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DATA PROCESSING TITLEHOLDER AND OFFICERS
The titleholder responsible for the processing of personal information gathered via this website is Comdata S.p.A., with registered offices situated at No.1, Via Caboto, Corsico (MI), the Company that designed and currently manages the site and decides on its configuration and modification, also in terms of its business activities and services.

Furthermore, the personal information gathered via the site may be processed by external parties, Comdata group companies or service providers working on behalf of Comdata and officially appointed as Data Processing Officers, who will process the information in accordance with the purposes for which it was gathered.

NECESSITY AND ESSENTIALITY OF THE INFORMATION
Personal information will only be gathered and stored via this website when this is essential for the achievement of the purposes stipulated in this Policy or in the individual information fact sheets posted on the website and linked to specific information gathering templates. Users will be able to browse the website without necessarily being registered or identified. The website has been designed in such a way as to respect user anonymity. It is Comdata’s policy to avoid gathering any personal information in cases where the individual specific purposes can be achieved by utilising anonymous information alone (such as, for example, overall analysis of website hits, conducted by statistical means and without tracking individual users’ browsing behaviour).

PURPOSES FOR WHICH THE DATA IS PROCESSED
The personal information of users will be processed for the purposes of fulfilling requests from users for information and materials and to put the user in contact with the marketing departments of group companies.

The gathering of identification and contact details – where necessary for specific departments – will be preceded by a special information fact sheet that indicates the purposes for which such information will be used.

TYPES OF INFORMATION
The personal information that users submit in writing to Comdata includes contact details (such as contact telephone numbers and e-mail addresses) and information relating to messages forwarded to the website operators.

Personal information relating to non-registered users is information that only allows the indirect identification of the individual concerned and only in case of need, for example upon specific request by the Courts or the Police Forces (such as, for example, in the case of information that enables the correlation of an anonymous user’s activities and browsing on the website at the IP address, in other words the Internet Protocol that identifies a specific computer or device (e.g.: smartphone, tablet) from which the connection or browsing activity originated).

PROCESSING METHODS AND SECURITY MEASURES
Users’ personal information will be processed using automated methods and strictly to the extent and for the length of time required for the specific purposes for which said information was originally gathered.

The Comdata website is protected against potential computerised attack and unauthorised access by means of appropriate security measures designed to guarantee the integrity, confidentiality and availability of personal information relative to both the online operators appearing on the website via their dedicated pages, or to registered users browsing the website.

Notwithstanding the Company’s best efforts, Comdata is unable to totally guarantee its users that the measures adopted to ensure the security of the website, data transmission and the information itself are capable of totally eliminating any and all potential risk of unauthorised access or loss of data. Users are thus urged to ensure that their computers and/or electronic devices (e.g.: smartphones, tablets) are equipped with adequate technological systems for the protection of both incoming and outgoing online data transmissions (such as updated antivirus systems) and that their Internet service providers have adopted appropriate measures to guarantee the security of online data transmissions.

ACCESS TO INFORMATION AND DATA PROTECTION RIGHTS
In terms of Regulation No. EU 679/2016, interested parties are entitled, at any time, to receive confirmation regarding the existence or otherwise of any personal information regarding them, to know what information is held and its origin, to confirm its accuracy and to request that the aforesaid information be supplemented, updated or rectified. Furthermore, the parties to whom the personal information refers are also entitled to request that the aforesaid information be deleted, that it be rendered anonymous or that the processing of said information be restricted and, in any event, even to object to the information being processed at all.

PERSONAL DATA PROTECTION OFFICER (DPO)
Anyone wishing to exercise the aforesaid rights can write to Personal Data Protection Officer (DPO) designated by Comdata S.p.A. at the postal address of the Comdata S.p.A. registered offices, or send an e-mail to the following address: dpo@comdatagroup.com

PROTECTION
Anyone who believes that his/her rights may have been violated can approach the applicable Oversight Authority as contemplated in Art. 77 of Regulation No. EU 679/2016, this without prejudice to the individual’s right to approach the Judicial Authorities.