Information on the processing of personal data

DATA CONTROLLER

QTE S.r.l. with registered office in Via Meuccio Ruini n.10, 42124 Reggio Emilia, tax code and VAT number 02650440353 (hereinafter "QTE") PRIVACY@QTELEMATICS.EU

DATA PROTECTION OFFICER (RPD/DPO)

The contact details of the Data Protection Office (DPO) are  DPO@QTELEMATICS.EU

RIGHTS OF DATA SUBJECTS

Data subjects have the following rights:

  -  To obtain confirmation of whether or not processing is taking place and, if so, to obtain access to the data concerning the data subject

  -  Know the origin of the data processed by the Controller

  -  Verify the accuracy of the data concerning the data subject

  -  Object, for legitimate reasons, to the processing  

  -  Ask for any 

• integration
• deletion
• updating
• rectification
• bblocking of personal data processed in violation of the law
• portability

Requests may be addressed to the Data Controller or the DPO/DPO. 

Data subjects also have the right to

  - To be informed about breaches that may present a high risk for data subjects

  - To lodge a complaint with the competent supervisory authority in the Member State where they habitually reside or work or in the State where the alleged breach occurred.

OBLIGATION TO PROVIDE DATA

When the provision of personal data is a legal or contractual obligation or a necessary requirement for the conclusion of a contract, if the data subject does not provide the personal data requested, it will not be possible to proceed with the activity for which such data is requested (e.g. conclusion of the contract).

ANONYMISED DATA

The Data Controller will use the appropriately anonymised data, so that it cannot be traced back to the Data Subject, for the development of its business activities.

LEGITIMATE INTEREST OF THE DATA CONTROLLER

The Data Controller may use its legitimate interest as the legal basis for a specific purpose by balancing its rights with those of the data subject, taking into account the data subject's 'reasonable expectations' in view also of its existing relationship with the Data Controller. When the processing is based on the legitimate interest of the Controller, there is no need to request consent from the data subject in order to pursue that specific purpose. The processing must not adversely affect the rights and freedoms of the data subject.

Depending on the processing, the legitimate interest of the Controller is specified in the notice, where present.

TRANSFERS OUTSIDE THE EU

Transfers to third countries will take place in accordance with the legislation in force:

• iin countries recognised as safe by the EU Commission

• in countries with which Europe has international agreements on data protection

• with entities with which the Controller has entered into legally binding agreements that provide adequate guarantees for the protection of Data Subjects as required by law.

• where exceptions are provided for, such as the consent of the data subject or the need, which is not repetitive, for types and amounts of data that allow it.

INTRODUCTION

This information notice supplements the general data and is provided in the commercial context of the relationship between the Parties for the description of the processing of personal data. 

In particular, TSPs/DEALERS/DEALERS/ SUPPLIERS enter into commercial agreements with the Controller concerning Goods and/or Services useful to the Controller's business and/or pertaining to commercial activities. Below is the information required by the standard for the processing of personal data, where involved. The purposes described also apply to non-personal data.

PURPOSES AND LEGAL BASES

The personal data of the data subject are processed for the following purposes:

Establishment, execution of the contract for the chosen service and sending e-mails of commercial communications within the scope of the contractual relationship. 

Fulfilling obligations under applicable regulations and legislation

If necessary, to ascertain, exercise or defend the Controller's rights in or out of court

Marketing: e.g. sms and e-mail, telephone calls with operator and traditional mail for promotional and commercial proposals regarding services/products offered by the Company 

The applicable legal bases of processing identified by the GDPR are

Performance of a contract to which you are a party (e.g. provision of service, communication of access credentials)

Need to fulfil legal obligations

Legitimate interest of the Data Controller to facilitate the management of business activities and to send commercial emails (so-called soft-spam).

Consent, requested time by time, where necessary, in order to comply with the provisions of the law (free, contextual/specific, informed, revocable).

RETENTION PERIOD

The data retention period is:

10 years after the termination of the contract for administrative and accounting data in compliance with the legal obligation requiring retention

In the event of litigation for the duration of the litigation and for the terms of appeal. 

