GLOBAL PRIVACY POLICY STATEMENT (in force from __/__/2019)

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.

We are Maserati S.p.A., data controller established in Italy and this Privacy Policy Statement will help you to gain a better understanding of which data are collected, for what purposes and how we manage your information.

To make the explanation below as comprehensible and usable as possible, we have inserted examples and created Definitions which provide more detailed explanations and which can be consulted here. If you have any questions about the Privacy Policy Statement or about how your information is processed, you can write to us here.

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.

  1. 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.

  1. 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.

  1. 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.

  1. 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.

  1. 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).

  1. 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:

  1. 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.

  1. 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.

  1. 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.

  1. 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.
  1. 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.

  1. 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. 

  1. 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:

  • access your Data: depending on how you use our Services, we will provide you with the Data that we have about you such as name, surname, age, IP Address, Unique Identifiers, e-mail, preferences expressed, together with the Privacy Policy Statement that you received when you provided them to us and the source of your Data (if, for example, they were communicated to us by one of our Partners);
  • 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.

8) What is not covered by the Privacy Policy Statement

This Privacy Policy Statement explains and covers processing that we perform as data processor on Our Websites and App and on the Websites and Apps of our Partners.

The Privacy Policy Statement does not cover processing carried out by entities other than Maserati S.p.A. and, in particular, it does not cover:

  • 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 after having clicked on the links found on Our Websites and App in which this Privacy Policy Statement is not cited;
  • processing carried out by FCA group companies in the capacity of autonomous data controllers (e.g. https://careers.fcagroup.com/).

With respect to those circumstances, we do not accept any liability in relation to the processing of your Data not covered by this Privacy Policy Statement.

9) Are you located outside the European Union?

The sections below explain the way in which we process your information if you are located outside the European Union or if the law of the country in which you are located provides derogations or necessary specifications of what is envisaged above by our Privacy Policy Statement.

  • Australia
  • Bahrain
  • Belarus
  • Brazil
  • Chile
  • China
  • Colombia
  • Costa Rica
  • Dominican Republic
  • Ecuador
  • Egypt
  • Georgia
  • Guatemala
  • Hong Kong
  • India
  • Indonesia
  • Japan
  • Jordan
  • Kazakhstan
  • Kuwait
  • Lebanon
  • Macao
  • Malaysia
  • Mexico
  • Morocco
  • New Zealand
  • Oman
  • Panama
  • Peru
  • Philippines
  • Principality of Monaco
  • Puerto Rico
  • Qatar
  • Russia
  • Saudi Arabia
  • Serbia
  • Singapore
  • South Africa
  • South Korea
  • Taiwan
  • Thailand
  • Turkey
  • UAE
  • Ukraine
  • Uruguay
  • USA
  • Vietnam

10) Changes to Privacy Policy Statement

This Privacy Policy Statement is in force from the date indicated at the start of this document. We reserve the right to modify or simply update its content, in part or in full, also due to changes of the applicable regulations. If substantial changes are made to the Privacy Policy Statement, you will receive a message on the Browser or on the Application.

The previous Privacy Policy Statement is available here.

11) Set your preferences for Data collected from the Browser, Device and Application

       a. Cookies

Cookies provided by us:

Technical Name Data Controller Type of cookie, function and purpose Duration
_device Maserati Function Memorises the type of device if the user is browsing from the mobile phone Session
adobeDTMadvertising Maserati Function Memorises the user's choice relating to advertising cookies 29 days
adobeDTMcomfort Maserati Function Memorises the user's choice relating to comfort cookies 29 days
adobeDTMperformance Maserati Function Memorises the user's choice relating to performance cookies 29 days
CookieConsent Maserati Function Memorises the status of the user's consent to cookies for the current domain 1 year
filter-colours-external Maserati Function Memorises the user's choice for filters on external colours Session
filter-colours-internal Maserati Function Memorises the user's choice for filters on internal colours Session
ip_location Maserati Function Memorises the user's location based upon the IP 30 days
ip_location_reject Maserati Function Memorises if the user has refused the redirect from the international website to the website of his/her nation 1 day
JSESSIONID Maserati Browsing Preserves the user's statuses on the different website pages Session
maserati_cookie_agree Maserati Function Memorises the user's acceptance of the cookie policy 30 days

If you want to block these Cookies, you can follow your Browser's instructions (Internet Explorer, Firefox, Chrome, Safari). You can also use the tool AdChoice provided by the Digital Advertising Alliance or the tool YourOnlineChoice provided by the European Interactive Digital Advertising Alliance.

Cookies provided by third parties:

If you want to block the processing by these websites, we recommend that you click on one of the links above and exercise your preference. Google, for example, also permits the installation of a plug-in to opt-out from all websites in which Google cookies are present, available here https://tools.google.com/dlpage/gaoptout?hl=it.

     b. SDK

The SDK that we use on the Application are all of third parties and depend on the type of Device that you use, as indicated below. You can object by clicking on the indicated links or from the privacy settings of the Application.

On Apple Devices:

Adobe Analytics: https://www.adobe.com/it/privacy/opt-out.html;

Crashlytics: http://try.crashlytics.com/terms/

     c. Contents that could be useful to you

Due to how it is structured, we are not able to list comprehensively the identity of the participants in the Programmatic Advertising and therefore to know precisely who is communicating to us your data, such as the IP Address to display to you our Contents that could be useful to you.

If you wish to block the sharing of your Personal Data within the Programmatic Advertising which allow us to send to you Contents that could be useful to you you can use the tool AdChoice provided by the Digital Advertising Alliance or the tool YourOnlineChoice provided by the European Interactive Digital Advertising Alliance.

     d. Unique Identifiers

If you do not want your Device to share with us the Unique Identifiers or if you decide that you want to reset them, you can do so by setting your Device appropriately.

If your Device is iOS, go to “Settings”, then to “Privacy”, then “Advertising” and activate the button “Turn on Limit Ad Tracking”. On the same page you can also restore your advertising ID (known as IDFA).

    e. Information on your location

If you do not want to share with us Information on your location, you can deactivate the localisation permission from the settings on the Browser or your Device and/or Application. If you want to restrict the Information that we process on your location, you can do so from your Device by activating the tracking of your location only while you are using the Application or alternatively by only providing us with your address or postcode. 

    f. Promotional communications on the Device

If you want to block the sending of promotional communications via push notifications, you can deactivate that permission or select which type of contents you want to receive by changing the settings on your Device.

    g. Other tracking technologies

In our institutional newsletter and promotional communications by email we insert Other tracking technologies (e.g. pixels) which allow us to ascertain if they have been correctly sent and whether or not you have opened a specific content.

The information provided by the Other tracking technologies is used by us only subject to your consent expressed on the banner found on your first visit to Our Websites and App. If you have not provided this consent, we will not use this information. If you intend to block this tracking, all you have to do is not select the full download of the email images. On Outlook, for example, the block occurs by design, except where you click “Download Pictures”.

Definitions

Aggregate Information: this is statistical information about you which does not contain your Personal Data. We use this information to measure the effectiveness of our Services and to create statistical reports for our Partners and dealers. For example, we may collect Information on your location or on the Contents that could be useful to you which you have viewed. In that regard, we note that we do not share your Personal Data with these reports.

Application: this means our application “Maserati Owner (Link App store UK: https://apps.apple.com/gb/app/maserati-owner/id1312806215)_” for smartphone installed on your Device.

Associates: these are the companies that belong to our business group including: Maserati S.p.A. – parent company; Maserati North America Inc.; Maserati Canada Inc.; Maserati Japan KK; Maserati West Europe S.A.; Maserati GB Limited; Maserati Deutschland GmbH; Maserati (CHINA) Cars Trading Co. Ltd.; Maserati Schweiz A.G.

Browser: this means the programme that you use to access the Internet (e.g. Safari, Chrome, Firefox etc).

Combination and/or cross-referencing: this is the set of entirely automated and other operations with which we combine the Information on your location, the Data inferred from your activities, the Data collected from the Browser, Device and Application, the Data provided by you and those collected from Websites and Apps of our Partners to provide the Services, to measure the effectiveness of our Services and to create new ones, to offer you Contents that could be useful to you. We may perform combination and/or cross-referencing operations even with different sources, such as between information collected from Our Websites and App, from the Websites and Apps of our Partners and/or with Data collected from public or publicly accessible sources.

Contents that could be useful to you: for example if you search for the “Ghibli” model, we may display to you on Our Websites and App or through Programmatic advertising other contents relating to this model. The customisation of contents may occur through the Combination and/or Cross-Referencing of Data.

