Privacy Policy

Privacy Policy

This policy describes the ways in which our company, Qooder SA, processes your personal data in relation to browsing on this website (the "Website"), to inform you about which personal data are collected, how they are used, which third parties may have access to such data and how you can exercise your rights regarding this processing.

The processing takes place in full compliance with the Swiss Federal Data Protection Act ("LPD") and with EU Regulation 2016/679 - "Regulation on the protection of individuals with regard to the processing of personal data and the free circulation of such data "(the "Regulation").

We recommend that you read this privacy policy carefully. By accessing the Website itself, you declare to accept it; in the event that you do not consent to this policy, we invite you not to access other pages of the Website.

Data Controller, representative of the Data Controller and data processors

The data controller is Qooder SA, with registered office in Vacallo (Switzerland), Via dei Lauri 4, in the person of the legal representatives pro tempore, e-mail: privacy@qooder.com (the "Controller").

Pursuant to art. 27 of the Regulation, we have appointed, as the representative established in the EU territory for the purposes of applying the regulations on the processing of personal data, Qooder Italia S.r.l., with registered office in Como, Via Volta 66, Tax Code, VAT number and listing number in the Como Companies Register no. 03434900134. The representative can be contacted at privacy@qooder.com.

Some external subjects (natural and legal persons) have also been appointed as data processors, who provide specific services or related, instrumental or support activities additional to those we provide, the complete list of which can be consulted by sending a specific request to privacy@qooder.com.

Source of personal data

Personal data is collected directly from you.

Categories of data processed

When you browse the Website, some of your personal data are processed:

1. Browsing data

When you browse the Website, the Data Controller receives and collects the identification of the navigation tool, the IP address, the operating system used and the name of the ISP (Internet Service Provider) of the device itself and the pages visited. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Website and to check its correct operation.

The data could be used to ascertain responsibility in the event of computer crimes: except for this possibility, the data are currently not stored for more than 7 days.

2. Cookies

The Website uses some types of cookies. For further details you can consult the cookie policy.

3. Data provided by the data subject

In case of the sending of communications through the appropriate form, or registration on the Website, which allows access to specific areas of the same, you will need to provide some personal data (e.g.: first name and surname, e-mail).

Furthermore, any sending of communications through the Website involves the acquisition of the e-mail address and any additional personal data that you indicate, which we may use for our communications with you.

Purpose and legal basis of the processing

The data is processed for the following purposes:

a) Website operation. Legal basis: our legitimate interest;

b) possible access to specific functions of the Website. Legal basis: your consent;

c) management and execution of the contractual relationship and/or the adoption of pre-contractual measures if required (for example: the acquisition of preliminary information for the conclusion of a contract; the execution of operations on the basis of the obligations deriving from the contract concluded with the customer or supplier; etc.). Legal basis: execution of a contract of which you are a party or of pre-contractual measures taken at your request;

d) fulfilment of the obligations established by laws or regulations, including accounting, tax and administrative ones, as well as by provisions issued by authorities legitimated by the law and possibly by supervisory and control bodies. Legal basis: fulfilment of a legal obligation;

e) subject to your consent, for commercial, promotional and other marketing purposes, including the promotion and sale of our products and services, carried out through letters, telephone, advertising material, automated communication systems, etc.; the sending of informative material, as well as ascertaining of the degree of customer satisfaction with the quality of the services provided and the activity carried out and the performing of market surveys (through personal or telephone interviews, questionnaires, etc..). Legal basis: your consent;

f) subject to your consent, profiling activities, aimed at improving the services offered according to the needs of customers and in order to obtain information on commercial behaviour and habits in the automotive and financial sector. The profiling activity, concerning individuals or groups, could be carried out through the processing of customer identification data through a relationship between the data that are used to identify the data subjects and the analytical indications relating to their personal sphere (behaviours, habits and propensities to consumption);

g) upon your specific request, to provide the "Newsletter" service, through a mailing list. Legal basis: your consent.

Personal data are processed lawfully, correctly and transparently, according to the methods and for the purposes indicated above.

