Privacy and Cookie Policy
Privacy Notice to Customers and Suppliers on the Protection of Personal Data
Pursuant to Articles 13 and 14 of Regulation (EU) 2016/679
Rev. 2 del31.01.2019
Dear Customer and Supplier,
In compliance with the provisions of Articles 13 and 14 of the European Regulation (EU) 2016/679 (General Regulation on the protection of individuals with regard to the processing of personal data, hereinafter “Regulation” or “GDPR”), we inform you that your personal data provided by you or in any case acquired during registration, within the scope of our activity, will be processed in compliance with the Regulation and the principles of fairness, according to the conditions of lawfulness provided for in Article 6 of the Regulation, transparency and protection of confidentiality provided for therein.
This information concerns the personal data sent by the visitor user when filling in the contact forms on our website, made available in order to allow visitors to contact the manager of the site itself by sending an email communication with their contact details and any preliminary notations or questions, and the data that our system may automatically record while visiting the site:
- When you fill in a contact form, the computer system may record the medium and site through which you have accessed our site, while the data that you voluntarily provide us with through the contact forms will be converted into an email that may be stored in the email system. Your data may also be recorded in a database on the server attached to the website;
- However, when you visit our site, even if you do not fill in a contact form, we may automatically collect certain information from you, such as the medium and site through which you accessed our site, your IP address, the date and time you accessed our service, the hardware, software or browser you use and information about your computer’s operating system, your clicks, the pages you visited on our site and your operations
1. Personal data controller
The Data Controller (hereinafter “Controller”), pursuant to Article 4 of the Regulation, is LORAN ITALIA S.r.l., with registered office in: Viale Giuseppe De Gennaro, 1 – 70123 (Ba) – Italy (hereinafter referred to as “LORAN”), in the person of
its legal representative who, within the scope of his prerogatives, may avail himself of the collaboration of expressly appointed data processors and/or authorised persons.
2. Purpose of personal data processing
The data provided to the Data Controller, which do not fall within the special categories of personal data as listed in Article 9 of the Regulations, will be processed by LORAN for the following purposes:
2.a Administrative and accounting purposes
All your data are processed exclusively for purposes related to the economic activity of LORAN and in particular for administrative-accounting purposes: pre-contractual requirements, (offers, order processing, etc.), fulfilment of legal, community and contractual obligations; risk control (in particular fraud, insolvency, reliability, etc.), dispute management, management of electronic payment instruments, as well as processing requests forwarded by the user to provide the good and/or service requested. For this purpose, the data you provide us with when making a reservation may be (first and last name, address, contact details, photocopy of driving licence, payment method, tax data for invoicing) and the data relating to your rent and the related services you requested
With reference to these processing purposes, any refusal by the data subject to provide the requested data will result in the impossibility of establishing contractual relations.
2.b Measuring satisfaction
To measure your experience in using our platforms, the products and services we offer and to ensure the correct functioning of the web pages and their content.
2.c Operational and strategic marketing
Update you by sending you promotional material, including personalised material, through periodic newsletters (technical communications, commercial and promotional communications relating to the activities carried out by LORAN, events, training updates, etc.), through market surveys, retargeting, telemarketing, web marketing, etc. carried out by the Data Controller in its own interest and in the interest of the associated companies of SOA CORPORATE S.r.l. Group and/or in the interest of third companies, but also directly through companies appointed by the Data Controller as data processors, about services, offers and initiatives of LORAN or to make you participate in market surveys (in order to better know your preferences and be able to improve our offer);
2.d Profiling
Carry out profiling activities, i.e. the analysis and processing of information relating to users, their preferences, habits, consumption choices and/or browsing experiences. This activity is also carried out through the use of technologies such as cookies (for more information see the “Cookie Policy”). Please note that all our data and preference analysis activities will not be carried out using exclusively automated methods, but will always involve the intervention and assessment of our staff.
