Information provided to the interested party in accordance with Article 13 of the personal data protection Code (Legislative Decree n. 196 of 30 June 2003)
By personal data processing we mean any operation or number of operations, carried out with or without the assistance of electronic means, regarding the collection, recording, organization, storage, consultation, processing, change, selection, retrieval, comparison, utilization, interconnection, blocking, communication, dissemination, erasing and destruction of data, whether or not the same are entered in a data bank.
Personal information provided by the Applicants and/or Customers forwarding requests is only used to execute the requested service, and is only disclosed to third parties if strictly necessary and functional to this purpose, in compliance with the statements made pursuant to the Code. Personal information is processed by staff specially appointed to process them within the limits in which that processing may be necessary to perform their duties, by carrying out only the necessary operations.
Purposes of data processing
The purposes of our data processing are the following:
- performing the obligations arising from the General Terms & Conditions, the Regulation and/or delivery of directly related and/or ancillary services. In such cases, in accordance with Article 24 of the Code, the consent procedure is not necessary when data processing is required to pursue obligations deriving from a contract, whereas, during the negotiation, your consent is not necessary when data processing is required to meet specific requests made by you prior to the conclusion of the contract;
- providing the services required by the Applicant and/or Customer when registering on the website and/or App e creating his own account and user profile, including the collection, storage, and processing of the data for establishing, and subsequently operating, technical, and administrative management of the relationship connected with provision of the Services, and for exchanging messages in regard to management of the services;
- managing payments (with the relevant processing - as required by law - of the payment data, including the identifying details of the credit card or pre-paid card) for the required services and any accessory charges, in accordance with the provisions of the General Terms & Conditions and/or other specific contractual conditions published on the website or otherwise made available to the Customer;
- fulfilling legal, accounting, fiscal, administrative and contractual obligations related to the provision of the required service;
- managing relations with authorities and external public entities for purposes connected with specific requests, for the fulfilment of legal obligations or special procedures (e.g.: re-notification to the actual offender of the notice of assessment for traffic violations, collection of Service data to evaluate their effectiveness and analyse urban mobility);
- Establishing measures to protect against credit risk, including activities aimed at identifying the Customer and his economic reliability/solvency, also during the contractual relationship;
- setting up a geolocation system of the Vehicles and any measures aimed at protecting the vehicle fleet against possible unlawful or fraudulent acts of the customers;
- recording video images of the Vehicle's interior, of geolocation data and of the dynamic parameters in connection with abnormal events, for the purpose of possible crash kinematic reconstruction and to protect the vehicle fleet against possible unlawful or fraudulent acts of the customers;
- verifying the Customer's Driving license with the competent authority;
- developing initiatives in relation with the contractual relationship for improving the service provided, such as surveys to solicit Customers' feedback;
- developing commercial, promotional, advertising and marketing initiatives. In such cases, your consent - separate and specific - is optional, and your refusal will have no consequence on the execution of the contract relationship.
Methods of data processing
Your personal information collected in the website and App will be mainly treated with electronic or automated tools to guarantee maximum safety and confidentiality. However, there might be occasions when the data so collected is treated manually without using electronic means. The data collected will be processed in full compliance with the law, as well as with principles of lawfulness, fairness, transparency, protection of confidentiality of your rights, and without excess, for the sole purpose of fulfilling legal and contractual obligations arising from the contractual relationship and/or of correctly executing the related performances. The data might also be treated to assert or defend DriveNow's rights in a judicial process. DriveNow does not collect nor treat any sensitive data regarding its Customers. Should it learn about sensitive data, they will be processed only and exclusively for the finalities connected with the provision of the Service and will not be communicated or used in any way not linked to the rental function.
We also inform you that Vehicles will be subject to geolocation, in order to properly provide the Service. Geolocation will be carried out in view of the provisions of the Code, and the data thus collected will be used with the sole purposes of properly execute the Service and protect the vehicle fleet. In particular, DriveNow will be immediately notified when the vehicle is approaching the outer limits of the area of use prescribed in the General Terms & Conditions. DriveNow reserves the right to collect, process and use data relating to the vehicle usage (including geolocation data) in order to detect and correct defects and malfunctions, identify and analyse any claim from third parties, or to further develop DriveNow services.
DriveNow will keep such data as far as possible separated from contractual data, so that during their treatment it is not possible to link the vehicle usage data with the driver's personal information.
