This privacy notice (“Privacy Policy”) is provided pursuant to Art. 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) in order to inform you about the processing of your personal data (“Personal Data”), as described below.

1. Data Controller

The processing of Personal Data for the purpose of providing assistance and consultancy services that can be requested via the website https://www.focacciagroup.com/ (the “Website”), and/or by telephone, is carried out by Focaccia Group S.r.l., Single-Member Company, Tax Code and VAT No. 02422050399, with registered office at s.s.16, km 172, 48015 – Cervia (RA), (hereinafter “Focaccia” and/or the „Controller“), in relation to the production, conversion and fitting-out of motor vehicles, mopeds, electric vehicles and, in general, any means of transport and relative components.

For any information regarding the processing of Personal Data, as well as to exercise your rights, you can contact the Data Controller at any time at the following email address: [privacy.clienti@focacciagroup.com].

2. Types of Personal Data

The Personal Data processed for the assistance and/or consultancy services provided by the Controller includes: personal and contact details (name, surname, province and region of residence, mobile phone number, email address).

In the case of specific requests for after-sales assistance, administration or vehicle homologation, data relating to the purchased vehicle may also be processed, such as: licence plate number and vehicle identification number.

In addition to this, computer systems and software procedures used for the operation of the Website automatically collect certain information, such as your IP address or other parameters relating to your operating system. By its nature, such information may, through processing and association with other data, allow you to be identified.

3. Purposes and Legal Basis of Processing

The Personal Data is processed:

1. in order to ensure the provision of the assistance and/or consultancy services requested by you via the Website – in accordance with the relative „Terms and Conditions of use“ – and/or by directly contacting Focaccia by telephone and/or using the contact forms provided, as well as to properly and accurately respond to your requests for information and assistance pursuant to Art. 6(1) lett. b) of the GDPR;
2. in order to comply with the legal obligations to which the Controller is subject, for example in accounting and tax matters, pursuant to Art. 6(1), lett. c) of the GDPR;

Subject to your specific, free and informed consent, pursuant to Art. 6(1), lett. a) of the GDPR, the Controller may:

3. contact you via automated (e.g. automated calls and/or calls with an operator, email) and non-automated means (e.g. calls with an operator, postal mail) to keep you up-to-date on the products and services offered by the Controller;
4. disclose Personal Data to third-party partners of Focaccia engaged in commercial cooperation with the Controller, such as automotive manufacturers and dealers outside the Focaccia network.

We may also send you emails to promote goods and/or services similar to those for which you requested consultancy and/or assistance services from Focaccia, without your consent, although you will have the right to object to such communications at any time.

4. Nature of Data Provision and Consequences of Refusal

The provision of your Personal Data is optional. However, some Personal Data is necessary to allow us to provide the assistance and/or consultancy services requested via the Website and/or by contacting Focaccia Group by telephone and/or using the contact forms provided, as well as to respond to your requests for information and assistance pursuant to Art. 6(1) lett. b) of the GDPR and to comply with the legal obligations to which we are subject. Failure to provide this information will prevent you from using the services offered by Focaccia.

Where necessary for the processing activities described in this Privacy Policy, consent is voluntary. Failure to provide one or more consents will not prevent you from using the services and products offered by Focaccia Group.

5. Processing Methods

Personal Data is processed using IT, manual and/or telematic tools and devices, in accordance with the principles of fairness, lawfulness and transparency.

The Controller guarantees the adoption of appropriate technical and organisational measures to ensure adequate security levels pursuant to Art. 25 and 32 of the GDPR, in relation to the specific processing purposes defined by current data protection regulations. Processing is carried out by internal personnel employed by Focaccia, duly authorised and trained in accordance with Art. 29 of the GDPR and Art. 2-quaterdecies of Italian Leg. Decree 196/03. Processing can also be carried out by third parties, appropriately appointed as external data processors pursuant to Art. 28 of the GDPR.

In any case, the logical and physical security and confidentiality of the processed data are guaranteed.

6. Data Retention

The Personal Data will be kept only for the time strictly necessary for the purposes for which it is collected, in accordance with the data minimisation principle pursuant to Art. 5(1), lett. c) of the GDPR, as well as the legal obligations to which the Controller is subject. Should you decide to withdraw your consent, the Personal Data processed exclusively on the basis of such consent will be promptly deleted or anonymised.

7. Data Transfer

Your Personal Data will be processed within the European Union. If, for technical and/or organisational reasons, Personal Data is transferred to third countries outside the European Union or international organisations, the Controller guarantees compliance with Art. 44 and seq. of the GDPR. In particular, such transfers will be made to countries ensuring an adequate level of protection as determined by the European Commission, or otherwise subject to appropriate safeguards such as Standard Contractual Clauses approved by the European Commission or the use of entities participating in international data transfer frameworks.

Personal Data is/will not be disclosed to unspecified recipients in any form, except where required by law or requested by law enforcement authorities, judicial authorities, intelligence and security bodies, or other public authorities for defence, national security or crime prevention purposes.

For further information, you can contact the Controller, in writing, using the contact details provided above.

8. Data Subject Rights

You may exercise at any time the rights set out in Art. 15 to 22 of the GDPR and in particular obtain:

• confirmation as to whether or not your personal data is being processed and access to such data and to the following information: purposes of processing, categories of personal data, recipients and/or categories of recipients, retention period;
• rectification of inaccurate personal data concerning you and/or completion of any incomplete data, also providing a supplementary statement;
• erasure of personal data where applicable in accordance with the GDPR;
• restriction of processing where provided for by current privacy regulations;
• data portability, in particular the right to have your data sent directly to another data controller.

You also have the right to withdraw your consent at any time without compromising the lawfulness of processing based on consent before its withdrawal, as well as the right to object at any time to the processing of Personal Data pursuant to Art. 21 of the GDPR.

If you believe that the processing of Personal Data infringes the GDPR, you have the right to lodge a complaint with the Italian Data Protection Authority pursuant to Art. 77 of the GDPR, or to seek judicial remedy.

Requests to exercise your rights can be submitted using the contact details provided in paragraph 1 of this Privacy Policy.