Legal information

Privacy

Notice on the processing of personal data of website users

Articles 13 and 14 of Regulation 2016/679/EU (also the "GDPR" below)

This English text is a courtesy translation. In case of any discrepancy, the Italian version prevails.

Why this notice

SINERGIE EXPRESS S.R.L. (also the "Company" or the "Controller" below) is committed to respecting and protecting your privacy, and wants you to feel safe both when simply browsing the site and if you decide to register and give us your personal data in order to use the services made available to its Users and Customers. On this page the Company sets out information on the processing of personal data of users who visit or consult the website reachable online at www.ponyexpressmilano.it (the "Site"). This notice covers the Company website only, and not other websites the user may reach through a link (for those, please refer to their own privacy notices and policies). Reproduction or use of the pages, materials and information contained in the Site, by any means and on any medium, is not permitted without the prior written consent of the Company. Copying and printing are permitted for strictly personal, non-commercial use (for requests and clarifications, contact the Company at the details given below). Other uses of the content, services and information on this site are not permitted. As to the content offered and the information provided, the Company will keep the Site reasonably up to date and reviewed, without offering any warranty as to the adequacy, accuracy or completeness of the information provided, and expressly disclaims all liability for any errors of omission in the information provided on the Site.

Origin — Browsing data

The Company informs you that the personal data you provide, acquired together with a request for information or contact, registration on the site and use of the services through a smartphone or any other tool used to access the Internet, as well as the data needed to deliver those services, including browsing data and the data used for any purchase of the products and services offered by the Company, and also the mere so-called "browsing" data of the site by Users, will be processed in accordance with applicable law. The IT systems and software procedures used to operate this website acquire, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet protocols. This is information that is not collected in order to be linked to identified data subjects, but which by its very nature could, through processing and association with data held by third parties, allow browsing users to be identified. This category of data includes the "IP addresses" or the domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the web server, the size of the file obtained in reply, the numeric code indicating the status of the reply given by the web server (successful, error and so on) and other parameters relating to the user's operating system and IT environment. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check that the Company website works correctly. Please note that the data described above could be used to establish liability in the event of computer crimes against the Company site or against other sites connected or linked to it. Except in that event, web contact data is currently not retained for more than a few days.

Origin — Data provided by the user

The Company collects, stores and processes your personal data in order to supply the products and services offered on the Site, or to meet legal obligations. For certain specific Services, Products, Promotions and similar, the Company may also process your data for commercial purposes. In those cases a specific, separate and optional consent will be requested, always revocable in the manner and at the contact details given below. The optional, explicit and voluntary sending of e-mail to the addresses shown in the relevant section of the Website, as well as the completion of questionnaires (for example forms), communication by chat, push notification through an app, social networks, call centre and similar, entails the subsequent acquisition of some of your personal data, including data collected through use of the apps and related services, needed in order to answer your requests. We also point out that, when a mobile connection is used to reach digital content and services offered directly by the Company or by our Partners, it may be necessary to transfer your personal data to those third parties. Please note that you may reach the Site, or connect to areas where you may be allowed to publish information using blogs or message boards, to communicate with others, for example arriving from the Company page on Facebook®, LinkedIn®, YouTube® and other social network sites, to review products and offers and to publish comments or content. Before interacting with such areas we invite you to read the General Terms of Use carefully, bearing in mind that in certain circumstances published information can be seen by anyone with access to the Internet, and that all information you include in your posts can be read, collected and used by third parties.

Purposes of the processing and legal basis

The data is processed for the following purposes:

1) purposes strictly connected with and necessary to registration on the site www.Azienda.it, to the services and apps developed or made available by the Company, to the use of the related information services, to the handling of contact or information requests, and to the purchase of products and services offered through the Company site; 2) ancillary activities connected with handling the User's or Customer's requests and sending a reply, which may include the transmission of promotional material; completion of the purchase order for the products and services offered, including matters relating to credit card payment, management of shipments, of any exercise of the right of withdrawal provided for distance purchases, and updates on the availability of products and services temporarily unavailable; 3) purposes connected with compliance with obligations laid down by EU and national law, with the protection of public order, and with the detection and prosecution of offences; 4) direct marketing, that is the sending of advertising material, direct selling, market research or commercial communication about products and services offered by the Company. This activity may also concern products and services of companies of the Company group, and may be carried out by sending advertising, informative or promotional material and invitations to take part in initiatives, events and offers intended to reward users and customers, performed by "traditional" means (for example paper mail or calls from an operator) or by "automated" contact systems (for example SMS or MMS, telephone calls without an operator, e-mail, fax, interactive applications), pursuant to Article 130, paragraphs 1 and 2, of Legislative Decree 196/03 as amended.

Providing data for the purposes under points 1), 2) and 3), which relate to a pre-contractual or contractual stage, or serve a request of the user, or are required by a specific legal provision, is mandatory. Without it, it will not be possible to receive the information or access the services requested. As to point 4) of this notice, the user's or customer's consent to the processing is instead free and optional, and always revocable, with no consequence for the usability of the products and services, save that the Company will be unable to keep users and customers informed about new initiatives or about particular promotions or benefits that may be available.

The Company may send commercial communications about products and services similar to those already supplied, pursuant to Directive 2002/58/EU, using the e-mail or postal details you provided on those occasions. You may object to this in the manner and at the contact details given below.

