INFORMATION NOTICE
- Pursuant to and for the purposes of Articles 13 and 14 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of Personal Data and on the free movement of such data (General Data Protection Regulation, hereinafter, also, "Regulation" or "GDPR") and repealing Directive 95/46/EC, we inform you that the Personal Data you voluntarily make available to ITALO - Nuovo Trasporto Viaggiatori S. p.A. (hereinafter, also, "the Company" or "ITALO") will be processed in compliance with current legislation on the protection of Personal Data and, in any case, with the principles of confidentiality that inspire the Company's activities.
The processing is related to making available to you the free wi-fi service on board our trains as well as the Italolive on-board portal, which will allow you to enjoy numerous multimedia contents, such as, for example, videos, audio, magazines, e-books, etc. Once authenticated, you will be able to browse freely and for free on the internet network. This service is provided by a third party acting as an Internet service provider who, about the processing of your personal data, acts as an independent Data Controller. Therefore, we invite you to read the information notice on the processing of personal data provided by the service provider at the time of your authentication to the free wi-fi service.
When you browse our Italo live Onboard Portal, information capable of identifying your device or browser may be collected in the form of files called “cookies”. "Cookies" are encrypted text strings that are stored by a website on the user's device in order to allow their rapid identification at a later time. These files allow you to customize a website, to provide the user with easier navigation and, through a quantitative verification of access to the various web pages, a better presentation of the most requested information. Cookies generally use anonymous information and, therefore, do not allow the processing of data relating to your person. Furthermore, cookies may be used to store your login data and therefore make your recognition automatic (and therefore the Username & Password entry procedure is superfluous).
The cookies we use include both session cookies, which are automatically deleted when the browser is closed, and persistent cookies, which remain stored for a predetermined period of time. ITALO uses only first-party cookies; therefore, the sending of third-party cookies is excluded. In general, ITALO uses only “technical cookies”, necessary in order to guarantee the user the best functionality of the Italolive portal and to provide the service requested.
1. Categories of personal data processed
ITALO will process the following categories of personal data provided by You:
- Common personal data, such as Your e-mail address and the state of Your optional consent given / denied by You with reference to the marketing purposes indicated in the following par. 2;
2. Purpose of processing
The Personal Data you make available to ITALO will be used:
a) to enable your navigation on the Italolive Onboard Portal;
b) following your eventual and specific consent, for the sending by electronic mail, by the Company, of informative and/or promotional communications, also of a commercial nature (including our newsletter), of advertising material and/or offers of goods and services both of ITALO and of ITALO's business partners, of ITALO's parent companies, subsidiaries and/or investees, as well as, on behalf of ITALO, by natural or legal entities contractually linked to ITALO and/or that, in any case, collaborate in ITALO's business activities.
3. Provision of Personal Data and consequences of refusal
With reference to the purpose highlighted in paragraph 2 above under (a), the provision of your personal data is mandatory. Your refusal and/or the provision of inaccurate and/or incomplete information may make it impossible for you to authenticate and use the free wi-fi services. With reference to the further purpose highlighted in (b), the provision of your personal data is optional. However, your refusal and/or the provision of inaccurate and/or incomplete information may prevent the performance of so-called marketing activities. We also inform you that you can always request the deactivation of cookies by changing your browser settings, but such deactivation may slow down or prevent access to certain parts of the Portal or sites accessible through the Internet.
4. Means of processing
The processing of your Personal Data will be carried out by means of suitable paper, electronic and/or telematic instruments, with logic strictly related to the above purposes and, in any case, in such a way as to ensure the security and confidentiality of the personal data.
5. Recipients or Categories of recipients of personal data Your Personal Data may come to the attention of the shareholders, members of the Board of Directors or other administrative body, the Data Protection Officer, and, in any case, Data Processors and/or employees and collaborators, acting under the authority of the Data Controller in the exercise of their function. Your Data may be communicated to any subjects that provide ITALO with services or performances instrumental to the purposes indicated in paragraph 2 above such as, by way of example only, parent, subsidiary, and/or investee companies for administrative accounting purposes; subjects, entities and/or companies that manage and/or participate in the management and/or maintenance of the websites and electronic and/or telematic tools used by ITALO; suppliers, contractors, subcontractors, or other subjects and/or entities that provide (on behalf of ITALO or independently): (i) the management of authentication/access to the Services; (ii) the sending of informative and promotional communications, including of a commercial nature, advertising material and/or offers of goods and services in the manner indicated in paragraph 2 lett. (b); consultants who assist the Company in various capacities with reference to legal, tax, social security, accounting, organizational aspects; to Police Forces or Judicial Authorities within the scope of investigations or judicial police inquiries for the purpose of prevention, ascertainment, or repression of crimes; any other subject to whom the data must be communicated according to an express provision of law. Your personal data may possibly be transferred abroad, in accordance with current regulations, including to countries outside the European Union where the Company may pursue its interests. Transfer to non-EU countries, in addition to cases where this is guaranteed by Commission Adequacy Decisions, is done in such a way as to provide appropriate and adequate Safeguards in accordance with Articles 46 or 47 or 49 of the GDPR.
