Website Privacy and Cookie Policy
1. Introduction
Zehus S.p.A., with registered office in Via Luigi Sturzo 45, Milan (Italy) which can be contacted at the email address privacy@zehus.it,(the “Company” or “Zehus”) process – in its capacity of data controller – personal data provided by the user (the “User”) of the website www.zehus.it (the “Website”) with regard to the use of the Website and the provision of the requested services available on the Website (the “Services”), in compliance with the terms of this privacy notice (the “Privacy Notice”).
2. What kind of personal data does Zehuscollect about the User?
The Company processes personal data voluntarily provided by Users in their interactions with the Website, and in particular:
a) the data voluntarily provided by the Users, in connection with the forwarding of any requests for information or assistance or the sharing with Zehus, through the Website, of comments on the products and services offered by the Company ("Identification Data");
b) browsing data relating to the use of the services offered on the Website, such as IP addresses or domain names of the devices used by Users, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server and other parameters relating to the Users' operating system and computer environment. These data are collected by means of cookies, in accordance with the cookie policy, available at the following link http://www.zehus.it/cookie-policy/ ("Browsing Data");
c) geolocation data of the vehicle through which the User benefits from the Services, limited to the cases provided for in this notice. In particular, and for the purposes of providing the Service, the Company may register the serial number of the vehicle associated to the e-mail address of the User and identify the exact location of the vehicle for businessmaintenance reasons (especially in the event of theft, accident, or serious damage to the vehicle) in order to take appropriate action.
(Collectively defined as "PersonalData").
3. What are the purposes of the processing?
The Company processes Personal Data for the following purposes:
a) allow the provision of the Services offered through the Website, including the possibility of obtaining answers to requests for information or assistance from the User (hereinafter "Contractual Purposes");
b) comply with the obligations deriving from applicable legislation, including the execution of any communications to the competent authorities and supervisory bodies and the response to possible requests from the authorities themselves (hereinafter "Law Purposes");
c) development and improvement of the Services offered through the Website;
d) to exercise or defend legal claims incourt proceedings or in administrative or out-of-court procedures;
e) set up a vehicle geo-localization system for maintenance purposes of the vehicle fleet and any possible measures to protect the vehicle fleet against any illegal or fraudulent acts or violations of the terms and conditions of use of the Service;
f) to complete a potential merger, sale of assets or transfer of all or a material part of its business, by disclosing and transferring the Personal Data to the third party or parties involved in the transaction as part of the transaction.
(the purpose as per letters from c)to e) above are jointly referred to as “Legitimate Business Interest Purposes”).
4. On which legal basis does Zehus process the Personal Data?
The processing of User Data for Contractual Purposes is necessary to allow Users to benefit from the Services offered on the Website and to allow Zehus to respond to any requests for information or assistance from Users, as well as to any comments that Users may provide on the Website.
In particular:
· with regard to Browsing Data, the computer systems and software procedures used to operate this Website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected in order to be associated with identified interested parties, but by its nature could, through processing and association with data held by third parties, allow the Users to be identified. The collection of such Browsing Data is therefore automatic, during the browsing of the Website, and their transmission is mandatory in order to use the Website;
· the Identification Data are spontaneously provided to Zehus by the Users who wish to request information ora ssistance as well as to share their comments with Zehus. Their provision is therefore entirely optional, but if the User chooses to provide the Identification Data to Zehus, their processing is mandatory, otherwise Zehus would not be ableto provide the information or assistance requested nor to consider the comments voluntarily made by Users.
The processing of Users’ Data for the Law Purposes is mandatory, as it is necessary to enable Zehus to comply with applicable laws.
The processing of Users' Data for the Legitimate Business Interest Purpose is carried out, pursuant to Article6(f) of Regulation (EU) 2016/679 (known as the "GDPR"), in pursuit of the Company's legitimate interest (and in the case referred to in paragraph 3(e), also the legitimate interest of the Company's contractual counterparties) to:
· develop and improve the Website and the related Services;
· defend their rights and for the safeguarding of its business assets and vehicle fleet with respect to the purposes mentioned under paragraph 3 letters d) and e) above;
· carry out activities functional to the sale of companies and business units, acquisitions, mergers, demergers or other transformations of the Company.
