If you are reading this document, it is because you have accessed Our Websites and App and/or the Websites and Apps of our Partners or because you have participated in Our Events.
1) Which data do we process
We collect data from Our Websites and App, from the Websites and Apps of our Partners as well as during participation at Our Events. The data collected and the purposes of the processing depend upon how you use our Services and on how you manage the controls of the Browser, Device and/or Application that you are using.
- Data provided by you
During the performance of the Services, you may provide us with Personal Data such as your name, surname, email address and telephone number, or those of third parties, as well as your preferences (e.g. with regard to certain car models or services to be received from the local dealer). This happens, for example, when you request a test drive, when you search for the dealer closest to you, when you participate in one of Our Events or when you ask questions or make requests or interact with our assistance services. You can also choose to provide us with Information on your location if, for example, you want to find, via Our Websites and App, one of our dealers in your local area (e.g. London or New York).
If you provide data of third parties, you accept all legal obligations and responsibilities, granting the broadest indemnity in relation to any dispute, demand, compensation claim for damages from processing, etc. that may be received by us from the third parties whose Personal Data have been sent by you and thus processed in violation of the applicable rules on personal data protection.
- Data collected from the Browser, Device and Application
When you access Our Websites and App, we collect information on the Browser, Device and Application that you are using. This information includes the IP Address, the date, time and requested URL, the Unique Identifiers and other information such as the type of Browser or Device which, as appropriate, may consist of the operating system, language, network settings, name of the telephone operator or internet provider, plug-in list or third party applications installed.
Part of this information is collected by way of Cookies, SDK and Other tracking technologies found within your Browser or Device, which help us, for example, to avoid anomalies in displaying contents, or crashes of the Services but also to provide you with the Contents that could be useful to you. You will find the full list of Cookies, SDK by clicking here.
- Data inferred from your activities
We collect information based upon your interactions with our Services to be able to improve them (e.g. if we see that you are interested in a particular model, in Our Events or in periodic servicing in a certain area, we will concentrate on promoting these contents) as well as to ascertain the Contents that could be useful to you.
- Information on your location
We collect information on your location to allow you to view dealers close to you, as part of our Services, and to send you Contents that could be useful to you. Your position may be determined by:
- manually entering an address, city or postcode;
- Device Sensors;
- the IP Address.
Your location is identified more or less accurately and constantly, depending on whether it is collected from the Browser or from the Device and based upon the privacy settings that you set on the same. We guarantee that the Information on your location will not be used to infer your Sensitive Data.
You can alter the ways in which we determine your location by changing the settings on your Browser or Device, as indicated in the section How to control your data below.
- Data collected from Websites and Apps of our Partners
We collect information about you also from the Websites and Apps of our Partners. The latter may communicate to us your Personal Data only because they have guaranteed contractually to us that they have obtained your consent or have another legal basis that legitimises the communication/sharing with us (for example, if you have asked one of our Partners to book a Maserati test drive or when you purchase Maserati merchandising and you ask to receive sales communications). In this regard, we note that we make every effort commercially possible to verify the conformity of the data that we receive before using them, also asking you not to provide your Sensitive Data (this activity will be known below as Indirect Collection).
- Data collected from public or publicly accessible sources
We collect and enhance your Personal Data with information extracted from public or publicly and generally accessible sources within the limits provided by law and applicable to us. These sources may consist of public registers, online publications, lists or rolls. We note that a preliminary check is always performed on the possibility of using this information, in accordance with best practices established by the Italian Supervisory Authority to which we are subject (Garante per la protezione dei dati personali).
For convenience, we will collectively indicate all the Personal Data cited thus far as “Data”.
2) Why we use your Data
The Data are used for the following purposes:
- To provide our Services and to respond to your requests
We use your Data to be able to offer you our Services, including booking test drives on Our Websites and App or on the Websites and Apps of our Partners and their performance, the organisation of Our Events at which you participate, the response to requests/suggestions/reports and, if you wish, the sending of institutional newsletters on our activities and/or those of the business group to which we belong.