Related to the purpose of the processing. E.g. the Criterion applied by the Data Controller for commercial communications at the conclusion of the contract between the parties is 24 months, without prejudice to the unsubscription at any time by the interested party even before this term.

Once the retention period has expired, the data will be destroyed, deleted or rendered anonymous.

INTRODUCTION

This information integrates the general data and is provided both to the Interested Parties who propose their candidature for a job position to the Controller and for the specific personnel searches that may be promoted by the Controller also with the support of specialised entities (Head Hunters, temporary employment agencies).

Below is the information required by the rule for the processing of personal data whether they are provided directly by the Data Subject or by third parties to the Data Controller.

CATEGORIES OF DATA AND SOURCE FROM WHICH THEY ORIGINATE 

The personal data subject to processing may be those provided spontaneously by the Data Subject with his/her application (CV, motivational letter, cover letter, certification of academic course, etc.) and/or those expressly requested by the Data Controller for specific open positions provided either by the Data Subject himself/herself or by third party intermediaries that may be involved such as temporary employment agencies and/or Head Hunters. Depending on the case, they may only be common data or, if lawful, may include special data (e.g. belonging to protected categories).

PURPOSES AND LEGAL BASES

The data subject's personal data are processed for the following purposes:

Examination of the candidate's profile and assessment and organisation of meetings and interviews

Preparation of recruitment documentation in the event of a positive assessment

If necessary, to ascertain, exercise or defend the rights of the Controller in judicial or extrajudicial proceedings

The applicable legal bases for processing identified by the GDPR are:

Execution of pre-contractual activities

Legal obligations  

Legitimate interest of the Data Controller for a better organisation of the activity (e.g. communication via the telephone number provided also via SMS)

RETENTION PERIOD

The maximum data retention period is 24 months from the date on which the data is provided. 

Once the aforementioned retention period has expired, the data will be destroyed, deleted or rendered anonymous.

INTRODUCTION

This notice supplements the general data and is given to interested parties who use the Owner's sites. In particular, it applies to the sites:

1. https://www.qtelematics.eu 

Below is the information required by law for the processing of personal data.

CATEGORIES OF DATA AND SOURCE FROM WHICH THEY ORIGINATE 

 The personal data subject to processing are provided by those who navigate on the site and interact with it. The data may concern identification and contact data (name, surname, e-mail address, etc.), special data (ex art. 9 GDPR) that may be spontaneously provided by filling in the contact form. The geolocation data processed are those communicated by the telematic devices installed on the vehicles transmitted to the system.

PURPOSE AND LEGAL BASIS AND CRITERIA FOR DURATION OF PROCESSING

The personal data of the data subject are processed for the following purposes:

a) CONTACT FORM: Responding to requests or questions submitted by the User. The basis of which is the legitimate interest of the Controller to be identified in the reasonable expectation that the User expects his/her personal data to be processed by the Controller in order to respond to his/her contact request. In the event that particular data is provided, the legal basis is consent c confirmed by ticking the appropriate box. The data will be processed for the time necessary to manage the request sent via the form if some of the data of the interested party are used for other purposes and/or if the relationship of the interested party with the owner changes, please refer to the specific information concerning the interested party (e.g. from interested prospect to customer and/or retailer). 

b) COMMUNICATIONS BY EMAIL: The Controller informs that after the expiry of the contract, by means of e-mail communications, the interested party may receive commercial communications aimed at proposing a reactivation of the Service and/or informing about new products/services provided by the Controller. The legitimate interest of the Data Controller in promoting its business with former users of its Services is the basis of the processing given the reasonable expectations of the same. The processing will last for 12 months from the conclusion of the contract unless the right to object is exercised before that period.

c) APP: through the applications and web portals made available by the Data Controller, Users can make use of the services purchased and active to manage the geolocation data recorded in the system according to the specific functionalities for each service. The retention period is linked to what is signed in the service contract and in relation to the settings configurable by the User within the App. The legal basis is the contract to which the Data Subject is also a party as a User of the Service. Specific disclosures are made when subscribing to the Service and any updates made available to Data Subjects.