The processing for Legitimate Business Interest Purposes is not mandatory and Users may object to such processing in the manner set out in paragraph 9 below, unless the Company or its contractual counterparties (in the case referred to in paragraph 3, letter (e)) have an interest which prevails over that of the Users in performing the processing of the Personal Data or the Company processes the Personal Data in order to defend its rights.
5. Who can have access to Personal Data ?
For the purposes referred to in paragraph 3 above, the Personal Data provided by the Users may be brought to the attention of or communicated to the following categories of entities, located within the European Union
i. employees and/or workers of the Company, in the performance of their relative duties or contractual obligations, inherent to the relationship with the Users;
ii. third party service providers who provide assistance or consultancy services to Zehus, with particular - but not exclusive - reference to technological, accounting, administrative, legal and insurance issues;
iii. companies of the group to which Zehus belongs;
iv. entities (including Public Authorities) that have access to the data under applicable law; and
v. with specific reference to the Legitimate Business Interest Purposes set out in paragraph 3(f), to potential purchasers of the Company and entities resulting from the merger or any other form of transformation affecting the Company.
6. Are the Personal Data transferred abroad?
The Personal Data will not be transferred to countries outside the European Economic Area.
7. How does Zehus process Personal Data?
Personal Data will be processed both electronically and/or manually, in any case in such a way as to guarantee the security, protection and confidentiality of the data, due to appropriate administrative, technical, personnel and physical measures against loss, theft and unauthorized use, disclosure or modification.
8. Which is the retention period applicable to the Personal Data?
Users’ Data will be kept only for the time necessary to pursue the specific purposes for which they were collected, as indicated in this policy.
In particular,
· Personal Data collected for Contractual Purposes and Legitimate Business Interests Purposes will be kept for a period equal to the time necessary to provide the relevant Service (including any renewals) and for10 years after its termination, except in cases where the retention for a longer period is required for any litigation, requests of competent authorities or pursuant to applicable legislation;
· Geo-localization data described under point 2 letter c)are collected for 90 days, except in cases where the retention for a longer period is required for any litigation, requests of competent authorities or pursuant to applicable legislation while
· Personal Data collected for Law Purposes will be kept for the term provided for by applicable law.
Finally, Browsing Data will be kept for the term provided for in the cookie policy.
9. What are the Users’ rights?
The User, at any given time, can exercise the following rights, by sending an email to privacy@zehus.it:
· obtain from Zehus confirmation of the existence of Personal Data and to be informed of its content and source, verify its accuracy and request its integration, update or amendment;
· request the erasure, anonymization or restriction of the processing of Personal Data processed in breach of the applicable laws;
· withdraw the consent to the processing of the Personal Data(if and to the extent such a consent is necessary);
· request Zehus to limit the processing of the Personal Data where: (1) the User contests the accuracy of the Personal Data until Zehus have taken sufficient steps to correct or verify its accuracy; (2) the processing is unlawful but you do not want us to erase the Personal Data; (3) Zehus no longer needs the Personal Data for the purposes of the processing, but the User requires them for the establishment, exercise or defence of legal claims; or (4) The User has objected to processing justified on legitimate interests, pending verification as to whether Zehus has compelling legitimate grounds to continue processing;
· object to the processing of the Personal Data, except incase where Zehus demonstrates the existence of legitimate prevailing arguments,or the processing is necessary to exercise or defend Zehus’ rights pursuant toSection 21 of the GDPR;
· request the erasure of the Personal Data without undue delay;
· receive an electronic copy of the Personal Data, if the User would like to port its Personal Data to itself or a different provider, when Zehus is relying upon the User’s consent or the fact that the processing is necessary for the provision of the Services and the Personal Data is processed by automatic means; and
· lodge a complaint with the Italian Data ProtectionSupervisory Authority (https://www.garanteprivacy.it/).