This processing is based upon the execution of a contractual obligation or pre-contractual measures adopted at your request.
- To comply with legal obligations to which we are subject
We may use your Data to be able to comply with any regulatory and tax obligations to which we are subject, which form the legal basis for this processing.
- To identify anomalies in our Services
We use the Data provided by you, the Data collected from the Browser, Device and Application, the Data inferred from your activities and Aggregate Information to avoid anomalies in the Services. We may, for example, notice an anomaly in the opening of Our Websites and App, or of a link, or use the Data to ascertain how to avoid a system bug occurring.
This processing is based upon the need to guarantee the performance of the Services, as well as for our legitimate interest in avoiding disservices.
- To customise our Services, including the Contents that could be useful to you
We use your Data, particularly the Data inferred from your activities, the Information on your location and the Data collected from the Browser, Device and Application, to improve our Services (e.g. Our Websites and App, Our Events, our promotional communications) and to display to you only Contents that could be useful to you.
The Contents that could be useful to you:
- are not created using Sensitive Data such as those that could be inferred from Information on your location;
- could be visible even on websites and mobile applications other than our own as they are uploaded on Programmatic Advertising platforms only to the extent that you have authorised us to be able to upload them onto these platforms.
The customisation of our Services and the provision of Contents that could be useful to you by us may be more or less thorough depending on the consents expressed, which you may decide whether or not to provide by way of:
- the banner shown upon your first visit to Our Websites and App as regards the Data collected from the Browser, Device and Application;
- the data collection forms, in which we ask you to express your preferences with regard to the Data provided by you and the Data relating to your activities;
- the banners of the Browser or the Device to enable the sharing of Information on your location.
- To measure the effectiveness of our Services and to create new ones
We use your Data and Aggregate Information to measure the performance of our Services or to create new ones. This may occur, for example, by analysing your interactions with our dealers, Our Events, our newsletter and/or promotional communications (if requested).
Subject to consent to the customisation of our Services, the measurement of the effectiveness of our Services and the creation of new ones is based upon our legitimate interest in creating and maintaining Services that are truly useful for our users.
- To send you promotional communications
Except for the institutional newsletter service, to which you may freely choose to register, we use the contact information provided to us by you to send you communications on new models or on the Services that we offer, on our initiatives and/or to ask you to participate in our customer satisfaction surveys. In some cases, the communications may contain product or service promotions of some selected Partners (without sharing your Data with them). Those communications may also be customised if you have consented to the customisation of the Services, including Contents that could be useful to you.
In that regard, we note that no communication will be sent to you without your prior consent, which you can provide through the specific tick-box for this purpose and/or by allowing the Device to receive push notifications. We remind you that you can also select just some contact channels (e.g. only email or SMS) by clicking on the “click here to select the individual contact channels” link in the consent form or by selecting the individual channels in the privacy settings of the Application.
- To protect our interests and those of our users
We may have to use your Data as part of our activities of identifying, preventing and reacting to fraudulent or unlawful activities or those that prejudice the security of Our Websites and App or Services. This may occur, for example, in cases where you use the Application in a manner not permitted, to verify the so-called Indirect Collection , or in circumstances of inappropriate behaviour at Our Events.
This purpose is based upon our legitimate interest in protecting ourselves and our users, including you.
3) How we use your Data
All data collected for the purposes indicated above are processed both manually and through automated decision-making processes, i.e. through programmes and/or algorithms which analyse information such as Data inferred from your activities, Information on your location and Data collected from the Browser, Device and Application.
Your Data may also be subject to combination and/or cross-referencing. This allows us to ascertain, for example, that if our Services are used by a Browser and by a Device with the same IP address or Unique Identifiers, it could be a single user; or also to send promotional communications or Contents that could be useful to you closely related to the Information on your location or the Data inferred from your activities or even to Data collected from the Browser, Device and Application.
