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Privacy Policy

Scope

  1. This page contains our privacy policy (“Privacy Policy”) and explains how we use and protect the personal information of the users (“Users”) of this website www.octotelematics.com (“Website”). 
     
  2. This Privacy Policy applies solely to the Website run by Octo Telematics [S.p.A.] (“OCTO”) and does not cover any other websites visited by Users via links.
     
  3. This Privacy Policy complies with the requirements laid down under art. 13 of the Regulation no. 679/2016/EU (General Data Protection Regulation – “GDPR”) and, as amended or replaced from time to time, the Privacy and Electronic Communications Directive 2002/58/EC, together with the equivalent legislation of any other applicable jurisdiction and all other applicable law, regulations and codes of conduct in any relevant jurisdiction relating to the protection or processing of personal data and privacy, including (1) the resolutions of the data protection Authorities in any relevant jurisdiction and, in particular, of the Italian Data Protection Authority (Garante per la protezione dei dati personali); and (2) the resolutions and opinions of the European Data Protection Supervisor, the Working Party established under Article 29 of the EU Data Protection Directive 95/46/EC (and/or the European Data Protection Board to be established under Article 68 of the GDPR).


Controller.  Data Protection Officer

  1. The “controller” (within the meaning of Article 4(7) of the GDPR) is: Octo Telematics S.p.A., with registered office at  Via Lamaro, 51 00173 Roma – Italy, Tel.: +39 (06) 726 53 41 - Fax: +39 (06) 729 01 45, email privacy@octotelematics.com.
     
  2. The Users may also contact OCTO’s Data Protection Officer, also in order to exercise their data protection right as detailed in paragraph 8, at the following contact details:

Mr. Filippo Verna
Viale dei Parioli, 87 | 00197 Roma
Tel. +39 06 9934 0531
Fax +39 06 4522 0656
Email: dpo@octotelematics.com 
Website: www.vega-law.com

Modalities of the processing.  Sharing of personal data

  1. Personal data relating to the services provided by this Website are processed through paper and electronic means by OCTO’s personnel (technical staff) expressly authorized.  Personal data are stored on OCTO’s proprietary servers in Italy.  No information deriving from the web services is passed on or disclosed to third parties acting as autonomous controllers.
     
  2. We will never share Users’ personal data with any third party that intends to use it for direct marketing purposes, unless we have specifically informed Users and the same Users have given us specific consent to do this.
     
  3. We may share Users’ personal data with:
    a) companies of the OCTO Group located in the EU;
    b) third party suppliers located in the EU;
    c) other third parties as part of a corporate transaction such as a merger or sale of assets; public authorities and entities, for legal and tax purposes, or, possibly, in order to protect the business as well as the customers, staff or suppliers of OCTO. In some cases, OCTO may be requested to communicate the personal data in accordance with the legitimate orders from public authorities and to meet the national security requirements or comply with statutory provisions.

In cases under para a), b) and c), these companies must abide by our data privacy and security requirements and are not allowed to use personal data they receive from us for purposes other than those listed in this Privacy Policy.


Browsing data. Cookies

  1. In the normal course of operation, the information systems and software procedures involved in the operation of this Website acquire certain items of personal information, the transmission of which is implicit in the use of internet communication protocols.
     
  2. The information in question is not collected in order to be associated with specific Users, but could by its very nature allow the identification of these Users as a result of processing and association with information held by third parties.
     
  3. This category of information includes IP addresses or domain names of computers used by Users who connect to the Website, addresses of the required resources in URI (Uniform Resource Identifier) notation, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server's response (successful, error, etc.) and other parameters pertaining to the User's operating system and information technology environment
     
  4. The above information is used solely for the purpose of (a) enable Users to move around it and to use its features (technical cookies). Without these essential cookies, we may not be able to provide certain services or features and our Website will not perform as smoothly for Users as we would like; and (b) obtaining anonymous statistical information (analytics cookies) on the use of the Website.  The information could be used to ascertain responsibility in the case of information technology offences committed against the Website.
     
  5. The above cookies are placed directly by OCTO (so called “first party cookies”) or by a third party (so called “third party cookies”), as detailed below.
     
  6. Our Website uses technical and analytics cookies and does not use profiling or advertisement cookies, i.e. those used to track a User’s navigation online and create a profile based on personal tastes, habits and choices, etc.   Therefore, OCTO is not required to obtain Users’ prior consent in order to install cookies.  That said, the User may deactivate first party cookies (i.e., technical and analytics) by clicking on the indicated links or, in the case of third party technical cookies, by accessing the privacy notices and – as the case may be - consent forms of such third party. Nonetheless the deactivation of such cookies could comprise the correct navigation and function of the Website.
     

TECHNICAL AND MARKETING COOKIES 

Name of the service/the party applying the cookie: 
1) 
Octo Telematics

2) Youtube
3) Youtube
4) Youtube

Name of the cookie: 
1) 
JSESSIONID (Technical)
2) GPS (Marketing)
3) VISITOR_INFO1_LIVE (Marketing)
4) YSC (Marketing)

Purpose of the cookie: 
1) 
Preserves users states across page requests.

