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Information on the processing of personal data (Privacy Code - Legislative Decree no. 30.6.2003, n. 196 - Art. 13)

The company Ellepi rental snc (hereafter, collectively, "Ellepi") informs that holds your information qualified as personal data under the Code regarding the protection of personal data (Legislative Decree no. 30.6.2003, n. 196 - Privacy Code), and that it will proceed to its processing for the purposes and with the procedures shown below. This informative pursuant to art. 13 of Legislative Decree no. June 30, 2003, n. 196 (Privacy Code), will allow you to know all our policies on the treatment of the data we collect, whether to understand how your personal information is managed when using our services (at the business premises and our rental locations) and when benefits from online services available in all sections of www.ellepirental.com web site (the "site") where it is required to provide personal data . This in order to enable then to pay a consent to treatment of your expressed, aware, informed and specific personal information, regardless of the means of communication and the purposes for which it comes into contact with the company. About the collection of data on this site, we remind you that the various sections where we collect your personal data are also published further information and specifications in accordance with art. 13 of the Privacy Code (or under specific statutory provisions contained in the General Provisions of the Authority Guarantor for privacy) for necessary reading before providing the required data. The information and data provided by you or otherwise acquired using the area of the site will be handled in compliance with the provisions of the Privacy Code (whose complete text can be found on the Data Protection Commissioner www.garanteprivacy.it web site), the Recommendation of the Group of European Guarantors No. 2 of 17 May 2001 and the obligations of confidentiality that inspire the activities of the company. “Processing of personal data” consists of any operation or set of operations, carried out without the aid of electronic instruments, concerning the collection, recording, the organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure and destruction of data, even if not registered in a database. We inform you, therefore, that such information will be treated manually and / or with the support of computer or electronic means for the following purposes.

A. Primary purposes of the processing of personal data

The access and navigation of the site are free, but the possibility of using some online services available is permitted only after the user's registration. The registration process consists of filling out an online form in which it is required to indicate his personal data - to insert some mandatory, so in the first place, to make the reservation . The primary and main purposes of the processing of user data are recorded to allow him access to the web pages of the Site where he can take advantage of online services and pre- and post-contractual assistance for the management of each contract, administrative or technical result . With reference to this last treatment, the purpose is also to handle any type of request - technical, commercial and / or contractual - received by the company and to provide its customers with answers.The treatment that we intend to do then also pursue the following goals which do not relate only to the collection of online data, but also all the means, procedures and services - even offline - with whom the company collects its personal data:

a) the establishment and execution of obligations arising from rental contracts a and / or the provision of main or ancillary services, and related to the type of contract requested by the customer; b) management of payments (with their treatment - by law - of the payment details, including the identity of the credit card if such payment instrument is selected by the customer) of the requested services and possible economic burdens of extra services, based on the provisions of the terms and conditions of rental and / or other specific terms and conditions published on the site or otherwise made available to the customer; c) the fulfillment of legal, accounting, tax, administrative and contractual obligations associated with relationships in place, or to constitute, or to providing of the services requested; d) management of relationships with third parties for purposes related to insurance relationships or to relationships - in the broadest sense - related to administrative practices or laws affecting vehicles (eg: changes in ownership, etc) or to relations with suppliers (eg: garages, etc) e) management of relationships with public authorities and third parties bodies for purposes connected to particular requests, the fulfillment of legal obligations or particular procedures (eg: re-notification of the actual offender verbal complaint of violation of the Highway Code); f) elaboration of measures for the protection against the risk of credit, including activities aimed at identifying the customer, ascertain the veracity of the data provided, its economic reliability / solvency, even during the relationship; g) Provide measures related to the protection of company assets (eg fleet); h) preparation of measures for the protection of the staff of the Company against any acts carried out by customers which are unlawful or fraudulent or otherwise in violation of the agreement or the law or the principles of good practice in trade relationships, including the activities and treatments designed to identify the person responsible for such acts and to retain the information for subsequent determinations of judicial or of other kind protection of the company; i) the collection, storage and processing of your data to make statistical analyzes in anonymous and / or aggregate, with no possibility of identifying the user, aimed at verifying the quality of services offered;

