Privacy Policy

The purpose of this document is to inform the natural person (hereinafter “Data Subject”) about the processing of his/her personal data

(hereinafter “Personal Data”) collected by the data controller, Rossoruote s.r.l., with registered o􀀟ce in Via Broseta,35 24122 Bergamo,

Tax Code/VAT No. 04519540167, e-mail address amministrazione@rossoruote.it, (hereinafter “Data Controller”), via the website

www.rossoruote.it (hereinafter “Application”).

Changes and updates will be e􀀳ective as soon as they are published on the Application. In case of non-acceptance of the changes made

to the Privacy Policy, the Data Subject shall stop using this Application and may ask the Data Controller to delete his/her Personal Data.

1. Categories of Personal Data processed

The Data Controller processes the following types of Personal Data voluntarily provided by the Data Subject:

Contact Data: 􀀻rst name, last name, address, e-mail address, phone number, pictures, authentication credentials, any further

information sent by the Data Subject, etc.

Fiscal and payment Data: tax code, VAT number, credit card data, bank account details, etc.

The Data Controller processes the following types of Personal Data collected automatically:

Technical Data: Personal Data produced by devices, applications, tools and protocols such as, for example, information about

the device used, IP addresses, browser type, type of Internet provider (ISP). Such Personal Data may leave traces which,

combined with unique identifiers and other information received by the servers, can be used to create profiles of individuals

Usage Data: such as, for example, pages visited, number of clicks, actions taken, duration of sessions, etc.

If the Data Subject decides not to provide Personal Data for which there is a legal or contractual obligation, or if such data is a

necessary requirement for the conclusion of the contract with the Data Controller, it will be impossible for the Data Controller to

establish or continue any relationship with the Data Subject.

The Data Subject who communicates Personal Data of third parties to the Data Controller is directly and exclusively liable for their

origin, collection, processing, communication or divulgation.

2. Cookies and similar technologies

The Application uses cookies, web beacons, univocal identi􀀻ers and other similar technologies to collect the Data Subject’s

Personal Data on visited pages and links and other actions performed during the use of the Application. This data is stored and

then used the next time the interested party browses the Application. The full Cookie Policy can be viewed at the following

address: https://www.rossoruote.it/cookie

3. Legal basis and purpose of data processing

The processing of Personal Data is necessary:

1. for the performance of the contract with the Data Subject and especially:
2. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject
3. registration and authentication of the Data Subject: to allow the Data Subject to register in the Application, to access it

and to be identified in it, also via external platforms

3. support and contact with the Data Subject: to answer the Data Subject’s requests
4. management of payment: to manage payments by credit card, bank transfer or other methods
5. for legal obligations and especially:
6. 1. the fulfilment of any obligation provided for by the applicable norms, laws and regulations, in particular, on tax and

fiscal matters

1. for the legitimate interest of the Data Controller, for:
2. marketing purposes by e-mail of products and/or services of the Data Controller to directly sell the Data Controller‘s

products or services using the email provided by the Data Subject in the context of the sale of a product or service similar to

the one being sold

2. management, optimization and monitoring of the technical infrastructure: to identify and solve any technical issue, to

improve the performance of the Application, to manage and organize the information in a computer system (e.g. server,

database, etc.)

3. security and anti-fraud: to guarantee the security of the Data Controller’s assets, infrastructures and networks
4. anonymous data based statistics: in order to carry out statistical analysis on aggregated and anonymous data in order to

analyze behaviors of the Data Subject to improve products and/or services provided by the Data Controller and better meet

the expectations of the Data Subject

1. on the basis the Data Subject’s consent, for:

1. profiling the Data Subject for marketing purposes: to provide the Data Subject with information on the Data Controller’s

products and/or services through automated processing designed to collect personal information to predict or assess the

Data Subject’s preferences or behaviors

2. retargeting and remarketing: to reach with a customized advertisement the Data Subject who has already visited or shown

interest in the products and/or services o􀀳ered by the Application using his Personal Data. The Data Subject may opt-out by

visiting the Network Advertising Initiative page

3. marketing purposes of the Data Controller’s products and/or services: to send information or commercial and/or

promotional materials, to perform direct sales activities of the Data Controller’s products and/or services or to conduct

market research with automated and traditional methods

4. marketing purposes of third-party products and/or services: to send information or commercial and/or promotional materials of third parties, to carry out direct sales activities or to perform market research of their products and/or services with automated and traditional methods

On the basis of the legitimate interest of the Data Controllerowner, the application allows interactions with external web platforms

or social networks whose processing of personal data is governed by their respective privacy policies to which please refer. The

interactions and information acquired by this Application are in any case subject to the privacy settings that the Data Subject has

chosen on such platforms or social networks. Such information – in the absence of speci􀀻c consent to processing for other

purposes – is used exclusively to allow the use of the Application and to provide the information and services requested.

The Data Subject’s Personal Data may also be used by the Data Controller to protect itself in judicial proceedings before the

competent courts.

4. Data processing methods and receivers of Personal Data

The processing of Personal Data is performed via paper-based and computer tools with methods of organization and logics strictly

related to the specified purposes and through the adoption of appropriate security measures.

Personal Data are processed exclusively by:

• persons authorized by the Data Controller to process Personal Data who have committed themselves to con􀀻dentiality or have an appropriate legal obligation of confidentiality;
• subjects that operate independently as separate data controllers or by subjects designated as data processors by the Data
• Controller in order to carry out all the processing activities necessary to pursue the purposes set out in this policy (for example, business partners, consultants, IT companies, service providers, hosting providers);
• subjects or bodies to whom it is mandatory to communicate Personal Data by law or by order of the authorities.

The subjects listed above are required to use appropriate measures and guarantees to protect Personal Data and may only access

data necessary to perform their duties.

Personal Data will not be indiscriminately shared in any way.

5. Place

Personal Data will not be transferred outside the territory of the European Economic Area (EEA).

6. Personal Data storage period

Personal Data will be stored for the period of time that is required to fulfill the purposes for which it was collected. In particular:

• for purposes related to the execution of the contract between the Data Controller and the Data Subject, will be stored for the
• entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the
• event of legal disputes, for the entire duration of such disputes, until the time limit for appeals has expired
• for purposes related to legitimate interests of the Data Controller, they will be stored until the fulfilment of such interest
• in compliance with legal obligations, by order of an authority and for legal protection, they shall be stored according to the
• relevant timeframes provided for by such obligations, regulations and, in any case, until the expiry of the prescriptive term
• provided for by the rules in force
• for purposes based on the consent of the Data Subject, they will be stored until the consent is revoked

At the end of the conservation period, all Personal Data will be deleted or stored in a form that does not allow the identi􀀻cation of the Data Subject.

7. Rights of the Data Subject

Data Subjects may exercise speci􀀻c rights regarding the Personal Data processed by the Data Controller. In particular, the Data

Subject has the right to:

• be informed about the processing of their Personal Data
• withdraw consent at any time
• restrict the processing of his or her Personal Data
• object to the processing of their Personal Data
• access their Personal Data
• verify and request the rectification of their Personal Data
• restrict the processing of their Personal Data
• obtain the erasure of their Personal Data
• transfer their Personal Data to another data controller
• file a complaint with the Personal Data protection supervisory authority and/or take legal action.

In order to use their rights, Data Subjects may send a request to the following e-mail address amministrazione@rossoruote.it.

Requests will be immediately treated by the Data Controller and processed as soon as possible, in any case within 30 days.