INFORMATION IN ACCORDANCE WITH ART. 13 OF REG. (EU) NO. 2016/679 (“GPDR”)

This notice describes which of your personal data is collected by Bettolo S.r.l. (hereinafter referred to as “us” or “Bettolo”), when you browse the site www.terminalbettolo.com (hereinafter “Site“), when you use our services, for which the purposes for this and how it is processed. You will also find the information necessary to exercise your rights under GDPR.

You are hereby informed that the personal data collected during said procedures will be processed in order to respond to your requests, allow you to use the services offered by Bettolo, manage you application, and to provide better services, marketing and support for you and other customers, as set out above.

1.Who processes your data: data controller – DPO

Bettolo S.r.l., with registered offices at Via Balleydier 7N – 16149 Genova, [email protected], is the data controller of your data processing (hereinafter, “Controller” or “Bettolo”).

The Data Protection Officer (“DPO”) may be contacted at the following address [email protected]

2.Which data we process – Type of data processed

Website used data.

For the sole purpose of information security and performance monitoring, the systems underlying the Site may acquire information that can potentially be traced back to the user’s personal data. For example, the IP address of the computer, the time of access to the Site, the pages of the Site visited, the URI (Uniform Resource Identifier) addresses of the resources requested and other parameters relating to the operating system and the computer environment of the user may be recorded. These data are recorded in special logs and may be communicated exclusively to the Judicial Authorities, in the event of significant IT security events. Otherwise (absence of security issues) they are deleted from the systems as quickly as the IT organisation allows, and in any case no later than the working week.

Data provided by you

We will retain the contact information you provide us with (e.g., first name, last name, e-mail and telephone number) when you contact us to request information by e-mail or through the form on the Site or when you send us your CV through the “Send Curriculum Vitae” form (to view the extended information for candidates click here).

Data required for booking on Online Terminal for Drivers

We will retain the contact information that you provide us with (e.g. your port ID number and date of birth) when you make a booking in the “Online Terminal for Drivers” section of the Site.

3. Where we get your data – Data collection method

Via the use of the Site’s features.

We use cookies and other technology to improve the functionality of the Site and make their use more efficient. To find out more, please view our Cookie Policy.

Directly from you.

For example, when you send us an email or you use the form on the Site

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4. Why and how long we process your data for – Purpose and legal basis for data processing; retention period

To prevent or investigate illegal behavior or to protect and assert rights.

For example, we may use your data to prevent the breach of our intellectual property rights (for example, counterfeiting of our and/or our partners’ trademarks) or other illegal activities, as permitted by the applicable law. The legal basis for this processing is the legitimate interest of the Controller. The data retention period is equal to the time that is reasonably necessary to assert our rights from the point at which we become aware of the illegal behavior or the potential to commit illegal behavior.

To respond to your requests.

We will process your data in order to be able to respond to your requests received by filling in the form on the Site (by choosing from the drop-down menu the different options) or when you send us an e-mail to the addresses on the Site. The legal basis for such processing is the execution of your request. The data retention period of your data is equal to the time necessary to process your request, after which they will be stored solely for the performance of legal obligations in force, for administrative purposes and/or to assert or defend a right, in the event of litigation and pre-litigation.

To evaluate unsolicited applications.

We will process your data in order to evaluate applications received via the “Send Curriculum Vitae” form. The processing is necessary for the execution of pre-contractual measures requested by the data subject, pursuant to art. 6, par. 1, lett. b) GDPR and art. 111-bis Legislative Decree 196/2003. For further information, please consult the information notice available at this link.

To enable you to use the E-terminal portal.

We will process your data used to register you for the service as well as any data you may have entered by filling in the form (in particular, your first name, last name and date of birth) available to you. The legal basis for such processing is the performance of the requested service. The data retention period is 3 months.

To enable you to make a booking for the Online Terminal for Drivers.

