PRIVACY POLICY

The following Privacy Policy (the “Policy”) – according to article 13 of General European Regulation on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (hereinafter referred to as “GDPR”) aims to describe how the personal data of web site users are processed and collected by browsing or using the website https://esolutions.free2move.com(the “Web Site”).

Please read this Policy carefully before using this website because it explains how we will process personal data (the “Data”). Using this website indicates that you accept this Policy.

Free2Move eSolutions S.p.A. (hereinafter “eSolutions” or the “Company”) with its registered office in Milan, Via Privata Anton Francesco Grazzini, 14 – 20158 is Data Controller of the user personal data gathered during the browsing activity on the Web Site.

1-PERSONAL DATA PROCESSED

We care about your privacy. We collect and process various types of Data via this website.
This includes:
a) Information you provide to us when requesting and using our services and our website, such as e-mail address
b) Information that we need when you report a problem with our website

  • (browsing data like e.g. IP address, location – country -, information on pages visited by the user within the website, access time on the website, navigation time on each page, clickstream analysis. While Company does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information or by using other information collected);
    Information collected with cookies. Please refer to the website Cookie Policy for details.

Personal Data voluntary processed by the user

c) The optional, explicit and voluntary compilation and forwarding of the forms on the Website, entail the acquisition of the sender’s name, surname, cell phone, country of residence, email address, as well as the additional personal data included in the requests you forwarded, in the forms included in the footer and in the “Contacts” section of the Web Site.

2- INFORMATION ABOUT THE PROCESSING OF PERSONAL DATA
Your Data will be processed to administrate and fulfil your request and for general administration purposes by Company as a controller under the applicable data protection legislation, as follow:

Data / Data Categories Purposes Legal Basis
Respective identification and contact details if applicable (name, surname, cell phone, country of residence, company, email address*)
  • Contacting, communication and request fulfilment
  • Newsletter un-/subscription
Purposes related to the performance of a contract or related to steps at the request of the data subject prior to entering into a contract according to Art. 6 (1) 1 b) General Data Protection Regulation (GDPR)
Information collected via cookies Please see Cookies Policy for detailed information Purposes for which you have provided consent according to Art. 6 (1) 1 a) GDPR unless you have exercised your right to withdraw consent (Art. 7 (3) GDPR)

The Data elements marked with an asterisk (*) are mandatory and a contractual requirement. You are therefore obliged to provide the Data. In case you do not provide the Data, we cannot fulfil your request.
The Data may be processed in hardcopy, by automated or electronic means.

3 – HOW TO PROCESS THE PERSONAL DATA

The data processing carries out with information system and organizational and logical methods strictly related to indicated purposes and are implemented all technical and procedure security measures to ensure the confidentiality, integrity, availability and resilience of data processing, in compliance with the article 32 of GDPR.

The personal data could be transferred to abroad, outside the EU also, in comply with the applicable law.

4 – DATA TRANSFER OUTSIDE OF THE EEA

Within its contractual relations Company may transfer the Data in countries outside of the European Economic Area (EEA), including store them in databases managed by entities acting on behalf of Data Controller. Databases management and Data processing are bound to the purposes of the processing, mentioned above and are carried out according to GDPR and – if applicable – local data protection law.

In case the Data are transferred outside of the EEA, Company will use any appropriate contractual measures to guarantee an adequate protection of the Data including – among the others – agreements based on the standard contractual clauses adopted by the EU Commission, and where required additional measures, to rule the transfer of Data outside of the EEA.

To receive information about our mentioned safeguards and to obtain a copy of respective safeguards please contact us via e-mail privacy-esolutions@f2m-esolutions.com.

