FLEXIPASS KEYLESS MOBILE ACCESS SRLS
Italy
Company registered in Bolzano,
Paid social capital in EURO: 1.000,00
VAT number: IT02961420219
Privacy policy
The protection of your personal data is of particular concern to us. Therefore, we respect your privacy and process your data exclusively on the basis of the applicable provisions of data protection law and in accordance with this privacy policy.
In the following data protection information, we inform you about the type, scope and purpose of data collection as well as the processing of personal data in the context of the use of our website.
All terms in this privacy policy have the meaning defined in the General Data Protection Regulation (EU) 679/2016 (hereinafter DSGVO).
1. Person responsible for data processing
The provider of the website and the responsible party for data processing on the website within the meaning of the General Data Protection Regulation (DSGVO) is FLEXIPASS MOBILE ACCESS GMBH with its registered office in I-39012 - Merano - Goethestrasse no. 7. Further details and contact options can be found in our imprint.
2. Data security and processing methods
2.1 We process user data in a proper manner and take appropriate security measures to prevent unauthorized access and unauthorized forwarding, modification or destruction of data. In particular, we use SSL or TLS encryption on our website to protect the transmission of personal data and other confidential content. You can recognize an encrypted connection by the string "https://" and the lock symbol in your browser line.
2.2 However, we would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.
3. Legal basis of the processing
With regard to the processing of personal data on the basis of the General Data Protection Regulation applicable as of May 25, 2018, we would like to point out that the legal basis for consents is Art. 6 para. 1 lit. a and Art. 7 DSGVO, the legal basis for processing for the performance of our services and implementation of contractual measures is Art. 6 (1) lit. b DSGVO, the legal basis for processing to fulfill our legal obligations is Art. 6 (1) lit. c DSGVO, and the legal basis for processing to protect our legitimate interests is Art. 6 (1) lit. f DSGVO.
4. Purposes of processing
4.1 We process your data for the purpose of providing our services and our contractual, business and other legal obligations (including providing and performing our services, sending newsletters, processing inquiries).
4.2 Furthermore, we process your data in accordance with the legal requirements on the basis of our legitimate interests. These processing purposes include statistical analyses, which on the one hand serve to optimize our online offer, and on the other hand serve our own business purposes.
4.3 Users can find more detailed information about these processing purposes and the personal data used for each purpose in the relevant sections of this document.
5. Place of data processing and persons involved in processing
5.1 Data shall be processed at the Controller's premises and at all other places where the entities involved in data processing are located.
5.2 Insofar as content, tools or other means from other providers (hereinafter collectively referred to as "Third-Party Providers") are used within the scope of this Privacy Policy and their named registered office is abroad, it is to be assumed that a transfer of data to the Third-Party Providers' countries of domicile will take place. The transfer of data to third countries takes place either on the basis of legal permission, user consent, special guarantees, such as the Privacy Shield, or special contractual clauses that ensure legally required security of the data.
5.3 In addition to the data controller, other persons may have access to the data internally (human resources, sales, marketing, legal department, system administrators) or externally - and in the case where necessary, designated by the data controller as processors (such as technical service providers, delivery companies, hosting providers, IT companies or communication agencies).
5.4 The data processing includes the transmission or oven laying to third parties if this is necessary for the fulfillment of legal or accounting obligations, as well as for the prevention of threats to public order or law enforcement.
6. Contacting
6.1 On our website, we offer you the opportunity to contact us by e-mail and/or via a contact form. In this case, the information provided by the user will be stored for the purpose of processing his request and for possible follow-up questions.
6.2 The legal basis for the processing of the data is our legitimate interest in responding to your request pursuant to Art. 6 (1) lit. f DSGVO. If your contact aims at the conclusion of a contract, the additional legal basis for the processing is Art. 6 para. 1 lit. b DSGVO.
6.3 The user data may be passed on to our joint controllers.
7.1 As an additional service, we offer you our newsletter. By subscribing to our newsletter, you agree to receive it and to the procedure described below.