2.e Sharing Partners’ commercial promotions
Communicate your data to our commercial partners and to SOA CORPORATE S.r.l. Group who will contact you to let you know about their offers, promotions, updates on products and services.
2.f General contact purposes
To provide you with a better browsing experience in line with the preferences you have already expressed when browsing online, i.e. the possibility of contacting you via the contact details you have sent us in order to deal with any requests you may have made in the message sent to us via the contact forms, or to arrange an appointment with you at
your nearest facility or inform you of any appointment reminders, messages and promotional and market research initiatives promoted by the facilities participating in our project.
3. Modalities and legal bases of the processing
Information may be provided by you when you register with us, on paper and/or electronic forms, at events, trade shows and exhibitions in which LORAN participates or which are organized by LORAN, by members of LORAN’s sales and service network or LORAN’s business partners, or in the course of your interaction with LORAN’s websites, Internet and mobile applications.
The legal basis for the processing of which:
purpose a) will be the fulfilment of the contractual relationship established with you (art. 6, co. 1, lett. b) and c) of the Regulation), in fact, the processing carried out for these purposes is necessary for the fulfilment of contractual obligations and does not require specific consent from the data subject.
purposes (b) The processing operations carried out for these purposes are based on a legitimate interest of the Controller.
purpose c) Processing for these purposes is carried out with the specific consent provided by the user, except for commercial communications relating to services similar to those already purchased and/or subscribed to by the user, for which processing is based on a legitimate interest of the Controller.
purpose d) Processing for these purposes is carried out with the specific consent provided by the user, except for an activity of analysis of elementary information relating to his or her consumption preferences.
purposes (e) Processing for these purposes is carried out with the specific consent provided by the user,
purpose f ) will be the fulfilment of the contractual relationship established with you (art. 6, co. 1, lett. b) and c) of the Regulation), in fact, the processing carried out for these purposes are necessary for the fulfilment of contractual obligations and do not require specific consent from the data subject.
Your consent will always be freely revocable by writing to privacy@soacorporate.com and will be taken over by the privacy office on the staff of the Data Protection Officer.
Please note that if you revoke your consent, you will no longer be the recipient of any type of communication, by any means. On the other hand, if you wish, you may revoke your consent only for the receipt of communications by electronic means (e.g. e-mail, sms, instant messaging), continuing to receive technical and/or commercial communications only by paper mail or telephone contact with an operator, if any.
This site collects and processes data on the basis of your consent. By using or consulting this site, visitors and users explicitly approve this statement and consent to the processing of their data in relation to the methods and purposes f) of paragraph 2 “Purposes of the Processing of Personal Data” of this statement, described below, including possible disclosure to third parties if necessary for the provision of a service.
Failure to provide and/or consent, where necessary, to the processing of your data for the purposes described in paragraph 2), will make it impossible for us to contact you and process your request, send you communications relating to our promotional activities or provide certain services, and your browsing experience on the site may be compromised.
4. Nature of the provision of data and method of processing
The provision of data by the interested party is compulsory for the purpose 2.a) while for the purposes 2.c), 2.d), 2.e), consent is optional and explicit.
The processing of the data (e.g. name, surname, contacts, address, etc.) required to manage the booking and the relative rent and to fulfil the relative obligations (e.g. regarding tax, accounting, insurance) will be carried out with the aid of computerised, telematic and/or paper-based instruments, according to logic strictly related to the above-mentioned purposes and in any case adopting procedures and measures suitable to protect the security and safety of the data.
confidentiality and by the staff and employees of LORAN or the companies expressly appointed as data processors.
Where you provide personal data of third parties (e.g. additional drivers), you must ensure that such third parties are informed and have consented (where necessary) to the use of the data as described in this policy.