4) With whom do we share your Data
We share your Data with the following categories of entities (“Recipients”):
- persons authorised by us: these are our employees and collaborators who have signed a confidentiality agreement and specific rules for the processing of your Data;
- our processors: these are external entities to which we entrust some processing operations. For example, this category includes providers for the security of our systems, consultants, accountants, data hosting technological platforms, etc. This category also includes our dealers present across the world. With each of these entities, we have signed a contract to guarantee that your Data is processed according to adequate measures and only at our instruction;
- system administrators: these are our employees or our processors to whom the management of our computer systems is entrusted and who therefore have the power to access, modify, suspend and restrict the processing of your data. Those persons have been selected and adequately trained in advance and their activities are tracked by systems that cannot be modified by them, as required by the measures of the Italian Supervisory Authority;
- our Associates: for example, if you are a Brazilian citizen, we may share your requests/questions with our local branch to respond to you in your native language. The same applies if we want to create commercial initiatives based upon our market analyses. All Associates have signed with us agreements on the processing of your Data;
- forces of order or any another authority whose measures are mandatory for us: this occurs, for example, when we must comply with a judicial measure, a law or when it is necessary to defend ourselves in court.
5) Where are your Data
We are present and we offer our Services almost all over the world. We guarantee that your Data will be processed by us and by the Recipients in respect of the European and Italian legislation to which we are subject. In fact, transfers of your Data to the Recipients may occur based upon an adequacy decision (e.g. EU-US Privacy Shield; Swiss-US Privacy Shield) or on Standard Contractual Clauses approved by the European Commission. Further information is available by writing here.
6) For how long do we store your Data
Data processed for the purposes indicated above will be stored for the time strictly necessary to achieve those purposes or until your consent is withdrawn, if this is the legal basis that allows us to process them.
Data processed to fulfil legal obligations to which we are subject will be stored for the time provided by those rules. Data processed to protect our interests and those of our users will be stored for the time permitted by Italian regulations in protection of our interests (Art. 2946 et seq. of the Italian Civil Code). You may request further information on the storage criteria and periods by writing here.
7) How you can control your data
At any time, you may ask to:
- make your Data portable: depending on how you use our Services, we will provide you with a table in Excel format which contains the Data that we have about you.
- rectify your Data: for example, you can ask us to modify the email address or telephone number that you provided to us if they are not correct;
- restrict the processing of your Data: for example, if you believe that the processing carried out by us is unlawful and/or your believe that some processing performed based upon our legitimate interest is not appropriate;
- erase your Data: for example, if you no longer intend to use our Services and you do not want your Personal Data to be stored anymore;
- update your preferences for the processing of your Data based upon consent: depending on how you use our Services, you can ask us not to send to you sales communications and/or not to customise our Services including the Contents that could be useful to you.
The response times provided by the European regulations to which we are subject are 1 month from your request (extendable to a further 2 months in the case of particular complexities). You may exercise any of the rights listed above by writing here.
You may exercise the same rights with respect to any processing performed directly by Facebook on our social media pages by way of the form found here.
At any time you may also:
- contact our data protection officer (DPO) by clicking here;
- contact the local Supervisory Authority whose details are found here;
- block the sending of promotional communications by clicking the link found at the bottom of every e-mail;
- set your preferences for Data collected from the Browser, Device and Application by following the instructions found here.
- processing carried out by our Partners in the capacity of autonomous data controllers (see Indirect Collection) or that carried out by some social media networks, such as Facebook, within our pages and indicated here;
- processing carried out by our dealers in the capacity of autonomous data controllers;
- processing carried out by FCA group companies in the capacity of autonomous data controllers (e.g. https://careers.fcagroup.com/).
9) Are you located outside the European Union?
- Costa Rica
- Dominican Republic
- Hong Kong
- New Zealand
- Principality of Monaco
- Puerto Rico
- Saudi Arabia
- South Africa
- South Korea
11) Set your preferences for Data collected from the Browser, Device and Application
Cookies provided by us: