Privacy policy

General privacy policy (effective since: 19/06/2024)

 

If you are reading this privacy policy (“Policy”), it is because you have somehow got in touch with Quattrolinee S.r.l. (“Quattrolinee”, “we”, “our”, “us”) registered in Italy (VAT IT12671260011) with registered office at c.so Vittorio Emanuele II, 25 - Turin. 

We provide this Policy as Controller of your Personal Data to help you better understand how we handle your data, for what purposes and how you can control your information. 

At the end of this document, you will find Definitions, referring to more detailed explanations of the capitalized terms.   The types of Personal Data we collect depends on how you interact with us. The categories below may be provided directly by you or by third parties:

• Identification data: any data that identifies you such as your name, surname, national and tax IDs details, and account details (e.g., nickname).

• Contact details: any information allowing us to contact you through any means such as e-mail and postal addresses, mobile number, social media accounts. This category also includes IDs shared by social media (e.g., Meta) that allow us to show our ads to you. Social media act as Joint Controllers with us when we use their business targeting services. 

• Filled data: any information inserted by you in our Forms.

• Device data: your IP Address, the date, time and the requested URL, Unique Identifiers and other information such as the type of your Browser or Device, the website you have arrived from (site of origin), the information you look at and any other actions carried out on our Pages. This information is collected using Cookies and Other Tracking Technologies that are on your Browser or Device. You can find the complete list of Cookies in the footer of our Pages or by clicking here. 

• Data inferred by your activity: information based on your online interactions with our Forms and Services (e.g., if you are interested in specific pages; when you contact us by e-mail, telephone regarding our products or request other information, we will collect and maintain a record of your contact details, communications and our responses) that allow us to create inferred data thanks to the Combination and/or Crossing. 

• Third party data: any Identification data, Contact details, Filled data relating to a person other than you that we may process for the provision of our Services. If you provide us with the data of third parties (e.g., third parties’ e-mail), you will be held responsible for having shared such information with us. You must be legally authorized to share it (i.e., authorized by the third party to share their information or for any other legitimate reason). You must fully indemnify us against any complaints, claims or demands for compensation of damages which may arise from the processing of third-party Personal Data in violation of applicable data protection law.

• Joint data: any Contact details shared by Business partners (e.g., social media, co-branding companies, etc.) to whom we ask to send or display our ads to their users based on certain criteria/interests. These so-called micro-targeting and/or retargeting activities typically do not lead to the direct collection of Personal Data by us. Instead, they usually allow us to obtain Aggregated data on the effectiveness of those ads or lead to the registration of new members via our Forms. In accordance with Italian legislation, in carrying out these activities both we and our business partners make every reasonable effort to verify the lawfulness of the data (including joint controllership agreements) before they are used. You can request more information on our list of active Business partners and the obligations of the respective parties by writing to dpo@quattrolinee.it. 

How you engage with us determines the types of data we collect and the purposes we process such data for, as shown in our grids. You are not obliged to provide any information to us, but if you do not provide information when requested, this will impact some or all our purposes.

 

If you are a digital user visiting our Pages, we process your data as below. 

 

We process the data that you provide as required by the applicable law and regulations. Moreover, we process your data to prevent fraudulent and illegal behaviour or activities which could compromise you, our security, Services and Pages. These processing operations are based on legal obligations upon us and our legitimate interest. Except for the retention periods / criteria described in the grids above or mandatory periods defined by the law, we may process your data for these purposes for no longer than 5 years. 

 

Your data may be stored, accessed, used, processed, and disclosed outside your jurisdiction, including within the European Union, the United States of America, or any other country where our Service providers and sub-processors are located, or where their servers or cloud computing infrastructures may be hosted. We take steps to ensure that the processing of your data by our Recipients (as defined in the grids above) is compliant with the applicable data protection laws, including the Italian laws to which we are subject. Where required by Italian and/or EU data protection law, transfers of your data to recipients outside of Italy and/or EU will be subject to adequate safeguards (such as the EU standard contractual clauses for data transfers between EU and non-EU countries), and/or other legal basis according to the Italian and the EU legislation. For more information on the adequate safeguards, we have implemented with regard to data that is transferred to third countries, please write to: dpo@quattrolinee.it. 

 

Based on how you got in touch with us, you can ask at any time to: 

In accordance with the applicable data protection laws, we will reply to your request within one month of its receipt (extendable for two further months in case of particular complexity). Please mind that some of your rights may not be available or be subject to restrictions if the applicable law allows.  

You can exercise any of the rights listed above:

 

This Policy explains and covers the processing operations that we carry out as Controller. The icons illustrated are under a free license.

