[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)
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.
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.
Your Personal Data may be shared with the following subjects, on a need‑to‑know 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) third‑party consultants and other third‑party service providers who perform services for us or on our behalf and require access to such information to do that job; (iii) parent Company (E‑Novia 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 email@example.com.
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 15‑21 of EU Reg. no. 679/2016, at any time and without unjustified limitations, by contacting the Data Controller at firstname.lastname@example.org 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 machine‑readable format and have the right to transmit those data to another controller (Art. 20);
● Have the right to object (Art. 21);
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.
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 re‑sent 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.
When browsing a website, you may also receive cookies from websites or web servers other than the website being visited (i.e., third‑party 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 pre‑set 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).
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 opt‑out option
www.blubrake.com (hereinafter, “Website” or “Blubrake”) uses third‑party 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 third‑party 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. list‑manage.com
Necessary _abck HTTP 1 year us4.list‑manage.com
Necessary ak_bmsc HTTP 1 day us4.list‑manage.com
Necessary bm_sv HTTP Session list‑manage.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
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 real‑time offers from third‑party advertisers. mc.us4.list‑manage.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.
If you do not want your data to be used by Google Analytics, you can install the browser add‑on in the manner described by Google at the following addresses:
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