If there is evidence of an emergency or a violation of the main provisions of the framework agreement or of the individual rental contract (especially in the event of theft, accident, or serious damage to the vehicle), DriveNow may determine the concerned vehicle's geolocation in order examine the evidence and take the necessary precautionary measures.
Recording of video and other data in case of abnormal events
The vehicle is equipped with a device for the recording of video images of its interior, of geolocation data and of the dynamic parameters in connection with abnormal events, treated in accordance with the Legislative Decree n. 196 of 30 June 2003, (Privacy Code) for the purpose of possible crash kinematic reconstruction and to protect the vehicle fleet against possible unlawful or fraudulent acts of the customers. These images and data are saved on the device exclusively with regards to the 30 seconds before and after detecting an abnormal event (such as, for instance, a speed reduction beyond certain parameters, which might indicate a possible accident) or the manual activation by the driver. The images and related data may be disclosed to insurance companies and their intermediaries and/or auxiliaries, submitted to Courts or disclosed to competent authorities, and shall be stored by DriveNow for a maximum period identical to the relevant limitation period, including, with regard to road traffic accident, the 2-year period indicated in Article 2947, paragraph 2, of the Civil Code.
Categories of subject to whom the personal data can be disclosed
With regard to the scope of disclosure of your data, the information provided by you may be disclosed to the following subjects or subject categories:
1. Police, armed forces and other public authorities, for the fulfilment of obligations under the law, regulations or Community legislation. In such instances, Article 24 of the Code removes the obligation to acquire the individual's previous consent to the disclosure;
2. Companies, entities or associations, or parent companies, subsidiaries or affiliates within the meaning of Article 2359 of the Civil Code, or among them and companies subject to joint control, as well as between consortia, enterprise networks and clusters and temporary associations of enterprises and with their members, limited to disclosures made for administrative and/or accounting purposes;
3. insurance companies competent for the settlement of claims;
4. debt collection companies;
5.companies specialising in managing commercial or credit information, or in advertising;
6. other companies providing car sharing and/or ancillary services, linked to DriveNow through various types of agreements;
7. other companies having a contractual relationship with DriveNow which provide claims management services;
8. public authorities having an agreement with DriveNow for the provision of car sharing services, in fulfilment of the commitments given to them;
9. public authorities competent for issuing driving licenses (Ministry of Infrastructures and Transports - Directorate General for Motor Vehicles) in order to verify the validity of the driving license provided by the Customer and its correspondence with the Customer's personal data and address.
Data collected and saved in the DriveNow database will be processed by the employees and/or associates of the Data Processing Proprietor (as defined below) or by the persons in charge of processing such data ("Data Processing Representatives"); such information will not be disclosed to third parties, except as provided above and, in any case, within the limits indicated therein. DriveNow reserves the option of commissioning third parties to process personal data on its own behalf ("Data Processing Managers") and may accordingly share personal information with such third parties.
Obligatory or optional consent to provide personal information/ consequences of refusal
The Customer is free to disclose or not his personal information as requested by DriveNow from time to time, but failing to do so may entail the impossibility to provide required services. Consent for personal information data processing is not needed for all the above specified treatments however related and/or necessary to fulfil an obligation under the law, Community legislation or to fulfil obligations deriving from a contract you are party of, or to implement specific requests by you before the contract is concluded. If you choose not to consent to data processing operations for commercial and promotional purposes - whenever requested in particular sections of the website - your refusal will bear no consequences.
What is Onsite Targeting?
What is Remarketing/Retargeting?
Our internet site uses Remarketing/Retargeting to tailor its web-based commercial provision on the users. This technology allows us to address users who have already shown interest for the website, with DriveNow ads on the websites of our commercial partners. These ads are shown on the websites of our commercial partners through cookies or following market analysis of users' behaviour on the Net. Ads are shown completely anonymously and the data collected in this way shall under no circumstance be used together with the personal information stored by us.
Use of Google Analytics (this text was provided by Google, Inc) and analysis by "adjust.io"" technology
The website/App use Google Analytics, a monitoring service operated by Google Inc. ("Google"). Google Analytics uses so-called "cookies", or "trails of information" stored in your computer/mobile device make analyses based on the web pages you visit or the Apps you use. Information generated by cookies are transferred to and saved on a Google server in the USA. Google will use this information to assess your use of the website or App, with a view to drawing up website activity reports for the website operators and providing other website and App use-related services. If necessary, Google may also send this information to third parties, as far as this is required by law or as far as third parties have been commissioned by Google to process this data. Google will not match your IP address to any other personal information in its possession. You can disable cookies by changing your browser settings. In this case, however, you may not be able to use all the features of this website/App. By using the website/App, you consents that Google shall process data in the way described above and only in fulfilment of the aforementioned purposes.
