Privacy Policy
1. Privacy notice on the processing of personal data collected through the website pursuant to EU Regulation No. 679/2016 and Legislative Decree No. 196/2003
Autostrada Pedemontana Lombarda S.p.A. (also “APL”), in compliance with the principles laid down by EU Regulation No. 679/2016 – General Data Protection Regulation (the “Regulation”) and the applicable national legislation (Legislative Decree No. 196/2003, the “Privacy Code”), provides users with the opportunity to interact with its portal at www.pedemontana.com, which corresponds to the home page of the official website of Autostrada Pedemontana Lombarda S.p.A. In addition to describing how the website and the related Reserved Area are managed, this page is intended to inform users accessing the Autostrada Pedemontana Lombarda S.p.A. portal, in its capacity as Data Controller, about the processing of personal data carried out through the website and the related rights and safeguards provided for under the Regulation and the Privacy Code.
This privacy notice is provided exclusively in relation to the website of Autostrada Pedemontana Lombarda S.p.A. and does not extend to processing activities carried out by third parties that users may access through links available on the same website. With regard to such further processing activities, Autostrada Pedemontana Lombarda S.p.A. assumes no responsibility. Users are therefore required to refer to the individual privacy policies of the relevant third-party websites.
2. Purposes of the processing
Autostrada Pedemontana Lombarda S.p.A., through the website, may collect and process the User’s personal data for the following purposes:
a) Pursuing the legitimate interests of Autostrada Pedemontana Lombarda S.p.A. and/or third parties (for example, the right to defend itself in legal proceedings, accurate invoicing and the allocation of payments received, the management of complaints and disputes, the possible judicial and extrajudicial recovery of debts, and the prevention of fraud and/or unlawful activities), which, according to the Data Controller’s assessment, do not outweigh the User’s fundamental rights and freedoms and constitute the legal basis for such processing.
b) Purposes related to compliance with obligations arising from applicable laws and regulations, including national and EU legislation, as well as from provisions issued by authorities legally authorised to do so, which constitute the legal basis for such processing.
3. Place and methods of processing
The processing activities relating to the website and the web services of the Reserved Area are carried out at the premises of Autostrada Pedemontana Lombarda S.p.A., as well as by external entities, including the website service provider and operator, appointed as data processors. Such processing is carried out for the time strictly necessary to achieve the purposes for which the data are collected, including, where applicable, through the use of automated tools, while observing the security measures designed to prevent data loss, unlawful or improper use, and unauthorised access.
The data are processed by personnel of the Company authorised to process personal data, or by external parties appointed to carry out occasional maintenance operations, in accordance with the principles of fairness, lawfulness, transparency, relevance and non-excessiveness in relation to the purposes for which the data are collected and subsequently processed.
4. Types and nature of data processed
Autostrada Pedemontana Lombarda S.p.A. collects, through its website www.pedemontana.com and through the “pedemontana lombarda” mobile application, information relating to users who visit the website and make use of the web services available in the Reserved Area of the website and the services available through the mobile application. In particular, Autostrada Pedemontana Lombarda S.p.A. collects and processes the following information.
Browsing data
Access to the website entails the recording of data used solely to obtain statistical information or to ensure its proper functioning.
The data collected include public IP addresses
Such data are not collected for the purpose of associating them with identified individuals; however, due to their nature, they may make it possible to identify users by processing and cross-referencing them with data held by third parties, particularly where it is necessary to establish liability in the event of alleged cyber offences against the website.
The data are used solely to obtain anonymous statistical information on the use of the website and to monitor its proper functioning. They are retained for the time necessary to carry out analysis activities and comparative statistical analyses, in pursuit of the legitimate interests of Autostrada Pedemontana Lombarda S.p.A.
Data voluntarily provided by the user or acquired by the Company
Autostrada Pedemontana Lombarda S.p.A. limits the collection of information relating to users exclusively to the pursuit of the purposes described in paragraph 2 above and to the services expressly requested, such as:
a) Payment of payment reminders: for the purpose of paying payment reminders relating to outstanding toll charges, users may use the relevant web service, which requires them to provide only the payment reminder number. After entering the above-mentioned number, users may proceed with payment by credit card. Alternatively, users may use the web payment method, which requires them to provide the following personal data: email address and password. Upon registration, users must read the User Privacy Notice. Once registered, users may proceed with payment of payment reminders relating to outstanding toll charges by providing the payment reminder number and using a credit card. For both payment methods described above, credit card details are stored on a dedicated portal managed by the bank providing the service and are not accessible to APL. The payment process is managed directly by the relevant credit institutions.
b) Other data voluntarily provided by the User: in connection with the services offered through the website, users may provide Autostrada Pedemontana Lombarda S.p.A. with additional data, beyond those indicated for the purposes described above, in order to receive further information and services (for example, to request information, submit complaints or disputes concerning toll charges and payment reminders, report service disruptions or malfunctions, etc.). Such data are processed by Autostrada Pedemontana Lombarda S.p.A. solely for purposes strictly related to the User’s request or communication. Failure to provide such data may result in the inability to obtain the requested service.