A.1. Communication and dissemination of personal data for the achievement of the primary purposes of the processing

In all cases described above - and according to the applicable rules of the Privacy Code - Ellepi may disclose personal information outside all subjects whose intervention is necessary in the treatment according to the services you request. In addition, for the pursuit of the primary purposes, the data may be disclosed to any other third party outside where no communication is required under the law or to comply properly with Ellepi in contractual services, pre or post-contractual (ex. assistance technical and support request or send a complaint presented by the customer against a third party supplier of goods and / or services related to the rental relationship). With reference to the scope of disclosure of personal data, we inform you that the information given can be communicated to, or may be aware of, the following subjects or categories of persons: 1. police, armed forces and other public authorities, for the fulfillment of obligations of law, regulations or legislation. In this context, are included law communications of the prosecuting authorities - under the provisions of article 126 C.d.s. and the Interior Ministry Circular no. 300 / A / 1/44248/109/16/1 of 12 August 2003, as amended following the judgment of the Constitutional Court 27/2005 (and including all subsequent amendments and supplements) - in case you need to re-notify or cause thirds to re-notify (in cases such as the re-notification made by third parties with which Ellepi has lease agreements of vehicles - of these companies owned - that are then hired by Ellepi to its customers) to your person sanctions imposed as a result of breach of rules of the highway code during the use of a vehicle showing the registered holder of Ellepi, and in which you are found to be the actual driver; 2. associated and / or controlled by the firm companies as well as parent companies (possibly based abroad), as well as companies, consortia and / or other legal entities in which companies participate as a partner; 3. consultants and / or Company partners, including companies or other entities with which exist agreements or contracts for the rental of vehicles subsequently intended for use by employees or other kind of society or entity. 4. the competent insurance companies for settling claims; 5. to companies, organizations, consortia and associations engaged in the protection of credit activities; to companies and individuals contractually tied to companies performing accidents’ management activities. Even in the case of communication / data transfer abroad, its treatment will be in full compliance with the requirements of Art. 42-45 of the Code, the European Union Directive n. 46/95 / EEC for the transfer within the EU, of the applicable general authorizations relating to the transfer abroad of personal data to non-European Union third countries. It may happen that, in relation to specific activities related to the execution of the rental agreement (eg claims management), the Company may proceed with collection and processing of sensitive data as defined in Article 4, paragraph 1, letter . (D) of the Code. In particular, Ellepi may proceed to the processing of health data or disclosing the state of his health. In such cases, it requires your written consent, we inform you that Ellepi will proceed to the processing in full compliance with the code and the respective general authorizations of the Guarantor applicable to the processing of sensitive data. Your sensitive data will not be disseminated in any way, they may be disclosed only to the following categories of persons: 1. police, armed forces and other government agencies, for the exclusive fulfillment of obligations of law, regulations or legislation, cases in which Article 26 of the Code excludes the obligation to acquire the prior consent of the interested one; 2. competent insurance companies for settling claims; 3. companies or entities contractually bound to Ellepi performing accidents’ management activities. Under Article 13, paragraph 1, letter d) We also inform about the subjects or categories of persons to whom the personal data may be communicated or who can get to know, for the same purposes specified here, as data processors or persons in charge: employees of the Company, in charge of external treatment operating at the rental stations in the territory , managers and web site managers www.ellepirental.com . Finally, your personal data will not be diffused, except in cases provided by law.

