Privacy Policy
The privacy policy below (the “Policy”), drawn up in accordance with Art. 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter the “GDPR”), is intended to set out the methods of processing and collection of the personal data of users who use the Services provided by Free2Move eSolutions S.p. A. as specified in further detail in the terms of use (“Legal Notice”), through the https://esolutions.free2move.com website and/or the "eSolutions Charging" and "Maserati Home Charge" apps (hereinafter “Site/App/Software”).
Please read this Policy carefully before using the Site/App/Software, because it explains how we will process personal data (the “Data”). Use of the Site/App/Software indicates that the user accepts this Policy.
1) DATA CONTROLLER
Free2move eSolutions S.p.A. (hereinafter “eSolutions” or the “Company”) with its registered office at Piazzale Lodi, 3 – 20137 Milan is the Data Controller of the user personal data gathered during browsing activity on the Site/App/Software.
2) PERSONAL DATA PROCESSED AND PURPOSES OF PROCESSING
We care about users’ privacy. We collect and process various types of Data via the Site/App/Software.
These include:
- The information provided by the user when requesting and using our services and through the Site/App/Software: given name, surname, telephone number, e-mail address, payment details, home address, tax code/VAT number;
- Information we need when the user reports an issue via the Site/App/Software
- Data associated with browsing the Site and using the Data Controller’s App and Software, such as IP address, location (country), information on pages visited by the user within the Site, time spent accessing the Site/App/Software, time spent browsing each page, clickstream analysis. While the Company does not collect this information in order to link it to specific users, it is still possible to identify those users either directly via that information or by using other information collected;
- The data on the geographical location data of the user using the Site/App/Software; Information collected with cookies. For further details, go to https://www.esolutions.free2move.com/cookie-policy.
3) INFORMATION ON PROCESSING OF PERSONAL DATA
User Data will be processed to handle and fulfil requests and for general administration purposes by the Company as a data controller under the applicable data protection legislation, as follows:
Purposes | Data / Categories of data (mandatory data are marked with an *) | Legal basis |
---|---|---|
Contact, communication and request fulfilment | *Respective identification and contact details, where applicable (given name, surname, mobile number, e-mail address, payment details, home address, tax code/VAT number) | Purposes related to the performance of a contract or to the procedures to be followed at the request of the data subject prior to entering into a contract in accordance with Art. 6.1 b) of the General Data Protection Regulation (GDPR) |
For further details, see the Cookies Policy | Information collected via cookies | Purposes for which the user has provided consent in accordance with Art. 6.1 a) of the GDPR, unless the right to withdraw consent has been exercised (GDPR Art. 7(3)) |
|
*Respective geolocation data | Purposes for which the user has provided consent in accordance with Art. 6.1 a) of the GDPR, unless the right to withdraw consent has been exercised (GDPR Art. 7(3)). Purposes related to the performance of a contract or to the procedures to be followed at the request of the data subject prior to entering into a contract in accordance with Art. 6.1 b) of the General Data Protection Regulation (GDPR) |
Newsletter sign-up | *Respective identification and contact details, where applicable (given name, surname, mobile number, e-mail address) | Purposes for which the user has provided consent in accordance with Art. 6.1 a) of the GDPR, unless the right to withdraw consent has been exercised (GDPR Art. 7(3)) |
The Data marked with an asterisk (*) are mandatory and a contractual requirement. The user is therefore obliged to provide the said Data. In case you do not provide the Data, we cannot fulfil your request.
4) METHODS OF PROCESSING OF PERSONAL DATA
The Data are processed using computer systems and organisational and logical methods strictly related to the indicated purposes and all technical and procedural security measures are implemented to ensure the confidentiality, integrity, availability and resilience of the data processing, in accordance with GDPR Art. 32.
The personal data may be transferred abroad, including outside the EU, in accordance with the applicable regulations.
5) DATA TRANSFER OUTSIDE THE EEA
Within its contractual relations, the Company may transfer the Data to countries outside the European Economic Area (EEA) and may store them in databases managed by entities acting on behalf of the Data Controller. Database management and Data processing are restricted to the aforementioned purposes of the processing and are carried out in accordance with the GDPR and – where applicable – with local data protection legislation.
In case the Data are transferred outside the EEA, the Company will adopt any appropriate contractual measures to guarantee adequate protection of the Data, including but not limited to agreements based on the standard contractual clauses adopted by the European Commission, and additional measures where required, to govern the transfer of Data outside the EEA.
