Information pursuant to Art. 13 EU Reg. no. 2016/679

Dear user, the company Repower Vendita Italia S.p.A. – VAT: 13181080154 - with registered office in 20129 Milan (MI), Via Giulio Uberti no. 37, in the person of its legal representative, as data controller (hereinafter referred to as "Data Controller") hereby informs you that, pursuant to Art. 13 of EU Reg. no. 2016/679 (hereinafter referred to as "GDPR"), it wishes to process your personal data in accordance with the applicable regulations and as further specified below.

  1. Purpose of the Processing and categories of data processed:
    The Data Controller will process personal identification and contact data (by way of example only: first name, last name, telephone numbers, e-mail, etc., hereinafter also "Data"), freely communicated by you at the time of registration to the "LAMBRO" App.

  2. Purpose, legal basis of the processing and consequences of the non-disclosure of Data:
    The aforementioned Data will be processed lawfully and fairly for the purposes described below.

    1. Management of the "Dashboard" service, both pre-contractual and contractual.
      The data provided by you will be processed by the Controller to allow you to use the service, having as its object the collection of telemetric data of the Lambro used by you (in particular, battery status, kilometres travelled, average speed, etc.) and therefore to follow up on your requests and proceed to carry out all the consequent operations, among which are also those technical and administrative activities connected to contractual obligations.
      This need represents the legal basis that legitimizes the consequent processing pursuant to Article 6 co.1 lett. "b)" of the GDPR. In the event of failure to provide it, the Data Controller may be unable to provide the services requested.
    2. In addition, only with your consent, you will be able to use a geolocation service functional to the planning of a route.
      This consent represents the legal basis legitimizing the consequent processing pursuant to Article 6 co.1 lett. "a)" of the GDPR. If consent is not given, the Data Controller may find itself unable to provide the services requested.

  3. Method of processing:
    The processing of your Data is carried out by means of the operations indicated in art. 4 n. 2) GDPR and precisely:
    collection, recording, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, comparison or interconnection, limitation, deletion or destruction of the Data.
    Your Data is subject to both paper and electronic and/or automated processing.
    The Data acquired shall be processed in full compliance with the law, as well as with the principles of lawfulness, correctness, transparency, non-excessiveness and protection of your confidentiality and your rights, with particular regard to the minimum security measures provided for as regards their processing by means of computerized, manual and automated tools with logics strictly related to the purposes indicated above and in any case in such a way as to guarantee the security and confidentiality of the Data.
    The processing of Data of underage subjects is not envisaged.

  4. Data storage period::
    The Data Controller shall retain the Data in compliance with local laws for as long as necessary to fulfil the above mentioned purposes and to satisfy its legitimate business interests, legal obligations or to establish, exercise or defend legal rights. Once the need to retain the Data for these purposes has passed, the Data will be securely deleted. For further information on the retention periods, please refer to the extract from the Personal Data Retention Policy of Repower Vendita Italia S.p.A. at the following link.

  5. . Categories of recipients of personal data:
    Your Data may be made accessible for the purposes described above:

    • to employees and consultants of the Controller in Italy and possibly also abroad, in their capacity as data processors and/or sub-controllers or persons authorised to process the data pursuant to the GDPR, and/or persons with specific functions and duties pursuant to Article 2-quaterdecies of Legislative Decree no. 196/2003;

    • to other Repower Group companies (parent companies, subsidiaries and/or associates) both in Italy and possibly abroad, and to their employees and associates (e.g. for administrative and accounting purposes);

    • to third party companies or other subjects carrying out outsourcing activities on behalf of the Controller, as data processors, including suppliers (e.g. companies dealing with app maintenance and bug fixing) or subjects in charge of carrying out accessory or instrumental services for the above-mentioned purposes, with which the Controller enters into appropriate agreements.

    The Controller also reserves the right to make personal data accessible to certain third parties, including: legal entities, law enforcement agencies and parties in compliance with legal obligations to provide information or claims; police forces, army and other public administrations, for the fulfilment of obligations provided for by law, regulations or EU legislation.
    In the event that such parties are established in countries outside the EU, the Data Controller ensures that the transfer of Data outside the EU will take place in accordance with the applicable legal provisions.

