PRIVACY POLICY (ART. 13 REG. UE 2016/679) – COOKIE POLICY

For the purposes set out in the aforementioned EU Regulation 2016/679 (hereinafter "G.D.P.R. 2016/679"), containing the new provisions for the protection of "privacy" and relating to the protection and processing of personal data, we inform you that the processing of data personal data will be based on principles of lawfulness, correctness and transparency, limitation of purposes and conservation, minimization of data, accuracy, integrity and accountability, to protect the privacy and rights of the interested party.

WHAT IS MEANT BY PROCESSING OF PERSONAL DATA
The treatment of personal data constitutes any operation or set of operations, carried out even without the aid of electronic instruments, concerning the collection, registration, organization, conservation, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, cancellation and destruction of data, even if not recorded in a database.

JOINT DATA CONTROLLERS
Considering that pursuant to art. 26, first paragraph, of the GDPR, "when two or more data controllers jointly determine the purposes and means of processing, they are joint data controllers", we communicate the following references:
ACCELERATION, with registered office in Malta – Ballut road - MGARR, MGR 0001 – Reg.No: MT28525117 – in the name of its legal representative

GUIDATTIVA SRL, as reseller for Italy, with registered office in Borgomanero (NO) Viale Marconi 2/C - C.F. e P.I: 02078960032, - in the name of its legal representative
From now on, the parties will be identified as "Joint Controllers" or "Parties"

DATA PROCESSING LOCATION
The Joint Controllers process personal data mainly on servers and in IT and conventional environments, at the OVH data center located in Warsaw, Poland, equipped with anti-DDDoS protection.
The retention of personal data connected to web services takes place at the company headquarters of the Joint Controllers, in their respective registered offices. The data will be stored both in digital format on a password-protected local server and in paper format in special databases in special locked cabinets.
The data is stored in compliance with specific security measures to prevent data loss, illicit or incorrect use and unauthorized access and only for the time necessary to pursue the purposes indicated below.

PERSONS AUTHORIZED FOR TREATMENT
The data will be processed, under the responsibility of each Joint Controller, by authorized and adequately trained subjects pursuant to art. 29 of the GDPR, involved in the functions necessary to carry out the specific purposes indicated below and who operate in Acceleration and in the designated offices of Guidattiva Srl, the company responsible for sales for the Italian territory. The data may be processed by Data Processors who have entered into specific agreements, conventions or memorandums of understanding with the Parties, qualified professionals identified periodically by the Joint Controllers through public procedures, and in collaboration with the competent offices of the Parties.
The updated list of Data Processors can be requested from the Joint Controllers at any time.

TYPE OF DATA PROCESSED
1) Navigation data: The computer systems and software procedures used to operate this site acquire, during normal operation, some personal data which are then implicitly transmitted in the use of Internet communication protocols.
2) Data provided voluntarily by users/visitors: If users/visitors, by connecting to this site, send their personal data to access certain services, or to make requests by e-mail, this involves the acquisition by the Co-owners of the sender's address and/or any other personal data that will be used exclusively to respond to the request. The personal data provided by users/visitors will be communicated to third parties only if the communication is necessary to comply with the requests of the users/visitors themselves.
3) Cookies: Various technologies can be used on the website to improve it and make it easier to use, effective and secure. These technologies allow us, or commissioned third parties working for us, to collect data automatically. Examples of such technological solutions are cookies.

Cookies are not used to transmit information of a personal nature, nor are so-called persistent cookies of any kind, i.e. systems for tracking users, used.

The use of session cookies (which are not stored permanently on the user's computer and disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to allow the safe and efficient exploration of the site. The Session cookies used on this site avoid the use of other IT techniques potentially prejudicial to the privacy of users' browsing and do not allow the acquisition of personal identification data of the user.

The site uses "first-party" technical cookies, which are used to navigate or provide a service requested by the user. Which are not used for other purposes and are installed directly by the owner of the website. Without the use of these cookies, some operations could not be performed or would be more complex and/or less secure.

This type of cookie is generally used to personalize the browsing experience, automatically recognizing a user who has already been on the site (also, for example, by "logging in" with his username and password) and recovering and setting his preferences.