2) Registers a unique ID to enable tracking based on geographical GPS location.
3) 
Tries to estimate the users' bandwidth on pages with integrated YouTube videos.
4) 
Registers a unique ID to keep statistics of what videos from YouTube the user has seen.

Retention: 
1) 
2 years

2) Session
3) Session

4) Session
5) 4 months

Link: 
1) NA

2) NA
3) NA
4) NA

ANALYTICS COOKIES 

Name of the service/the party applying the cookie: 
1) 
Google analytics
2) Google analytics
3) Google analytics
4) Google analytics
5) Google analytics

Name of the cookie:
1) 
utma
2) utmb
3) utmc
4) utmt
5) utmz

Purpose of the cookie:
1) 
Collects data on the number of times a user has visited the website as well as dates for the first and most recent visit. Used by Google Analytics to generate anonymous statistics.
2) Registers a timestamp with the exact time of when the user accessed the website. Used by Google Analytics to calculate the duration of a website visit and anonymous statistics.
3) Registers a timestamp with the exact time of when the user leaves the website. Used by Google Analytics to calculate the duration of a website visit and anonymous statistics.
4) Used to throttle the speed of requests to the server.
5) Collects data on where the user came from, what search engine was used, what link was clicked an d what search term was used. Used by Google Analytics to generate anonymous statistics.

Retention:
1) 
2 years

2) Session
3) Session

4) Session
5) 4 months

Link:
1) 
https://tools.google.com/dlpage/gaoptout
2) https://tools.google.com/dlpage/gaoptout
3) https://tools.google.com/dlpage/gaoptout
4) https://tools.google.com/dlpage/gaoptout
5) https://tools.google.com/dlpage/gaoptout


Information voluntarily shared by Users

  1. The optional, explicit or voluntary sending of e-mails to the addresses indicated on this Website entails the subsequent acquisition of the User’s (sender's) e-mail address, required to respond to requests, and any other personal information included in the message. Specific information summaries will be progressively reported or displayed on certain pages of this Website that may be set up to provide specific services on request.


Purposes and legal basis of the processing

  1. Personal data collected through the Website are used for the following purposes:
    a) enable Users to move around it and to use its features (through technical cookies).  In such a case, the legal basis is represented by the performance of the terms of use of the Website;

    b) obtaining anonymous statistical information on the use of the Website (through analytics cookies).  In such a case, the legal basis is represented by OCTO legitimate interest;

    c) respond to the Users’ requests sent through the contact details included in the Website.  In such a case, the legal basis is represented by the Users’ request.
     
  2. Data retention for the processing activities carried out through cookies are set out in the tables above.  For the purpose under par. 6.1, lett. c) above, personal data will be retained as long as necessary in order to answer Users’ requests.


How can Users change the cookie settings

1. By changing the settings in his/her browser, a User can decide to subject the installation of any type of cookie to his/her prior acceptance or fully prevent their installation. Please note that the setup of each browser is different and is explained in the "Help" menu of the browser.  Herein below there is a link to the most commonly used browsers’ settings:

​​​​​​​2. After altering the browser’s cookie settings, some of the website  functions may not work correctly.

​​​​​​​3. To disable cookies placed by Google Analytics,  download a plug-in specific for Users’ browser from the following website: https://tools.google.com/dlpage/gaoptout.


Users’ rights

  1. The Users, at any time and at no charge, can have and/or exercise the following rights, as specified in the GDPR:
    a) the right to be informed on the purposes and methods of the processing;
    b) the right of access;
    c) the right to obtain a copy of the data held overseas and obtain information concerning the place in which such data are kept;
    d) the right to ask for updating, rectification or integration of the data;
    e) the right to request the cancellation, anonymization or blocking of the data;
    f) 
    the right to restrict the processing;
    g) the right to object to the processing, wholly or partly, also where it is carried out through automated individual decision-making, including profiling;
    h) the right to revoke the consent to the processing of the data freely and at any time;
    i) the right to data portability, (i.e. to receive an electronic copy of User’s personal data, if the User would like to port his/her personal data to himself or a different provider);
    j) the right to limitation of the processing;
    k) the right to contact the data protection officer at the following email address: dpo@octotelematics.com;
    l) the right to lodge a complaint in front of the competent national data protection or judicial authority.

​​​​​​​In order to exercise the rights mentioned above, please use the contact details in par. 2 above.


Updates to this Privacy Policy
​​​​

1. We can modify or update this Privacy Policy also following different interpretations, decisions, opinions and orders relating upcoming data protection laws and regulations. Please look at the effective date at the top of this Privacy Policy to see when this Privacy Policy was last revised.  Any changes to this Privacy Policy will be notified in advance and will in any case be available when we post the revised Privacy Policy on our Website. If we make material chances to this Privacy Policy that expand our rights to use the personal data we have already collected from Users, we will notify Users and provide Users with a choice about our future use of the personal data.

 

Additional Definitions:
- Necessary Cookies: They help make the website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these.

- Statistic Cookies: Help website owners understand how visitors interact with websites by collecting and reporting information anonymously.

- Marketing Cookies: used to track visitors across websites, their intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.