Gruppo Intergea Spa (hereinafter also referred to as “Intergea”) cares about privacy and personal data protection. Therefore, we hereby intend to inform you about how we will process your personal data collected when using our websites and applications, or when contacting our operators (hereinafter, collectively, referred to as “Platforms”).
For example, we can gather personal information when:
- you request to register;
- you use services through the Platforms;
- you call our operators.
In particular, we need to process the details provided to us at the time of registration. With your consent, we may also use other information that you freely provided to us at the time of registration or relating to how you interact with us (hereinafter, collectively referred to as “Data”).
1. What Data will we use?
We may collect and process the following Data:
1.1. Data collected through the application or registration form
For the registration, we may ask you to provide us data such as personal information (first and last name) and your contact details (telephone number, email address).
It is optional to communicate such data through the specific form; however, if the mandatory required data (marked with *) will not be provided, we will not be able to complete the registration process and/or provide the requested services.
With your consent, we may also use further information provided through the form, e.g. company name and VAT number.
1.2. Data collected through the use of the Platforms
During the use of our Platforms, we will process the Data necessary to guarantee you the correct use of the Platforms themselves and of the connected services, such as log-in related data, pages visited, your requests, your car preferences (indicated in the specific section of our application), car specifics of viewed vehicles, cars comparisons that you make, and further information that you may provide us to make the experience with our Platforms aesthetically complete (e.g. personal profile picture and vehicle picture).
Such information – without your specific consent to process it for further purposes – will be used only to enable a better use of our Platforms and to provide you any requested information or services.
1.3. Browsing data
Even when you are not logged in, our systems – used to ensure the correct functioning of our websites and our applications – gather some personal information whose transmission is implicit for the use of our electronic communication system.
Such information is not collected to identify the user, but by its very nature, it could allow your identification through processing and association with a third party’s own data. That is, for example, IP addresses, domain names of the computer used to navigate our pages and applications, browser type and version, browser plug-in types and versions, mobile device identifier (IDFA or AndroidID). Further information also includes other parameters relating to your operating system, URIs (Uniform Resource Identifier) of the requested resources, time of the request, size of the response file, and the numerical code indicating the status of the response given by the server.
Such data, without your specific consent to process it for further purposes, is solely used to gather anonymous statistical information on the use of our websites and applications and to optimize their use and functioning.
Such data is deleted immediately after processing.
1.4. Additional data
With your consent, we may also use additional data provided to us through the application and/or registration form, or during the use of our Platforms. Additional data also includes your interaction with us, our operators, and our sales consultants.
2. For what purposes will we use your Data and on what legal ground?
We will use your Data, by electronic means too:
- To allow you to use our Platforms. Your Data will be used to provide you the requested services and, in more general terms, for all related contractual and administrative procedure;
- to fulfill the legal obligations or to comply with any orders from the judiciary;
- For statistical purposes, anonymously and aggregately. With your consent we may also use your Data to:
- Send you commercial and/or promotional information as well as advertising material. We could carry out direct sales activities or send interactive commercial communications about Intergea or third party’s products, services, and other activities. We may carry out market research as well. For example, we may send you emails or instant messages (e.g. SMSs and WhatsApp), or have you called by our operators for commercial offers, initiatives, and promotions about our or a third party’s products and services. These may differ from the ones you may have requested;
- Examine both your preferences and the way you interact with us. In particular, to better understand your interests and preferences towards our services and our communications, we may examine – possibly using automated systems – the information provided when registering to our Platforms and other services provided by the Platforms. These include your interest in the communications and the newsletters we will send you, the way you use our Platforms, and your interest in our social platforms (e.g. Facebook). Finally, we may enrich your profile with statistical information that we may lawfully acquire from other sources such as data related to your living area (e.g. demographic information, geo-referencing data, etc.) or the electronic devices you use to interact with us.
In any case, you will not be subject to an automated decision-making process with the effects referred to in Article 22 of the GDPR.
- To communicate your Data to our Business Partners for independent marketing purposes;
The use of our Platforms and of the related services are in no way conditioned by the above-mentioned consents.
3. Retention period of personal Data
Your personal Data will be retained for the time necessary to satisfy the requested services. If you have not given consent to the processing for further purposes, your Data will be deleted or made anonymous after 12 months from the date of receipt of your request. The information associated with your account will remain stored as long as the account is active. In case you decide to delete the account, your Data will be deleted within 30 days from the cancellation at the latest.
In any case – for the purposes set out in point 2, letters (e) and (f) – information related to the details of the services you use and your interaction with us will be retained for no longer than 12 months from the date of collection.
