PRIVACY NOTICE PURSUANT TO ART. 13 OF EU REGULATION 2016/679
Adriafer Rail Services
Cookies, Personal Data, Information, Regulation, Site, Treatment, Users.
- Cookies: Cookies are text files (letters and/or numbers) containing packets of information that are stored on the User’s computer or mobile device every time the User visits a website through a browser. On each subsequent visit, the browser sends the cookies back to the website that originated them. Cookies can be stored only for the time of use of a particular site (i.e. session cookies), or for a longer period of time independent of the session (i.e. persistent cookies).
- Personal Data: any information relating to a natural person who is identified or identifiable, directly or indirectly, by reference to name, an identification number, location data, an online identifier or features of his physical, physiological, genetic, mental, economic, cultural or social identity.
- Information Notice: this document, consisting of the Personal Data Processing Information and the Cookies Information.
- Regulation: EU Regulation 2016/679 of 27 April 2016.
- Site: this website.
- Processing: any operation or set of operations concerning Personal Data, such as, but not limited to, collection, organisation, structuring, storage, modification, retrieval, consultation, use, disclosure, interconnection, restriction, erasure and destruction.
- Users: users of the Website.
2. DATA CONTROLLER
Adriafer Rail Services S.r.l.
The Data Controller referred to in this Information Notice is Adriafer Rail Services S.r.l., with registered office in Trieste, Punto F.co Nuovo – Magazzino n.53, snc – 34123, C.F./P.IVA and Register of Companies of Venezia Giulia no.
Any request by the User relating to the Processing carried out by Adriafer Rail Services concerning his or her Personal Data (including the exercise of the rights referred to in point 7 below) should be addressed to Adriafer Rail Services by post to its registered office, or by e-mail to the following address email@example.com;
3. PURPOSE AND LEGAL BASIS OF PROCESSING
Adriafer Rail Services collects and uses Users’ Personal Data for the following purposes:
- Browsing the Site: consent;
- Management of contact requests: consent;
Managing contact requests received at the Site through the completion of the contact form or by e-mail from Users.The collection of Personal Data for the purposes set out in point b) is necessary for the handling of contact requests sent by the User. Such Processing is based on the free, specific, informed and unequivocal consent of the User, expressed by means of a declaration or positive action (e.g. flag) on the Site. Withdrawal of consent may be exercised at any time, following the instructions set out in section 7 lit. (a) of this Information Notice.
- Site improvement: legitimate interest.
Carry out statistical analysis on the use of the Site, to improve the Site. Where possible, Adriafer Rail Services uses anonymous Personal Data (Personal Data that does not identify or make Users identifiable) to achieve this purpose.The Processing referred to in point d) is based on the legitimate interest of Adriafer Rail Services consisting of the benefit that the Company may obtain from the provision of a Site that facilitates navigation and improves the experience of Users, which Adriafer Rail Services considers to be overriding with respect to the Users’ right to privacy. Opposition to this Processing (if it does not concern anonymous data) may be exercised at any time by following the instructions set out in point 7 letter f) of this Information Notice.
4. MODE OF DATA COLLECTION
Adriafer Rail Services collects Personal Data in the following ways:
- Personal Data entered on the Site or communicated by e-mail by Users;
Personal Data entered on the Site or communicated by e-mail by Users: this is Personal Data provided, by way of example but not limited to, when filling in the contact form, or by e-mail sent to the Adriafer Rail Services addresses available on the Site (e.g. firstname.lastname@example.org or email@example.com,);
- Personal data automatically collected by the Site (via Cookies).
Personal Data collected automatically by the Site: this is Personal Data collected automatically by the Site through, but not limited to, Cookies (for further information, Adriafer Rail Services recommends that you read the Cookies Policy available below in sections 8 and 9).
5. POSSIBLE CATEGORIES OF RECIPIENTS OF PERSONAL DATA
Employees, third-party service providers, technical and commercial third parties.