6. Criteria used for data retention
The data concerning you will be retained for a period no longer than is necessary to achieve the purposes for which they were collected and, in any case, for a period no longer than is necessary to fulfill regulatory obligations. Personal data will be retained, for marketing purposes referred to in paragraph 2 letter b), until any withdrawal of consent given for that purpose.
7. Privacy rights of data subjects
We inform you that at any time Relative to your Personal Data, you may exercise the privacy rights provided within the limits and under the conditions set forth in Articles 7 and 15-22 of the GDPR. In order to exercise these rights, described below, we invite you to contact the Data Controller through the Privacy Office at the email address privacy@ntvspa.it; such a request will be answered appropriately in the timeframe provided by the GDPR. In relation to the Personal Data subject to processing referred to in this privacy notice you are granted, at any time, the right to:
- Withdrawal of consent at any time without affecting the lawfulness of processing based on consent before revocation;
- Access, including the right to obtain copies of Personal Data concerning you, as long as the rights and freedoms of other individuals are not affected (Art. 15 GDPR);
- Right to rectification (art. 16 GDPR);
- Right to erasure (art. 17 GDPR);
- Right to restriction of processing(art. 18 GDPR);
- Right to portability, understood as the right to obtain from the Data Controller the data in a structured, commonly used and machine-readable format for transmission to another Data Controller without hindrance, if technically feasible (art. 20 GDPR);
- Right to object (21 GDPR);
Please note that pursuant to Article 77 GDPR you may lodge a complaint with the Supervisory Authority in the event of violation of the current legislation on the protection of personal data by following the procedures and directions published on the Authority’s official website at www.garanteprivacy.it.
8. Browser settings. Cookie management and direct link to dedicated browser section
Please note that browsers usually accept cookies by default; you can also reject cookies through your browser settings. You may also choose the option that rejects only third-party cookies. Keep in mind that this choice may affect your Web browsing experience. Please be advised that you may manifest your options regarding the Site's use of cookies through your browser settings by performing the specific procedure provided to change/manage such settings available at the following links:
- Internet Explorer
- Firefox
- Google Chrome
- Safari
9. Data Controller, Data Processors and Personal Data Processor
The Data Controller of your Personal Data is ITALO - Nuovo Trasporto Viaggiatori S.p.A. with registered office in Rome (RM) Via Casilina, 1 - 00182, in the person of the Legal Representative pro tempore. Any request regarding the Personal Data processed by ITALO - Nuovo Trasporto Viaggiatori S.p.A. may be sent to the Company's registered office, or by writing to the e-mail address privacy@ntvspa.it. The updated list of appointed Data Processors pursuant to Article 28 GDPR is available at the Company and can be known through special request made in the manner indicated above. The contact information of the Data Protection Officer is dpo@ntvspa.it. This policy will be subject to updates. ITALO therefore invites Users who wish to know how ITALO processes the Personal Data collected by ITALO to periodically visit this page.
Last update: February 2024
This is an English courtesy translation of the original documentation prepared in Italian language. Please consider that only the original version in italian language has legal value.
Data Controller
Italo – Nuovo Trasporto Viaggiatori S.p.A.
POLICY REGARDING OPTIONAL CONSENTS COLLECTED BEFORE 7.02.2024
INFORMATION NOTICE –“FREEWI-FI SERVICE ON BOARD"
REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL OF 27 APRIL 2016
Pursuant to and for the effects of article 13 Regulation (EU) 2016/679 of the European Parliament and of the Counsil of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on free movement of such data, and repealing Directive 95/46/EC (“General Data Protection Regulation” or simply “Regulation” or “GDPR”), we inform you that ITALO - Nuovo Trasporto Viaggiatori S.p.A. (ITALO) collects and processes Your personal data in compliance with data protection law in force and, in any case, in accordance with the principles of confidentiality that our Company is inspired by.
Personal data processing at issue is related to making available to you the free wi-fi service on board of our trains as well as the Italolive portal, which will allow you to enjoy numerous multimedia contents, such as video, audio, magazine, e-book, etc.
Once the authentication is performed, you can browse freely and for free on the internet network. This service is provided by a third party acting as an Internet service provider who, with reference to the processing of your personal data, operates as an independent Data Controller. Therefore, we invite you to read the information notice on the processing of personal data provided by the aforementioned service provider in phase of authentication to the free wi-fi service.
When you navigate inside our Portal, information capable of identifying your device or browser may be collected in the form of files called “cookies. "Cookies" are encrypted text strings that are stored by a website on the user's device in order to allow their rapid identification at a later time. These files allow you to customize a website, to provide the user with easier navigation and, through a quantitative verifi cation of access to the various web pages, a better presentation of the most requested information. Cookies generally use anonymous information and, therefore, do not allow the processing of data relating to your person. Furthermore, cookies may be used to store your login data and therefore make your recognition automatic (and therefore the User Name & Password entry procedure is superfluous).
The cookies we use include both session cookies, which are automatically deleted when the browser is closed, and persistent c ookies, which remain stored for a predetermined period of time.
ITALO uses only first-party cookies; therefore the sending of third-party cookies is excluded.
