VOCE DEL CLIENTE SERVICE
Personal Data Protection Policy
(Ai sensi dell’art. 13 del Regolamento Europeo n. 679/2016)
Before acquiring your personal data for the management of reports and complaints, Busitalia Sita Nord s.r.l. kindly requests you to carefully read the personal data protection policy.
I. Data Controller and DPO
In this section we indicate which are our references
- Busitalia Sita Nord s.r.l., Data Controller, represented by the pro-tempore Chief Executive Officer, can be contacted at the email firstname.lastname@example.org, with registered office in piazza della Croce Rossa, 1 Rome.
- The Data Protection Officer can be contacted at the email email@example.com.
II. Types of personal data
In this section we indicate what types of data we ask you for
The personal data being processed fall into the following categories:
- Common data of those who submit the complaint: personal data (name, surname, address), contact details (e-mail)
- Customer's common data (if different from the person submitting the complaint) and of any other passengers: personal data (name and surname), card number or copy of personal ticket, proxy and copy of identity document
- Optional data: telephone contact
The aforementioned data will be processed by computer and paper media in such a way as to guarantee suitable security and confidentiality measures.
III. Processing Purposes
In this section we indicate why we ask you for your data
a. Management of the report/case procedure; Legal basis (Contractual)
b. Transmission of the complaint also containing any special category data to the pertinent Providers; (Legal basis: Legal - measure 5.2 Annex A to ART (Transport Regulation Authority) Resolution 28/2021 and art. 9 par. 2 lett. g) GDPR)
c. Improvement in the management of the report/complaint in case of communication difficulties and/or to speed up response times through telephone contact details provided by the data subject; Legal basis (Consent)
The provision of the data necessary for the pursuit of the purposes referred to in points a) and b) is “mandatory” and your refusal will make it impossible for Busitalia Sita Nord s.r.l. to manage the case.
The provision of the data necessary for the pursuit of the purpose referred to in point c) is “optional”, therefore failure to provide it will only make it impossible to improve case management in the event of communication difficulties and/or to speed up response times.
Any consent given may be freely withdrawn at any time, without prejudice to the lawfulness of the processing carried out before withdrawal. The withdrawal of consent can be communicated to the email address: firstname.lastname@example.org.
IV. Processing of particular categories of personal data
In this section we indicate how your particular data will be processed
Based on the nature of the subject of the report/complaint submitted by you, Busitalia Sita Nord s.r.l. may become aware of data belonging to so-called "special" categories (for example data relating to health). In consideration of the fact that such data have been made available to Busitalia Sita Nord s.r.l. manifestly and freely, you are not required to give explicit consent for case management. Busitalia Sita Nord s.r.l. assures you that such data will be processed exclusively for purposes strictly connected and instrumental to the management of the case itself (for example to be able to apply the specific insurance coverage); in the absence of such personal data, Busitalia Sita Nord s.r.l. will not be able to partially or totally process your request.
V. Data recipients
In this section we indicate who will process your data and to whom it will be communicated
Personal data will be processed by the following to pursue the aforementioned purposes:
Parties associated with Busitalia Sita Nord s.r.l.
- Data processors (Busitalia Sita Nord s.r.l. employees)
- Outsourced consultants
- Service companies (also IT)
Parties not directly associated with Busitalia Sita Nord s.r.l.
- Insurance service companies
- Other providers to whom the complaint will be sent if the subject of the same is within their remit
- Judicial authorities
- Police authorities
- Transport Regulation Authority
Your data will only be processed by parties expressly authorised by Busitalia Sita Nord s.r.l. or by companies acting as Data Processors on behalf of Busitalia Sita Nord s.r.l., and which have signed a distinct contract that specifically regulates the processing entrusted to them and the obligations regarding data protection. Your data will never be disclosed.
Furthermore, personal data may also be transmitted to other independent Data Controllers on the basis of laws or regulations, or on the basis of the specific consent you have provided.
The updated list of data recipients is available by writing to email@example.com, or to the Data Protection Officer at firstname.lastname@example.org.
VI. Data disclosure
In this section we guarantee that your data will not be disclosed
Your personal data will never be published, displayed or made available/consulted by unknown parties.
VII. Data retention
In this section we indicate how long we will keep your data
The personal data you have provided to us will be kept for:
- Purposes whose provision is mandatory: 5 years from case closure.
- Purposes whose provision is optional: 24 months from case closure.
without prejudice to further retention for the following purposes: archiving in the public interest, scientific or historical research, statistical purposes or technical reasons (e.g. business continuity).
VIII. Rights of Data Subjects
In this section we indicate which rights we guarantee you
EU Regulation 2016/679 (Articles 15 to 23) grants data subjects specific rights. In particular, in relation to the processing of your personal data, you have the right to ask Busitalia Sita Nord s.r.l. for data access, correction, rectification, limitation, opposition, portability and withdrawal of consent. In addition, you may lodge a complaint to the Supervisory Authority, which in Italy is the Data Protection Authority.
You can exercise your rights at any time by contacting the Data Controller at email@example.com or by contacting the Data Protection Officer at firstname.lastname@example.org.
In this section we ask for your consent to the processing of data
For processing indicated in Par. III - "Processing Purposes", point c.