PURPOSE AND PROCEDURE FOR THE PROCESSING OF PERSONAL DATA

The personal data you have provided (“Data”) will be processed for the following purposes:

a)   allowing Triboo Digitale Srl to manage the services offered by the website, to fulfil orders and activities connected to them, including transactions relating to administrative and tax obligations, to answer questions via the contact form and to manage any returned products;

b)   allowing FCA Italy S.p.A. to complete the registration process to the website;

c)   subject to your express consent, sending commercial communications as well as sending advertising on FCA Italy S.p.A. products and services, or performing market researches (“Marketing”);

d)   subject to your express consent, analyzing your behaviors, habits and propensity to consume to enhance products and services provided by FCA Italy S.p.A. as well as satisfy your expectations (“Profiling”);

e)   subject to your express consent, communicating Data to FCA Italy S.p.A.  subsidiaries and affiliates, as well as their partners in the automotive, financial, insurance and telecommunication sectors, that will process them to send commercial communications as well as advertising on their products and services, or perform market researches (“Marketing third Party”).

The Data may be processed in hardcopy, by automated or electronic means including via mail or e-mail, phone (e.g. automated phone calls, SMS, MMS), fax and any other mean (e.g. web sites, mobile apps).

CONSEQUENCES OF FAILURE TO PROVIDE THE DATA

Submitting the Data is never mandatory. However, not providing the Data marked as mandatory will prevent Triboo Digitale Srl and FCA Italy S.p.A. from providing the services referred to in points a) and b). On the other hand, not providing the optional Data will allow you to access the services anyway.

RECIPIENTS OF THE DATA

The Data may be processed by natural persons and/or legal entities, acting on behalf of the Data Controllers specified below  and under specific contractual obligations, based in EU Member States or in countries outside the EU.

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

DATA TRANSFER OUTSIDE OF THE EEA

Within its contractual relations the Data Controllers 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 the Data Controllers. Databases management and Data processing are bound to the purposes of the processing and are carried out according to applicable data protection law.

In case the Data are transferred outside of the EEA the Data Controllers 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 to rule the transfer of personal data outside of the EEA.

DATA CONTROLLER AND DATA PROTECTION OFFICER TEAM

The Data Controller for the purposes referred to in point a) is Triboo Digitale Srl, with registered office in Viale Sarca 336, 20126 Milan, Italy.

You can contact the Data Protection Officer of Triboo Digitale Srl at the email address lapo.curinigalletti@triboo.it.

The Data Controller for the purposes referred to in points b), c), d), e) is FCA Italy S.p.A., with registered office in Corso Giovanni Agnelli 200 – 10135 Turin, Italy.

You can contact the Data Protection Officer team at the email address dpo@fcagroup.com.

DATA RETENTION

The Data processed for the purposes referred to in points a) and b) will be kept for the period deemed strictly necessary to fulfil such purposes. However these Data may be stored  for a longer period, as may be necessary to protect Data Controllers’ interests related to potential liability related to the provision of the services referred to in points a) and b).

 Data processed for Marketing and Profiling purposes will be kept from the moment you give consent until the moment you withdraw the consent. Once consent is withdrawn, Data will no longer be used for these purposes, although they may still be kept, in particular as may be necessary to protect Data Controllers’ interests related to potential liability related to this processing unless further clarification are provided by the competent Supervisory Authority in this regard.

YOUR RIGHTS

You can exercise the following rights:

  1. right to access means the right to obtain from the Data Controllers whether your Data are being processed and, where applicable, have access to them; 
  2. right to rectification and right to erasure means the right to obtain the rectification of inaccurate and/or incomplete Data, as well as the erasure of Data when the request is legitimate;
  3. right to restriction of processing means the right to request suspension of the processing when the request is legitimate;
  4. right to data portability means the right to obtain Data in a structured format, ordinary used and readable, as well as the right to transfer Data to other controllers;
  5. right to object means the right to object to the processing of Data when the request is legitimate, including when the Data are processed for marketing or profiling, if applicable;
  6. right to lodge a complaint with a supervisory authority in case of unlawful processing of Data.

 

You can exercise the abovementioned rights by writing: for the purposes referred to in point a) to Triboo Digitale Srl, Viale Sarca 336, 20126 Milan, Italy or to the email address triboospa@legalmail.it; for the purposes referred to in points b), c), d), e)  to FCA Italy S.p.A., Corso Giovanni Agnelli 200 – 10135 Turin, Italy or to the email address privacy@fcagroup.com.