LORAN may process your common personal data, without your express consent, for the following service purposes:
- managing and maintaining the site
- enable the user to use the functionalities provided;
- manage user requests and reports;
- sending newsletters, technical information related to road safety;
- collection of spontaneous applications;
- process a contact request;
- to fulfil the obligations provided for by laws, regulations, Community legislation or an order from the Authority;
- prevent or detect fraudulent activity or abuse detrimental to the Site;
- exercise the rights of the Controller, such as the right to exercise a right in court, as well as for the fields and purposes of the activities rendered to the
In the above cases, the legal basis for the processing of personal data is the performance of a contract with you or the provision of products specifically requested or the fulfilment of a legal obligation or the protection of our legitimate interests.
Navigation data:
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected and saved in order to be associated with identified interested parties, but 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, the URI addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server and other parameters relating to the user’s operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check that it is functioning correctly.
Data provided voluntarily by the user:
The optional, explicit and voluntary sending of electronic mail to the addresses indicated on this site or the completion and sending of contact forms entails the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the message. The processing is carried out directly by the data controller, also through its internal staff.
Cookies are short pieces of text that allow the web server to store information to be reused during the same visit to the site (session cookies) or later, even after a few days (persistent cookies). Cookies are stored, according to the user’s preferences, by the individual browser on the specific device being used (computer, tablet, smartphone). Similar technologies such as, for example, transparent GIFs and all forms of local storage introduced with HTML5 can be used to collect information about user behaviour and the use of services. While browsing, the site will install these types of cookies: session, analytical and third-party profiling cookies, and in the remainder of this document we will refer to cookies and all similar technologies by simply using the term “cookies”.
Depending on the characteristics and use of cookies, we can distinguish different categories:
- Technical cookies: are those used only to “carry out the transmission of a communication over an electronic communications network, or to the extent strictly necessary for the provider of an information society service explicitly requested by the subscriber or user to provide such service”. They are not used for any other purpose and are normally installed directly by the owner or operator of the site.
They can be subdivided into navigation or session cookies, which guarantee normal navigation and use of the website; functionality cookies, which allow the user to navigate according to a series of selected criteria in order to improve the service rendered to the same. Users’ prior consent is not required for their installation, while the obligation to provide information pursuant to art. 13 of the Regulations remains in place, which the site manager, if he uses only such devices, may provide in the manner he deems most appropriate.
- Profiling cookies: these are those designed to create user profiles and are used to send advertising messages in line with the preferences expressed by the user while surfing the web. Because of the particular invasiveness that such devices may have in the private sphere of users, European and Italian legislation provides that the user must be adequately informed about the use of such devices and thus express his valid consent. Article 122 of Legislative Decree 196/03 provides that “the storage of information in the terminal equipment of a contracting party or user or access to information already stored is permitted only if the contracting party or user has given his or her consent after having been informed in the simplified manner referred to in Article 13(3)” (Article 122(1) of Legislative Decree 196/03). This site uses cookies from
- Third-party cookies: When you visit the website you may receive cookies from sites operated by other organisations (third parties), such as scripts or social plug-ins from Facebook, Twitter, Google, LinkedIn. These are parts of the page you visit, generated directly by these sites and integrated into the page of the host site. The most common use of social plugins is to share content on social networks. The presence of these involves the transmission of cookies to and from all sites managed by third parties. The management of the information collected by “third parties” is governed by the relevant disclosures, which you should refer to. For the sake of transparency and convenience, here are the web addresses of the different policies and cookie management methods.
- Facebook: https://www.facebook.com/help/cookies/
- Twitter: https://support.twitter.com/articles/20170514
- LinkedIn: https://www.linkedin.com/legal/cookie-policy
- Google: http://www.google.it/intl/it/policies/technologies/cookies/
- https://www.google.it/policies/privacy/partners/
This site also includes certain components of third-party analytical cookies sent by:
- Google Analytics: a web traffic analysis service provided by Google. Again, these are third-party cookies collected and managed anonymously to monitor and improve the performance of the host site (performance cookies). Google Analytics uses cookies to anonymously collect and analyse information about website usage behaviour, including the user’s IP address. This information is collected and processed for the purpose of compiling reports on website activity. Google will not associate the IP address with any other data held by Google, nor will it attempt to link an IP address with the identity of a user. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. This website uses Google’s analysis tool to monitor or collect personally identifiable information. The user can selectively disable the action of Google Analytics by following the directions specified in the following link: https://tools.google.com/dlpage/gaoptout.