5. Cookies
A cookie is a small text file that a website sends to a browser and stores on the user’s computer when they visit a website. Autostrada Pedemontana Lombarda S.p.A. uses cookies to enable the website to function or to improve its performance, as well as to provide information about the website and users’ browsing activities. In general, the website uses cookies both for technical purposes and for other purposes: while technical cookies are used where they are strictly necessary for the technical operation of the website and for providing the service expressly requested by users (e.g. authentication, language settings, etc.), cookies used for other purposes (e.g. analytics cookies) are used to analyse users’ behaviour on the website in order to improve its content.
Technical cookies
Technical cookies are essential to enable users to navigate the website and use its features, such as accessing the Reserved Area (e.g. registration and authentication). These cookies are strictly necessary and are used to store a unique identifier in order to manage and identify the user as distinct from other users visiting the website at that time, thereby providing the user with a consistent and accurate service. In addition, these cookies enable the website to remember users’ choices (e.g. username, language, country of origin, etc.), to record when users provide their consent to certain options (for example, by accepting the use of certain cookies through the information banner), and to enable users to view content.
Analytics cookies
These cookies may be session cookies or persistent cookies, and may be installed by the website or by third parties, such as WAI (Web Analytics Italia). They are used solely to monitor and improve the performance of the website. These cookies collect aggregated statistics on how users use the website, such as the pages visited most frequently. In addition, analytics cookies make it possible to measure the number of visitors to the website, thereby enabling the website to be improved and enhanced, for example by determining whether users can easily find the information they are looking for or identifying which aspects of the website are of greatest interest. These cookies are used by Autostrada Pedemontana Lombarda S.p.A. to carry out anonymous and aggregated statistical analyses of users’ browsing activities on the website, the number of pages visited and the number of clicks, by means of mechanisms for masking users’ IP addresses and without WAI (Web Analytics Italia) being able to cross-reference such information with other information in its possession for the purpose of identifying users.
Disabling cookies through the browser
If they so wish, users may delete cookies placed by the website through their browser settings.
Most web browsers are set to accept cookies. However, users may configure their browser to restrict the number of cookies accepted or to block all cookies by changing the browser settings as follows:
Google Chrome
Click the “wrench” icon in the top right-hand corner and select “Settings”. Then select “Show advanced settings” and change the “Privacy” settings.
Mozilla Firefox
From the drop-down menu in the top left-hand corner, select “Options”. In the pop-up window, select “Privacy”. Users can then adjust their cookie settings.
Safari
From the drop-down settings menu in the top right-hand corner, select “Preferences”. Select “Security”, where users can adjust their cookie settings.
Please note, however, that disabling the use of all cookies on the website may impair certain functionalities (e.g. the ability to authenticate).
Microsoft Edge
From the drop-down settings menu in the top right-hand corner, select “Settings”. Select “Security”, where users can adjust their cookie settings.
Further information on cookies
The website www.allaboutcookies.org contains instructions on managing cookies in the most widely used browsers. Alternatively, users may consult the documentation provided with the software installed on their device.
6. Disclosure of data
The data provided by users, as well as the data collected by the website in connection with the relevant services (e.g. IP address), will not be disclosed.
7. Data retention
The data are processed for the time necessary to provide the services requested by the User and to carry out the activities connected with and necessary for the provision of such services, as described in paragraph 2 above.
8. Data subject rights
Users, in their capacity as data subjects (i.e. persons to whom the data relate), may exercise at any time, by contacting the Data Controller, Autostrada Pedemontana Lombarda S.p.A., the rights set out in Articles 15 to 21 of the Regulation, and in particular:
- obtain confirmation as to whether their personal data are being processed and, where this is the case, request from the Data Controller access to information relating to such processing (e.g. purposes of the processing, categories of data processed, recipients or categories of recipients of the data, retention period, etc.);
- request the rectification of inaccurate or incomplete data;
- request the Data Controller to erase their personal data (e.g. where the personal data are no longer necessary in relation to the purposes for which they were collected, or where consent on which the processing is based has been withdrawn, etc.);
- request the restriction of processing (e.g. where the User contests the accuracy of the data; where the processing is unlawful and the User objects to the erasure of the personal data; where the data are necessary for the establishment, exercise or defence of the User’s legal claims, even where the Data Controller no longer needs them; or where the right to object is exercised, for the period necessary to verify whether legitimate grounds exist);
- receive their personal data in a structured, commonly used and machine-readable format (e.g. PDF) and transmit such data to another Data Controller, or obtain the direct transmission of the data from one Data Controller to another, where technically feasible (the so-called right to data portability).
The User also has the right to object, in whole or in part and on legitimate grounds, to the processing of personal data concerning them.
These rights may be exercised directly by Users by contacting Autostrada Pedemontana Lombarda S.p.A., with registered office at Via Benigno Crespi, 17, 20159 Milan (MI), or by contacting the following email address: posta@pedemontana.com.
Finally, if the User considers that the processing of the data provided infringes data protection legislation, the User has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) (www.garanteprivacy.it).
9. Amendments to the Privacy Policy
Autostrada Pedemontana Lombarda S.p.A. reserves the right to make amendments to this Privacy Policy at any time.
Data Controller
Autostrada Pedemontana Lombarda S.p.A., with registered office at Via Benigno Crespi, 17, 20159 Milan (MI) is the Data Controller for the processing of personal data carried out through the website.
Data Protection Officer
The Data Protection Officer (“DPO”) may be contacted at the following email address: dpo@pedemontana.com.