7.2 We send newsletters, e-mails and other electronic notifications with promotional information (hereinafter "newsletter") only with the consent of the recipients or legal permission.
7.3 Registration for our newsletter takes place in a so-called double opt-in procedure. I.e. after registration, you will receive an e-mail in which you are asked to confirm your registration. This confirmation is necessary so that no one can register with other e-mail addresses. The registrations for the newsletter are logged in order to be able to prove the registration process according to the legal requirements. This includes the storage of the registration and confirmation time, as well as the IP address. Likewise, changes to your data stored with the dispatch service provider are logged.
7.4 The newsletter is sent using the "Mailelite" platform of the provider UAB "MailerLite", J. Basanavičiaus 15, LT-03108 Vilnius, Lithuania (hereinafter referred to as the "Shipping Service Provider"). You can view Mailerlite's privacy policy here: https://www.mailerlite.com/legal/privacy-policy.
7.5 UAB "MailerLite" d/b/a Mailerlie is certified under the Privacy Shield agreement, thereby providing a guarantee of compliance with the European level of data protection.
7.6 The email addresses of our newsletter recipients as well as their other data described in the context of this notice are stored on the servers of the shipping service provider. The shipping service provider uses this information to send and evaluate the newsletter on our behalf. Furthermore, according to its own information, the dispatch service provider may use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletters or for economic purposes to determine from which countries the recipients come. However, the dispatch service provider does not use the data of our newsletter recipients to write to them themselves or to pass them on to third parties.
7.7 To register for the newsletter, it is sufficient to provide your e-mail address. Optionally, we ask you to provide the following data, such as first and last name for the purpose of personalizing the newsletter and industry, in order to adapt the content of the newsletter to the interests of our readers.
7.8 The newsletters contain a so-called "web beacon", i.e. a pixel-sized file that is retrieved from the server of the dispatch service provider when the newsletter is opened. Within the scope of this retrieval, technical information, such as information about the browser and your system, as well as your IP address and the time of the retrieval are initially collected. This information is used for the technical improvement of the services based on the technical data or the target groups and their reading behavior, based on the retrieval locations (which can be determined with the help of the IP address) or the access times. The statistical surveys also determine whether the newsletters are opened, when they are opened, and which links are clicked. For technical reasons, this information can be assigned to individual newsletter recipients. However, it is neither our intention nor that of the dispatch service provider to observe individual users. The evaluations serve us much more to recognize the reading habits of our users and to adapt our content to them or to send different content according to the interests of our users.
7.9 The use of the dispatch service provider, performance of the statistical surveys and analyses as well as logging of the registration process, are carried out on the basis of our legitimate interests pursuant to Art. 6 para. 1 lit. f DSGVO. Our interest is directed towards the use of a user-friendly as well as secure newsletter system that serves our business interests as well as meets the expectations of the users.
7.10 You can cancel the receipt of our newsletter at any time, i.e. revoke your consent. You will find a link to cancel the newsletter at the end of each newsletter.
8. Collection of access data
8.1 When you access our website, information of a general nature is automatically collected that your browser transmits to our server. This information (so-called server log files) includes, for example, the web browser used, the operating system used, the domain name of your Internet service provider, and the like.
8.2 This information is technically necessary in order to correctly deliver website content requested by you and is statistically evaluated by us in order to optimize our website and the technology behind it.
8.3 The processing is carried out in accordance with Art. 6 para. 1 lit. f DSGVO on the basis of our legitimate interest in improving the stability and functionality of our website. A transfer or other use of the data does not take place. However, we reserve the right to check the server log files retrospectively should concrete indications point to illegal use.
9.1 On our website we sometimes use so-called cookies. Cookies are small text files that your Internet browser places and stores on your computer. Cookies do not cause any damage to your computer and do not contain viruses. Cookies serve to make our offer more user-friendly, effective and secure.
