Pursuant to and for the effects of article 13 Regulation (EU) 2016/679 of the European Parliament and of the Counsil of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or simply “Regulation” or “GDPR”), we inform you that ITALO - Nuovo Trasporto Viaggiatori S.p.A. (ITALO) collects and processes Your personal data in compliance with data protection law in force and, in any case, in accordance with the principles of confidentiality that our Company is inspired by.
1. Categories of personal data processed
Italo will process the following categories of personal data provided by You:
Personal data, such as, for example, name, surname, phone, e-mail, customer loyalty code;
Bank and/or payment details;
Data related to the device used, such as, for example, type of device, IP address;
In case of invoice request, VAT number, surname, business name, address, e-mail.
2. Purposes of the processing activities
Your Personal Data will be processed by ITALO for:
a. purposes related to the fulfillment of contractual obligations, including administrative and accounting purposes relating to the execution of the transport service requested by you, including the execution of the activities envisaged by Regulation (EU) no. 2007/1371 of the European Parliament and of the Council of 23 October 2007 concerning the rights and obligations of passengers in railway transport.
In particular, we inform you that your contact details (e.g. e-mail address, telephone number) may be used to contact you in order to allow you to express an optional opinion about the quality of the services of ITALO you have used;
b. purposes related to the fulfillment of provisions of law and regulations currently in force;
c. fraud prevention activities. This purpose, whose legal basis is the legitimate interest of ITALO, involves the possibility of action in order to counteract any fraud event;
d. the Personal Data you have made available to ITALO will also be processed for purposes related to direct sales of services similar to those purchased by you, pursuant to the provisions of art. 130, paragraph 4 of Legislative Decree n. 196/2003 as subsequently modified and amended. It will be possible for the Company to use the email addresses, provided by you in the context of the purchase of the transport service, in order to keep you informed about the services offered by ITALO on board of its trains, collateral to the transportation service. The legal basis for this processing purpose is the legitimate interest of the Data Controller to offer passengers a better travel experience. However, you may, at any time (initially or on the occasion of subsequent communications) object to such processing also by means of a specific request to the Data Controller, formulated in accordance with the provisions of article 6 of this information notice.
We inform You that, with reference to the purposes specified in points a), b) and c), the provision of Your Personal Data is mandatory.
Your refusal and / or the provision of inaccurate and / or incomplete information would determine:
the impossibility to stipulate the transport contract and / or to guarantee the regular and timely execution of the contractual relationship;
the mismatch of the results of the processing of Personal Data with the obligations imposed by current legislation, including tax law;
the impossibility on the part of ITALO to carry out the activities envisaged by Regulation (EU) no. 2007/1371 of the European Parliament and of the Council of 23 October 2007 on the rights and obligations of passengers in railway transport.
In addition, the information relating to the tickets purchased by you will also be used, in aggregate form following specific anonymisation activities, for the execution of statistical analysis activities on performance of sales of Italo.
3. Methods of the processing activities
In relation to the purposes indicated, Your personal data will be processed by suitable paper-based, electronic and/or Web-based instruments with logic strictly related to the aforesaid purposes and, in any case, such as to ensure data security and confidentiality.
4. Recipients or categories of recipients of the personal data
Members of the Board of Directors, the Data Protection Officer and, in any case, the Data Processors and all persons acting under the authority of the Data Controller, authorized to processing activities may be aware of Your personal data during the execution of their duties.
Your Personal Data may be communicated to any qualified entities that provide ITALO services necessary for the above-mentioned purposes, such as, for example, parent companies, subsidiaries, affiliates, entities, institutions and / or companies that manage and / or participate in the management and / or maintenance of websites and electronic and / or telematic tools used by ITALO; suppliers, contractors, subcontractors, banking and / or insurance companies, consultants who assist ITALO with particular reference to legal, tax, administrative, organizational issues; to police or judicial authorities in the context of investigations or judicial police investigations for the purpose of prevention, detection or repression of crimes; any other party to whom the Data must be communicated on the basis of a specific legal provision.
Your personal data may be transferred abroad, also in countries outside the European Union, where the Company pursues its own interest, in accordance with applicable law.
5. Duration and criteria used to determine the period for which the personal data will be stored
For the purposes a), b), c) and d) referred to in paragraph 2 "Purposes of Processing activities" of this information notice, your Personal Data will be processed only for the time strictly necessary to achieve the same purposes for which they are acquired.
5.2 Retention period
Your Personal Data will be stored in accordance with the following criteria:
- the Data processed for purposes related to the fulfillment of contractual and legal obligations with reference to letters a), b) and c) of paragraph 2 "Purposes of Processing activities" of this information notice, will be kept for a period of 10 years following upon purchase, unless the need for further conservation arises, to allow ITALO to defend its rights;
- the Data processed for purposes of direct sales activities of services similar to those purchased by you as per letter d) of paragraph 2 "Purpose of the Processing activities" of this information notice, will be kept for a maximum period of 24 months;
6. Data subject’s rights
We would like to inform You that at every time You could exercise Your rights according to Article 7 and Articles 15-22 of GDPR 2016/679. To exercise Your rights, You can contact the Data Controller at firstname.lastname@example.org. To Your request, the Company will give You a feedback without delay within 30 days. You have the right to:
- revoke the consent previously given, without prejudice to the lawfulness of the processing based on consent before the revocation;
- request from the Data Controller access to or rectification or erasure of personal data (“right to be forgotten”) or the restriction of processing concerning You or to object to processing; - obtain data portability;
- lodge a complaint with the competent supervisory authority.
7. Data Controller and Data Processor for processing activities
The Data Controller is ITALO – Nuovo Trasporto Viaggiatori S.p.A., with registered office in Viale del Policlinico, no. 149/B, Rome, Italy, in the person of Legal Representative. Any request relating to the personal data processed by ITALO - Nuovo Trasporto Viaggiatori S.p.A. may be sent to the company’s registered office or to its email email@example.com.
The updated list of Data Processors is made available by the Company and may be obtained upon a specific request submitted as detailed above.
The Data Protection Officer’s contacts is firstname.lastname@example.org
This privacy information notice could be updated. Italo invites You to periodically visit this page in order to know how does Italo process Your Data.
Last updated November 2019.
ITALO – Nuovo Trasporto Viaggiatori S.p.A.