The Policy does not cover processing carried out by parties other than Quattrolinee and in particular does not cover the processing carried out:

• By us when you subscribed to our services called “Club” subject to a specific privacy policy shared with you when you signed the contract and available at any time in your personal area; 

• By our Business partners as autonomous Controllers including those carried out by social media platforms within our Pages. With respect to such, we do not assume any responsibility for the processing of your data not covered by this Policy.

 

This Policy is entered into force on the date indicated at the beginning of this document. We reserve the right to modify or update this Policy, in full or in part, at our discretion or as a consequence of changes in applicable regulations. We will inform you of substantial changes via your Contact details.

 

Aggregated data: refers to statistical information about you that does not contain your Personal Data. We use this information for analysing and improving our Services and creating new services and features and to create statistical reports for Business partners.

Authorities: refers to a government, being supranational, federal, state or governmental, prefectural or local government, statutory, administrative or regulatory body, court, agency, including a law enforcement agency, or any other authority in any part of the world (also outside of your jurisdiction) whose regulations, directives, notices, resolutions, orders, decrees, injunctions, warrants, subpoenas, or judgments are binding upon us and requires us to disclose your Personal Data. We will not share your data without your consent, unless we are under a legal obligation to comply with said regulations.

Browser: refers to programs used to access the internet (e.g., Safari, Chrome, Firefox, etc.).

Business partners: means third-party entities who communicate your Personal Data to us only after they have contractually assured us that they have obtained your consent or that they have another legal basis that legitimizes their communication/sharing of such data with us. This definition also includes the selected partners with whom we may share i) Aggregated data for business intelligence or partnership purposes. You may ask the disclosure of Business partners processing your Persona Data by writing to our DPO.

Combination and/or Crossing: this is the set of fully automated and non-automated operations which we used to create inferred data about you. We may also combine and/or cross information from different sources.

Controller or Joint Controller: refers to the legal person, public authority, service or other entity which, individually or jointly, determines the purposes and means for processing your Personal Data. In other cases, it may be preceded by the word "autonomous" (e.g., "autonomous Controller") to indicate that your Personal Data is processed by a subject other than us.

Cookie: A cookie is a small text file that is downloaded onto your Device (e.g., smartphone, computer) when you access our Pages. It allows websites to recognize your Device and store information about your preferences or past actions (e.g., the fact that you visited our Pages, your language and other information). The information collected via cookies may be about you, your preferences or your Device and is mostly used to make our Pages work as you expect them to. Information collection via cookies does not usually directly identify you, but it can give you a more personalized experience on our Pages you are visiting, as they might be used to record your preferences regarding the use of Cookies (technical cookies), analyse and improve our Services and create new services and features.

Device: refers to the electronic device (e.g., iPhone) which you use to visit our Pages.  

Forms: any form through which we can directly collect your data (e.g., newsletter sign-up, etc.). 

IP Address: is a unique number used by your Browser or your Device in order to connect to the internet. The internet service provider provides this number allowing identification of the provider and/or the approximate area where you are located. Without this data, you cannot connect to the internet and use our Services.

Other Tracking Technologies: pixel tags (tracers used with Cookies and embedded in images on web pages to track certain activities, such as to see if an e-mail has been read) or Unique Identifiers embedded in links to promotional communications that send us information when clicked on.

Pages: includes our website (https://quattrolinee-dev.quattrolinee.com) and our social media pages. 

Personal Data: means any information relating to an identified or identifiable natural person whether directly or indirectly, as well as any information that is linked or reasonably linkable to a particular individual or household. For example, an e-mail address (if it refers to one or more aspects of an individual), IP addresses, and Unique Identifiers are considered Personal data. 

Personnel: our employees and collaborators who have undertaken an obligation of confidentiality and abide by specific rules concerning the processing of your Personal Data. This category also includes our or our Service providers’ system administrators which assist us with the management of our IT systems and therefore can access, modify, suspend and limit the processing of your Personal data. These individuals have been previously selected, adequately trained and their activities tracked by systems they cannot modify.

Service providers: refers to an entities that we engage to process your Personal Data solely on behalf of and pursuant to the written instructions provided by us or external individuals (contractors) to whom we delegate some processing activities. For example, security systems providers, accounting, administrative, legal, tax, financial and debt collection consultants, data hosting platform providers. You may ask the disclosure of Service provides processing your Persona Data by writing to our DPO.

Services: collectively, this means all the services/product available and accessible via our Pages.

Unique Identifiers: consist of information that can uniquely identify you through your Browser and Device. On the Browser, your IP Address and Cookies are considered Unique Identifiers. On your Device, advertising identifiers provided by manufacturers, such as Apple's IDFA and Android’s AAIG, which we use for analysing and improving our Services and creating new services and features are considered Unique Identifiers. Please note that for these purposes and in line with the opinions of the relevant European and Italian Supervisory Authority, we do not use other Unique Identifiers such as MAC Addresses and IMEIs as they are not resettable by you.