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INFORMATION ON THE PROCESSING
OF PERSONAL DATA

GENERAL INTRODUCTION

The purpose of this Policy is to describe how the website of CA Auto Bank S.p.A. (hereinafter, “CA Auto Bank”) is managed, with reference to the processing of personal data of users. This information is provided pursuant to the EU Regulation on the protection of natural persons with regard to the processing of personal data, no. 2016/679, and current Italian legislation on privacy to those who interact with the web services of CA Auto Bank S.p.A. starting from the address www.ca-autobankgroup.com, corresponding to the home page of the CA Auto Bank website. The information is provided only for the CA Auto Bank website and not also for other websites that may be visited by users through links.

1. DATA CONTROLLER

The Data Controller is CA Auto Bank S.p.A., with registered office in Turin, Corso Orbassano 367, Tax Code and P.I. 08349560014, entered in the Bank Register no. 5764.

2. TYPE OF DATA PROCESSED

2.1) Data provided voluntarily by users

It is your prerogative, after reading the appropriate notice, to release your personal data on the site in order to access certain freely chosen products and/or services. Based on your consent, your personal data will be processed for the purpose of activating the product and/or service you have freely chosen. The provision of any required consents is optional and, in the absence of said consent, we will not be able to proceed with the performance of the activities. You have the right to revoke at any time the consents previously given with reference to the purposes that may be described through the methods indicated in section 6) hereinbelow.
Processing shall always take place:

  • in full compliance with existing regulations, based on the information provided and in a fair and transparent manner;
  • collecting a minimum amount of Data and in any case collecting only the Data necessary for the services covered by the contract;
  • in an accurate and up-to-date manner;
  • keeping the Data only for the time necessary to perform the services under the contract.

2.2) Browsing data

  • The computer systems and software procedures used to operate this website collect, in the course of their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses, type of browser, operating system, domain name and addresses of Web sites from which access or exit was made, information on pages visited by users within the site, access time, stay on the individual page, internal path analysis and other parameters related to the user’s operating system and computer environment. These technical/IT data are collected and used in an aggregate and anonymous manner for the sole purpose of:
  • improving the quality of service and optimizing the functioning of the site;
  • understanding user conduct in order to improve online communication;
  • preparing statistical information concerning the use of the site. These data may, moreover, be used:
  • to comply with requirements dictated by national regulations and communicate as well as with provisions issued by Supervisory and Control Bodies, including in relation to obligations to monitor operational and credit risks at the Banking Group level as well as
  • to ascertain responsibility in the event of possible computer crimes to the detriment of the site and to investigate in the event of any litigation. The provision of the data described above is necessary to browse the Web site, and any refusal to provide such data makes it impossible to carry out this activity. The data provided shall be processed for the time necessary to carry out the operations described herein. This site makes use of technical and analytical cookies to enable proper use of the site and improve your browsing experience. To learn more, learn about the cookies used and disable them if necessary, please access the Cookie Policy.

2.3) Marketing and promotion
In addition, based on your consent, on the pages dedicated to the collection of your personal data, personal data will be processed to:

a)

receive promotional materials regarding the various types of products of CA Auto Bank S.p.A Such processing includes traditional and non-conventional marketing activities, commercial information, sending of advertising material or the performance of market research, direct sales activities or interactive commercial communications on products, services and other activities of the Data Controller, and refers to any product already active at the time of subscription or activated in the future. The provision of data is optional and failure to consent to such processing will affect the performance of the activities described above. You have the right to revoke at any time the consent previously given with reference to the purposes referred to in this paragraph through the methods indicated in section 6).
The data provided will be processed for 24 (twenty-four) months after their provision and will subsequently be anonymized or deleted.

b)

receive only promotional materials that are most pertinent to your preferences and habits.
Such processing includes the analysis of personal data collected in order to consider and predict certain personal aspects including financial situation, preferences, interests, conduct, location, or movements in order to limit promotional activities to only those products or promotions that are pertinent based on the analysis previously performed.
The provision of data is optional and failure to consent to such processing affects the performance of the activities described above.
You have the right to revoke at any time the consent previously given with reference to the purposes referred to in this paragraph through the methods indicated in section 6).
The data provided will be processed for 12 (twelve) months after their provision and will subsequently be anonymized or deleted.

c)

receive promotional materials related to products and services offered by other companies.
Such processing includes the communication of personal data to CA Auto Bank’s partner companies – including, but not limited to, vehicle manufacturing and sales companies, third parties and/or other companies of the CA Auto Bank Group and the Crédit Agricole Group – for the purposes of traditional and non-conventional marketing, commercial information, sending advertising material or performing market research, direct sales activities or interactive commercial communications on products, services and other activities regarding products of third parties.
You have the right to revoke at any time the consent previously given with reference to the purposes referred to in this paragraph through the methods indicated in section 6).
The data provided will be processed for 24 (twenty-four) months after their provision and will subsequently be anonymized or deleted.