5- COMMUNICATION OF PERSONAL DATA

Company could authorize internal or external parties to perform the data processing. The internal parties are “people in charge of data processing” involved in the business organization like as administrative, commercial and marketing staff, legal department, system administrator etc; while external parties act as “data processors” and must be appointed as such by Company. The Data Processor could be transferred the personal data to:

  • technical service suppliers
  • postal carriers
  • hosting providers
  • information technology companies
  • communication agencies

In particular, we disclose your personal data for the below listed purposes to the following recipients:

Data Purposes Recipients
Email address, contact details if provided
  • Administration newsletter
  • Contacting communication and request fulfilment.
Your Data will be disclosed to the following companies and also to their respective Information Technology- service providers to support the administration of the named purposes:
– FCA ITALY S.p.A. – c.so Agnelli, 200 – 10135 Torino, Italy
– ENGIE EPS Italia S.r.l. – Via Anton Francesco Grazzini, 14 – 20158 Milano, Italy
– MailUp S.p.A. – via Pola, 9 – 20124 Milano, Italy
– DigitHub Italia S.r.l. – Corso Monforte, 41 – 20122 Milano, Italy
We disclose your Data to the respective Stellantis Group Companies and ENGIE EPS Group Companies if it is necessary to fulfil your request.
Information collected via cookies Please see Cookies Policy for detailed information Purposes for which you have provided consent according to Art. 6 (1) 1 a) GDPR unless you have exercised your right to withdraw consent (Art. 7 (3) GDPR)

The Data may be disclosed to third parties to comply with legal obligations, to execute Public Authorities orders or to exercise a Company right before judicial authorities.

6 – DATA SUBJECTS RIGHTS

Data Controller shall provide the data subjects the exercise of the following privacy rights:

  • confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data, ae required by 15 article of GDPR (Right of access);
  • rectification of inaccurate personal data concerning him or her or integration of him or her incomplete personal data (Right to rectification);
  • erasure of personal data concerning him or her, in accordance with the reasons described in article 17 of GDPR (Right to be forgotten);
  • restriction of processing, when one or more of the cases provided by the article 18 of GDPR (Right to restriction);
  • receive the personal data concerning him or her, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller (Right to data portability)

Moreover, the user has the right to make opt-out of consent of data processing, anytime, without prejudice to
the lawfulness of the processing based on the consent given before the opt-out.

To exercise your rights, you can send an email with the following subject “PRIVACY”, to privacy-esolutions@f2m-esolutions.com.
The data subject can claim Privacy Authority, when he believes the data processing is carried out in violation of the Regulation. Further information is available on the website http://www.garanteprivacy.it.

7 – LINKS TO THIRD PARTY WEBSITES
Third party websites accessible from this website are under the third party responsibility. Company declines all responsibility concerning requests and/or provision of Data to third party websites.
This website can also contain iFrames with content of third parties. Company is not responsible for third-party content presented in iFrames. The information presented therein is the sole responsibility of those website owners.
Company has no control or responsibility for the content of independent websites and provides this external content to its visitors for their convenience. As a result, when you visit a page containing such content, you may be presented with cookies from these third party websites.
Company does not control the distribution of these cookies.
Please check the third party’s cookies policy and privacy policy for more information.

8 – LINKS TO SOCIAL NETWORKS
Our website includes links to social networks.
In order to protect your Data while visiting our website we do not use social plugins. Instead HTML-links are embedded onto the website, enabling easy sharing onto social media platforms. Embedding the link prevents a direct connection with various social media network servers when opening a page from our website. When clicking on one of the buttons, a browser window opens and directs the user to the respective service provider website on which (after having logged in) for example, the “Like” or “Share” button can be used.
For more information on the purpose and scope of data processing and further use of your Data by the provider and their websites as well as your rights and possible settings to protect your privacy, please refer to the data protection information of the respective service provider.

9 – DATA RETENTION
Your Data will be stored until you unsubscribe to the service. Your Data will be stored for two years after the unsubscription request has been fulfilled and then will be deleted.

10 – AMENDMENTS
Company reserves the right to partly or fully amend the Privacy Policy, or simply to update its content (e.g. as a result of changes in applicable law). We will publish any update on this website. You should therefore periodically review these for changes to our Privacy Policy.

11 – CONTACTING US
Free2Move eSolutions S.p.A. – Via Privata Anton Francesco Grazzini, 14 – 20158, Milan – Italy.

You can contact the Company writing to the following email address privacy-esolutions@f2m-esolutions.com.

3 May 2021

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