At E-GAP S.r.l., in order to properly perform Our work, we collect and use information about You and therefore we are committed to protecting and respecting Your privacy. This Privacy Policy (hereinafter, the “Policy”), as set forth in Article 13 of the European Regulation No. 679/2016 (hereinafter, “GDPR” – General Data Protection Regulation), describes our rights with respect to the information collected that We process and the measures We take to protect Your data.
Index
1. Data Controller and useful definitions for an informed reading
2. Data Processor
3. Legal Basis of the Processing
4. Data Processing
4.1 Automatic collection of certain Data
4.2 Purposes of the Processing
4.3 Sharing of Personal Data with third parties
4.4 Transfer of Data
4.5 Data Security. Where Personal Data are stored and processed
4.6 How long do we store your Data?
4.7 Do we process your Data through an automated process?
5. Processing of Application Data sent to E-GAP
6. User rights
7. Changes to this Privacy Policy
First of all, you should know that when we talk about “E-GAP”, “us”, “our” or “we” we refer to E-GAP S.r.l., a Benefit Company, (C.F. and P. IVA 14253861000), in the person of the legal representative pro tempore, with registered office in Via Flavia, 3 – 00187 Rome, a company that deals with the development, production and marketing of innovative products or services, of high technological value, for electric mobility in cities.
E-GAP is the “Data Controller”.
When we speak of “Customer” or “User” we refer to you as the recipient of our services.
With the term “Services” and / or “Products” we mean all the products and services that we offer and that you can purchase through the E-GAP application, or through the Web platforms that we make available to you.
When we refer to “Devices” or “Computers” we mean any technological device, connected to the Net, through which you interact with Us.
Finally, when we speak of “Personal Data” or “Data” we refer both to the data that You provide us directly for the use of our services and to the data that are automatically collected, relative to Your interaction with our website and with our App.
When we refer to “Processing” we are referring to the processing of your Personal Data.
E-GAP has appointed an Internal Data Processor who can be contacted at the following e-mail address: privacy@e-gap.com.
As provided for by Article 6 of the GDPR, E-GAP processes your Personal Data only if there is a suitable legal basis provided by the applicable law and for the achievement of specific purposes. In particular, the legal basis that legitimizes the Processing of Personal Data provided by you may be:
You are under no obligation, either by law or by contract, to provide us with your Personal Data. However, for the provision of all our Services and “additional services” that we may offer you, your failure to provide and/or consent to the provision of our Services will make it impossible for us to provide the requested service, as it is dependent on the knowledge of some of your Personal Data, such as, for example, your first and last name, your e-mail address and telephone number and your location.
Where the lack of providing certain Personal Data makes it impossible for us to provide the Service or to provide you with the information you request, the Data that you will have to provide will be marked as mandatory (*Required field).
We receive and store any Data you provide to us in an informed, unambiguous, specific and free manner in connection with the Services we offer. You may choose not to provide certain Data but, if you do, you might not be able to use some of our Services.
The Personal Data you provide us through interaction with your Device on our Website, App or by contacting Customer Service are:
Please note that all the Data listed will be required to enable us to provide the Services, only if you request them.
The Personal Data we collect and use automatically are:
We use your personal information to send you direct marketing info or material by e-mail if you have accepted this option in the relevant contact form. You can decide to stop receiving marketing communications when you wish. To find out more, please also read the section on Cookie Policy.
Personal Data will be collected and processed by us for the following purposes:
In any case, E-GAP is available to clarify the specific legal basis that applies to the Processing, and in particular whether the provision of Personal Data is a legal or contractual obligation, or a requirement necessary to entering into a contract.
We do not sell your Personal Data to third parties.
However, E-GAP may disclose your Information to other E-GAP’s group companies or subsidiaries, which are subject either to this Policy or to procedures that provide protections similar to those described in this Policy.
To facilitate the efficient use of information and to provide Users with content and/or resources, the information may be disclosed to third parties.
These third party service providers have access only to the Personal Data necessary for the performance of their activities, but they may not process Data they become aware of for any other purpose. In addition, these third party service providers are required to process all Personal Data of which they become aware in accordance with this Privacy Policy and applicable laws.
In cases other than those listed above, Your Personal Data will only be shared with third parties with Your explicit consent and You will have the opportunity to choose whether or not to allow further third party communications.