B. Purpose of the secondary processing of personal data for purposes of a promotional nature, advertising and marketing

The personal data collected may also be processed, both in print mode (ex: filling out forms, coupons and paper similar in physical premises of the Company and subsequent use in electronically on the website) for the following purposes that are specified below as requested by the General Authority Provision of 4 July 2013 laying down the lines contrast with spam Guide: a) business promotion, b) advertising. Through the granting of consent to treatment for Marketing Purposes,that person specifically takes note of such promotional and expressly authorizes, once consented according to the procedures, commercial and marketing proposals in the sense of the treatment side ,in accordance with art. 130 of the Code of privacy because the company deemed to employ means for treatment for Marketing Purposes such as email. With reference to the sending of newsletters by e-mail to which you may agree, we inform you that the electronic content of these promotional communications may be assisted by software (such as cookies) able to make Ellepi aware about some parameters like for example: the moment of the opening of the Newsletter, the newsletter pages viewed, links clicked within the newsletter, links to the sites of the Company directly from the newsletter. These parameters, which do not constitute profiling of the recipient, are intended to make Ellepi aware about certain statistical data regarding the reservation of services from multiple sources. Paying therefore the optional consent, the person concerned takes specifically acknowledges and allows such additional, possible secondary treatments. In any case, even if the person concerned has given consent to authorize Ellepi to pursue all the objectives , will remain free at all times to withdraw, without any formality by sending a clear notice with that meaning to Ellepi at the email:info@ellepirental.com Following the receipt of such request for opt-out, Ellepi will promptly proceed with the removal and deletion of data from the database used for the for Marketing Purposes treatment and inform for the same cancellation purposes any third party to whom the data have been communicated. The mere receipt of the cancellation request will automatically be worth confirming the cancellation.

C. Using technology to capture information stored in the user terminal equipment ("Cookies")

With regard to transactions on the site of the SO-CALLED cookies or similar technologies, please review the specific Privacy Cookies.

D. Navigation data

The computer systems and software procedures aimed at operating the site, acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested subjects, but by their real nature could, through processing and associations with data held by third parties, identify users. In this category of data are included IP addresses or domain names of computers used by users who connect to the site, the URI (Uniform Resource Identifier) of requested resources, time of request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code indicating the status of the response from the server (successful, error, etc..) and other parameters regarding the operating system and the user’s computer system. This data is used only to obtain anonymous statistical information about the site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical crimes against the site except for this possibility, the data on web contacts are not stored permanently, unless the user requests (eg: access to the Website pages that list the services used, the required information, etc).

E. Type of personal data subject to processing

Being understood that "personal data" means "any information concerning a natural person, identified or identifiable, even indirectly, by reference to any other information including a personal identification number" and that "sensitive data" means " personal data revealing racial or ethnic origin, religious beliefs, philosophical or other beliefs, political opinions, membership of parties, unions, associations or organizations of a religious, philosophical, political or trade union membership and personal data disclosing health and sex life, "the Company informs of the following. As part of the commercial relations with the Company there may be a processing of personal data falling into the category of "sensitive" data referred to in Articles 4, paragraph 1, letter d) and 26 of the Privacy Code. In any case, beyond the possibility of derogation under Article 26, paragraph 4 of the Code, such data may be processed only with the written consent or equivalent ("equivalent" agreement is also the expression of will on- online through procedures such as clicking the type buttons web pages "agree", "Send", etc or check boxes or boxes next to the word "agree", etc) concerned and in compliance with the General Authorizations of the Guarantor to the processing of data. In particular, in addition to request it from time to time on written or equivalent consent, our activities are previously authorized by General Authorizations 2, 4 and 5 in force in the reference year. The purposes of the processing of sensitive data arehy related to the rental relationship management (processing of data revealing racial or ethnic origin in the case of indicating the name of the foreign customer who hire a vehicle, processing of medical data in the context of management procedures for claims involving personal injury, processing of data related to a particular state of the driver in the field - for example - of verbal dispute notified to the Ellepi for breach of the Highway Code rules relating to the overcoming of the BAC to the guide). In other cases, the processing of sensitive data can be implied by particular contractual relationships, as in the case of resale of a vehicle subject to a disability. In such cases, for example, the data controller in order to evaluate the different types of disabilities eligible for tax benefits (VAT reduced to 4%, road tax, etc.) should always view the sensitive data indicated on the health certificate (disability certificate, the handicapped, etc.) showing medical history and conditions of the customer-buyer and maintains in its records - for the law - all paperwork, to establish, in the case of verification or objection by the Agency Offices, the legality of the conditions for applying the facilities. In such cases, we inform you that the treatment will be in compliance with the instructions contained in the Privacy Authority Provision of 16 February 2011 entitled "Privacy: more protected for the disabled who buy a car." As part of the commercial relations with the companies could then also be a processing of personal data which are included in the data category of "judicial" in Articles 4, paragraph 1, letter e) and 27 of the Privacy Code, with particular reference to data disclosing quality or situations relevant under the criminal law. Under Article. 27 of the Privacy Code, the processing of judicial data by private entities is allowed only if expressly authorized by law or by order of the Guarantor, the latter represented by the General Authorisation No. 7 (in force in the reference year) to the processing of judicial data. Referred to in Chapter IV, paragraph 1, letter a.3) General Authorisation No. 7 on the processing of judicial data of the purposes of the processing of authorized judicial data are as follows: a) establish liability in relation to the claims or events relating to human life; b) cooperation in establishing of concrete risk situations for the proper exercise of insurance activities, as regards offenses directly related to the same activity; c) to exercise or defend a right also to a third party before the courts, including administrative or arbitration and conciliation procedures in cases provided by the laws, community laws, regulations or collective agreements, provided that the right to assert or defend is not overridden by the data subject's one and the data are processed exclusively for such purposes and for no longer than is necessary for its pursuit. In any case, the Ellepi will - if applicable - the only essential data for the purposes for which it is authorized, and that can not be fulfilled on a case by case basis, by processing anonymous data or personal data different nature.