4. Third parties communication
You Data may be shared, for administrative purposes, with Intergea’s parent companies, Intergea’s subsidiaries, and companies controlled by Intergea, for the sole purpose of managing the Platforms and providing the services requested. They may also be shared with our service providers, e.g. IT services. These entities will act as data processors.
Your Data may also be communicated by Intergea to its business partners, whose collaboration is necessary for the provision of the services requested. In particular, the financial or insurance companies, car manufacturers, or companies delegated by them, whose collaboration is necessary to manage the contacts involved in every instance (hereinafter also referred to as “Business Partners”). These communications will happen in case of a quote request and/or test-drives requests you might send us.
Our Business Partners will operate as independent data controllers in compliance with their privacy policies. These will be sent to you directly by them together with the quotes or information requested.
A complete list of the entities whom your Data may be communicated will be made available upon written request to the contacts indicated below.
5. Data transfer outside the EU
Your Data will not be transferred outside the territory of the European Union.
6. Rights of the subject
You have the right to request access to your Data, to edit or delete it.
Moreover, you can ask for a limitation of the treatment and can oppose to it. You can ask for the delivery of any of it.
Rights of the Subject
6.1 Access rights
The Subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning her/him are being processed. If so, she/he has the right to access personal data and the following information: a) the purpose of the processing;
- the categories of personal data being processed;
- the recipients or categories of recipients to whom such personal data has been or will be disclosed, particularly in the case of third countries or international organizations recipients, and, in such case, the existence of adequate guarantees;
- the intended period of personal data retention, where possible, or the criteria used to determine such period, where not possible;
- the Subject has the right to know that she/he can request access to her/his Data, to edit or delete it. Moreover, the Subject can ask for limitation to the treatment and can oppose to it;
- the right to lodge a complaint with a supervisory authority;
- in case the Data is not collected directly through the Subject, every piece of information available on its origin;
- the existence of an automated decision-making process, including profiling, that might produce legal effects concerning her/him or that might significantly affect her or him in a similar way, and, at least in such cases, significant information about the logic used, and the importance and expected consequences of such processing for the Subject.
The Subject has the right to obtain from the data controller the rectification of inaccurate personal data concerning her/him without
6.2 Cancellation rights
The Subject has the right to obtain from the data controller the deletion of her/his personal data without undue delay. The data collector has the obligation to delete personal data without undue delay, when:
- personal data is no longer necessary for the purposes for which it was collected and/or processed;
- the Subject withdraws her/his consent on which the treatment is based and there is no other legal basis for the treatment;
- the Subject opposes the treatment, and there are no overriding legitimate grounds to proceed with the treatment;
- personal data has been processed unlawfully;
- personal data is to be deleted to fulfill a legal obligation under European Union Law or the law of the Member State to which the data controller is subject;
6.3 Limitation of the treatment rights
The Subject has the right to obtain from the data controller the limitation of the treatment when:
- the Subject contests the accuracy of personal data, for the time necessary for the data controller to verify such accuracy;
- the treatment is unlawful and the Subject asks for a limitation of the use instead of a deletion of the data;
- even though the data controller no longer needs the data for the treatment, personal data is necessary for the Subject to ascertain, exercise, or defend a right in court;
- the Subject has opposed to the treatment, pending verification about legitimate reasons of the data controller over those of the Subject.
6.4 Opposition rights
The Subject has the right to oppose to her/his personal data treatment when this is based on the legitimate interests of the data collector, including profiling, at any time. The Subject has the right to oppose to her/his personal data treatment when this is carried out for direct marketing purposes, including profiling insofar it is related to such direct marketing, at any time.
6.5 Data portability rights
The Subject has the right to obtain the personal data concerning her/him in a clear machine-readable format from the data controller and has the right to transmit such data to another data collector without hindrance from the original data controller when:
a) the treatment is consent or contract based;
b) the treatment is carried out by automated means.
Regarding the Subject’s portability rights, she/he has the right to obtain the direct transmission of personal data from one data controller to the other, when feasible.
7. How can I edit my preferences or revoke my consent?
You can check, edit or revoke your consents at any time (by stating that you do not wish to receive commercial information via email and/or instant messaging too). You simply have to contact Intergea.
8. How do I contact Intergea to exercise my rights?
You can exercise your right by writing to the data collector, Intergea, at the following address:
Gruppo Intergea Spa,
Corso Vinzaglio, 9 – 10121 Torino
9. How can I contact the Control Authority to raise a claim?
Any complaints may be submitted to the Control Authority whose reference is:
Garante per la Protezione dei Dati Personali
Piazza di Monte Citorio n. 121
Fax: (+39) 06.69677.3785
Phone number: (+39) 06.696771
E-mail address: email@example.com
Last update: June 2019