Session cookies remain active only until the browser is closed or you log out. Persistent cookies remain active when you close your browser and will be available on subsequent visits. In some cases an expiry date is set, determined by the server at the time of their creation, in others the duration is unlimited until they are removed by the user.
4.2 How to manage and deactivate cookies
Users can decide whether or not to accept cookies by using the settings on their browser. The usability of the public contents is also possible by completely disabling cookies, while the total or partial disabling of technical cookies may compromise the use of the site functions reserved to registered users. Disabling “third party” cookies, on the other hand, does not affect the navigability of the sites in any way. The setting can be defined specifically for different websites and web applications. In addition, browsers generally allow you to customise the settings for different types of cookies, define whether or not to accept them and remove them.
Below are links to the main browsers:
Learn more about how to manage cookies in your browser: http://aboutcookies.org
For more information on cookies and to manage your preferences for third-party profiling cookies, please visit: http://www.youronlinechoices.com
4.3 Other third-party cookies
When you visit a website you may receive cookies both from the site you visit (‘owners’) and from sites operated by other organisations (‘third parties’). An example of this is the presence of ‘social plug-ins’ for Facebook, Twitter, Google+, LinkedIn, etc. These are parts of the visited page generated directly by these sites and integrated into the page of the host site. The most common use of social plugins is to share content on social networks.
The presence of these plugins results in the transmission of cookies to and from all sites operated by third parties. The management of the information collected by “third parties” is governed by the relevant information sheets, which you should refer to. For the sake of transparency and convenience, the web addresses of the various privacy notices and cookie management procedures are listed below.
Cookies are linked to the browser used and CAN BE DISABLED DIRECTLY FROM THE BROWSER, thus refusing/revoking consent to the use of cookies. It should be borne in mind that disabling cookies may prevent the correct use of some functions of the site itself.
Instructions for disabling cookies can be found on the following web pages:
Mozilla Firefox – Microsoft Internet Explorer – Microsoft Edge – Google Chrome – Opera – Apple Safari
5. Storage periods of Personal Data
The personal data provided by you, will be processed for the time strictly necessary to achieve the purposes, described above, to fulfil contractual, legal and regulatory obligations without prejudice to the prescriptive and legal terms of the Authorities, in compliance with the rights and obligations arising therefrom or to defend or enforce a right.
Data will be stored according to the following criteria:
- The Data processed for the purposes set forth in letter a) of paragraph 2 “Purposes of the Processing of Personal Data” of this Policy will be retained for a period of 10 years following the termination of the relationship, unless the need for further retention arises to enable LORAN to defend its rights;
- the Data processed for the purposes referred to in letters b), c) of paragraph 2 “Purposes of the Processing of Personal Data” of this notice shall be kept for a maximum period of 24 (twenty-four) months.
- the Data processed for the purposes referred to in letter d) of paragraph 2 “Purposes of the Processing of Personal Data” of this Policy shall be kept for a maximum period of 12 (twelve) months
- For the purposes set out in letters e) of paragraph 2 “Purposes of the Processing of Personal Data” of this notice, your Personal Data will be processed until you withdraw your consent.
- We inform you that data relating to navigation logs, if recorded, will be kept by the Controller for a period of 3 years.
Finally, the personal data of the site related to the purposes of letter f) may be stored also until the time allowed by the Italian law to protect the legitimate interests of the owner of LORAN (art. 2947, co. 1 and 3 c.c.).
6. Redirecting to external sites
The website may use so-called social plug-ins. Social plug-ins are special tools that make it possible to incorporate social network functions directly into the website (e.g. the Facebook “like” function).
All social plug-ins on the website are marked with the respective logo owned by the social network platform (e.g. Facebook, Google, Twitter, Linkedin).
