Privacy Policy

Privacy Policy

 

At E-GAP S.r.l. Società Benefit, 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.

1.  Data Controller and useful definitions for an informed reading

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”, that is the entity that – pursuant to and in compliance with the GDPR – determines the purposes and methods of personal data processing.
When we speak of “Customer” or “User” we refer to you as the recipient of our services.
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, which shall comply with the principles of lawfulness, fairness and transparency.

2.  Legal Basis of the Processing

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:

• your explicit, free, specific, informed and unambiguous consent to the Processing;
• the pursuit of our legitimate interests; or
• to comply with legal obligations.

3.  Data Processing

We receive and store any Data you provide to us in an informed, unambiguous, specific and free manner.

3.1. Automatic collection of certain Data

The Personal Data we collect and use automatically are:

• your Internet Protocol (IP) address;
• information about your Computer, your Device and your connection, such as the applications on your Device or the type and version of your browser, operating system or time zone you have set;
• information related to the use of the website, browsing data, and technical data necessary for the website to function.

To find out more, please also read the section on Cookie Policy.

3.2. Purposes of the Processing

Personal Data will be collected and processed by us for the following purposes:

• comply with the obligations imposed by applicable laws and regulations and respond to requests from public authorities;
• to adapt content and resources to your preferences and the preferences of other Users;
• to communicate with you, respond to your requests or questions by phone, chat or e-mail;
• to create, publish and improve content that is most relevant to you and other Customers;
• to ensure that the content provided through our website is presented in the most effective way for you, based on your Device;
• to send push notifications directly to your Device;

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.

3.3. Sharing of Personal Data with third parties

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?
Matomo Analytics	Audience profiling

3.4. Transfer of Data

We do not sell your Personal Data to third parties and process them 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.

3.5. Data Security. Where Personal Data are stored and processed

We use high standard 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 “3.3 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.

3.6. How long do we store your Data?

We retain your Personal Data for a period of time not exceeding that necessary for the purposes for which they have been collected.

4. Processing of Application Data sent to E-GAP

All the provisions of this Policy also apply if you would like to work with us, either by applying by e-mail.

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 5 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, with your consent, be transferred to other companies of the E-GAP group, in compliance with our Policy.

5. User rights

Pursuant to Articles 15-22 of the GDPR, to which we refer for further details, you have the right to:

• access and obtain a copy of your Personal Data;
• request the updating and/or rectification of your Personal Data;
• request erasure of your Personal Data, i.e. benefit from the “right to be forgotten”, however, this right is subject to legal obligations that may require us to retain the Data;
• obtain the restriction of the processing of your Personal Data;
• obtain the Personal Data you provide in a structured, commonly used and electronically readable format, so that we can transmit it to a different data processor if necessary;
• object to the processing.

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.

6. Changes to this Privacy Policy

Any material changes to this Policy will be made by posting a notice on our website or by contacting you through other channels.

7. Communications

Questions, comments and/or requests regarding this Policy are welcome and should be addressed to E-GAP, at the following e-mail address: [email protected].