Data retention period

The retention period of personal data:

- for the purposes referred to in section a) of the previous paragraph, it is equal to the duration of the browsing session on the Website and in any case for no more than 7 days (except to ascertain responsibility in the event of computer crimes).After this deadline, personal data will be destroyed, deleted or made anonymous (if not already collected anonymously);

- for the purposes referred to in section b), it is equal to the period necessary to execute the specific functionality of the Website requested;

- for the purposes referred to in section c), it is equal to the period of completion of the contract and, subsequently, for the time in which we are subject to retention obligations for fiscal or administrative purposes or as otherwise required by law. Therefore, after the definition of the contractual relationship, the data will be stored in accordance with the ordinary limitation period, equal to 10 years (unless, in this case, a shorter limitation period is applied);

- for the purposes referred to in section d), it is equal to that established by law. The data will therefore be kept for the period of execution of the contract and, after the termination of the contractual relationship, in accordance with the provisions of the law (10 years);

- for the purposes referred to in section e), it is equal to no more than 24 months for those persons concerned who are already our customers and no more than 12 months for potential customers

- for the purposes referred to in section f) it is equal to and not more than 12 months;

- for the purposes referred to in section g), it is equal to the entire duration of the "Newsletter" service, until the time you unsubscribe from the service itself.

In the case of judicial litigation, personal data will be kept for the entire duration of the same, until the expiry of the terms to promote any appeals.

Nature of the provision of data and consequences of refusal to provide it

The provision of data can be mandatory or optional.

In relation to the purpose referred to in section a) of the paragraph "Purpose and legal basis of the processing", the provision of data is mandatory. The related processing does not require your consent, as it is based on our legitimate interest.

In relation to the purpose referred to in section b), the provision of data is not mandatory, but it is necessary to have access to the specific functionality of the Website requested from time to time. Failure to provide the data would make it impossible to have access to this specific functionality. Its processing requires your consent.

In relation to the purpose referred to in section c), the provision of data is not mandatory, but it is strictly necessary for the purpose of carrying out pre-contractual and/or contractual activities. Any refusal to provide such data would make it impossible for us to carry out the same contractual relationships and legal obligations. Its processing does not require your consent.

In relation to the purpose referred to in section d), the provision of data is mandatory. Failure to provide the data would make it impossible to proceed with any contractual relationships. Its processing does not require your consent.

Otherwise, the provision of data for the purposes referred to in sections e) and f) is optional and failure to release them does not entail any consequences regarding access to the Website, but will not allow us to carry out further statistical, commercial or profiling activities. This processing requires your prior consent; in any case, you can interrupt the processing at any time by requesting deletion of the data, by writing to privacy@qooder.com.

With reference to the purpose referred to in section g), the provision of personal data is always optional; however, failure to provide the data will prevent provision of the "Newsletter" service. The processing of data by us for this purpose requires your prior consent. In any case, you can interrupt the processing at any time by requesting deletion of the data, using the appropriate "unsubscribe" function contained in each newsletter.

Special categories of data

In relation to specific obligations, the data subject could provide particular categories of data, such as personal data suitable for detecting the state of health, as well as biometric data intended to uniquely identify a natural person. For the processing of such data, the explicit consent of the data subject is required, expressed in writing. In any case, the data will always be used within the limits of the execution of specific services requested and, in the absence of consent, we will not be able to provide the requested service.

Personal data processing method

The processing will consist of any operation or set of operations, carried out with or without the aid of automated processes and applied to personal data or sets of personal data, such as the collection, recording, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, or any other form of making available, comparison or interconnection, limitation, deletion or destruction.

In relation to the purposes indicated, the processing of personal data takes place using manual, IT and electronic tools with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of the data.

We guarantee that the security and confidentiality of personal data will be protected by adequate security measures, in accordance with the provisions of the LPD and the Regulations, in order to reduce the risk of destruction or loss, even accidental, of data, of unauthorised access or processing that is not permitted or does not comply with the purposes of the collection. In any case, we assume no responsibility for the data transmitted via Internet. Similarly, any and all our liability in the event of opening links or other web pages connected to the Website is excluded.

The data processing will be carried out in compliance with the principle of strict necessity. Therefore, the processing will be reduced to a minimum and in such a way as to exclude it when the purposes pursued in individual cases can be achieved through the use of anonymous data.

Scope of communication and dissemination of personal data

The data are processed by the designated personnel who need to have knowledge of them in the execution of their activities, duly appointed as the subject authorised for processing by the Data Controller or by external managers. The data may also be communicated or transferred to the Controller's subsidiaries, parent companies or associates, including abroad, as well as to our sales and service network.

Furthermore, in carrying out our business, for the execution of contractual or legal obligations or to fulfil your specific requests, we may communicate your personal data to subjects whose intervention is strictly functional to the execution of the contractual relationship.

To carry out the activities indicated above, we can therefore communicate personal data to the following subjects or categories of subjects:

- banking institutions (in the cases envisaged) for the management of collections and payments;

- subjects who carry out activities connected and instrumental to the execution of the contractual relationship (for example: service providers and technical assistance; delivery of products; transmission, enveloping, transportation and sorting of communications to customers or suppliers; archiving services of documentation relating to relationships with customers or suppliers);

- public administrations and third parties in fulfilment of legal obligations.