Personal Data are processed by Adriafer Rail Services and/or by third parties, selected for their reliability and competence, to whom they may be communicated as necessary or appropriate, provided that they are within Italy, the European Union. In particular, Adriafer Rail Services informs Users that Personal Data may be processed by, and/or communicated to:
- Employees and/or collaborators of Adriafer Rail Services;
- third-party service providers necessary to ensure the operation of the Site (by way of example: hosting services company);
- third parties providing services for the analysis of navigation data on the Site (Google Analytics).
6. PERSONAL DATA RETENTION PERIOD (OR CRITERIA FOR DETERMINATION)
Personal Data are kept by Adriafer Rail Services for the period of time strictly necessary to achieve the purposes for which they were collected, as set out in point 3 above. In particular, subject to the exercise of the right of revocation of consent as set out in section 7 letter a) below or the right of objection as set out in section 7 letter f), Adriafer Rail Services retains the Personal Data for the following periods of time:
- Cookies: see Cookies Policy;
Cookies: for the purpose mentioned under point 3 letter a), we recommend reading the Cookies Policy, available under points 8 and 9 below;
- Personal data collected for contact requests: 6 months after receipt of request.
Personal Data spontaneously sent to Adriafer Rail Services via the “Contact” form or by e-mail: for the purpose referred to in point 3 letter b), for the period of 6 months from receipt of the contact request, in order to verify whether the User requires further assistance on the same subject. Notwithstanding this time limit, in the event of a complaint or grievance being sent via the ‘Contact’ form, the User’s Personal Data shall be retained for the period referred to in point f) below.
Once these terms have expired, Adriafer Rail Services will automatically delete the Personal Data collected or irreversibly transform it into anonymous form.
7. USER RIGHTS
Revocation of consent, access to Personal Data, rectification or integration of Personal Data, deletion of Personal Data, restriction of Processing, objection to Processing, portability of Personal Data, data breach, complaint to competent authorities.
Pursuant to and for the purposes of the Rules, for the period referred to in Section 6 of this Notice, each User is entitled to:
- with reference to the Processing referred to in point 3 letter b), withdraw consent at any time without prejudice to the lawfulness of the Processing, by sending an e-mail to Adriafer Rail Services or by exercising the opt-out in Adriafer Rail Services’ commercial communications (see article 7 of the Regulation);
- request from Adriafer Rail Services access to the Personal Data and information on the relevant Processing and any copy in electronic format, unless specifically requested otherwise by the User (see article 15 of the Regulation);
- request the rectification and/or integration of Personal Data, without undue delay (see Article 16 of the Regulation);
- for specific reasons (e.g. unlawful processing, revocation of consent, non-existence of the purpose of the Processing), request the deletion of Personal Data, without undue delay (see Article 17 of the Regulation);
- in specific circumstances (e.g. inaccuracy of Personal Data, unlawfulness of the Processing, exercise of a right in a court of law), request the restriction of the Processing (Article 18 of the Regulation);
- receive in a structured, commonly used and readable format the Personal Data concerning him/her and, consequently, exercise the right of portability and transmit such data to another data controller (Art. 19 of the Regulation);
- with reference to the Processing referred to in point 3 letter d), object at any time to the Processing of Personal Data by sending an e-mail to Adriafer Rail Services (see Article 21 of the Regulation);
- to be informed by Adriafer without undue delay of any breach or unauthorised access by third parties to its systems containing Personal Data (so-called data breach – see Article 34 of the Regulation);
- lodge a complaint with the supervisory authority of the EU country in which he/she resides, works or where he/she considers that his/her rights have been infringed (see Article 77 of the Regulation).
For further information on the terms and conditions for the exercise of the rights granted to the User, the latter may consult the text of the EU Regulation published at the following link https://eur-lex.europa.eu/legal-content/IT/TXT/PDF/?uri=CELEX:32016R0679&from=IT, or contact Adriafer Rail Services in the forms provided for in point 2 of this Information Notice.
