PRIVACY POLICY PURSUANT TO ART. 13 OF REGULATION (EU) 2016/679

In compliance with the provisions of Art. 13 of Regulation (EU) 2016/679 (hereinafter ‘GDPR’), concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, this policy is provided to those participating in the MOMI TransAlp project organised by Fedabo S.p.A. Società Benefit.

Data controller

The data controller is Fedabo S.p.A. SB, with registered office in Darfo Boario Terme (Bs) Via Prade n. 24 and email address fedabo@fedabo.it. It recognises the importance of personal data protection, undertakes to respect the privacy of users, to treat private data with caution and confidentiality and not to use it for purposes other than those specified below.

Type of personal data

Personal data is provided directly by the data subjects when joining the MOMI TransAlp project. The data processed includes: personal details, contact details and, where necessary, information related to participation in the bike test (e.g. name, surname, date of birth, residence, email address, telephone number, technical characteristics of the vehicle tested, feedback on the experience, any images or videos collected during the initiative, etc.).

Purpose of processing and legal basis

Fedabo processes your personal data for the following purposes:

1. Management of participation in the MOMI TransAlp project (logistical organisation, operational communications, insurance and safety of participants, analysis of the test experience).
2. Fulfilment of legal obligations (e.g. tax, insurance, project reporting).
3. Sending of informative and promotional communications related to MOMI TransAlp and other Fedabo projects or initiatives related to sustainable mobility or energy efficiency.

The legal bases for the processing are:

• the performance of a contract or pre-contractual measures (Art. 6(1)(b) GDPR),
• the fulfilment of legal obligations (Art. 6(1)(c) GDPR),
• the legitimate interest of the Data Controller (Art. 6(1)(f) GDPR),
• the consent of the data subject, where required for specific purposes (Art. 6(1)(a) GDPR).

Methods and principles of processing

The processing will be carried out using paper and digital methods, in compliance with the principles of lawfulness, fairness, transparency, minimisation, accuracy and storage limitation, by persons authorised by Fedabo and with the adoption of appropriate technical and organisational measures to ensure data security.

Necessity of provision

The provision of data is necessary to allow participation in the MOMI TransAlp project. Any refusal will make it impossible to participate.

Communication of data and transfer abroad

The data may be communicated to third parties involved in the project (e.g. technical partners, public bodies, insurance companies, logistics or technology service providers) exclusively for purposes related to the implementation of the initiative. Some data may be transferred to countries outside the EU only if adequate safeguards are in place in accordance with Articles 44 et seq. of the GDPR.

Where necessary, the recipients will be designated as Data Processors in accordance with Article 28 of the GDPR.

Data retention period

Personal data will be retained for the time necessary to achieve the purposes indicated above, and in any case:

• for the duration of the MOMI TransAlp project;
• for a further 10 years to comply with legal and contractual obligations, as well as for defensive purposes in the event of disputes.

Rights of the data subject

As a data subject, you may exercise your rights under Articles 15-22 of the GDPR (access, rectification, erasure, restriction, objection, data portability, withdrawal of consent) by writing to: fedabo@fedabo.it or by registered letter to the Data Controller’s registered office.

You also have the right to lodge a complaint with the Data Protection Authority.