  6. Transfer of Data
    The Data are stored on servers located within the European Union. In any event, it is understood that the Data Controller is also entitled to transfer the Data with the Swiss parent company Repower AG and/or to transfer the Data to other nonEU countries, should this become necessary; in this case, the Data Controller hereby assures that the transfer of the Data outside the EU will take place in compliance with the applicable legal provisions in force, applying all the necessary safeguards to the aforesaid transfers.

  7. Rights of the data subject
    As data subject, you have the rights set out in Articles 13(2)(b), (c) and (d), 15, 16, 17, 18, 19 and 21 GDPR and specifically the rights to:

    • obtain confirmation of the existence or otherwise of Data concerning you, even if not yet recorded, and their communication in intelligible form;

    • obtain an indication of: a) the origin of the Data; b) the purposes and methods of processing, as well as the relevant legal basis; c) the logic applied in the event of processing carried out with the aid of electronic instruments; d) the identification details of the Data Controller, the Data Protection Officer and any representative designated pursuant to Article 13, paragraph 1 of the GDPR; e) the subjects or categories of subjects to whom Data may be communicated or who may become aware of it in their capacity as designated representatives in the territory of the State and as data processors;

    • obtain: a) the updating, rectification or, where interested therein, the integration of the Data; b) the cancellation, transformation into anonymous form or blocking of personal data processed in breach of the law, including those the conservation of which is not necessary in relation to the purposes for which the data were collected or subsequently processed; c) confirmation that the operations as per letters a) and b) have been notified, also related to their content, to the entities to whom or which the data were made available, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected;

    • object, in whole or in part: a) on legitimate grounds, to the processing of Data concerning him/her, even if pertinent to the purpose of collection; b) to the processing of Data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys, by means of automated calling systems without the intervention of an operator, by email and/or by traditional marketing methods via telephone and/or paper mail. It should be noted that the data subject's right to object, as set out in point b) above, for direct marketing purposes by automated means extends to traditional marketing methods and that, in any case, the data subject's right to object may also be exercised in part. Therefore, the data subject may decide to receive only communications by traditional means or only automated communications or neither of the two types of communication;

    • where applicable, he/she also has the rights referred to in Articles 16 - 21 of the GDPR (Right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to complain to the Data Protection Authority;

    • to withdraw at any time any consent that may have been given.

    As far as the right to data portability is concerned, the data subject may request to receive or transfer his or her personal data held by the Controller in a commonly used and readable structured format, for further personal use or to provide them to other data controllers.
    With reference to the contractual relationship, the data that may commonly be subject to portability are personal and contact data.

  8. Procedures for exercising rights
    You may exercise your rights or make a request at any time by sending: a registered letter with return receipt to Repower Vendita Italia S.p.A. – VAT. 13181080154 - with head office in 20129 Milan (MI), Via Giulio Uberti no. 37; or an e-mail to:
    The deadline for the reply is one month. The aforesaid deadline may be extended to two months in particularly complex cases: should this occur, within one month the Data Controller shall provide a notice of the reasons for the extension. The Data Controller has the right to request the information necessary to identify the applicant.
    In general terms, the exercise of the rights is free of charge, except in the case of manifestly unfounded or excessive requests, for which the Controller may reserve the right to request a reasonable contribution to the data subject based on the administrative costs to be incurred.
    In termini generali l’esercizio dei diritti è gratuito, salvo il caso di richieste manifestamente infondate o eccessive, per cui il Titolare può riservarsi la facoltà di richiedere all’interessato un ragionevole contributo spese basato sui costi amministrativi da sostenere.

  9. Data Controller, Data Protection Officer and Categories of Data Processors
    The Data Controller is the company Repower Vendita Italia S.p.A. - VAT: 13181080154 - with registered office in 20129 Milan (MI), Via Giulio Uberti n. 37, in the person of its legal representative. The Data Protection Officer may be contacted at the following e-mail address:
    The list of categories of Data Processors is kept at the registered office of the Data Controller.

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