In general, ITALO uses only “technical cookies”, necessary in order to guarantee the user the best functionality of the Italolive portal and to provide the service requested.
1. Categories of personal data processed ITALO will process the following categories of personal data provided by You: - Common personal data, such as Your e-mail address and the state of Your optional consent given / denied by You with reference to the marketing purposes indicated in the following par. 2;
2. Purposes of the processing activies
Your Personal Data will be processed by ITALO for the following purposes:
a) to make possible your navigation on Italolive portal;
b) after your consent, for the sending by e-mail of informative and promotional communications, including commercial messages (such as our newsletter), advertising materials and/or offers of goods and services, sent by Italo, by its controlling companies, by subsidiaries and/or by companies in which it has interests, as well as by individuals or organizations contractually tied to ITALO and/or that engage in commercial activities in collaboration with ITALO.
With regard to the purpose indicated under letter (a), presentation of your personal information is obligatory. Should you refuse, and/or should the information presented prove inexact and/or incomplete, then this could make impossible Your authentication and usage of free wi-fi services.
With regard to the further purpose indicated under letter (b), the presentation of your personal information is optional. Nevertheless, should you refuse to present it, or should the information presented prove to be inexact and/or incomplete, then this could make impossible the performance of the so-called marketing activities.
You may request that the cookies be deactivated by modifying the settings of the browser, but a similar deactivation will slow down or prevent access to certain portions of the Portal or to sites accessible over Internet.
3. Methods of the processing activities
In relation to the purposes indicated, Your personal data will be processed by suitable paper-based, electronic and/or Web-based instruments with logic strictly related to the aforesaid purposes and, in any case, such as to ensure data security and confidentiality.
4. Recipients or categories of recipients of the personal data
Your personal data shall be processed by all persons acting under the authority of the Data Controller, authorized to processing activities during the execution of their duties. Your data shall be communicated to any qualified entities that provide ITALO services necessary for the above- mentioned purposes, such as, for example, parent companies, subsidiaries, affiliates, entities, institutions and / or companies that manage and / or participate in the management and / or maintenance of websites and electronic and / or telematic tools used by ITALO; su ppliers, contractors, subcontractors, or other subjects and/or organizations that handle (on behalf of ITALO or independently)): (i) the management of authentication/access to the Services; (ii) the sending of informational and promotional communications, including commercial messages, advertising materials and/or offers of goods and services, in accordance with the procedures indicated under paragraph 2, letter (b) above; consultants who assist the Company in various areas, in particular with regard to matters involving legal affairs, taxes, social security, accounting and organizational affairs; any other subject to which the information must be communicated, based on an express provision of the law.
Your personal data could possibly be transferred abroad, in conformity with the provisions of the rules and regulations currently in force, including to countries that are not members of the European Union, but where the Company decides to pursue its interest.. Transfer of personal data to a third country, it is granted by an adequacy decision by the Commission or it is made in order to provide appropriate and adequate guarantee according to Article 46 or 47 or 49 GDPR.
5. Criteria used to determine the period for which the personal data will be stored
Your personal data will be stored for a period necessary to pursue the purposes for which they were collected and, in any cas e, for a period of time no longer than time necessary to fulfill regulatory obligations. Personal data will be stored, with reference to marketing activities indicated under par. 2 lett b), until you withdraw your consent.
6. Data subject’s rights
We would like to inform You that at every time You could exercise Your rights according to Article 7 and Articles 15-22 of GDPR 2016/679.
To exercise Your rights, You can contact the Data Controller at privacy@ntvspa.it. To Your request, the Company will give You a feedback in accordance with GDPR.
You have the right to:
- request from the Data Controller access to or rectification or erasure of personal data (“right to be forgotten”) or the restriction of processing concerning You or to object to processing;
- revoke the consent previously given, without prejudice to the lawfulness of the processing based on consent before the revocation;
- obtain data portability;
- lodge a complaint with the competent supervisory authority.
7. Browser Settings. Cookies management and direct link with the dedicated browser section
Web browsers usually accept cookies by default; it is also possible to reject cookies by setting your browser. You can choose an option that rejects only third-party cookies. Please consider that this choice could impact on your experience while browsing the web.. We inform you that you may set your options for the use of cookies by the Website through your browser settings by performing the specific procedure for changing/managing these settings available at the following links:
- Internet Explorer
- Firefox
- Google Chrome
- Safari
8. Data Controller and Data Processor for the personal data processing
The Data Controller is ITALO - Nuovo Trasporto Viaggiatori S.p.A., with registered office in Via Casilina, 1 - 00182, Rome, Italy, in the person of its legal representative pro tempore. Any request relating to the personal data processed by ITALO - Nuovo Trasporto Viaggiatori S.p.A. may be sent to the company’s registered office or to its email privacy@ntvspa.it. The updated list of Data Processors is made available by the Company and may be obtained upon a specific request submitted as detailed above. The Data Protection Officer’s contact is dpo@ntvspa.it
This is an English courtesy translation of the original documentation prepared in Italian language. Please consider that only the original version in italian language has legal value.
Data Controller
Italo – Nuovo Trasporto Viaggiatori S.p.A
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