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GENERAL POLICY

 

POLICY PURSUANT TO AND FOR THE EFFECTS OF ART. 13 OF REGULATION (EU) 2016/679

OF THE EUROPEAN PARLIAMENT AND THE COUNCIL OF 27 APRIL 2016

RELATING TO THE PROTECTION OF INDIVIDUALS WITH REGARD

TO THE PROCESSING OF PERSONAL DATA, AS WELL AS THE FREE CIRCULATION OF SUCH DATA

 

1. FOREWORD

In compliance with the obligations set out in art. 13 of EU Regulation 2016/679 (hereinafter "Regulation"), this policy is provided for all those who use the services provided by GRUPPO BRESCIA MOBILITÀ Companies and/or who want to establish a contract relation with the same Companies.

2. DATA CONTROLLER and DATA PROTECTION OFFICER

The Companies of GRUPPO BRESCIA MOBILITÀ have defined an agreement as joint data controllers, in order to simplify the relationship with the various Companies for users, avoiding repeatedly requesting the same data.

The Companies are therefore joint controllers:

BRESCIA MOBILITÀ S.P.A. with registered office in Via L. Magnolini, 3 – 25135 Brescia, Tax Code and VAT number 02246660985;

BRESCIA TRASPORTI S.P.A. with registered office in Via San Donino, 30 – 25128 Brescia, Tax Code and VAT number 03513620173;

METRO BRESCIA S.R.L., with registered office in Via L. Magnolini, 3 – 25135 Brescia, Tax Code and VAT number 03368590984;

For any question regarding the protection of personal data, including the exercise of the rights recognised to the interested party by current legislation, refer to dpogruppobsm@bresciamobilita.it.

3. PURPOSE OF PROCESSING, TYPE OF DATA PROCESSED, OBLIGATION TO PROVIDE DATA

The Companies of GRUPPO BRESCIA MOBILITÀ process all personal data necessary for the provision of the services requested or in any case for the fulfilment of the relation between the parties, including carrying out surveys aimed at verifying customer satisfaction, with a view to improving the services provided.

In any case, the Companies of GRUPPO BRESCIA MOBILITÀ only request and process data that are strictly functional to the purposes of the processing carried out, including the electronic sending of reminders on the expiry of the contract or regarding obligations required by law. The provision of data is optional, but failure to provide it could hamper the possibility of providing the requested service or establishing the contract relation being defined.

These are usually common data (including all data that allow direct identification such as personal data and images or indirect identification such as tax code, license plate number, and e-mail address), but for the provision of some services it may also be necessary to process information belonging to particular categories of data pursuant to art. 9 and art. 10 of EU Regulation 2016/679. Such particular categories referred to in art. 9 of the Regulation include data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data intended to uniquely identify an individual, data relating to the health or sexual life or sexual orientation of the person. art. 10 of EU Regulation 2016/679, instead, refers to the processing of personal data relating to criminal convictions and offenses.

 

4. DATA RETENTION PERIOD

The data provided are kept for the entire duration of the contract relation in place and in any case at least for the minimum time required by the relevant legal regulations. In the absence of such legal provisions, GRUPPO BRESCIA MOBILITÀ Companies set, according to the purpose for which the data were collected, a limited retention period, in any case not exceeding ten (10) years from the end of the relation with the interested party.

With reference to the retention of information deriving from video surveillance systems and the use of travel documents, data retention is limited to seven (7) days; after this deadline, unless otherwise requested by the public security authorities, the data are deleted or made anonymous.

5. RIGHTS OF THE DATA SUBJECT

The data subject can exercise all the rights established by the reference legislation, and more precisely can request access to personal data concerning him/her, their rectification or cancellation, the limitation of processing, as well as revoke the consent provided or oppose to the processing itself, compatibly with compliance with the legal obligations to which the Companies of GRUPPO BRESCIA MOBILITÀ must comply with.

In the same way, the data subject can exercise the right to the portability of his/her data and to lodge a complaint with the Data Protection Authority.

6. COMMUNICATION AND DISCLOSURE OF DATA

The personal data collected may be disclosed to third parties in charge of carrying out related and instrumental activities for the processing of the same and to the competent Authorities in compliance with legal obligations. On the other hand, there is no provision for large-scale dissemination or in any case for uses not immediately connected with the purpose for which the data are provided. The dissemination of data outside the European Union is not envisaged.

