Owners App: Privacy Policy

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Maserati S.p.A., with registered offices at Viale Ciro Menotti 322, 41100 MODENA, Italy (“Maserati”), is committed to protecting the online privacy of the users of this application (“App”). As such, this Privacy Policy has been written and uploaded to third-party platforms (“Store”), in order to allow you to understand Maserati’s policy regarding your privacy, and how your personal information will be handled when using this App. This Privacy Policy will also provide you with information so that you are able to consent to the processing of your personal data in an explicit and informed manner, where appropriate.

In general, any information and data which you provide to Maserati over the App, or which is otherwise gathered via the App by Maserati, in the context of the use of Maserati’s services (“Services”) as better defined in the Section 3 below, will be processed by Maserati in a lawful, fair and transparent manner. To this end, and as further described below, Maserati takes into consideration internationally recognised principles governing the processing of personal data, such as purpose limitation, storage limitation, data minimisation, data quality and confidentiality.

CONTENTS

Data controller and Data Protection Officer
Personal Data processed:
1. Data related to your Device
2. Data related to your location
3. Name, contact details and other Personal Data
4. SDKs and tracking technologies
Purposes of processing
Grounds for processing and mandatory / discretionary nature of processing
Recipients of Personal Data
Transfer of Personal Data
Retention of Personal Data
Data subjects’ rights
Amendments

1. Data controller and Data Protection Officer

Maserati, as identified at the top of this Privacy Policy, is the data controller regarding all personal data processing carried out through the App.

To get in touch with Maserati’s Data Protection Officer, please contact: dpo@maserati.com.

2. Personal Data processed

When you download, install and use the App on your device, Maserati will collect and process information regarding you (as an individual), which allows you to be identified either by itself, or together with other information which has been collected.

This information may be classified as “Personal Data”, and can be collected by Maserati both when you choose to provide it (e.g., when you sign up for an account, in order to receive Maserati’s Services) or simply by analysing your behaviour on the App.

Personal Data which may be processed by Maserati through the App are as follows:

1. Data related to your Device

By selecting the “Install” option at the Store regarding the App, you authorize Maserati to set up the App on your mobile device (“Device”), as well as to access some Personal Data and other information on your Device which are needed for its successful installation (e.g., Device model, operating system version, screen resolution, network connection type, language, etc.). This information sharing is inherent to the App’s set-up and, as such, you may not object to it unless you uninstall the App from your Device.

2. Data related to your location

Once the App has been installed, during the registration and using the Service Booking feature you will be asked to consent to the App accessing your Device’s location, only when you are using it. This allows the App to provide more precise and useful Services to you, allowing you to find the dealers next to your location.

If you believe that the sharing your location is too invasive, you can always revoke the access to your position from the Device settings and simply provide a zip code or state for the Services you are interested in.

3. Name, contact details and other Personal Data

When creating an account on the App, you will be asked to provide information such as your name (first and last), date of birth, mobile number, dealer where you bought your car, e-mail address and VIN (Vehicle Identification Number).

4. SDKs and tracking technologies

SDKs (Software Development Kits) and similar technologies are information that applications can record and/or read on your Device. In general, these technologies allow an analysis of the use of an application, with the goal to avoid malfunctions and improve users’ experience.

Maserati uses SDKs and similar technologies provided by third parties acting, as the case may be, as independent data controllers from Maserati (using the data they collect for their own purposes and under terms defined by them) or as data processors for Maserati (processing personal data on Maserati’s behalf).

For further details on how these third parties may use your information, please refer to their privacy policies:

Adobe Analytics: https://www.adobe.com/it/privacy/opt-out.html;
Crashlytics: http://try.crashlytics.com/terms/

Unless provided by the opt-out mechanism of the third party, if you wish to prevent your Device’s operating system from sharing your Personal Data with Maserati or with the third parties mentioned for profiling purposes, you can do so:

1. By setting up your Device appropriately: more specifically,

a. if you have an IOS Device, go to “Settings”, then “Privacy”, then “Advertising” and click the “Restrict Data Collection” button. You can also reset your IDFA on that same page;

b. if you have an Android Device, go to “Google Settings” / “Settings”, scroll down to “Google”, then click “Ads” and select “Opt out of interest-based ads” / “Opt out of Ads Personalisation”.