We will process your personal data when you fill in the form on https://gate.terminalbettolo.com/login?callbackUrl=%2Ftd%2Freservation-list, to enable you to make the relevant booking. The legal basis for such processing is the execution of your request and the data retention period is equal to the time required to process such requests and/or equal to the legal or regulatory obligations imposed and for a maximum of 1 month from your access to the Terminal.

To obtain information on the use of the Site.

When you browse the Site, the software procedures and the computer system concerning the operation of web applications acquire, in the course of their normal operation, certain data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected in order to be associated with identified interested parties, but through processing and association with data held by the Controller or by third parties, allow users to be identified.

Geographic location data will only be used in an anonymous form that does not in any way make it possible, even in combination with your Unique Device Identifier (UDID), MAC address, IMEI or IMSI codes or other customer codes, to trace your identity directly or indirectly.

This category of data includes the IP addresses or domain names of the devices used by users who connect to the application, the URI (Uniform Resource Identifier) 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 (successful, error, etc.), the sections of the Site visited, the type of device used, the country from which it is connected and other parameters relating to the user’s operating system and computer environment. Bettolo uses this information exclusively to allow navigation on its Site and to carry out the operations usually associated with use of the Site. The legal basis for this processing is Bettolo’s legitimate interest in communicating with the public via telematic networks. The data retention period of information that could potentially allow identification is equal to the duration of the browsing session on the Website.

Other purposes permitted by law.

In certain circumstances, we may process your data if there is a legitimate interest of the Controller, in accordance with Article 6(1)(f) of the GDPR. In relation to the aforementioned purposes, the processing of personal data is carried out using manual and telematic tools with logic strictly related to the purposes and, in any case, in such a way as to ensure the security and confidentiality of the data in accordance with the law.

5.Nature of the provision of personal data

For the purposes of the above paragraph, the provision of data is necessary, failing which it will be impossible to follow up and process requests received.

6. Where your data is processed – data transfer

Data will be processed and stored at our offices in Via Balleydier 7N – 16149 Genova as well as at the suppliers working site.

7. Who we share your data with – personal data recipients

Service providers

Bettolo uses third-party service providers who act as autonomous data controllers or data processors, in the latter case according to agreements in accordance with Article 28 GDPR. When such providers operate from a third country, they do so on the basis of standard contractual clauses in accordance with the European Commission’s decision on protection clauses or pursuant to an adequacy decision of the European Commission on the level of data protection. These parties only come into possession of personal data necessary for the performance of their functions and may only use such data for the purpose of performing such services on our behalf or to comply with legal requirements. An up-to-date list of third-party providers, acting as data controllers within the meaning of Article 28 GDPR, is available with a request to [email protected]

Other group companies.

Your data may be shared with other companies in the group to which Bettolo belongs for internal administrative and organisational purposes, to provide you with the services you have requested or to provide you with assistance. Up-to-date information on the companies receiving your data is available by writing to [email protected]

Judicial or administrative authorities.

Where we believe we have to do so in order to comply with a court order or authority, or in order to comply with legal obligations or in order to legally protect ourselves or third parties, we may disclose your information to a judicial authority or an administrative authority of the State or the European Union.

8. Your rights

ou can contact Bettolo to request access to your personal data, modify it, delete it or limit its processing, to oppose its processing, and to request the portability of your data, when processing is carried out by automated means; you can also withdraw your consent at any time (this will not prejudice the lawfulness of the processing on the basis of the consent granted prior to the withdrawal).

You have the right to lodge a complaint to the Italian supervisory authority and, at any time, to ask the Controller for information about the data processors and parties that are authorized by the Controller to process your data.

You can exercise your rights by contacting Bettolo or by writing to the DPO at [email protected]

9. What happens if we change this policy

We may make changes to our privacy policy. We will publish an updated version on our website. It will have a different date to the one given below. Please visit the Site regularly to check for updates.

Version updated to February 8, 2023.