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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 information is disclosed to all natural persons using the services provided by the BRESCIA MOBILITÀ GROUP companies as part of the use of the BresciAPP application!

2. DATA CONTROLLER AND DATA PROTECTION OFFICER

The companies of the BRESCIA MOBILITÀ GROUP have defined an agreement as joint data controllers, in order to simplify the relationship between companies and users, thus avoiding recurrent requests of the same data.

The following companies are 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 no. 03513620173;
  • METRO BRESCIA Limited liability company, with registered office in Via L. Magnolini, 3 - 25135 Brescia, Tax Code and VAT no. 03368590984;

For any question regarding the protection of personal data, including the exercise of the rights granted to data subjects by the current legislation, please contact dpogruppobsm@bresciamobilita.it.

3. PURPOSE OF PROCESSING, TYPE OF DATA PROCESSED, NATURE OF DATA PROVISION

As regards the use of the BresciAPP! Application, the BRESCIA MOBILITÀ GROUP companies shall process all personal data required for the provision of the services requested or in any case for the fulfilment of the relationship between the parties, such as

a) identification data of the device used by the data subject (log, IP, user agent ...),

b) common personal data spontaneously provided by the data subject (name, surname, email address, car license plate, BiciMia card number ...).

c) location data

In the cases referred to in points a) and b) above, the legal basis of the processing is to be found

  • in the legitimate interest of the Data Controller to make the service requested by the data subject safe and usable,
  • in the implementation of contractual or pre-contractual measures related to the provision of a service requested by the data subject.

In the case referred to in point c), the legal basis of the processing is represented by the consent of the data subject, or by the authorization provided by them, by selecting "Allow", "Allow once" or "Allow when using the 'APP”, upon using the Application for the first time.

Users may enable/disable the geo-location settings at any time, through privacy settings of their device: Android: BresciAPP! App, App Permissions, Location; iOS: Privacy, Location, BresciAPP!.

The provision of the personal data listed above is optional. However, failure to provide such data could jeopardise the provision of the requested service or the achievement of the contractual relationship being defined.

4. DATA RETENTION PERIOD

The companies of the BRESCIA MOBILITÀ GROUP shall retain personal data and other information (e.g., accounting data relating to the purchase of tickets) for the time necessary to provide the services requested by the data subjects, to allow them to use this application, to comply with applicable laws and to resolve disputes with any parties. As a result, data shall be deleted as soon as it is no longer necessary for the aforementioned purposes.

The criteria used to define the duration of the processing are based on the retention obligations set out by laws and regulations in force and by the operational requirements of this application, such as the maintenance of accounts, the management of relationships with users and the reply to the request for the exercise of rights, the filing of complaints and requests from law enforcement or competent authorities.

In case of inquiries about a specific retention period for certain types of personal data processed, data subjects may contact the companies of the BRESCIA MOBILITÀ GROUP by email at dpogruppobsm@bresciamobilita.it.

5. RIGHTS OF DATA SUBJECTS

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.

Similarly, data subjects may exercise the right to the portability of their data and to lodge a complaint with the Authority for the protection of personal data (Data Protection Authority – Garante della Privacy).

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.

Specifically, upon providing services, data may be shared with persons acting on behalf of the BRESCIA MOBILITÀ GROUP companies as external Data Controllers, or involved in the transaction for different purposes, including:

  • Hosting Providers
  • IT service providers
  • Payment service providers.

Personal data may not be disclosed on a large scale or for uses not strictly connected with the purpose for which the data is provided

Personal data may not be disclosed outside the European Union.