For further information visit www.google.com/int/it/analytics/privacyoverview.html (informazioni generali su Google Analytics e sulla protezione dei dati).
The website/App uses, in particular, "adjust.io" technology from Adeven GmbH ("adeven"). Adeven memorises users' IP and MAC addresses - albeit anonymously - for market analyses. This data does not allow to identify the individual producing it. Information thus collected can be used to analyse function and usage of the website/App in order to generate anonymous statistics and charts about the number of visitors and number of pages visited by the user, etc. Such analyses are only used for our market research, with the aim of optimising the website/App and adapt it to your preferences. By using the website/App you consent to the processing of data collected anonymously in the way previously indicated and for the aforementioned purposes. You can opt out of future data collection and storage at any time sending an email to email@example.com
How can I avoid the storage of cookies?
You can choose whether to accept cookies or not. Many Internet browser automatically accept cookies. It is usually possible to set your browser to reject cookies. When cookies are rejected, in the long term some features of our website may not be used. If cookies are accepted, they can be subsequently deleted. For instance, in Internet Explorer 8 cookies can be deleted in "Security settings">"Delete history". When the cookies are deleted, all settings they control, including advertising settings, are deleted and can no longer be restored.
Data Processing Proprietor and Managers
DriveNow is Proprietor of the data treatment for the information you provide (Data Processing Proprietor").
You may consult the latest listing of Data Processing Managers at the DriveNow office. You may at any time contact the Data Processing Proprietor or the Data Processing Managers to exercise your rights as are provided under Article 7 of the Code (Right to access personal data and other rights), entirely reproduced below:
Art. 7 (Right to access personal data and other rights)
You may at any time contact the Data Processing Proprietor or the Data Processing Managers to exercise your rights as are provided under Article 7 of the Code (Right to access personal data and other rights), entirely reproduced below:
Article 7, Legislative Decree n. 196 of 30 June 2003
1. The data subject shall have the right to obtain confirmation as to the existence of personal data
concerning him/her, regardless of its being already recorded, and communication of such data in an intelligible form.
2. The data subject shall have the right to be informed:
a) of the source of the personal data;
b) of the purposes and methods of its processing;
c) of the logic applied to the processing, if the latter is carried out with the help of electronic means;
d) of the identification details concerning the data controller, data processors and the representative designated as per Article 5, Paragraph 2;
e) of the entities or categories of entity to whom or which the personal data may be communicated and who become aware of said data in their capacity as designated representative in the State's territory, data processors or persons in charge of processing.
3. The data subject shall have the right to obtain:
a) updating, correction or, where interested therein, integration of the data;
b) deletion, anonymity or blocking of data that has been unlawfully processed, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed;
c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data was communicated or divulged, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. The data subject shall have the right to object, in whole or in part:
a) on legitimate grounds, to the processing of personal data concerning him/her, even though it is relevant to the purpose of collection;
b) to the processing of personal data concerning him, where this is performed for the purpose of sending advertising material, making direct sales or conducting market or commercial communication surveys.
Google Maps use
Interaction with external social networks and platforms
These services allow you to interact with social networks, or with other external platforms, directly from the website. The interaction and information acquired by the DriveNow App are in any case determined by the user's privacy settings for each social network. When an interactive service with social networks is installed, even if the user does not use the service, the network might collect traffic data related to the pages in which it is installed.
Twitter "Tweet" button and social widgets (Twitter)
Twitter "Tweet" button and social widgets are interactive services with the Twitter social network, provided by Twitter Inc.
It should be noted that, as website managers, we are not aware of the content of the transferred data nor of their use by Twitter.
Facebook "Like" button and social widgets (such as "liking" through Facebook ) (Facebook, Inc.)
Facebook "Like" button and social widgets are interactive services with the Twitter social network, provided by Facebook, Inc.
It should be noted that, as website managers, we are not aware of the content of the transferred data nor of their use by Facebook.
Pinterest "Pin It" button and social widgets (Pinterest, Inc.)
Pinterest "Pin It" button and social widgets are interactive services with the Twitter social network, provided by Pinterest, Inc.
It should be noted that, as website managers, we are not aware of the content of the transferred data nor of their use by Pinterest.
Google+1 "+1" button and social widgets
Google+1 "+1" button and social widgets are interactive services with the Twitter social network, provided by Google Inc.