9.2 Most of the cookies we use are so-called "session cookies". They are automatically deleted after the end of your visit. Other cookies remain stored on your terminal device until you delete them. These cookies enable us to recognize your browser on your next visit.
9.3 You can set your browser so that you are informed about the setting of cookies and allow cookies only in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.
9.4 Cookies that are required to carry out the electronic communication process or to provide certain functions you have requested are stored on the basis of Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. Insofar as other cookies (e.g. cookies to analyze your surfing behavior or cookies from third-party providers) are stored, these will be treated separately in this data protection declaration.
10.1 Based on our legitimate interests (interest in the analysis, optimization and economic benefit of our website), we use for our website "Google Analytics", a web analytics service provided by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA.
10.2 Google Analytics uses cookies that allow an analysis of your use of our website and is used by Google to compile reports for us as the operator of this website about your activities on our website and to provide other services related to website use and internet use. The information generated by the cookies in this way is usually transferred to a server operated by Google Inc. in the USA and stored there.
10.3 Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law.
10.4 We only use Google Analytics with IP anonymization activated. This means that the IP address of the user is shortened by Google within member states of the European Union or in other contracting states of the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there.
10.5 Users can prevent the storage of cookies by setting their browser software accordingly; users can also prevent the collection of data generated by the cookie and related to their use of the online offer to Google and the processing of this data by Google by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=de.
11. Google Re/Marketing Services
11.1 Based on our legitimate interests (i.e. interest in the analysis, optimization and economical use of our website), we use the marketing and remarketing services (in short "Google Marketing Services") of Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, ("Google").
11.2 The Google Marketing Services allow us to display advertisements for and on our website in a more targeted manner in order to present users only with ads that potentially match their interests. If, for example, a user is shown ads for products he or she was interested in on other websites, this is referred to as "remarketing". For these purposes, when our website and other websites on which Google marketing services are active are called up, a code is executed directly by Google and so-called (re)marketing tags (invisible graphics or code, also referred to as "web beacons") are integrated into the website. With their help, an individual cookie, i.e. a small file, is stored on the user's device (similar technologies can be used instead of cookies). The cookies can be set by various domains, including google.com, doubleclick.net, invitemedia.com, admeld.com, googlesyndication.com, or googleadservices.com. This file records which websites the user has visited, which content he is interested in and which offers he has clicked on, as well as technical information on the browser and operating system, referring websites, time of visit and other information on the use of the online offer. The IP address of the user is also recorded, whereby we inform Google Analytics that the IP address is shortened within Member States of the European Union or in other contracting states to the Agreement on the European Economic Area and only in exceptional cases is transferred in full to a Google server in the USA and shortened there. The IP address will not be merged with data of the user within other offers of Google. The aforementioned information may also be linked on the part of Google with such information from other sources. If the user subsequently visits other websites, he can be shown ads tailored to his interests.
11.3 User data is processed pseudonymously as part of the Google marketing services, i.e. Google does not store and process, for example, the name or email address of the users, but processes the relevant data in a cookie-related manner within pseudonymous user profiles. I.e. from Google's perspective, the ads are not managed and displayed for a specifically identified person, but for the cookie holder, regardless of who this cookie holder is. This does not apply if a user has expressly allowed Google to process the data without this pseudonymization. The information collected by Google marketing services about users is transmitted to Google and stored on Google's servers in the USA.
11.4 The Google marketing services we use include, among others, the online advertising program "Google AdWords". In the case of Google AdWords, each AdWords customer receives a different "conversion cookie". Cookies can therefore not be tracked across the websites of AdWords customers. The information obtained using the cookie is used to create conversion statistics for AdWords customers who have opted-in to conversion tracking. The AdWords customers learn the total number of users who clicked on their ad and were redirected to a page tagged with a conversion tracking tag. However, they do not receive any information with which users can be personally identified.
11.5 We may integrate third-party advertisements based on the Google marketing service "DoubleClick". DoubleClick uses cookies that enable Google and its partner websites to serve ads based on users' visits to this website or other websites on the Internet.
