This Privacy Notice explains how personal data (“Data”) provided by you to – and collected by – CNH Industrial Italia S.p.A. and FCA Italy S.p.A. (respectively “CNH Industrial” and “FCA” or, collectively, the “Companies”) through this website will be handled in compliance with applicable laws and regulations. CNH Industrial and FCA, each one in the limit of its own sphere of competence and responsibility, are committed to protecting and respecting your privacy.
- HOW YOUR DATA IS OBTAINED
Data that are provided by you and that may be collected, processed and stored respectively by each Company are the following:
- Data provided by you in order to receive information about the project TechPro2 (the “Project”) such as identification, contact or professional information;
- Browsing data (e.g. IP address, location - country -, information on pages visited within this website, access time on this website, navigation time on each page, clickstream analysis. This Data will be used for no other purposes than improving your browsing experience on this website. Companies do not link this information to specific users);
- HOW YOUR DATA IS USED
Data may be processed by each Company for the purpose of fulfilling your request for information aimed at participating to the Project as well as improving your user experience while browsing this website, on the basis of the legitimate interest of the Companies in promoting the Project.
Each of the Companies autonomously collects, processes and stores Data into their own systems, in order to reply to the requests regarding the Project they respectively promote and in the limit of their own spheres of competence.
Data may be processed electronically within IT systems, and manually, in paper form. Data will be processed and stored for its whole lifecycle, ensuring security and confidentiality of the same in compliance with principles of fairness, lawfulness and transparency and in accordance with the provisions of applicable laws and regulations.
- CONSEQUENCES OF FAILURE TO PROVIDE DATA
Submitting Data is never mandatory. However, not providing Data that is necessary in relation to the information required and that is marked as mandatory may prevent the Companies from answering to your questions about the Project.
- HOW YOUR DATA IS SHARED
Data may be shared and communicated to selected institutes, subsidiaries and affiliates of the CNH Industrial Group or of the FCA Group, trusted external parties, service providers, authorized dealers and distributors and business partners, based in and outside the European Union, which are under specific contractual obligation and may use it solely for the fulfillment of the purposes listed above.
Data may be communicated to third parties to comply with legal obligations, to respond to order of Public Authorities or to exercise our rights before judicial authorities.
- HOW YOUR DATA IS TRANSFERRED
In order to perform Data processing activities as detailed above, Data may be transferred in countries outside of the European Economic Area (EEA), including storing such Data in digital or physical databases managed by entities acting on our behalf. Database management and Data processing are limited to the purposes of the processing and are carried out according to applicable data protection laws and regulations.
In case Data are transferred outside of the EEA, the Companies will use any appropriate contractual measures to guarantee adequate protection of the Data, including – among others – agreements based on Standard Data Protection Clauses adopted by the EU Commission applicable to the transfer of personal data outside the EEA.
In addition to the adoption of legitimate mechanisms for the data transfer outside the EEA, the CNH Industrial Group’s affiliates and subsidiaries in the U.S. participate to the Privacy Shield program and, therefore, are also committed to act in compliance with the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks and the CNH Industrial Privacy Shield Policy, available here: https://www.cnhindustrial.com/en-us/governance/policies_and_guidelines/Pages/corporate_policies.aspx
- HOW YOUR DATA IS RETAINED
The Companies maintain Data in their own systems and archives for as long as necessary to pursue the purposes described in this Privacy Notice taking into account, when applicable, legal and contractual requirements.
When Data is no longer necessary for the purposes for which it is processed, Data is deleted or kept in a form which does not permit the identification of data subjects, provided that FCA and CNH Industrial are not legally required or permitted to hold such Data. The Companies may continue to store Data for a longer period, as may be necessary to protect our interests related to potential liability connected to the provision of the services or products or the processing of Data.
- DATA CONTROLLERS AND DATA PROTECTION OFFICER
CNH Industrial Italia S.p.A. with corporate office in Via Plava 80, 10135 Torino is the Controller for the Data it collects, processes and stores in the framework of this Privacy Notice and only in relation to the projects it promotes.
FCA Italy S.p.A. with corporate office in Corso G. Agnelli 200, 10135 Torino is the Controller for the Data it collects, processes and stores in the framework of this Privacy Notice and only in relation to the projects it promotes. You can contact the FCA Data Protection Officer team at the email address email@example.com.
- YOUR RIGHTS REGARDING YOUR DATA
You may exercise your rights respectively towards the two autonomous Controllers as defined by applicable laws and regulations, among these:
- Right of access: right to obtain from the Controllers confirmation as to whether or not your personal information is being processed, and, if so, to demand to gain access to your personal data.
- Right to rectification: right to obtain from the Controllers the rectification of your personal data that you may consider inaccurate and to have incomplete information being completed, including by means of providing a supplementary statement.
- Right to erasure: right to obtain from us the erasure of your personal data without undue delay, where the request is made in accordance with the applicable laws and regulations.
- Right to object to data processing: right to object at any time to the processing of your personal data based on the legitimate interest of the Controllers.
- Right to limit the data processing: right to obtain from the Controllers a limitation on the processing activities when the accuracy and the precision of personal data is disputed, and for the time necessary for the Controllers to verify the accuracy of personal data.
- Right to data portability: right to receive the personal data you provided to the Controllers in a structured, commonly used and machine-readable format. You also have the right to transmit that data to another data controllers without hindrance from the Controllers, especially following these conditions: the processing is based on consent or on a contract and the processing is carried out by automated means.
- Right to make a complaint: without prejudice to any other administrative or judicial dispute, if you believe the data processing has been carried out illicitly or not compliant with applicable laws and regulations, you have the right to raise a complaint with the Supervisory Authority of the Member State in which you reside or work habitually, or of the State where any breach has occurred.
You can exercise the abovementioned rights by contacting CNH Industrial as follows:
- Filling the online form you can find here: https://privacy.cnhindustrial.com/en-us/footer/Pages/form.aspx;
- Writing an email to firstname.lastname@example.org;
- Sending a letter to the Controllers at the address indicated in the section 7 of this Privacy Notice, specifying “for the attention of Privacy Compliance”;
You can exercise the abovementioned rights by contacting FCA Italy S.p.A. writing an email to email@example.com.
Should you send us a request, the Companies may need to obtain additional personal information from you to verify your identity and contact you, if necessary. This information, together with other Data the Companies already withhold, will then be processed to meet your request, as required by applicable law. Where necessary, certain information may be transferred to other companies within or outside the CNH Industrial Group and FCA Group that act as data processors of your Data, in order to meet your request. Your Data will be processed for the necessary amount of time to evaluate and handle your request, after which your Data will be archived for a suitable time period allowing us to demonstrate that the request has been handled correctly and timely.
- THIRD PARTY WEBSITES
Third party websites accessible from this website are under the third party responsibility.
The Companies will not be liable for any requests and/or provision of Data processed through these websites.
- UPDATE TO THIS PRIVACY NOTICE
This Privacy Notice was updated in May 2021. The Companies reserve the right to partly or fully amend the Privacy Notice or to update its content from time to time to reflect changing legal requirements or our processing activities. Any update will be published on this website and it will be effective upon posting. You are encouraged to periodically review this Privacy Notice to learn how your Data are protected.