F. Indication by the individual to personal data of third parties

You acknowledge that the possible indication (for example in the form filing, even paper, such as rental contracts and / or online forms even on this site) of personal data and to any third party different from the person concerned is a processing of personal data with respect to which he poses as an independent owner, assuming all the obligations and responsibilities under the Privacy Code. In this sense, you are granting to Ellepi that any data to third parties that will be so designated by the user (and which will consequently be treated as if the third party had provided their informed consent to the treatment) has been acquired by the user himself in full compliance with the Privacy Code. You give the widest point on the indemnity with respect to any dispute, claim, demand compensation for damage from handling, etc that were to be sent to Ellepi by any third party concerned because of the supply of data provided by the user in violation of the rules on the protection of personal data applicable.

G. Owner and treatment

The identification details of the Controller of Ellepi as of the data of the treatment (in some cases the Company can be co-owner of the data and treatment are as follows: Ellepi autonoleggio SNC. Registered Office: Via tavolara 16 07026 Olbia-SS- P.iva 02679090908 PEC: ellepirental@pec.it

TEXT ARTICLE 7 OF THE CODE OF PRIVACY

Art. 7 (Right of access to personal data and other rights) 1. You have the right to obtain whether confirmation or not confirmation of personal data concerning you, even if not yet recorded, and their communication in intelligible form. 2. You have the right to obtain information: a) the origin of personal data; b) the purposes and methods of treatment; c) the logic applied in case of processing with the aid of electronic instruments; d) The identity of the owner, manager and the designated representative under Article 5, paragraph 2; e) subjects or categories of persons to whom the data may be communicated or who can learn about them as appointed representative in the State, managers or agents. 3. You have the right to: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data that is not needed to be kept for the purposes for which the data were collected or subsequently processed; c) certification that the operations in letters a) and b) have been notified, as also related to their contents, of those to whom the data were communicated or disclosed, except where such compliance is impossible or involves a manifestly disproportionate to the protected right. 4. You have the right to object, in whole or in part: a) for legitimate reasons, the processing of personal data, pertinent for collection purposes; b) the processing of personal data for purposes of sending advertising materials or direct selling or for carrying out marketing research or commercial communication.

Cookies

The Ellepirental.com website makes limited use of cookies. The services used are: - Google AdWords to offer a better service and offers relevant to users but does not store any personal data or credit card information in this data. - Google Analitycs. Statistics site, for example calculates the number of visitors, what kind of technology they are using (for example Mac or Windows), how much time they spend on the site. All data is collected in an anonymous and aggregated form, ie it is not possible to access the data disaggregated at IP level. For the operation of cookies in Google Analytics you can consult the official documentation provided by Google by clicking on this link https://www.google.com/intl/en_uk/analytics/learn/privacy.html