3. RECIPIENTS OF PERSONAL DATA

For the different purposes described heretofore, the Data Controller may communicate your data, always in compliance with the rights and guarantees provided for by the regulations in force, to:

  • companies of the CA Auto Bank and Crédit Agricole groups, or in any case their subsidiaries or associated companies
  • parties that provide financial and insurance services;
  • partner companies of CA Auto Bank including, but not limited to, vehicle manufacturing and sales companies;
  • your auto dealer, in its capacity as participating dealer of CA Auto Bank S.p.A.;
  • parties that perform data acquisition, processing and processing services necessary for the execution of instructions received from customers;
  • parties that provide services for the management of the Bank’s information system and telecommunications networks (including electronic mail);
  • parties that carry out activities of transmission, enveloping, transport and sorting of communications with the data subject;
  • parties that perform documentation storage and data entry activities;
  • parties that perform customer service activities (e.g.: call centers, customer service, etc.);
  • promotion and sale of products/services of the Bank and other companies of the group of which CA Auto Bank S.p.A. is part;
  • parties carrying out control activities (such as, without limitation, control and/or anti-terrorism activities) also on behalf of CA Auto Bank, review and certification of the activities carried out by the Bank also in the interest of customers.
    Where required, the parties indicated shall be appropriately appointed Data Processors in the manner provided for by the applicable legislation.

4. MANNER OF PROCESSING

Data are processed by automated and/or manual means for the time strictly necessary to achieve the purposes for which the data are collected, in accordance with applicable regulations. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. The provision of personal data by minors under 16 years of age is expressly prohibited..

5. DATA PROTECTION OFFICER

For any direct contact-formal and urgent, other than the exercise of your rights under section 6)-you may contact the Data Protection Officer as follows:

  • Email: dpo-italia@ca-autobank.com;
  • Phone: +39 011.4488.203 – an operator from our Customer Care will answer and redirect your call to the Data Protection Officer;
  • Traditional mail: CA Auto Bank S.p.a., C.so Orbassano 367 10137 Turin, Italy, indicating “For the attention of the Data Protection Officer”.

6. EXERCISABLE RIGHTS

In relation to the processing of personal data listed above you may request:

  • confirmation as to whether personal data concerning you are being processed and, if so, to obtain access to the personal data as well as the origin of such data, the purposes, methods of processing and logics applied in the case of processing carried out with the aid of electronic equipment;
  • the updating, integration, rectification, erasure or transformation into anonymous form of the personal data concerning you;
  • to restrict or object to the processing of personal data concerning you;
  • to receive in a structured, commonly used and machine-readable format, personal data concerning you or the transmission of the same to another data controller (i.e. right to portability);
  • – attestation that the requested operations have been brought to the knowledge of those to whom the data have been communicated or disseminated.

You may exercise your rights by contacting the Customer Care of CA Auto Bank S.p.A. as follows:

The Data Controller shall provide feedback to your requests within 30 (thirty) days of their receipt unless extended by 60 (sixty) days on account of their complexity and number; after the aforementioned time limits you have the right to lodge a complaint with the Italian Data Protection Authority in the forms and manner provided for by the legislation in force.
CA Auto Bank may make changes to this policy and it is your responsibility to check it on a regular basis.

7. TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

Your data will not be transferred by us to a non-EU country or international organization, except in exceptional and strictly necessary cases. If necessary, for technical or operational reasons, the same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, for which there is a specific adequacy decision by the European Commission. Any transfers of your personal data to non-EU countries, in the absence of an adequacy decision by the European Commission, will only be possible if adequate contractual or covenant-related safeguards, including standard data protection contractual clauses, or “SCC” for short, are provided by the Data Controllers and Data Processors involved.

CA Auto Bank may make changes to this policy and it is your responsibility to check it on a regular basis.