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Privacy Policy

pursuant to art. 13 of the EU Regulation 2016/679 (“GDPR”)

(version: January 2024)

Octo Telematics S.p.A., with registered office at Via Vincenzo Lamaro, 51, 00173 – Rome, VAT n. 03499230963 (“Octo”), in its capacity as the data controller (hereinafter, the “Data Controller”), will process your personal data (“Personal Data”) pursuant to this Privacy Policy, in accordance with the provisions of Regulation (EU) No. 679 of April 27, 2016, the General Data Protection Regulation (hereinafter the “GDPR” or the “Regulation”) as well as by the Italian Legislative Decree n°. 196/2003 – as amended by Legislative Decree 101/2018 – containing the “Privacy Code” (collectively, the “Applicable Legislation on Data Protection”).

Data Protection Officer

The Data Controller has appointed a Data Protection Officer (“DPO”). Please find below the contact details:

Octo Telematics S.p.A. Via Vincenzo Lamaro 51 00173 Rome, Italy

E-mail: dpo@marco-zappiaoctotelematics-com

Type of Data and Purpose of Processing

For monitoring the satisfaction index of the services provided to you by Octo, Octo has created an anonymous survey in which you can voluntarily participate. For the purposes of the survey, Octo as Data Controller will temporarily process the following information referring to you:

  • first and last name;
  • e-mail;
  • telephone number;
  • reason for the call.

Processing of Personal Data, for the purposes of this Privacy Policy, shall mean any operation or set of operations, performed or not with the aid of automated processes and applied to the Personal Data, in accordance with the provisions of the Applicable Legislation on Data Protection. We inform you that the Personal Data referred to you will be processed manually and/or with the support of computer or telematic means.

Legal Basis for Data Processing

The Data Controller will process your Personal Data exclusively upon the provision of your free and informed consent in accordance with Article 6, paragraph 1, letter a) of the GDPR.

Your Personal Data will be processed by the Data Controller exclusively to send you the anonymous survey.

Therefore, the provision of your Personal Data is necessary to enable you to receive and complete the survey for the evaluation of the quality of Data Controller’s services and to enable its improvement.

We will not use your Personal Data for other purposes than those described in this Privacy Policy, unless your consent has been obtained and you have been informed in advance, in accordance with the Applicable Legislation on Data Protection.

We also inform you that the above questionnaire will be carried out completely anonymously and that the Data Controller will have evidence of the results only and exclusively in anonymous and aggregated form.

Data Recipients and Thid Parties

For the purposes stated in this Privacy Policy, your Personal Data may be shared with:

a) employees and collaborators of the Data Controller who are in charge of data processing or companies’ part of the Octo Group;

b)   service providers (“Third Parties”), in their capacity as Data Processors, that perform activities on behalf of the Data Controller in compliance with the requirements of the Applicable Legislation on Data Protection.

OCTO will process Personal Data only in countries within the European Economic Area and will not transfer such Personal Data to countries outside the European Economic Area, unless such transfer is based on the prior written consent of the data subject or other appropriate measures, including (a) the adoption of the EU Commission’s Standard Contractual Clauses; (b) in the presence of adequacy decisions adopted by the European Commission inherent to the countries to which the Data is transferred; (c) binding corporate rules adopted by the OCTO Group or Data Processors or Sub-Processors designated by Octo.

Data Retention Period

Your Personal Data will be processed for as long as necessary to fulfill the purposes stated in this Privacy Policy and will be retained in accordance with the principles of proportionality and necessity. Except for specific necessities, Octo will retain your Personal Data for 15 days after being aware of the completion of the survey (barring disputes, requests by competent Authorities or applicable legal provisions).

At the end of data retention period, the Personal Data will be deleted or anonymized.

Data Subjects Rights

Pursuant to Articles 15 to 21 of the GDPR, in relation to the Personal Data disclosed, you have the right to:

  • obtain from the controller confirmation as to whether or not your personal data are being processed, and, where that is the case, access such data and obtain for a copy in an intelligible form;
  • ask for information on the methods, purposes and means for processing the personal data, including, if the processing is carried out through automated means, the logic applied;
  • obtain information and identification details of the Data Controller and data processors;
  • obtain the updating, rectification or integration of your personal data;
  • obtain the limitation, cancellation, anonymization or blocking of the personal data;
  • object, for legitimate reasons, to the processing of your personal data;
  • freely withdraw the consent to the processing of personal data at any time;
  • receive in a structured, commonly used and machine-readable format your personal data, including for the purpose of transmitting them to another data controller (data portability);
  • lodge a complaint with the Data Protection Authority.

Except as noted above regarding the possibility of lodging a complaint with the Data Protection Authority, you may exercise your rights by sending an e-mail to or by regular mail to the Data Controller’s address.

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