Information on personal data processing platform
Pursuant to article 13 of the European Regulation on general data protection 679/2016, Leasys as Data Controller is required to provide information on the use of your personal data.
Data are processed in a pertinent, lawful, fair manner through the use of adequate security measures and with the consent of the data subjects.
The Data Controller is LEASYS S.p.A. (hereinafter the “Controller”), headquartered in Turin - Corso Orbassano n. 367, VAT CODE 06714021000.
This information is intended for all the Customers (Players) or Users (User Community Personal) that use this platform to receive the I-Link service provided by Leasys S.p.A.
Source and type of data gathered
Leasys S.p.A gathers data entered by customers who register and geolocation data.
Geolocation data are used to locate the vehicle when it is picked up.
Depending on the party that uses the vehicle, geolocation data are used in different ways:
- View of vehicle location by the Player by clicking the “map” button, except when the vehicle is used by the members of the User Community;
- View of vehicle location by the User in case of acceptance of reservation and only to pick up the vehicle.
Purposes of processing
Data are processed in connection with the provision of the I-Link service, including the Car Finder service (locating the car when it is picked up) through the “Map” button.
The provision of data for the purposes hereunder is necessary for the execution of the contract and to use the car reservation service.
The data provided can be used also for internal administrative and management purposes, such as reporting, internal control and/or audit, research to create new products, to manage complaints and claims, as well as to improve products and services already distributed.
Data processing performed to manage the fleet and for maintenance purposes do not require the consent of the data subject, as this activity is based on the Data Controller’s legitimate interest.
The data provided will be processed until termination of the contract or the tenth year after the date of the last registration, whichever is later (pursuant to article 2220 of the Italian civil code).
Recipients of personal data
Personal data will be processed by LEASYS as well as by certain service providers to which LEASYS outsourced a number of activities to pursue the purposes indicated above. In this case, the same service providers will act as autonomous Data Controllers or will be designated as Data Protection Officers or Data Processors. LEASYS will provide adequate instructions to any designated Data Protection Officer or Data Processor, with special reference to the adoption of minimum security measures, to ensure data confidentiality and security.
The above-mentioned service providers include in essence: (i) the Companies that operate as Data Processors of User and Vehicle data, with particular reference to vehicle location data for purposes closely related to the delivery of services; (ii) LEASYS’s partners operating in the European Union and/or third parties, foreign as well, that support LEASYS S.p.A. in the provision solely of services covered by the contract and to fulfil legal obligations, or for the protection of rights in judicial proceedings. Personal data will not be disseminated.
For the processing activities indicated above in relation to contract performance, the consent provided previously continues to apply.
Manner of processing
In relation to the purposes described, personal data processing will take place through manual, computer and IT tools, based on rationales closely related to the foregoing purposes and, in any case, in keeping with safety and security standards.
Data conservation period
Personal data will be kept for the period strictly necessary to perform contractual services.
Data protection officer
For urgent and formal reasons, other than the exercise of the rights outlined in the paragraph on exercisable rights – the Data Protection Officer can be contacted as follows:
- Email: firstname.lastname@example.org;
- Telephone: 800 33 44 22 – one of our Customer Care customer will reply and redirect your call to the Data Protection Officer;
- Ordinary mail: Leasys S.p.A., C.so Orbassano n. 367 - 10135 Torino, c/o “Data Protection Officer”.
Regarding the personal data processing described above, you may request:
- confirmation that your personal data are being processed and, in this case, obtain access to the personal data and the origin of such data, the purposes and manners of processing and the rationales applied in case of processing performed with electronic tools;
- the update, completion, rectification, erasure or transformation in anonymous form of your personal data;
- to limit or oppose the processing of your personal data;
- to receive in a structured, commonly used and machine-readable format your personal data or the transmission thereof to another data controller (i.e. right to data portability);
- the attestation that the operations required have been brought to the knowledge of the parties to whom the data were communicated or disseminated.
You may exercise your rights by contacting LEASYS S.p.A. as follows:
- Telephone: 800334422;
- Email: dataprotection-Italia@leasys.com;
- Ordinary mail: Leasys S.p.A., C.so Orbassano n. 367 - 10135 Torino.
The Data Controller will reply to your requests within 30 (thirty) days of receipt thereof, save for a 60-day (sixty-day) extension due to the complexity and number of requests. If you do not receive a reply by the indicated deadlines, you have the right to file a formal complaint with the Italian Persona Data Protection Authority in the forms and manners provided for by the applicable law.