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.
Personal data processing at issue is related to making available to you the free wi-fi service on board of our trains as well as the Italolive portal, which will allow you to enjoy numerous multimedia contents, such as video, audio, magazine, e-book, etc. Once the authentication is performed, you can browse freely and for free on the internet network. This service is provided by a third party acting as an Internet service provider who, with reference to the processing of your personal data, operates as an independent Data Controller. Therefore, we invite you to read the information notice on the processing of personal data provided by the aforementioned service provider in phase of authentication to the free wi-fi service.
When you navigate inside our Portal, information capable of identifying your device or browser may be collected in the form of files called “cookies. "Cookies" are encrypted text strings that are stored by a website on the user's device in order to allow their rapid identification at a later time. These files allow you to customize a website, to provide the user with easier navigation and, through a quantitative verification of access to the various web pages, a better presentation of the most requested information. Cookies generally use anonymous information and, therefore, do not allow the processing of data relating to your person. Furthermore, cookies may be used to store your login data and therefore make your recognition automatic (and therefore the User Name & Password entry procedure is superfluous). The cookies we use include both session cookies, which are automatically deleted when the browser is closed, and persistent cookies, which remain stored for a predetermined period of time. ITALO uses only first-party cookies; therefore the sending of third-party cookies is excluded. In general, ITALO uses only “technical cookies”, necessary in order to guarantee the user the best functionality of the Italolive portal and to provide the service requested.
1. Categories of personal data processed
ITALO will process the following categories of personal data provided by You:
- Common personal data, such as Your e-mail address and the state of Your optional consent given / denied by You with reference to the marketing purposes indicated in the following par. 2;
2. Purposes of the processing activies
Your Personal Data will be processed by ITALO for the following purposes:
a) to make possible your navigation on Italolive portal;
b) after your consent, for the sending by e-mail of informative and promotional communications, including commercial messages (such as our newsletter), advertising materials and/or offers of goods and services, sent by Italo, by its controlling companies, by subsidiaries and/or by companies in which it has interests, as well as by individuals or organizations contractually tied to ITALO and/or that engage in commercial activities in collaboration with ITALO. With regard to the purpose indicated under letter (a), presentation of your personal information is obligatory. Should you refuse, and/or should the information presented prove inexact and/or incomplete, then this could make impossible Your authentication and usage of free wi-fi services.
With regard to the further purpose indicated under letter (b), the presentation of your personal information is optional. Nevertheless, should you refuse to present it, or should the information presented prove to be inexact and/or incomplete, then this could make impossible the performance of the so-called marketing activities.
You may request that the cookies be deactivated by modifying the settings of the browser, but a similar deactivation will slow down or prevent access to certain portions of the Portal or to sites accessible over Internet.
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
Your personal data shall be processed by all persons acting under the authority of the Data Controller, authorized to processing activities during the execution of their duties. Your data shall 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, or other subjects and/or organizations that handle (on behalf of ITALO or independently)): (i) the management of authentication/access to the Services; (ii) the sending of informational and promotional communications, including commercial messages, advertising materials and/or offers of goods and services, in accordance with the procedures indicated under paragraph 2, letter (b) above; consultants who assist the Company in various areas, in particular with regard to matters involving legal affairs, taxes, social security, accounting and organizational affairs; any other subject to which the information must be communicated, based on an express provision of the law.
Your personal data could possibly be transferred abroad, in conformity with the provisions of the rules and regulations currently in force, including to countries that are not members of the European Union, but where the Company decides to pursue its interest.. Transfer of personal data to a third country, it is granted by an adequacy decision by the Commission or it is made in order to provide appropriate and adequate guarantee according to Article 46 or 47 or 49 GDPR.
5. Criteria used to determine the period for which the personal data will be stored
Your personal data will be stored for a period necessary to pursue the purposes for which they were collected and, in any case, for a period of time no longer than time necessary to fulfill regulatory obligations. Personal data will be stored, with reference to marketing activities indicated under par. 2 lett b), until you withdraw your consent.
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 email@example.com. To Your request, the Company will give You a feedback in accordance with GDPR.
You have the right to:
- 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; - revoke the consent previously given, without prejudice to the lawfulness of the processing based on consent before the revocation; - obtain data portability; - lodge a complaint with the competent supervisory authority.
7. Browser Settings. Cookies management and direct link with the dedicated browser section
- Internet Explorer - Firefox - Google Chrome - Safari
8. Data Controller and Data Processor for the personal data processing
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 its legal representative pro tempore. 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 firstname.lastname@example.org. 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 contact is email@example.com
Italo – Nuovo Trasporto Viaggiatori S.p.A.
This is an English courtesy translation of the original documentation prepared in Italian language. Please consider that only the original version in italian language has legal value.