Your consent is not required for this type of communication, as the processing is aimed at fulfilling the contractual relationship or at complying with legal or regulatory obligations.

The subjects listed operate, in some cases, as external data processors, appointed for this purpose and, in other cases, as independent data controllers, issuing, in this case, a specific policy. Should you wish to know, in detail, the subjects to whom the data may be communicated, you can write to privacy@qooder.com.

In no case will personal data be disclosed by us.

Transfer of data abroad

Personal data may be transferred outside Switzerland or to countries outside the European Union, provided that the European Commission has established that these countries outside the European Union guarantee an adequate level of protection for the data being transferred, or by providing suitable and appropriate protection measures to protect personal data and the transfer of the same in accordance with the applicable laws, such as, for example, the adoption of standard contractual clauses adopted by the European Commission pursuant to art. 45 and 46 of the Regulation.

Social plug-ins of third parties

The Website may use social plug-ins provided and managed by third parties, such as Facebook.

As a result of this, you may send these third parties the information you are viewing on a certain part of the Website. If you are not logged into your account with these third parties, they cannot know your identity. Otherwise, the latter may be able to link the information relating to your visit to the Website to your account. Similarly, your interactions with the social plug-ins could be recorded by the latter.

You can consult the privacy policy of these third parties for further information on the measures adopted by them regarding the processing of personal data.

Rights of the data subject

You can ask us, at any time about the following:

- confirmation as to whether or not personal data concerning you is being processed and, in this case, to obtain access to the following information:(i) the purposes of the processing, (ii) the categories of personal data processed, (iii) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular, if recipients of third countries or international organisations, (iv) whenever possible, the retention period of the personal data provided, or, if not possible, the criteria used to determine the period, (v) the existence of an automated decision-making process, including profiling, the logic used, the importance and consequences expected (right of access);

- the correction of inaccurate personal data or the integration of incomplete data (right of correction);

- the deletion of personal data in the event of (i) revocation of the consent on which the processing is based, in the absence of a different legal basis that allows the processing itself by us; (ii) objection to the processing, in the absence of any other legitimate prevailing reason to proceed with the processing itself; (iii) unlawful processing; (iv) fulfilment of a legal obligation; except in cases where the processing is necessary for exercising of the right to freedom of expression and information, for the fulfilment of a legal obligation, for reasons of public interest in the health sector, for statistical purposes, for archiving in the public interest, scientific or historical research, or for the ascertaining, exercise or defence of a right in court (right to be forgotten);

- the limitation of the processing of personal data (right of limitation).

Furthermore, you have the right to:

- receive in a structured format, commonly used and readable by an automatic device, the personal data provided and transmit such data to another owner without impediments on our part, if the processing is based on consent and is carried out by electronic means (right to portability);

- object to the processing, including the related profiling, possibly based on our legitimate interest, if the data are processed for the purpose of direct marketing (right to object);

- withdraw consent to the processing, at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation;

- submit complaints to the competent supervisory authorities if you believe that the processing violates the privacy law.

To exercise your rights, as well as for any information, you can write to privacy@qooder.com. Furthermore, if you are in the EU territory, and the processing activities concern the offer of goods or the provision of services, you can also contact the representative of the Data Controller. in the EU, at the addresses indicated above.

Changes to this privacy policy

We reserve the right to update this information. Any changes will be communicated to users on the home page of the Website as soon as they are adopted and will be binding upon its publication.

If you do not intend to accept the changes made, you will have to stop using the Website and you can ask us to delete your personal data. Unless otherwise specified, the previous information will continue to apply to personal data collected up to that time.

Update: 31/01/2022

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Data Controller, representative of the Data Controller and data processors

Pursuant to art. 27 of the Regulation EU 2016/679 (the “Regulation”), we have appointed, as the representative established in the EU territory for the purposes of applying the regulations on the processing of personal data, Qooder Italia S.r.l., with registered office in Como, Via Volta 66, Tax Code, VAT number and listing number in the Como Companies Register no. 03434900134.The representative can be contacted at privacy@qooder.com.

Some external subjects (natural and legal persons) have also been appointed as data processors, who provide specific services or related, instrumental or support activities to those we provide, the complete list of which can be consulted by sending a specific request to privacy@qooder.com

What are cookies?

Cookies are small text files saved by the Website or by third parties in the Internet access device(computer, tablet, mobile phone, etc.) of visitors to the Website, to be then retransmitted to the same Website upon the next visit by the same visitor.

This information may relate to the visitor or device, and is mainly used to adapt the operation of a website to the visitor's expectations, offering a more personalised browsing experience and storing the choices made previously.

