing of the Data for marketing and profiling purposes, where applicable;
  • a right to contact the competent data protection authority in the event of the unlawful processing of the Data.

Data subjects may exercise the rights set out above by writing to the e-mail address privacy@f2m-esolutions.com.
Data subjects may also exercise their rights by contacting the Data Protection Authority – website http://www.garanteprivacy.it.

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