7. VIDEO SURVEILLANCE AND LOCALISATION SYSTEMS

In order to protect the safety of people and assets, video surveillance systems are operational at the headquarters of GRUPPO BRESCIA MOBILITÀ Companies, as well as in the areas affected by the relative services and in public transport vehicles, with images taken and sometimes audio recordings. The areas and vehicles equipped with these systems are identified by the appropriate signs on site.

For the same purposes, a GPS satellite localisation system is installed on board company vehicles; vehicles equipped with a GPS system are identified by the appropriate signs on the vehicle itself.

8. PERSONAL DATA OF MINORS

The communication of personal data relating to a minor must be made by a parent or by a person exercising the authority. We inform you that the Companies of GRUPPO BRESCIA MOBILITÀ do not carry out processing operations of the personal data of minors without the consent of the parents or of the person exercising the authority, except in the case in which the processing is necessary for the pursuit of the legitimate interest of the data controller or third parties, which is the case of ascertaining the identity of a user without a regular ticket on board the group's vehicles. In all other cases, Users under the age of 18 are advised not to communicate their personal data under any circumstances without the authorisation of the parent or person exercising parental authority. The Companies of GRUPPO BRESCIA MOBILITÀ reserve the right to inhibit access to services and do not guarantee the successful completion of the activities/services requested for any User who has concealed his/her minor age or has communicated his/her personal data in the absence of the consent of the parents or whoever exercises parental authority.

9. NAVIGATION DATA AND COOKIES

The computer systems and software procedures used to operate the website https://www.bresciamobilita.it and the BRESCIAPP APP! (which allows access to Gruppo Brescia Mobilità website) acquire, during their normal operation, some data whose transmission is implicit in the use of Internet communication protocols.

No personal data is acquired unless the user provides it knowingly. In fact, no software is used to transmit personal information, although software (cookies) are used to monitor, in an aggregate way and not to trace the visitor's identity, the browsing habits of our customers in order to improve the service offered and make browsing safer and more efficient.

Cookies

Cookies are generally characterised as text files containing small amounts of information that are downloaded to the user's device (only if enabled) who visits the sites of GRUPPO BRESCIA MOBILITÀ.

The cookies used are defined as session cookies, or temporary cookies that help the user to navigate within the sites and remember the choices made during the session, hence avoiding the use of other IT techniques that are potentially detrimental to the confidentiality of users' browsing. These cookies are deactivated as soon as the user leaves the site through the log out procedure or after an inactivity period of time.

The site of GRUPPO BRESCIA MOBILITÀ does not use advertising cookies and does not use profiling cookies, or cookies that can in some way keep track of customer habits and their personal data, nor are persistent cookies of any kind used, or systems for tracking users.

Many web browsers automatically accept cookies; however, if the user wishes, it is possible to set the browser in order not to accept them. In this case, the navigation of the site may not be complete, mainly due to the failure to install the so-called technical cookies (see below).

On the sites of GRUPPO BRESCIA MOBILITÀ and in the APP BRESCIAPP! the following types of cookies are used for the following purposes:

- Technical or system cookies

This type of cookie allows the user to navigate correctly and use particular functions such as access, where provided, to secure areas. Without these cookies, it will not always be possible to provide authentication services or the correct functioning of websites.

These cookies are not defined directly by GRUPPO BRESCIA MOBILITÀ, but are inherent in the software platforms used, therefore they are generated and used automatically by them. Their use is intended for the sole purpose of general technical operation and does not compromise the user's privacy, by not collecting information on the same.

- Statistics analysis cookies: performance, navigation

GRUPPO BRESCIA MOBILITÀ uses Google Analytics (Google Inc.) statistics platform and it incorporates the cookies and access methods indicated by the latter.

This analytical tool is used to collect standard log information used on the Internet and anonymous information on the visitor's browsing behaviour. The visitor can choose not to send information to Google Analytics for all websites, by visiting Google’s website at the link https://tools.google.com/dlpage/gaoptout, and by following the instructions.

The user who accesses the website https://www.bresciamobilita.it must express his/her choices regarding the cookies offered through the dedicated banner on the website’s home page, where the user can also refer to the dedicated cookie policy.

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