Privacy Policy

Privacy Policy – www.blubrake.com

 

[Last update: 11/11/2021]

What is this document? Pursuant to art. 13 European Reg. n. 679/2016 (“General Data Protection Regulation” or “GDPR”) and in compliance with the principles contained therein, blubrake s.r.l. intends to inform each user (the “User”) about the processing of personal data happening on its website (www.blubrake.com) .

Controller and contact detail

Blubrake SpA (hereinafter “Blubrake” or “Controller”, pursuant to art. 4(7) GDPR) with registered offices in

Via San Martino 12, 20122 Milan (Italy)

info@blubrake.it

Purpose of processing, Legal Basis, Personal Data and Retention Period

The Controller processes Personal Data for the following purposes, as specified here in below. The table also shows the legal basis which justifies the processing and the period of data retention:

Purpose Personal data Legal basis Data retention Provision of the services, dealer account creation and management.

 

Purpose Personal data Legal basis Data retention Provision of the services, dealer account creation and management. ✓ Anagraphic information

✓ Contact details Performance of a contract [Art. 6, 1, lett. b) GDPR] Until the dealer deletes the account. Recruit and select applicants. ✓ Anagraphic information

✓ Contact details

✓ Professional information Performance of a contract [Art. 6, 1, lett. b) GDPR] For the period of time necessary to complete the recruitment process and in any case not later than 1 year. Contact and customer care. ✓ Anagraphic information

✓ Contact details Performance of a contract [Art. 6, 1, lett. b) GDPR] For the period of time necessary to answer the customer. Send newsletters and/or other materials for marketing communication purposes. ✓ Anagraphic information

✓ Contact detail Consent [Art. 6, 1, lett. a) GDPR] Until the withdrawal of consent and in any case not later than 24 months from the date of the last contact. Allow the Controller to accomplish all formalities required by law. ✓ Anagraphic information

✓ Contact details Legal obligation [Art. 6, 1, lett. c) GDPR] Until the expiry of the data retention period, as provided by the applicable law. Improve the Website by analyzing how Users navigate and/or use the Website. ✓ IP address Legitimate interest

[Art. 6, 1, lett. f) GDPR] Not applicable (aggregate or anonymous data) Detecting or preventing fraudulent activity and exercising the Controller’s rights in Court. ✓ Anagraphic information

✓ Contact details

✓ Professional information Legitimate interest

[Art. 6, 1, lett. f) GDPR] 10 years

In case the User prefers not to communicate mandatory and/or necessary data for the fulfilment of certain purposes, Blubrake reserves the right to not provide the service through its Website.

Processing modalities

The processing of Personal Data will take place through automated and/or manual tools in order to ensure proper security measures to prevent access, disclosure, loss, incorrect, illegal or unauthorized use of data.

Data Sharing

Your Personal Data may be shared with the following subjects, on a needtoknow basis and in accordance with Applicable Privacy Laws: (i) Internet service providers and platforms used by the Controller as organisation tools, channels of communication and/or promotion; (ii) thirdparty consultants and other thirdparty service providers who perform services for us or on our behalf and require access to such information to do that job; (iii) parent Company (ENovia S.p.a.) and its subsidiary Companies. All of the relations with the subjects listed above are – and will be – formalized with a contract pursuant to Art. 28 GDPR (Data Protection Agreement or “DPA”). Personal data will be processed by internal staff specifically authorized under Article 29 of the GDPR. The names of all authorized personnel are available under request to the Data Controller, at info@blubrake.it.

Data processing locations

Personal data is processed at the headquarters of the Controller, as well as in the servers that host the website www.blubrake.it. The Data Controller ensures that when using cloud providers established outside the EEA, the processing of personal data by these recipients is carried out in accordance with applicable law. Transfers shall be carried out by means of appropriate safeguards, such as adequacy decisions, standard contractual clauses approved by the European Commission or other safeguards provided for in the GDPR.

Data Subjects’ rights The User may exercise all the rights provided for by Articles 1521 of EU Reg. no. 679/2016, at any time and without unjustified limitations, by contacting the Data Controller at info@blubrake.it Requests shall be filed free of charge and processed by the Controller within 30 days. Specifically, the User can:

● Obtain from the controller confirmation as to whether or not personal data are being processed (Art.15);

● Obtain from the controller the rectification of inaccurate personal data (Art. 16);

● Obtain from the controller the erasure of personal data (Art. 17);

● Obtain from the controller restriction of processing (Art. 18);

● Have the right to receive the personal data in a structured, commonly used and machinereadable format and have the right to transmit those data to another controller (Art. 20);

● Have the right to object (Art. 21);

Complaints

In any case, Users are always entitled to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali), under Art. 77 of the Regulation, if they believe that the Data Controller’s processing of their Personal Data is in violation of the applicable law.

Amendments

The Controller reserves the right to amend and update the Privacy Policy as a result of any further new or revised provisions of any national and EU laws and regulations on personal data protection.

Cookie Policy

Cookie Policy

Definitions, characteristics and application of the legislation

 

Cookies are small text files that may be sent to and registered on your computer or mobile device by the websites you visit, to then be resent to those same sites when you visit them again. It is thanks to these cookies that those websites can “remember” your actions and preferences (e.g., login data, language, font size, other display settings, etc.), so that you do not need to configure them again when you next visit the website, or when you change pages within a website.

