GDPR & Cookies — Keyless®

Data Controller and Cookies

Data controller

The controller of the data collected through the website www.keyless.it (the "Site") is Keyless S.r.l., with registered office in Via Aleardi, 34 - 31100 Treviso, Italy, VAT number IT04757270261, duly registered with the Treviso Chamber of Commerce, contactable at privacy@keyless.it. The controller processes Users' personal data ("Users" or, singular, "User") in compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council ("GDPR") and applicable national data protection law.

What cookies are

A cookie is a small text file that is sent to the browser and saved on the user's device when the user visits a website. Cookies can be technical (necessary for the Site to function), analytical or profiling, depending on the purpose for which they are used.

Browsing data

The computer systems used to operate the Site acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols (for example, IP addresses of devices used by Users, request times and other parameters related to Users' operating systems). This information is not collected in order to be associated with identified individuals, but by its very nature could, through processing and association with data held by third parties, allow Users to be identified. This data is used only to derive anonymous statistical information about the use of the Site and to check its correct functioning, and is retained only for the time strictly necessary for these purposes.

Data provided voluntarily by users

The optional and voluntary sending of requests or messages through the Site and its components (hereinafter "Forms") entails the subsequent acquisition of the sender's address, necessary to respond to Users' requests, as well as any other personal data entered in the message or Form filled in.

Purposes and Legal Basis of Processing

NOTICE PURSUANT TO ARTICLES 13 AND 14 OF REGULATION (EU) 2016/679 (GDPR)
In accordance with Articles 13 and 14 of the GDPR, in relation to the personal data that Keyless S.r.l. will come into possession of, we inform you as follows.

1. Purposes of processing and legal basis

The data collected is used by Keyless S.r.l. for the following purposes, each based on a specific legal basis pursuant to Art. 6 of the GDPR:

To perform a contract to which the data subject is party or to take pre-contractual steps requested by the data subject, including handling quote requests and providing technical and after-sales support (legal basis: performance of a contract, Art. 6.1.b GDPR);
To comply with legal, tax, accounting or regulatory obligations to which the Company is subject (legal basis: legal obligation, Art. 6.1.c GDPR);
To verify and evaluate customer satisfaction levels and improve our products and services (legal basis: legitimate interest of the controller, Art. 6.1.f GDPR);
To send communications and commercial offers relating to our own products or services or those of other companies in the Keyless group, including via email and other electronic and telematic tools (legal basis: specific consent of the data subject, Art. 6.1.a GDPR, revocable at any time);
To respond to requests and messages sent via the Site's contact forms (legal basis: consent and/or pre-contractual measures, Art. 6.1.a and 6.1.b GDPR).

2. Nature of data provision

Providing the data marked as mandatory in the Site's forms is necessary to process the request; refusal to provide it makes it impossible to obtain what is requested. Providing data for marketing purposes is instead optional: refusal does not affect the provision of the requested service.

3. Data retention period

Personal data is kept for the time strictly necessary to achieve the purposes for which it was collected, in compliance with tax and accounting legal obligations and, for data processed on the basis of consent, until such consent is withdrawn. Specific technical and organizational measures are adopted to prevent data loss, unlawful or incorrect use and unauthorized access, in accordance with Art. 32 of the GDPR.

4. Recipients of the data

Personal data may be disclosed, strictly within the limits necessary for the purposes indicated above, to:

Employees and collaborators of Keyless S.r.l. authorized to process data as they operate under the direct authority of the controller;
Banking and payment institutions, for the management of collections and payments arising from the execution of contracts;
External suppliers carrying out specific tasks on behalf of the Company (e.g. bookkeeping, payroll processing, IT systems management and hosting), appointed as data processors pursuant to Art. 28 of the GDPR;
Entities, companies, consortia or associations whose purpose is the verification, analysis, recovery and insurance of credit, solely for the purpose of credit protection;
Other companies of the Keyless group, exclusively for the processing purposes indicated above and in compliance with the GDPR.

Personal data is not subject to dissemination, except with the explicit and separate consent of the data subject.

5. Transfer of data outside the European Economic Area

Should it become necessary to transfer personal data to third countries outside the European Economic Area, the transfer will take place only in the presence of an adequacy decision by the European Commission or on the basis of appropriate safeguards such as standard contractual clauses adopted by the European Commission, pursuant to Articles 44 to 49 of the GDPR.

6. Data controller

The data controller is Keyless S.r.l., with registered office in Via Aleardi, 34 - 31100 Treviso, in the person of its pro tempore legal representative, contactable at privacy@keyless.it.

Your Consent

Pursuant to Art. 7 of the GDPR, consent to the processing of personal data for marketing purposes and commercial communications is optional, specific and revocable at any time, as easily as it was given, without affecting the lawfulness of processing carried out before its withdrawal.

By ticking the relevant box in the Site's forms, the data subject gives their free, specific, informed and unambiguous consent to the processing of their personal data for the purposes indicated in this notice.

Consent to receive commercial communications

By ticking the relevant box, the data subject agrees to receive communications from Keyless S.r.l. about products and services via email, SMS, phone or other communication tools. This consent may be withdrawn at any time by writing to privacy@keyless.it.

Your Rights (Articles 15-22 and 77 GDPR)

Pursuant to Articles 15 to 22 of Regulation (EU) 2016/679, as a data subject you have the right to obtain at any time, by contacting the data controller:

Right of access (Art. 15 GDPR): obtain confirmation as to whether or not personal data concerning you is being processed and, if so, access to your data and information about the processing;
Right to rectification (Art. 16 GDPR): obtain the rectification of inaccurate personal data or the completion of incomplete data;
Right to erasure or "right to be forgotten" (Art. 17 GDPR): obtain the erasure of personal data, when the conditions set out in the GDPR apply;
Right to restriction of processing (Art. 18 GDPR): obtain the restriction of processing when the conditions set out in the GDPR apply;
Right to data portability (Art. 20 GDPR): receive, in a structured, commonly used and machine-readable format, the personal data provided to the controller and transmit it to another controller;
Right to object (Art. 21 GDPR): object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you, or object at any time to processing for direct marketing purposes;
Right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you (Art. 22 GDPR);
Right to lodge a complaint (Art. 77 GDPR) with a supervisory authority, in particular with the Italian Data Protection Authority (Garante per la protezione dei dati personali, www.garanteprivacy.it), if you believe that the processing of your data infringes the GDPR, without prejudice to any other administrative or judicial remedy.

To exercise your rights, you can write at any time to privacy@keyless.it. The controller will respond to the request without undue delay and, in any event, within one month, as provided for by Art. 12 of the GDPR.