INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS
In compliance with the obligations arising from EU legislation (GDPR European Regulation for the protection of personal data 2016/679)
Dear user,
we wish to inform you that, pursuant to Articles 13 and 14 of the GDPR 2016/679, the information and data acquired by SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa will be processed in compliance with the principles referred to therein.
SALT qualifies as a “data controller” within the meaning of the Data Protection Regulation (EU) 2016/679 (“GDPR”), i.e., the entity that decides for what purposes and in what manner personal data is to be processed (hereafter, the Company is also referred to as the “Data Controller”).
The Data Controller is obliged to inform the interested parties in advance about the nature of the personal data being processed, the purposes and methods of processing, the possible recipients of the data and their rights.
The information is aimed at all the subjects interacting with SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa, including the company’s website.
1. Types of Data Collected
1.1 SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa collects Personal Data, Contact Data, Identification Data such as, by way of example, name, surname, date of birth, address, sex, nationality, e-mail contact, license plate, data that may be necessary for the purposes of managing the highway service, data for managing highway claims and any photographic images of the vehicle in the event of lane anomalies relating to the toll due.
1.2 Personal Data may be entered voluntarily by the User while browsing the company website (cookie policy). Personal data may also be provided during the use of the service if the conditions requiring their collection occur (e.g. toll anomalies, complaints, accidents, etc.).
1.3 The User assumes responsibility for the Personal Data, even of third parties, releasing the Owner from any liability.
1.4 The processing of all such Personal Data shall be carried out in compliance with the relevant legislation, reminding you that consent need not be given in order to use the highway service.
2. Purpose of the processing
2.1 The processing of the collected data is aimed at the management of the highway service, with specific reference to the contractual obligations deriving from the use of the service and concerning the functions institutionally carried out by SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa and in particular:
– communications with the user concerning the use of the service and the infrastructure as well as toll transactions and any related requests, carried out by SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa;
– communications with the user concerning the safety deriving from the use of the service and the infrastructure of the Ligure Toscano and Autocisa Sections;
– communications of a contractual nature with customers and/or suppliers concerning the administrative, commercial, fiscal, legal relations that may arise (including data acquired for the management of the Telepass contractual relationship or other – e.g. sale of Viacard products – at Punto Blu in Lido di Camaiore LU and at Punto Blu in Ponte Taro PR);
– communications with the user regarding the management of claims made on the infrastructure of the two Ligure Toscano and Autocisa sections;
– communications with the user concerning the management of complaints relating to the use of the service and the infrastructure managed by SALT Società Autostrada Ligure Toscana p.a. – Ligure Toscano Section and Autocisa Section;
– interventions on the website or by e-mail of SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa;
2.2 As well as to guarantee any obligations arising from the relationship established with the user.
3. Processing methods
3.1 Personal Data may be processed in paper, computerized and online form and entered into relevant databases which may be accessed, and therefore come to the attention of operators, who may carry out consultation, use, processing, comparison and any other appropriate operation, including automated in compliance with the provisions of the law necessary to ensure, among other things, the confidentiality and security of data and the accuracy, updating and relevance of the same in relation to the stated purposes.
3.2 In addition, we inform you that the computer systems and software procedures used to operate the service and this website may acquire, during their normal operation, your Personal Data, the transmission of which is implicit in the use of Internet communication protocols. It is, however, data collected not to be associated with specific individuals, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users who connect to the site, URI (Uniform Resource Identifier) of requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters regarding the operating system and computer environment. These data are used only to obtain anonymous statistical information on the use of the site and to check its correct functioning. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.
3.3 We inform you that the data managed as a result of contractual relationships established with SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa will therefore be processed in compliance with Regulation (EU) 2016/679 and used only for the purposes aimed at the proper functioning of business activities and the service offered.
4. Nature of data conferment
4.1 The transmission of data is:
a) Compulsory for the achievement of the purposes related to the obligations provided for by laws, regulations or Community legislation;
b) Optional, but sometimes necessary for the correct establishment and/or continuation of the relationship with our Company, and for the correct navigation on the site.
4.2 Any refusal to provide data or their incompleteness may make it impossible for the Owner to provide the services in their entirety and the legal obligations.
5. Scope of Data Communication
5.1 Your data may be disclosed, where necessary for the provision of services, to the staff of our Company (in the areas of Information Systems, Administration, Legal, Operations, Technical, depending on the purpose to be achieved possibly on the basis of the request of the interested party) and/or to third party companies appointed by SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa “External Managers”, in relation to the activities carried out.
5.2 Personal data may also be processed by third parties to whom the Company entrusts activities and services, or by public or controlling entities to whom the Company transmits data in compliance with regulatory obligations. These recipients will operate, depending on the case, as data controllers or autonomous holders and are included in the following categories:
(a) companies belonging to the same group as the Data Controller;
(b) subjects that provide management and maintenance services of information systems;
(c) subjects that provide legal, administrative, accounting, fiscal and financial advice and assistance;
(d) public bodies and public authorities;
(e) Banks, credit institutions, factoring companies, and debt collection companies.
5.3 The above recipients may also be established abroad, in EU or non-EU countries. In the latter case, the transfer of the data is carried out by virtue of the existence of a resolution of the European Commission about the adequacy of the level of data protection of the non-EU country. Moreover, it can also be carried out on the basis of appropriate and suitable guarantees provided by the Articles 46 or 47 of the GDPR (e.g., signing of the “standard clauses” of data protection adopted by the European Commission) or on the basis of additional prerequisites of legitimacy provided by the Article 49 of the GDPR. For further information on the possible transfer of personal data outside the European Union, please write to privacy@salt.it
5.4 The areas of communication mentioned above do not require your authorization, as they are functional to the provision of services, to defend a right in court or to pursue a legitimate interest of the owner. For any further communications that require your prior consent, we will be in touch.
6. Data retention period
The personal data collected, also taking into account any choices made by the interested parties relating to cancellation or revocation during processing, will be processed for a period corresponding to the needs for which they were collected, in compliance with contractual obligations entered into with the interested party or in accordance with applicable laws or regulations or for a period deemed appropriate for the defense in court.
7. Owner – DPO and Data Processors
The Data Controller, for all the processing purposes expressed in this information notice, is SALT Società Autostrada Ligure Toscana p.a. – Tronco Ligure Toscano and Tronco Autocisa, with registered office in Via Don Enrico Tazzoli 9, 55041 Lido di Camaiore (LU).
8. Data Protection Officer
The Company employs a Data Protection Officer (also known as a “Data Protection Officer” or “DPO”). The DPO can be contacted through the following communication channel: dpo@salt.it
9. Rights of the data subject
As foreseen by the regulation, you have the right to know which personal data is used, its origin, verify its accuracy or request its integration or updating, or correction or limitation. You also have the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their processing, and to amend or revoke the consents previously provided, without affecting the lawfulness of the processing based on the consent given before the revocation.
We also inform you that you have the right to complain to the Guarantor of the protection of personal data whose references you will find at the following link www.garanteprivacy.it
Requests can be handled by writing to privacy@salt.it