Privacy
Policy
This Policy is
intended to describe the management of this website (the "Website")
by FCA Group Purchasing S.r.l., in relation to the
processing of the Website's users/visitors personal data.
FCA Group
Purchasing S.r.l., in line with the current Italian
data protection law, undertakes to guarantee the privacy and the security of
each Website navigator's personal data, even when the Internet is accessed from
abroad, consistently with the requirements of the Fiat Chrysler Automobiles
N.V. Group Code of Conduct.
The Policy is
also provided as a general personal data protection information notice,
accessible to those who interact with the Website's services, pursuant to
Section 13 of Legislative Decree 196/03, issued in application of Art. 10 and
11 from European Directive 95/46/CE, except for more detailed personal data
protection information notices available in the Website's pages.
More
specifically, such detailed information notices , as
per Section 13 of Legislative Decree 196/03 - Personal Data Protection Code -
are provided, where necessary, in the Websites' pages where services are
offered. These information notices aim to define the data processing limits and
procedures for the provision of each service so that the customer/visitor may
freely provide consent and authorize collection of his/her personal data and
its subsequent use on the basis of their content.
Please note that
this information notice is not related to personal data processing by third
parties through other websites possibly accessed by the user using the
Website's links.
2. DATA
CONTROLLER, DATA PROCESSORS AND DATA PROCESSING OFFICERS OF THE DATA PROCESSING
The Data Controller is the head of the Human
Resources department of FCA Group Purchasing S.r.l.,
with registered office in Turin, Corso Agnelli 200, Italy. The Data
Processor for this Service is the Chief Financial Officer of FCA Group
Purchasing S.r.l.
The personal data that you have provided may be
handled by Data Processing Officers, internal and external, responsible for
managing the requested service and by Data Processor(s).
3. TYPE OF DATA PROCESSED AND PURPOSE OF PROCESSING
The Website
offers informative and interactive content. During website navigation,
information regarding the customer, or more generally regarding the visitor to
the site, may be acquired as follows:
Navigation
Data
During normal
operation, the IT systems and software procedures used to run the Website
collect some personal data, which are implicitly transmitted through the use of
Internet communication protocols.
The above
information are not collected in order to be associated with identified
users/visitors, but could, due to their own nature, and if processed and
integrated with third-party data, allow users/visitors to be identified.
The IP
addresses, the browser type, the operating system, the domain name and the
website referring or exit pages, the information on pages visited by the
users/visitors within the site, the access time, the navigation length on each
page, the clickstream analysis and the other parameters regarding the operating
system and the user IT environment, all fall under this category of data.
The above
technical data are collected and used in an aggregated and anonymous way for
the sole purpose of:
1.
improving the quality of the service and optimize the
functionality of the Website;
2.
understanding user behavior in order to improve online
communication;
3. providing statistical information concerning the use of the
Website.
The
following personal data of use are collected and stored on our servers online :
- The page from which the file was requested
- The file name
- The date and time of the request
- The volume of data transferred
- The status of the request (file transferred, file not found)
- Description of the type of Internet browser used
This
information may be used, as stated in the Terms & of Use, to carry out
checks and identify anomalous thresholds in the use of data.
Geographical
location data.
Upon previous consent of the user, the
Website may process geographical location data - in a discontinuous way - to
provide the services that user has requested.
Data voluntarily supplied by
the users/visitors
The
following rules are applicable when the users/visitors enter their personal
data on the Website after having read the detailed information notice provided
in order to access personally selected services.
"Opt-in" and "Opt-out" policies: the appropriate
detailed information notice is provided on pages of the Website that offer
specific services on request and, where required, the consent to the processing
of personal data is granted by the users/visitors before the activation of any
specific service. Such consent may be revoked at any time.
Data from minors
FCA
Group Purchasing S.r.l. does not allow minors under 18 years of age to transmit personal data.
The data processing will
be performed through automated means (i.e. using electronic procedures) and/or
manually (i.e. on paper) for the time necessary to achieve the purposes for
which the data were collected and in compliance with the applicable data
protection law.
4. TECHNOLOGIES
The use of
cookies by the Website is governed by the Cookie Policy.
This is a
technique used as an alternative to direct analysis of Web server log files. It
consists of collecting and processing navigation data using dedicated
JavaScript code in the HTML pages deemed of interest.
It consists in security measures built into digital
files, consisting of the ability to make secure, identifiable and traceable
protected intellectual work.
Using the DRM, the files are encoded and encrypted
to ensure a more controlled diffusion, make it harder duplication and allow a
use which is:
- limited, for example only for
-
certain time periods
- certain features (block of Print, Copy / Paste, etc.)
- authorized only for specific users (such as single
user, or specific Company)
Files protected with DRM are visible only with
specific SW as available and freely usable.
The aim is not to trace the user, but to prevent the
use and uncontrolled spread of confidential data while tracking.
5. WHO CAN BE AWARE OF YOUR DATA The personal data of the customer / visitor may be handled by other entities operating on behalf of FCA Group Purchasing Srl, under special contractual, in EU Member States or in countries outside the EU, and within the limits laid down by Articles. 43 and 44 letter b) of the Decree. n. 196/2003.The personal data of the customer / visitor may be disclosed to third parties to fulfill legal obligations, or to comply with orders from public authorities or to exercise a right in court.
6. CONNECTION TO THIRD PARTY SITES
It is possible to link to other websites from the
Website; the ability to do so is clearly indicated in order to inform the
user/visitor that he/she is leaving the Website.
The user/visitor should note that the above
mentioned websites are neither the property nor managed by FCA Group Purchasing
S.r.l. under its responsibility, as they are owned/managed by other companies and/or organizations. It is
therefore necessary to verify and accept their data protection policies.
FCA Group Purchasing S.r.l.
consequently declines all responsibility for (i)
requests related to and/or (ii) releases of personal data processed by
third-party sites.
7. DATA SUBJECT'S RIGHTS
In accordance with the
above, the Data Subject has also the right to request the complete and updated
list of all the data processors, to request cancellation, anonymization
or blocking of data that have been processed unlawfully and may make
opposition, for legitimate reasons, to their processing.
Data Subjects can write to
FCA Group Purchasing S.r.l. - Finance - C.so Agnelli 200 - 10135 Torino to exercise these rights and in
case of any problem or further requests for clarification related to this
notice.
8. POLICY CHANGES
This Privacy
Policy governs the methods for processing personal data provided by
users/visitors when navigating the Website. These methods may need to be
modified as a result of new laws entering into force or after examination and
updating of user/visitor's services. As a result, our policy may be modified
over time, and we kindly ask customers/visitors to periodically consult this
page.