Glossary

Type of cookies
Technical cookies	They are used for the sole purpose of transmitting a communication over an electronic communications network, or as strictly necessary for the provider of an information company service explicitly requested by the user to provide the service. Their storage in the device does not require the user's prior consent.
Analytics	They are used to collect and analyse statistical information on access to a website to ascertain how visitors use it, in order to be able to evaluate and improve its functioning and to collect information on the quality of the browsing offered. If they do not appear to be direct and univocal identifiers of a particular subject (that is to say, they do not allow direct identification of the data subject), they are equivalent to technical cookies and their use does not require any consent from the user.
Profiling cookies	They are aimed at creating profiles relating to the visitor and are used to send advertising messages in line with the preferences expressed during browsing. They can only be used with the express consent of the data subject.
Duration
Session cookies	They are stored during a browsing session, which expire and are normally deleted at the end of the session itself. The Website uses session cookies to follow the use made of the Website during a single browsing session and to help visitors use the Website more easily.
Persistent cookies	They are stored during a browsing session and are intended to remain on the device even after the session has ended. They allow the device to be recognised when it is used to log in again, essentially to help the visitor quickly reconnect to the Website. They are also used by the Website for analysis purposes.
Origin
Proprietary cookies (first party)	They are saved by the Website to record the movements made by the visitor. They are mainly used to manage the Website and to collect data that allow the services offered to be improved.
Third-party cookies	They are linked to a different subject, who installs them on the user's terminal, through the website manager.

Cookies used by this website

The Website uses the cookies reported in the tables below, for the purposes indicated therein.

Proprietary and third-party cookies are used.

How can cookies be disabled?

It is possible to intervene on the transmission of cookies and to prevent their installation or storage by modifying the browser configuration to block certain types. For detailed information on the necessary procedure, refer to the browser guide used. However, please note that this block risks significantly limiting the ease of use of the Website. Furthermore, some functions of the Website may not work properly if acceptance of the cookies is disabled.

Purpose and legal basis of the processing

The Data Controller will process the personal data obtained from technical cookies only to allow user navigation and the possibility of using the related services on the Website .It is possible to set the browser to block these cookies, but, as a consequence, some parts of the Website may not function properly. Their storage in the device does not require the user's consent.

With reference to analytics cookies, if they do not allow identification of the user, but only the processing of aggregate statistics, they are equivalent to technical cookies and, therefore, their storage in the device does not require the user's consent. If, instead, they allow the identification of the user, consent will be requested.

As for marketing or profiling cookies, they can only be installed with the user's consent, which can be revoked at any time.

Scope of communication and dissemination of personal data

The personal data are processed by the designated personnel who need to have knowledge of them in the execution of their activities, duly appointed as the subject authorised for processing by the Data Controller or by external managers Treatment.

Furthermore, in carrying out its business, for the execution of the obligations established by the applicable laws or regulations or to fulfil your specific requests, we may communicate your personal data to subjects whose intervention is strictly functional to the execution of the requested service. Your consent is not required for this type of communication as the processing is aimed at fulfilling the requested service or at complying with the legal or regulatory obligations.

In no case will personal data be disclosed by us.

Transfer of data abroad

Data retention period

Session cookies expire at the end of a browser session (usually when the browser is closed or the session expires).The retention period of persistent cookies is equal to the duration indicated in the tables below.

Rights of the data subject

You can ask the Data Controller, at any time:

- confirmation as to whether or not personal data concerning you is being processed and, in this case, to obtain access to the following information:(i) the purposes of the processing, (ii) the categories of personal data processed, (iii) the recipients or categories of recipients to whom the personal data have been or will be communicated, in particular, if recipients of third countries or international organisations, (iv) whenever possible, the retention period of the personal data provided, or, if not possible, the criteria used to determine this period, (v) the existence of an automated decision-making process, including profiling, the logic used, the importance and consequences expected (right of access);

- the correction of inaccurate personal data or the integration of incomplete data (right of correction);

- the deletion of personal data (right of deletion);

- the limitation of the processing of personal data (right of limitation).

Furthermore, you have the right to:

- object to the processing, including the related profiling, possibly based on our legitimate interest, if the data are processed for the purpose of direct marketing (right to object);

- withdraw consent to the processing, at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation;

- submit complaints to the competent supervisory authorities if you believe that the processing violates the privacy law.

To exercise your rights, as well as for any information, you can send an email to privacy@qooder.com.Furthermore, if you are in the EU territory, and the processing activities concern the offer of goods or the provision of services, you can also contact the representative of the Data Controller. in the EU, at the addresses indicated above.

Update: 31 January 2022

Privacy policy

Privacy Policy