Means and logic of the processing, retention periods and security measures

The processing is also carried out with the help of electronic or otherwise automated means, and is performed by the Company and by third parties the Company may use to store, manage and transmit the data. The data will be processed using logic for organising and processing your personal data, including data relating to the logs generated by access to and use of the services made available over the web and of the products and services used, connected with the purposes stated above, and in any case in a way that guarantees the security and confidentiality of the data. The personal data processed will be retained for the periods laid down by the law applicable from time to time. Still on data security, in the sections of the website set up for particular services, where personal data is requested from the browsing user, the data is encrypted using a security technology called Secure Sockets Layer, abbreviated to SSL. SSL technology encodes information before it is exchanged over the Internet between the user's device and the Company's central systems, making it unintelligible to unauthorised parties and so guaranteeing the confidentiality of the information transmitted. In addition, transactions carried out using electronic payment instruments are performed directly on the platform of the Payment Service Provider (PSP), and the Company retains only the minimum set of information needed to handle any dispute. Precisely with regard to personal data protection, the user or customer is invited, pursuant to Article 33 of the GDPR, to report to the Company any circumstance or event that could give rise to a potential personal data breach, so as to allow an immediate assessment and the adoption of any action to counter that event, by sending a communication to privacy@Azienda.it or by contacting Customer Service. The measures adopted by the Company do not relieve the Customer of the need to take due care in using, where required, passwords and PINs of adequate complexity, which must be updated periodically, above all if the Customer fears they have been breached or become known to third parties, and which must be kept carefully and made inaccessible to third parties, in order to avoid improper and unauthorised use.

Cookies

A cookie is a short string of text that is sent to your browser and, in some cases, saved on your computer (or on your smartphone, tablet or any other tool used to access the Internet). This generally happens each time you visit a website. The Company uses cookies for several purposes, in order to offer you a fast and secure digital experience, for example by letting you stay connected to the protected area while browsing through the pages of the site. Cookies stored on your device cannot be used to retrieve any data from your hard disk, to transmit computer viruses, or to identify and use your e-mail address. Each cookie is unique to the browser and device you use to access the Website or to use the Company app. In general, the purpose of cookies is to improve how the website works and the user's experience of it, although cookies can also be used to send advertising messages (as specified below). For more information on what cookies are and how they work, you can consult the "All about cookies" website at http://www.allaboutcookies.org .

Scope of disclosure and transfer of data.

In pursuit of the purposes stated above, the Company may disclose the personal data of users and customers, and have it processed, in Italy and abroad, by third parties with whom we have a relationship, where those third parties supply services at our request. We will give those third parties only the information needed to perform the services requested, taking every measure to protect your personal data. The data may be transferred outside the European Economic Area where this proves necessary in order to manage your contractual relationship. In that case, obligations of protection and security equivalent to those guaranteed by the Controller will be imposed on the recipients of the data. Where services offered directly by Partners are used, we will supply only the data strictly necessary to perform them. In every case, only the data needed to pursue the stated purposes will be disclosed, and where required the safeguards applicable to transfers of data to third countries will be applied. We may also disclose personal data to our commercial service suppliers, for marketing reasons, appointed as external data processors for that purpose. Personal data may further be disclosed to the competent public bodies and authorities in order to comply with legal obligations or to establish liability in the event of computer crimes against the site, and disclosed to, or held by, third parties (as processors or, where they are electronic communications service providers, as independent controllers) that supply IT and telematic services (for example hosting, website management and development services) and which the Company uses to carry out tasks and activities, including of a technical and organisational nature, instrumental to the operation of the website. The parties belonging to the categories listed above act as separate Controllers or as Processors appointed for the purpose by the Company. Personal data may also be known to employees and consultants of the Company who are specifically instructed and appointed as persons in charge of the processing. The categories of recipients to whom the data may be disclosed are available on request to the Company at the contact details given below.

Rights of data subjects

You may exercise at any time the rights granted to you by law, including the right:

a) to access your personal data, obtaining evidence of the purposes pursued by the Controller, of the categories of data involved, of the recipients to whom it may be disclosed, of the applicable retention period, and of the existence of automated decision-making; b) to obtain without delay the rectification of inaccurate personal data concerning you; c) to obtain, in the cases provided for, the erasure of your data; d) to obtain restriction of the processing, or to object to it, where possible; e) to request the portability of the data you provided to the Company, that is to receive it in a structured, commonly used and machine-readable format, including in order to transmit that data to another controller, within the limits and subject to the conditions of Article 20 of the GDPR. You may also lodge a complaint with the Italian Data Protection Authority pursuant to Article 77 of the GDPR.

For the processing under point 4) of the purposes, the Customer may at any time withdraw consent and exercise the right to object to direct marketing (in both "traditional" and "automated" form). Unless stated otherwise, the objection will be taken to cover both traditional and automated communications.

Data Controller

The data controller, pursuant to Article 4 of the Code and of the GDPR, is SINERGIE EXPRESS S.R.L., VIA RIPAMONTI GIUSEPPE 167 – 20141 MILANO (MI), VAT no. 05189340960, tax code 05189340960. The rights stated above may be exercised at the request of the data subject in the manner made known by Customer Service or on the Company website, or using the following contact: DI NUNNO ROBERTO (info@sinergieexpress.it). Use of the Website by the Customer or the User, including versions intended for tablets and smartphones, implies full knowledge and acceptance of the content and of any instructions included in the version of this notice published by the Company at the time the site is accessed. The Company informs you that this notice may be amended without notice, and therefore recommends reading it periodically. The Data Controller, SINERGIE EXPRESS S.R.L.