PURPOSE AND LEGAL BASIS OF THE TREATMENT
The processing has the purpose of entering customers and suppliers in the archives to regulate pre-contractual management (offers and estimates), sales/purchase contracts for products and services, internal operational or management needs, accounting, tax, civil law and related obligations. The treatment will be carried out by specially authorized personnel, electronically and on paper. The information collected can also be used for the following purposes:
- Create logins and passwords for Clients to work with the program
- Analyze the results of how users proceed with the program
- Organization of direct communication between the Parties and its Client users, in case of any need or assistance relating to the use of the online courses offered, if the Client has given the appropriate consent
- Facilitate collaboration between the Client and the Joint Controllers

The provision of data is mandatory for the fulfillment of the obligations deriving from the contractual relationships. Failure to provide data could result in the failure or partial execution of the contract and the continuation of the relationship.

METHODS OF PROCESSING AND STORAGE OF PERSONAL DATA
Data processing will be carried out manually in compliance with the provisions of art. 32 of the G.D.P.R. 2016/679, by persons specifically appointed and in compliance with the provisions of Article 29 of the G.D.P.R. 2016/679. The processing of personal data carried out by the Joint Controllers does not involve automated decision-making processes.

The data collected will be duly kept for the period of time necessary to achieve the purposes for which they are collected and processed and, in any case no later than the terms established by tax, labor and social security regulations and by the relevant Civil Code and for a further ten years.

FIELD OF COMMUNICATION AND DISSEMINATION OF DATA
We also inform you that the data collected will never be disclosed and will not be communicated without your explicit consent, except for the necessary communications which may involve the transfer of data to public bodies, consultants or other subjects for the fulfillment of legal obligations.
Furthermore, such data may be known, within the limits of current legislation, by employees and/or collaborators and/or subjects definable as "Data Processors" expressly appointed and appointed by the Data Controller.
The Parties, as Joint Data Controllers, inform the interested parties of the fact that personal data will not be transferred abroad to non-EU countries or to countries considered unsafe by the EU Guarantors.

PARTICULAR CATEGORIES OF PERSONAL DATA
Interested parties are informed that the Data Controller does not collect or process data that can be defined as "particular" for any purpose pursuant to articles 9 and 10 of the G.D.P.R. 2016/679: data that reveal "racial or ethnic origin, political opinions, religious or philosophical conventions, or trade union membership, as well as genetic data, biometric data intended to uniquely identify a natural person, data relating to the person's health or sex life or sexual orientation".

RIGHTS OF INTERESTED PARTIES
It is possible, pursuant to Article 13, par. 2, lit. b), c), d) of EU Regulation 2016/679, in relation to the data being processed referred to in this information notice, the interested party should contact each Data Controller without distinction to assert the following rights at any time:

• Access (art. 15 EU Regulation n. 2016/679);
• Correction (Article 16 of EU Regulation No. 2016/679);
• Cancellation (art. 17 EU Regulation n. 2016/679);
• Limitation (Article 18 of EU Regulation No. 2016/679);
• Portability, understood as the right to obtain data from the data controller in a structured format of common use and readable by an automatic device in order to transmit them to another data controller without impediments (Article 20 of EU Regulation No. 2016/679);
• Opposition to processing (Article 21 of EU Regulation No. 2016/679);
• Revocation of consent to processing, without prejudice to the lawfulness of the processing based on the consent acquired before the revocation (Article 7, paragraph 3 of EU Regulation No. 2016/679);
• Propose a complaint to the Personal Data Protection Authority (Article 51 of EU Regulation No. 2016/679).

To exercise these rights or if you wish to have more information on the processing of your personal data, the interested party can directly contact the Joint Data Controllers by writing to the following e-mail addresses:
mariateresa@drivingcamp.it
online@driveatbest.com

MODIFICATIONS TO THIS POLICY
The Joint Controllers undertake to adopt the fundamental principles of data protection and consider the protection of personal data as a natural duty. Therefore, they frequently review the privacy policies to ensure they are free from errors, clearly visible on the website and include all necessary information, and to verify that they are strictly observed, and compliant with the principles of the legislation on this matter.

This information on the protection of personal data may undergo changes over time in order to keep it abreast of the evolution and new opportunities of the Internet and to ensure its compliance with current legislation.
Without your explicit consent, the Parties will never apply restrictive provisions of the rights that are recognized in this statement.
Significant changes to this information will be announced on the website at the same time as the publication of the updated version of the information on the protection of personal data.

Read the Joint Controller Agreement