Your Data may then be processed by E-GAP’s technical service providers, in particular by:
| Who? | Why? |
| Salesforce | CRM |
| Stripe | Payment solutions |
| Matomo Analytics | Audience profiling |
We do not sell your Personal Data to third parties and process them primarily within the European Union.
We process your Personal Data primarily within the European Union. If Personal Data are transferred outside the European Union, we will ensure that they are transferred in accordance with this Policy, applicable regulations and to a country that provides a level of protection at least equivalent to that provided by the GDPR.
In the course of E-GAP’s development, we may sell or buy other companies or services. In this case, E-GAP is committed to ensuring the protection of your Personal Data and includes compliance with this Policy in the conditions of implementation of the planned transaction.
We use high standards of security when processing your Data and we will take all steps reasonably necessary to ensure that your Data are processed securely and in accordance with this Privacy Policy and all persons who will be involved in processing your Data on our behalf have been trained, instructed and appointed by us to ensure that your privacy is respected.
As explained in section “4.3 Sharing of Personal Data with third parties”, we do share your Data with third party suppliers, contractors or agents, but – even when we use them – your Personal Data will remain under our control and we will ensure that they are adequately protected.
E-GAP has designed all systems through which your Personal Data are collected, stored and processed according to the highest security standards to ensure that your privacy is respected.
The software we use are Salesforce and – with respect to the methods and payment of our Services and, therefore, the management of your Credit Card Information – we use Stripe. However, despite the continuous updating of this software, nothing is absolutely impenetrable, and we cannot guarantee the inviolability of its security.
We retain your Personal Data for a period of time not exceeding that necessary for the purposes for which they have been collected and, in any case, not longer than 10 years from the termination of the contractual relationship, after which they will be irreversibly deleted or anonymized.
Payment Data are retained for a maximum of 12 months from the date of collection.
We need to keep your Data to enable you to use the Services you have requested on an ongoing basis, but also for tax and accounting purposes or – subject to your consent – for commercial purposes.
We may also need to retain your Data for a longer period if we are required to comply with legal obligations or to deal with any complaints or legal disputes or to defend ourselves against claims regarding our contractual relationship and to comply with the express provisions of this Policy.
E-GAP may process your Data through automated systems/processes and automated decision making (such as profiling) to provide you and our Customers with the Services you have requested in the best possible way. For example, in order to implement the Services in the areas with the highest demand for our intervention, we may carry out an automated profiling process to identify the areas where we should focus our efforts.
All the provisions of this Policy also apply if you would like to work with us, either by applying by e-mail or on our website in the “careers” section.
We retain the Data you send us with your application in order to assess compatibility with any job openings at E-GAP; however, without your consent to the Processing, we cannot consider any application and will not be allowed to contact you, conduct interviews or check the references you provide.
Depending on the vacancy you apply for and the different countries where E-GAP operates, your Data may be transferred to other companies in the E-GAP group who will treat your Data in accordance with this Policy and applicable laws.
We may eventually use dedicated digital platforms and technology service providers who, with your consent, will be able to access your Data in order to manage the selection process of your application.
Without prejudice to the rights set out in paragraph 6 of this Policy, we will retain your Application Data throughout the selection process and may, if unsuccessful, retain it for up to one year after the selection process has been completed.
In the context of our recruitment and depending on the job offer you are applying for and the different countries in which E-GAP operates, your Data may be transferred to other companies of the E-GAP group, in compliance with our Policy.
Pursuant to Articles 15-22 of the GDPR, to which we refer for further details, you have the right to:
To the extent that the Processing of Personal Data is based on your consent, you also have the right to withdraw your consent at any time. Withdrawal of consent shall not affect the lawfulness of any Processing based on consent given prior to such withdrawal.
With regard to direct marketing and prospecting messages, you may at any time request that these communications be discontinued by unsubscribing, via the systematic link provided in these messages.
You may also lodge a complaint regarding the processing of your Personal Data with your local Data Protection Authority.
Any material changes to this Policy will be made by posting a notice on our website or by contacting you through other channels.
Questions, comments and requests regarding this Policy are welcome and should be addressed to E-GAP S.r.l., at the following e-mail address: privacy@e-gap.com.
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E-GAP uses cookies in order to better setup the website and to give you a better browsing experience. Some cookies are necessary to make our website work properly and cannot be disabled, others are optional.
Your preferences are important to us! By clicking "Accept all" you give us permission to use all cookies. However, you can disable optional cookies by clicking "Continue without accepting". To set your preferences click on "My preferences"; you can change your choices at any time with the icon at the bottom left of the screen.
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