11.6 We may integrate third-party advertisements based on the Google marketing service "AdSense". AdSense uses cookies that enable Google and its partner websites to display ads based on users' visits to this website or other websites on the Internet.
11.7 Furthermore, we can use the "Google Tag Manager" to integrate and manage the Google analysis and marketing services on our website.
11.8 For more information about Google's use of data for marketing purposes, please visit the overview page: https://www.google.com/policies/technologies/ads, Google's privacy policy is available at https://www.google.com/policies/privacy.
11.9 If you wish to object to interest-based advertising by Google marketing services, you can use the settings and opt-out options provided by Google: https://www.google.com/ads/preferences.
12. Social Media buttons and links
The links/buttons to social networks and platforms (hereinafter referred to as "social media") used as part of our Internet presence generally only establish contact between social networks and users when users click on the links/buttons and the respective networks, or their websites, are called up. This function corresponds to the mode of action of a regular online link.
13. Use of Google+ recommendation components
13.1 Based on our legitimate interests (interest in the analysis, optimization and economic benefit of our website), we use the "+1" button of the provider Google+ of the company Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043 USA, hereinafter "Google", on our site.
13.2 For each individual visit to our website that is equipped with such a "+1" component, this component causes a connection to be established between the browser you are using and Google's server. This process informs Google which specific page of our website is currently being visited. This applies regardless of whether you are registered or logged in to Google Plus. A transmission also takes place for non-registered or non-logged-in users.
According to Google's information, however, a further evaluation of your visit does not take place if you are not logged in to your Google account. If, on the other hand, you are a member of Google Plus and logged in to Google Plus at the time you use the plug-in, the information collected about your visit to the website will be linked to your Google Plus account and made known to other users.
13.3 If you do not want Google to associate the collected information directly with your Google Plus profile, you must log out of Google Plus before visiting our site.
14. Use of Facebook components
14.1 We use components of the provider facebook.com on our site based on our legitimate interests (interest in the analysis, optimization and economic benefit of our website). Facebook is a service of Facebook Inc, 1 Hacker Way, Menlo Park, California 94025, USA.
14.2 The plug-ins are recognizable by the Facebook logo (white "f") The list and appearance of Facebook social plug-ins can be viewed here: https://developers.facebook.com/docs/plugins/.
14.3 When you access our website, this component causes a direct connection to be established between the browser you are using and Facebook's servers. This process informs Facebook which specific page of our website you are currently visiting. If you visit our site and are logged in to Facebook during this time, Facebook will assign this information to your personal account. If you do not want Facebook to link information regarding the use of our website with your membership data stored on Facebook, you must log out of Facebook before accessing our site.
14.4 The content of the plug-in is transmitted by Facebook directly to the user's device and integrated by the user into the online offer. In the process, usage profiles of the users can be created from the processed data. We, therefore, have no influence on the scope of the data that Facebook collects with the help of this plug-in and therefore inform users according to our level of knowledge.
14.5 The purpose and scope of the data collection and the further processing and use of the data by Facebook, as well as the related rights and settings options for protecting the privacy of users, can be found in the privacy notices of Facebook: https://www.facebook.com/about/privacy/.
15. Use of YouTube components
15.1 On our website we use components (videos) of the company YouTube, LLC 901 Cherry Ave, 94066 San Bruno, CA, USA, a company of Google Inc, Amphitheatre Parkway, Mountain View, CA 94043, USA.
15.2 When you access a page that has an embedded video, a connection to the YouTube servers is established and the content is displayed on the website by notifying your browser.
15.3 We use the "extended data protection mode" option provided by YouTube, which, according to YouTube's information, only transmits data to the YouTube server, in particular which of our web pages you have visited when you watch the video. If you are logged in to YouTube at the same time, this information is assigned to your member account with YouTube. You can prevent this by logging out of your member account before visiting our website.