Cookie: this is a short text sent to your Browser by one or our websites or those of our Partners or dealers. It allows the website to memorise information such as the fact that your visited the website, your language and other information. Cookies are used for different purposes, for example, to register your preferences with respect to the use of Cookies (known as technical cookies), to measure the effectiveness of our Services or to customise our Services, including the Contents that could be useful to you. Information sent by Cookies is subject to Combination and/or Cross-Referencing with that of the SDK and Other tracking technologies.

Device Sensors: depending on your Device, these are sensors such as accelerometer, gyroscope, Bluetooth, Wi-Fi and GPS which in one way or another share the information collected by them with the Device and therefore with the Application. If authorised from the settings of your Device, these allow us to obtain Information on your location.

Device: this means the device (e.g. Apple smartphone) from which you visit Our Websites and App and/or the Websites and Apps of our Partners.  

Indirect collection: this is one of the Services that we provide on the Websites and Apps of our Partners. In these cases, the Partner itself guarantees to us that it has obtained your consent or has another legal basis that legitimises the communication/sharing with us of your Personal Data (e.g. Information on your location, Cookies, SDK etc). In that regard, we note that, before being used, we check the methods by which the Partners collect and transfer to us the data so that your preferences are respected.

IP Address: this means a unique number used by the Browser, Device and Application to connect to the Internet. This number is generated by those who provide to you the Internet connection service and it allows for you to be identified along with the provider itself and/or the approximate geographical location in which you are found. Without this information you cannot connect to the Internet which we use to provide you with the Services but also to collect Information on your location and to offer to you Contents that could be useful to you.

Other tracking technologies: this means the pixel tags (tracking used together with Cookies and inserted in images within the web page or in the Application with the aim of tracking certain activities, such as the display of Contents that could be useful to you or the opening of an email) or Unique Identifiers inserted into the sales communication links which send information to us once clicked.

Our Events: these are the events/showrooms organised by Maserati, by its dealers or in collaboration with other brands with which Maserati has close commercial collaboration agreements.

Our Websites and App: these include our pages on social networks, the Maserati Application, some sections of the websites of our dealers on which this Privacy Policy Statement is found as well as the following websites: www.maserati.com, www.maseratistore.com ____.

Personal Data: this means any information that makes a natural person identified or identifiable. For example, Personal Data includes IP Address, email address (if it contains the personal details of a natural person) and the Unique Identifiers.

Programmatic Advertising: these are platforms able to share information that is collected about you such as your IP Address and the data collected by Cookies, SDK and Other tracking technologies with entities interested in displaying Contents that could be useful to you. In our case, if you view on Our Websites and App the “Ghibli” model, we will ask the participants in the Programmatic Advertising to award us an advertising space in one of the websites that you visit to show you the Contents that could be useful to you. In that regard, we note that the communication of your Data to participants in the Programmatic Advertising is based upon your prior and specific content collected by accepting the banner present on your first visit to Our Websites and App. To find out how to object to this communication click here.

SDK: these are software libraries that are installed together with the Application. They allow for the collection of data similarly to what occurs with Cookies on the Browser. Through the SDK we may collect, depending on the settings of your Device, Information on your location, Unique Identifiers and Data inferred from your activities.

Sensitive Data (special categories of personal data): this means Personal Data which reveals racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data aimed at uniquely identifying a natural person, data relating to the health or sex life or sexual orientation of the person.

Services: collectively, this means the set of services found on Our Websites and App such as configuration of Maserati models, find dealers, booking of test drives, institutional newsletter, customer support and Our Events.

Unique Identifiers: this means the information able to identify you uniquely through your Browser, Device and/or Application. On the Browser, the IP Address and the Cookies are considered Unique Identifiers. On the Device, Unique Identifiers are the advertising indicators made available by manufacturers such as the Apple IDFA and the Android AAID used by us to measure the effectiveness of our Services or to customise our Services, including the Contents that could be useful to you. In this regard, we note that, for these purposes and in line with the opinions of the European Authorities, we do not use other Unique Identifiers such as the MAC Address and IMEI as they are not resettable by you. For the Application, on the other hand, the code which identifies the Application that you installed is considered a Unique Identifier. To find out how to reset or not to share with us the Unique Identifiers, click here.

Websites and Apps of our Partners: this means the websites and mobile applications of our Partners and our websites and apps which are managed by our Partners (e.g. maseratistore.com) with which we have commercial agreements (e.g. Indirect Collection) or all Websites and Apps on which this Privacy Policy Statement is found. The full list of our Partners is available by clicking here.

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