8. TYPES OF COOKIES
Technical cookies, necessary and functional for browsing the Site
Cookies necessary for navigation:
- Purpose: these are the Cookies that are indispensable to ensure the correct operation of the Site, as they allow the User to navigate within it and use its basic functionalities. Under no circumstances do these cookies collect information that can be used for commercial purposes. These necessary Cookies serve, among other things, to: (i) store data provided by the User during a browser session; (ii) maintain the User’s preferences and credentials while browsing the Site; (iii) display content in the chosen language at each access, recognising which country the User is connecting from (and remembering this setting in future accesses). For the Site to function properly, acceptance of the Cookies necessary for navigation is required, as failure to accept them may prevent, or greatly impair, the ability to navigate the Site.
- Data collected: navigation data.
- Duration: session cookie.
Functional cookies for navigation:
- Purpose: these are cookies that make it easier to use the Site. These cookies are able to store the User’s data for logging in to the Site, preventing the same data from having to be re-entered at each browsing session. These Cookies are intended to facilitate and speed up the use of the Site, but are not indispensable for navigating it.
- Data collected: data relating to navigation and preferences expressed during navigation.
- Duration: Session and permanent cookies.
Third-party analytical cookies
Cookie di Google Analytics
- Purpose: these are cookies provided by Google Inc. to monitor, in an anonymous and aggregate form, the statistical analysis of Users’ traffic on the Site in order to adapt the Site to the results of such analysis, in accordance with the interests shown by the Users themselves.
- Data collected: data relating to the User’s computer and visit to the Site and which, under no circumstances, allow Adriafer to autonomously trace the Users’ Personal Data: (i) the domain from which it accesses the Internet; (ii) the web address from which the User connected to the Site, if available; (iii) the date and time of the connection with the Site, how long the connection lasted and which pages were visited; (iv) the Internet Protocol address (IP) of the User; (v) the operating system of the computer and the browser used by the User; (vi) the aggregate demographic detail of Users accessing the Site.
- Duration: Session cookies.
For further information on Google analytics, the User may consult the following webpage: https://tools.google.com/dlpage/gaoptout.
9. ACCEPTANCE AND WAIVER OF COOKIES
Implied consent, banners, access to browser control panels, Your Online Choices service
The User may consent to the use of the Cookies described in section 8 above in the following ways:
- by continuing to browse the Site or by accessing any area of the Site;
- or by clicking on the ‘I agree’ button on the Cookies information banner published on the Site.
The manifestation of consent may be modified at any time by the User in accordance with the indications contained in this Policy, which is accessible via a link in the banner and on each page of the Site (footer). To this end, the User may also contact Adriafer Rail Services at any time to obtain information on the concrete ways in which he/she can exercise his/her consent/selective refusal or delete the Cookies.
However, Adriafer Rail Services specifies that deactivating the technical Cookies indicated in section 10 above may prevent proper navigation on the Site and/or limit its usability. Consequently, in order to better take advantage of the services of the Company accessible through the Site, the User is strongly advised not to proceed with the deactivation of these technical Cookies.
That said, with reference to all the Cookies on the Site, the User may change the settings relating to them, in the manner provided in the control panels of the browser used, such as, by way of example:
- Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
- Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
- Internet Explorer: https://support.microsoft.com/en-us/products/windows?os=windows-7
- Safari: https://support.apple.com/kb/PH19255?locale=it_IT
Moreover, with specific reference to profiling and advertising Cookies, in addition to being able to use the tools provided by the browser to activate or deactivate individual Cookies, Adriafer Rail Services informs the User that the website www.youronlinechoices.com lists the main providers that work with website operators to collect and use information useful for behavioural advertising. The User may deactivate or activate all companies (including the Company) or, alternatively, adjust his or her preferences individually for each company. In order to do so, the User may use the tool on www.youronlinechoices.com/it/le-tue-scelte to control any behavioural advertising preferences he or she makes while surfing the Internet.