15.4 Further information on YouTube data protection is provided by Google under the following link: https://support.google.com/youtube/answer/2801895?hl=de.
16. integration of further services and contents of third parties
16.1 It may happen that content or services from third-party providers, such as city maps or fonts from other websites, are integrated within our website based on our legitimate interests (i.e. interest in the analysis, optimization and economic benefit of our website). The integration of third-party content always requires that the third-party providers perceive the IP address of the users since without the IP address they could not send the content to the users' browser. The IP address is thus required for the display of this content. Furthermore, the providers of the third-party content can set their own cookies and process the users' data for their own purposes. In doing so, user profiles can be created from the processed data. We will use this content as sparingly as possible and in a data-avoiding manner and select reliable third-party providers with regard to data security.
16.2 The following presentation provides an overview of third-party providers and their content, along with links to their data protection statements, which contain further information on the processing of data and, in part already mentioned here, objection options (so-called opt-out):
16.2.1 The dispatch of our system messages is carried out by means of "Mandril", an interface of the e-mail dispatch offer "Mailchimp" of the provider Rocket Science Group, LLC, 675 Ponce De Leon Ave NE #5000, Atlanta, GA 30308, USA. You can view Mailchimp's privacy policy here: https://mailchimp.com/legal/privacy/.
16.2.2 External fonts from Google, Inc, https://www.google.com/fonts ("Google Fonts"). The integration of Google Fonts is done by a server call at Google (usually in the USA). Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
16.2.3 Maps of the service "Google Maps" provided by the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
16.2.4 Videos from the "YouTube" platform of the third-party provider Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. Privacy policy: https://www.google.com/policies/privacy/, Opt-Out: https://www.google.com/settings/ads/.
16.3 Further notes on data protection guarantees: Google is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with European data protection law. The Rocket Science Group LLC d/b/a MailChimp is certified under the Privacy Shield agreement and thereby offers a guarantee of compliance with the European data protection level. Adobe is certified under the Privacy Shield Agreement and thereby offers a guarantee of compliance with the European level of data protection.
17. Rights of the users
17.1 In accordance with legal requirements, users have the right to request information free of charge about the personal data we have stored about them.
17.2 In addition, users have the right to correct incorrect data, restrict processing and delete their personal data, if applicable, to assert their rights to data portability and, in the event of the assumption of unlawful data processing, to file a complaint with the competent supervisory authority.
17.3 Furthermore, users may object to the processing of their data and revoke consents, in principle with effect for the future (so-called opt-out).
18. Right of objection
Users may object to the future processing of their personal data in accordance with the legal requirements at any time. The objection can be made in particular against the processing for purposes of direct advertising.
19. Storage period
19.1 Personal data shall be processed and stored for as long as required by the purpose for which it was collected and for as long as there are no statutory retention obligations to the contrary. This applies, for example, to user data that must be retained for reasons of commercial or tax law.
19.2 Personal data collected for the purpose of fulfilling a contract concluded between the Provider and the User shall be stored until the complete fulfillment of this contract.
19.3 Personal data collected for the purpose of safeguarding the Provider's legitimate interests shall be retained for as long as necessary to fulfill these purposes. Users can obtain more detailed information about the Provider's legitimate interests in the relevant sections of this document or by contacting the Provider;
19.4 Personal data collected on the basis of the User's consent will be stored as long as the consent is not revoked.
19.5 After expiry of the retention period, personal data will be deleted. Therefore, the right to information, the right to deletion, the right to rectification and the right to data portability cannot be asserted after the expiry of the retention period.
20. Changes to this privacy policy
20.1 We reserve the right to adapt this data protection declaration from time to time so that it always complies with the current legal requirements or in order to implement changes to our services in the data protection declaration.
20.2 Insofar as user consent is required or components of the data protection declaration contain provisions of the contractual relationship with the users, the changes will only be made with the consent of the users.
20.3 We ask you to inform yourself about our data protection measures at regular intervals by consulting our data protection declaration. The new privacy policy will then apply to your next visit.