When you visit a page on our website and interact with the plug-in (e.g. by clicking the “Like” button) or decide to leave a comment, the corresponding information is transmitted from your browser directly to the social networking platform and stored there. For information on the purposes, type and manner of collection, processing, use and storage of personal data by the social network platform, as well as on how to exercise your rights, please consult the privacy policy adopted by the individual social network.
7. Linking to/from third-party sites
From this website it is possible to link to other websites.
The Data Controller declines all responsibility for any request and/or release of personal data to third party sites and for the management of authentication credentials provided by third parties.
8. Security measures
This site processes user data in a lawful and correct manner, adopting appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of data. The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the data controller, in some cases, categories of people involved in the organisation of the site (administrative, commercial, marketing, legal, system administrators) or external parties (such as third party technical service providers, hosting providers, IT companies, communication agencies) may have access to the data.
9. Scope of transfers and dissemination of personal data
In compliance with the purposes set out in point 2 and without prejudice to any communication to third parties carried out in execution of legal obligations, the data may be transferred by us to countries belonging to the European Community, to the subjects listed below:
- associated companies of the SOA CORPORATE S.r.l. Group to which LORAN belongs;
- police forces, armed forces and other public administrations, for the fulfilment of obligations provided for by law, regulations or Community legislation. This sphere of communication also includes communications required by law to the competent authorities – pursuant to the provisions of Article 126
C.d.s. and Ministry of the Interior Circular no. 300/A/1/44248/109/16/1 of 12 August 2003, as follows
as amended following the Constitutional Court’s ruling of 27/2005, in the event that it is necessary to re-notify, or to have third parties re-notify the Customer of, penalties imposed following a breach of the Highway Code during the use by you of a vehicle of which you are the registered owner and for which you are the actual driver;
- in case of communication/transfer abroad of the data, the relevant processing will be carried out in full compliance with the provisions of art. 44 of the Regulation, for the transfer within the EU, of the General Authorizations in force concerning the transfer of personal data to third countries not belonging to the European Union. It may happen that, in relation to specific activities connected to the execution of the contract of rent (e.g: claims management), LORAN may collect and process your special data, as defined in Article 9, of the Regulation, such as data relating to (i) your health condition (e.g., if you request support for a disability, or provide manual commands, or if you have an accident and we need to work with insurance companies or claims management regarding any injuries you have sustained) or (ii) your membership in a trade union (or similar organization) if you use a CDP discount code that can only be used by members of that trade union or organization. In particular, LORAN may process particular data that may reveal your state of health. In these cases, for which your written consent is required, we inform you that LORAN will process your personal data in full compliance with the provisions of the Regulations and the applicable General Authorisations of the Garante on the processing of personal data.
- service centres, repair shops, rent car companies and business partners in general, such as vehicle suppliers and outsourcing service companies,
- our staff, properly instructed and informed;
- banks and credit institutions;
- insurance companies responsible for settling claims;
- specialised companies for: the management of fee billing services; financial risk detection and fraud prevention (in particular databases set up to assess credit risk, managed by private individuals and accessible to many parties); debt recovery; management of fines; vehicle recovery;
- factoring companies;
- consultants and professionals (website management, computer archives, )
- auditors;
- legal, tax and IT consultants by companies and/or individuals who provide us with CED services and related maintenance;
- forwarders, carriers and couriers;
- judicial offices, in the context of criminal investigations or other entities whose right to access data is recognised by legal provisions;
- companies, entities and/or individuals carrying out activities related, instrumental and/or supporting ours, or necessary and/or functional to the performance of contracts or services
- Companies that install and operate satellite antitheft systems (GPS and similar) or position detectors on behalf of LORAN. With regard to the communication referred to in point 8 above, the installation of satellite antitheft systems or position detectors allows the vehicle to be located on the territory or in certain geographical areas, even without tracking The subjects belonging to the categories referred to in points 3, 5, 7, and 8 above, process the data as Joint Data Controllers pursuant to art. 26 of the Regulations.