To receive information about the protection referred to and to obtain a copy of the respective safeguards, please contact us via e-mail to privacy@f2m-esolutions.com.
6) COMMUNICATION OF PERSONAL DATA
The Data will be communicated to the persons authorised to process the Data, appointed from within the Company’s staff.
The Data may be communicated by the Company exclusively for the purposes indicated and, where necessary, to the following categories of entities:
- Companies belonging to the same group and/or with a shareholding in F2MeS
- Technical service providers
- Hosting providers
- Installation Service Providers
- Information technology service providers
- Customer Support Service Providers
- Service providers for marketing activities
- Accounting, administrative, legal, tax and financial consultants
- Debt collection service providers
- Where necessary, the competent judicial authorities
- Where necessary, public administrations and supervisory and control authorities
The Data will not be disclosed.
The entities belonging to the categories listed above may act, as appropriate, as data processors (and in this case will receive the appropriate instructions from the Company) or as independent data controllers. In the latter case, the Data will be communicated only with the express consent of the parties concerned, except in cases where the communication is mandatory or necessary pursuant to applicable law or for purposes for which the consent of the party concerned is not required.
7) RIGHTS OF THE DATA SUBJECT
The Data Controller must provide the data subjects with the option to exercise the following privacy rights:- the right to obtain confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data, as set out in GDPR Art. 15 (Right of access);
- the right to obtain rectification of inaccurate personal data concerning him or to have incomplete personal data completed (Right to rectification);
- the right to obtain the erasure of personal data concerning him or her where one of the grounds set out in GDPR Art. 17 applies (Right to be forgotten);
- the right to obtain restriction of processing where one or more of the cases set out in GDPR Art. 18 applies (Right to restriction of processing);
- the right to receive the personal data concerning him or her in a structured, commonly used and machine-readable format and the right to transmit those data to another controller (Right to data portability).
The user is further entitled to withdraw his or her consent to the data processing at any time without prejudice to the lawfulness of the processing based on the consent given before the opt-out.
To exercise his or her rights, the user can send an e-mail with the subject “PRIVACY”, to privacy@f2m-esolutions.com.
The data subject can contact the Italian Data Protection Authority when he or she believes the data processing has been carried out in violation of the GDPR. Further information is available on the website http://www.garanteprivacy.it.
8) LINKS TO THIRD-PARTY WEBSITES
Third-party websites accessible from this Site/App/Software website are the responsibility of the respective third parties.
The Company waives all responsibility concerning requests and/or provision of Data by third-party websites.
The Site/App/Software may also contain iFrames with third-party content. The Company is not responsible for third-party content presented in iFrames. The information presented therein is the sole responsibility of the owners of the said websites.
The Company has no control or responsibility for the content of independent websites and provides the said external content to its visitors for their convenience. As a result, when a user visits a page including such content, he or she may receive cookies from these third-party websites.
The Company does not control the distribution of these cookies.
Please check the third party’s cookies policy and privacy policy for more information.
9) LINKS TO SOCIAL NETWORKS
The Site/App/Software contain links to social networks.
In order to protect the user's Data while visiting the Site/App/Software, we do not use social plugins. Instead, HTML links are embedded in the Site/App/Software, enabling easy sharing on social media platforms. Embedding the link prevents a direct connection with various social media network servers when opening a page from our website. When clicking on one of the buttons, a browser window opens and directs the user to the respective service provider website on which (after having logged in), for example, the “Like” or “Share” button can be used.
For more information on the purpose and scope of data processing and further use of your Data by the provider and their websites as well as your rights and possible settings to protect your privacy, please refer to the data protection information of the respective service provider.
10) DATA RETENTION
The user's Data will be stored until he or she unsubscribes from the service. The Data will be stored in compliance with the terms provided for by law for the retention of administrative documents, after which they will be deleted or anonymised.
11) AMENDMENTS
The Company reserves the right to amend the Privacy Policy in whole or in part, or merely to update the content thereof (e.g. as a result of changes in applicable law). We will publish any update on this website. You should therefore periodically review any changes to our Privacy Policy.
12) CONTACT DETAILS
Free2move eSolutions S.p.A. – Piazzale Lodi, 3 – 20137 Milan – Italy.
You can contact the Company by writing an e-mail to privacy@f2m-esolutions.com.
January 2024