2. By modifying your privacy preferences in the “My app settings” section within the App.

3. Purposes of processing

Maserati intends to use your Personal Data, collected through the App, for the following purposes:

To provide Services you request, including allowing the creation of an account, using the Service Booking feature, providing you with information regarding your car, allowing you to reach the emergency service, to receive information from Maserati and sending you alerts regarding the App by means of push notifications (“Service Provision”);
For future marketing, promotional and publicity purposes, including to carry out direct marketing, market research and surveys, via e-mail, SMS, push notifications, banners, over the phone, instant messaging, through an operator, traditional mail, through Maserati’s official social media pages, regarding Maserati‘s products and services, as well as those of selected third parties (“Marketing”);
For future marketing, promotional and publicity purposes, by sending you direct e-mail marketing communication regarding products and services similar to those you have purchased through the use of the App (“Soft Spam”);
To create a profile of you as an actual and/or potential Maserati customer, by collecting and analysing information on the preferences you select and choices you make in the App, as well as through your Device data (e.g., AAIG). This information will be used to personalise the Services provided through the App, where possible, to suit your preferences and choices, as well as to serve you with information and advertisements which may be relevant to you and your interests. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias (“Profiling”);
For compliance with laws which impose upon Maserati the collection and/or further processing of certain kinds of Personal Data (“Compliance”);
To prevent and detect any misuse of the App, or any fraudulent activities carried out through the App (“Misuse/Fraud”).

4. Grounds for processing and mandatory / discretionary nature of processing

The grounds on which Maserati processes your Personal Data, according to the purposes identified in Section 3, are as follows:

Service Provision: processing for this purpose is necessary to provide the Services and, therefore, is necessary for the performance of a contract with you. It is not mandatory for you to give Maserati your Personal Data for these purposes; however, if you do not, Maserati will not be able to provide any Services to you.
Marketing: processing for these purposes is based on your consent. It is not mandatory for you to give consent to Maserati for use of your Personal Data for these purposes, and you will suffer no consequence if you choose not to (aside from not being able to receive further marketing communications from Maserati). Any consent given may also be withdrawn at a later stage (please see Section 8 for more information).
Soft Spam: processing for these purposes is based on the interest of Maserati of sending you direct e-mail marketing communication regarding products and services similar to those you have purchased through the use of the App. You can block these communications, and you will suffer no consequence if you do so (aside from not being able to receive further communications from the Maserati), by opposing through the link provided at the bottom of all such communications.
Profiling: processing for this purpose is based on your consent. It is not mandatory for you to give consent to Maserati for use of your Personal Data for this purpose, and you will suffer no consequence if you choose not to (aside from not being able to benefit from greater personalisation of your user experience regarding the App). Any consent given may also be withdrawn at a later stage, either by modifying your Device settings or contacting Maserati (please see Section 8 for more information).
Compliance: processing for this purpose is necessary for Maserati to comply with its legal obligations. When you provide any Personal Data to Maserati, Maserati must process it in accordance with the laws applicable to it, which may include retaining and reporting your Personal Data to official authorities for compliance with tax, customs or other legal obligations.
Misuse/Fraud: Information collected for this purpose is used exclusively to prevent and detect fraudulent activities or misuse of the App (for potentially criminal purposes).

5. Recipients of Personal Data

Your Personal Data may be shared with the following list of persons / entities (“Recipients”):

Persons, companies or professional firms providing Maserati with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters related to the provision of the Services and which act typically as data processors on behalf of Maserati;
Entities engaged in order to provide the Services (e.g., hosting providers or e-mail platform providers);
Persons authorised to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
Persons authorised by Maserati to process Personal Data needed to carry out activities strictly related to the provision of the Services, who have undertaken an obligation of confidentiality or are subject to an appropriate legal obligation of confidentiality (e.g., employees of Maserati);
Other companies within the Maserati Group for internal administrative purposes, including the processing of clients' or employees' Personal Data; and
Public entities, bodies or authorities to whom your Personal Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.

