+39.031.5476941
Privacy Policy - eBike Test Drive and Consultation
Preamble
Pursuant to Art. 13 of Regulation (EU) 2016/679 (hereinafter also "GDPR"), Ridewill s.r.l., as data controller (hereinafter also simply "controller" or "Ridewill"), informs data subjects about the use of personal data collected in connection with requests for e-bike test drives or free online e-bike consultations.
1. Data Controller and Data Protection Officer (DPO)
Pursuant to Art. 4(7) of the GDPR, the data controller is Ridewill, with registered office at Via Socrate, 6 -- 22070 Casnate con Bernate (Co). Tel.: +39.031.5476941, E-mail: info@ridewill.it PEC: ridewill@pec.it
The Data Protection Officer (DPO) of Ridewill can be contacted at the e-mail address dpo@trustds.it PEC: dpotrustds@legalmail.it
2. Purpose of processing, personal data processed, legal basis, data retention period, and nature of data provision
Purpose A): Management of e-bike test drive requests or free online e-bike consultation requests, in order to provide the requested service.
- Personal data processed: First name, last name, e-mail address, phone number;
- Legal basis for processing: The processing of personal data is based on the freely given consent of the data subject (Art. 6(1)(a) GDPR);
- Data retention period: Personal data will be stored until the service requested has been completed. Further data retention may occur in connection with contractual relationships established between the controller and the data subject following the requested services;
- Nature of data provision: Providing data is optional; without consent, data will not be processed for the intended purpose. However, failure to provide data will make it impossible to access the requested services.
3. Processing methods and recipients of data
Personal data collected is processed, after obtaining consent, in compliance with the principles set out in Art. 5 of the GDPR.
Processing is carried out by individuals authorized by the controller for the purposes indicated. Authorized persons are bound by professional secrecy. Data processing may also involve collaboration with other entities appointed as data processors, who process data in accordance with the purposes and means determined by the controller under Art. 28 GDPR.
Processing is also carried out using electronic tools, in particular through the services Calendly and WhatsApp for scheduling free online consultations.
Processing is carried out in compliance with the fundamental rights and freedoms of individuals and in accordance with the principles set out in Art. 5 GDPR, primarily fairness, lawfulness, and transparency. The controller ensures the relevance and proportionality of the information processed in relation to the purposes pursued.
4. Data transfer outside the European Economic Area (EEA)
The Controller does not transfer personal data outside the European Economic Area.
However, in the context of free online consultations, by using the WhatsApp and Calendly platforms, the user accepts the terms and conditions regarding personal data processing established by those platforms, according to which certain personal data may be transferred to the United States of America (USA). The transfer of such personal data to the USA is lawful following the adequacy decision adopted by the European Commission on July 10, 2023, pursuant to Art. 45 of the Regulation, which established appropriate data protection standards ensuring the rights and freedoms of data subjects, to which WhatsApp and Calendly adhere.
5. Rights of data subjects
Data subjects – meaning the individuals to whom the processed data refers – may exercise the rights provided for by Art. 15 et seq. of the GDPR, in particular: the right to access their personal data, request rectification or restriction, and deletion where applicable, as well as the right to object to processing and the right to data portability. If the legal basis for processing is consent, data subjects also have the right to withdraw their consent at any time without affecting the lawfulness of processing carried out before the withdrawal.
To exercise their rights, data subjects may contact the controller or the data protection officer using the contact details provided in this notice.
If data subjects believe that the processing of personal data by the Controller violates the GDPR, they have the right to lodge a complaint with a supervisory authority in the Member State where they habitually reside or work, or where the alleged violation occurred (Art. 77 GDPR). The Italian supervisory authority is the Garante per la protezione dei dati personali, whose contact information is available on its website (www.garanteprivacy.it).
Pursuant to Art. 79 GDPR, data subjects have the right to a judicial remedy if they believe that their rights have been violated as a result of processing.
6. Amendments to the data processing information
Ridewill may modify, add, or remove any part of this personal data processing information. To facilitate verification of any changes, the notice indicates the date of the last update.