Cookies are, therefore, used for electronic authentication, monitoring of sessions and storage of information regarding your activities when accessing a website. They may also contain a unique ID code which allows tracking of your browsing activities within a website, for statistical or advertising purposes. Some operations within a website may not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website.

When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., thirdparty cookies).

There are various types of cookies, depending on their characteristics and functions, which may be stored on your computer or mobile device for different periods of time: “session cookies”, which are automatically deleted when you close your browser, and “persistent cookies”, which will remain on your device until their preset expiration period passes.

According to the law which may be applicable to you, your consent may not always be necessary for cookies to be used through the Website. In particular, “technical cookies” – i.e. cookies used exclusively to transmit messages over an electronic communications network, or otherwise strictly necessary to provide a service specifically requested by you – typically do not require this consent. In other words, cookies which are indispensable for operation of the Website or required to perform activities you request may be used without your consent. This may include cookies used for analytics purposes (used to collect aggregated information on the number of users of a website, and how those users visit the website), browsing or session cookies (used to allow users to login) and function cookies (used to allow memorisation of choices made by a user when accessing the website, such as language or products selected for purchase, in order to improve the user’s experience).

Under Italian law, your express consent is not always required for the use of cookies. In particular, “technical cookies” – i.e., cookies used exclusively to transmit messages over an electronic communications network, or otherwise strictly necessary to provide a service explicitly requested by you – do not require your consent. In other words, cookies which are indispensable for the operation of the Website or required to perform activities you request may be used without your consent. The Italian Data Protection Authority (as defined in its “Determination of simplified procedures for information and collection of consent for the use of cookies”, 8 May 2014, and subsequent clarifications), has established that, among cookies which can be used without consent, the following are included:

 

Analytics cookies, when used directly by a website operator to collect information, in an aggregate form, on the number of users and how they use a website; Browsing or session cookies, to identify and authenticate users of a website; Function cookies, which allow users to browse a website according to a series of selected criteria (e.g., a certain language, products selected for purchase, etc.), in order to improve the services provided to those users.

 

On the other hand, “profiling cookies” – i.e., cookies used to create profiles on users and used to send advertising messages in line with the preferences revealed by users while browsing websites – require users’ prior consent.

 

Types of cookies used by the Website and optout option

 

www.blubrake.com (hereinafter, “Website” or “Blubrake”) uses thirdparty cookies – i.e. cookies from websites / web servers other than the Website, and which are used for specific purposes of the third parties owning those websites/webservers. These third parties will typically be considered independent data controllers regarding their cookies, and therefore you must refer to their privacy policies, information notices or other materials to obtain more information on them. Blubrake cannot control or ascertain the use which may be made, by these third parties, of thirdparty cookies, nor their exact characteristics or purpose.

 

Following the list of cookies used on this Website:

 

Type of cookie and data controller Technical name Type Term Functionality and purpose Blubrake

Necessary _grecaptcha HTML Persistent  

 

Necessary cookies contribute to the usability of the website by enabling basic functionality such as page navigation and access to secure areas of the website. listmanage.com

Necessary _abck HTTP 1 year us4.listmanage.com

Necessary ak_bmsc HTTP 1 day us4.listmanage.com

Necessary bm_sv HTTP Session listmanage.com

Necessary bm_sz HTTP 1 day Google

Necessary _GRECAPTCHA HTTP 179 days Google

Necessary rc::a HTML Persistent Google

Necessary rc::b HTML Session Google

Necessary rc::c HTML Session Blubrake

Preferences _icl_visitor_lang_js HTTP 1 day  

Allow the website to store information that affects its performance or appearance, such as your preferred language Blubrake

Preferences wpml_browser_redirect_test HTTP Session Vimeo

Preferences player HTTP 1 year Vimeo

Preferences sync_active HTML Persistent Google Analytics

Technical _ga HTTP 2 years  

 

 

These cookies are used to monitor performance, for reporting and for providing data that will influence the improvements made to the Website. The cookies collect information in an anonymous form

 

  Google Analytics

Technical _gat HTTP 1 day Google Analytics

Technical _gid HTTP 1 day Vimeo

Technical vuid HTTP 2 years Facebook Marketing _fbp HTTP 3 months  

 

These cookies are used to deliver a variety of advertising products such as realtime offers from thirdparty advertisers. mc.us4.listmanage.com Marketing _mcid HTTP 1 year Facebook Marketing tr Pixel User session duration

 

Your consent is not required for the installation of Google Analytics cookies as Blubrake uses it with the “anonymizelp” extension for anonymization.

 

Cookie settings

 

If you do not want your data to be used by Google Analytics, you can install the browser addon in the manner described by Google at the following addresses:

 

https://support.google.com/analytics/answer/181881?hl=it https://tools.google.com/dlpage/gaoptout

 

The installation of this addon prevents the Google Analytics JavaScript code (ga.js, analytics.js and dc.js) running on a website from sharing information with Google Analytics about your activity when you visit our Website.

 

How to view and modify cookies through the browser

 

You can block or delete all or some of the cookies used on the Website via your browser options. Your cookie preferences will be reset if different browsers are used to access the Website. For more information on how to set the preferences for cookies via your browser, refer to the following instructions:

 

Internet Explorer Firefox Chrome Safari