For the purposes referred to in letter 2.e), subject to your consent, the Customer’s data may be communicated to companies, bodies, consortia and associations operating in Italy, in member countries of the European Union, for the purposes of market research, economic analysis and statistics, marketing, promotion and sale, including home sales, of goods, products and services.
This site may share some of the data collected with services located outside the European Union. In particular, with Google, Facebook and Microsoft (LinkedIn) via social plug-ins and the Google Analytics service. The transfer is authorised under specific decisions of the European Union and the Data Protection Authority, in particular Decision 1250/2016 (Privacy Shield) for which no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
10. Rights of the persons concerned
We inform you that at any time, with regard to your Data, by means of a communication to be sent to the e-mail address privacy@soacorporate.com, or by writing to our head office by A/R to the address Viale Giuseppe De Gennaro, 1 – 70123 (Ba), you may exercise your rights within the limits and under the conditions provided for by articles 7 and 15, 16, 18, 20, 22 of the Regulation.
In particular, your right to revoke at any time any processing consents you may have given and to object to the processing of your data, in particular for marketing purposes or to analyse your preferences, as explained in the following paragraph, remains unaffected.
Interested parties who believe that their personal data is being processed through this service in violation of the provisions of the Regulations may send a communication to the Data Processor at dpo@soacorporate.com, or they may lodge a complaint with the Supervisory Authority (Privacy Guarantor), as provided for by Article 77 of the Regulations, or take legal action (Article 79 of the Regulations).
- Garante per la protezione dei dati personali Piazza Venezia n. 11 – 00187 Roma
Tel +39 06 69677 1
Fax +39 06.69677.3785
e-mail: garante@gpdp.it – Pec: protocollo@pec.gpdp.it
Website: http://www.garanteprivacy.it/
11. Withdrawal of consent to processing
The interested party may revoke consent to the processing of his/her personal data at any time by sending a registered letter with return receipt to the following address: Loran Italia S.r.l., with registered office in Viale Giuseppe De Gennaro, 1 – 70123 Bari (BA), accompanied by a photocopy of your identity document, with the following text: “revocation of consent to the processing of all my personal data“, or using the following E-mail: privacy@soacorporate.com.
At the end of this operation, your personal data will be removed from the archives as soon as possible.
If you would like more information about the processing of your personal data, please use the e-mail address: privacy@soacorporate.com . Before we can provide, or change, any of your information, we may need to verify your identity and answer a few questions to ensure regular contact.
12. Contact details of the Data Protection Officer
The Data Protection Officer appointed by LORAN can be contacted by e-mail at dpo@soacorporate.com.
13. Exercise of rights
You may contact LORAN in its capacity as Data Controller or the Data Protection Officer at the above-mentioned addresses to obtain an updated list of our data processors (i.e. our service providers), the entities to which your data is disclosed and to exercise your rights under Articles 15 to 22 of the Regulation.
Specifically, the User may at any time request access to his or her personal data stored in our Databases by making an explicit request by sending an email with the nature of the request to the email address privacy@soacorporate.com . The User may also exercise the right to delete/obliterate his or her personal data at any time.
The person concerned should address his or her request in writing to the attention of one of the following:
- By e-mail to the appropriate address: privacy@soacorporate.com
- By fax to the following number: +39 080 4322904
- By registered letter to the following address:
o Loran Italia S.r.l. in Viale Giuseppe De Gennaro, 1 – 70123
14. Update
This Privacy Policy is subject to updating. Therefore, LORAN invites interested parties who wish to know how the Personal Data collected is processed to periodically visit this page.
The possible entry into force of new industry regulations, as well as the constant review and updating of services to the user, may result in the need to change the terms and conditions described in this Policy. It is therefore possible that this document may change over time. We therefore encourage you to periodically consult this page. We will post any changes to this Policy on this page and, if the changes are material, we will provide you with a more prominent notice.
Earlier versions of this Policy will, in any case, be archived for reference purposes
This policy was updated on: 31/01/2019.