6. Transfer of Personal Data

Considering Maserati’s worldwide presence and business operations, your Personal Data may be transferred to Recipients located in several different countries. Maserati implements appropriate safeguards to ensure the lawfulness and security of these Personal Data transfers, such as by relying on adequacy decisions from the European Commission, standard data protection clauses adopted by the European Commission, or other safeguards or conditions considered adequate to the transfer at hand. More information about it are available sending a written request to Maserati at the following address: dpo@maserati.com.

7. Retention of Personal Data

Personal Data processed for Service Provision will be kept by Maserati for the period deemed strictly necessary to fulfil such purposes – in any case, as these Personal Data are processed for the provision of the Services, Maserati may continue to store this Personal Data for a longer period, as may be necessary to protect Maserati’s interests related to potential liability related to the provision of the Services.

Personal Data processed for Marketing, Soft Spam and Profiling will be kept by Maserati from the moment you give consent until the moment you withdraw the consent given and renewed at fixed intervals. Once consent is withdrawn, Personal Data will no longer be used for these purposes, although it may still be kept by Maserati, in particular as may be necessary to protect Maserati’s interests related to potential liability related to this processing.

Personal Data processed for Compliance will be kept by Maserati for the period required by the specific legal obligations for which the Personal Data were processed.

Personal Data processed for preventing Misuse/Fraud will be kept by Maserati for as long as deemed strictly necessary to fulfil the purposes for which it was collected.

8. Data subjects’ rights

As a data subject, you are entitled to exercise the following rights before Maserati, at any time:

Access your Personal Data being processed by Maserati (and/or a copy of that Personal Data), as well as information on the processing of your Personal Data;
Correct or update your Personal Data processed by Maserati, where it may be inaccurate or incomplete;
Request erasure of your Personal Data being processed by Maserati, where you feel that the processing is unnecessary or otherwise unlawful;
Request the restriction of the processing of your Personal Data, where you feel that the Personal Data processed is inaccurate, unnecessary or unlawfully processed, or where you have objected to the processing;
Exercise your right to portability: the right to obtain a copy of your Personal Data provided to Maserati, in a structured, commonly used and machine-readable format, as well as the transmission of that Personal Data to another data controller;
Object to the processing of your Personal Data, based on relevant grounds related to your particular situation, which you believe must prevent Maserati from processing your Personal Data; or
Withdraw your consent to processing (for Marketing, Soft Spam and Profiling).

Regarding Marketing carried out by means of push notifications, you may withdraw consent through your Device’s own settings. More specifically, on a IOS Device, go to “Settings”, then “Notification Center”, select the App and disable notifications by tapping it.

If you have an Android Device, go to “Settings”, scroll down to “Notifications”, select the App and choose “Block all”.

About the other means of communication (i.e., phone, SMS, email etc), you may have selected during the registration procedure, you may withdraw consent through the App settings (by de-selecting the relevant options).

In any case, you can modify your privacy preferences in the “My app settings” section within the App.

You can also withdraw consent regarding processing for Marketing by selecting the appropriate link included at the bottom of every marketing e-mail message received.

Aside from the above means, you can also exercise your rights described above by sending a written request to Maserati at the following address: privacy@maserati.com.

In any case, please note that, as a data subject, you are entitled to file a complaint with the competent supervisory authorities for the protection of Personal Data, if you believe that the processing of your Personal Data carried out through this App is unlawful.

9. Amendments

This Privacy Policy entered into force on 30/06/2018. Maserati reserves the right to partly or fully amend this Privacy Policy, or simply to update its content, e.g., as a result of changes in applicable law. Maserati will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the App. Maserati therefore invites you to regularly visit this Privacy Policy in order to acquaint yourself with the latest, updated version of the Privacy Policy, so that you may remain constantly informed on how Maserati collects and uses Personal Data.

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