10. Personal Data of Users under 18
The Website is not addressed to users under age of 18 and, in any case, Zehus does not collect and process wittingly Personal Data referred to users under age of 18. In case Zehus is aware of the collection and processing of such Personal Data, Zehus will delete it immediately.
11. Updates
This Privacy Notice might be subsequently updated or integrated, also as consequence of the adoption of local legislations implementing the applicable legislation. In any case Users will be able to review the updated version of the Privacy Notice on the website www.zehus.it.
Cookie Policy
Zehus S.p.A., with registered office in Milan,Viale Don Luigi Sturzo 45, 20154 (the “Company” or “Zehus”), in its capacity of data controller, wishes to inform the users (“Users”) about the use of cookies on the website www.zehus.it (the “Website”). Zehus can be contacted at the email address privacy@zehus.it.
What are cookies?
Cookies are small text strings that the Website sends to the User'sdevice (e.g., computer, smartphone, tablet), where they are stored and thentransmitted back to the Website, the next time the User's visit such Website.Cookies are useful because they allow the Website to recognize the User'sdevice and allow the User to browse on the pages of the Website, by rememberingthe preferences expressed and improving the User's browsing experience.
Cookies can be distinguished according to the following criteria:
(a) Based on the entity managing the cookies:
i. proprietary or first-party cookies: cookiesinstalled directly by the Company through the Website;
ii. third-party cookies: cookies that may be installedthrough the Website by third parties, other than the Company;
b) Based on the length of time they remain active:
i. session cookies: these cookies store the necessaryinformation during the browsing session and are deleted immediately after thesession expires, i.e. when the browser is closed;
ii. persistent cookies: these cookies are stored onthe User's hard drive and the Website reads them each time the User visits it.A persistent cookie has a fixed expiry date, after which it will stop working.
c) Depending on the purpose: these cookies are necessary to enable Usersto use the functionalities of the Site (so-called technical cookies). Othercookies may be used to obtain statistical information, aggregated or not, onthe number of Users accessing the Website and on how the Website is used(so-called analytical cookies). Lastly, other cookies may be used to trace theprofile of Users, so that they may be shown advertisements on the Website consistentwith Users’ interests, tastes and consumption habits (so-called profilingcookies).
Only technical cookies are installed on this Website, as better reportedat the following paragraph "Cookies on the Website".
Cookies can be stored on Users' devices only if they are essential forthe operation of the Website, otherwise the prior consent of the Users will berequired.
For further information on cookies, the User can click here.
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Browser settings
Users may decide to make the installation of any typeof cookie subject to their prior consent or to prevent cookies from beinginstalled, by modifying the settings of their browser. Please note that theconfiguration of each browser is different and is described in the “Help” menuof each browser. In order to understand how to change cookies settings, Userscan consult the following links:
Google Chrome
Mozilla Firefox
Internet Explorer
Opera
Safari
Users can also visit the website https://www.aboutcookies.org/, whichcontains comprehensive information on how to prevent the installation ofcookies on a wide range of desktop browsers.
Cookies installed on the Website
The Website uses technicalcookies which are strictly necessary to the functionality of the Website.
Name of the service/part that affixs the cookie
www.zehus.it
Name of the cookie
phpsessid
Purpose of the cookie
Allows WEB sites to store data about the state of serialization
Cookie duration
Session Cookie
Name of the cookie
displaycookieconsent
Purpose of the cookie
A technical cookie used to track User’s consent and possibly not to re-propose the short information on cookies in the future pages or possibly the second User visit.
Cookie duration
Session Cookie
Users can turn off the technical cookies listed within the table, by changing their browser settings (please see par. Browser settings above). However, disabling these cookies might compromise the correct browsing and functionality of the Website.
Changes and updates
The Company may make changes and/or additions tothis Cookie Policy, including as a result of any amendments to applicable laws. In any event, the updated version of this Cookies Policy will always beavailable on this Website, to be consulted by Users.