FOREWORD – In the regular course of its activities, CICLAT TRASPORTI AMBIENTE Società Cooperativa collects Personal Data from its customers, employees, suppliers, website users, job applicants, contractors, shareholders, partners, and other third parties. CICLAT TRASPORTI AMBIENTE Società Cooperativa recognizes the need to process Personal Data with care. We are committed to conducting our business in accordance with all applicable Data Protection and Privacy laws of the countries where we operate and in line with the highest standards of ethical conduct. Data protection is important to every part of our business. It is at the heart of our commitment to our customers, our values, our principles, our conduct, and our success, and it is essential for maintaining trust in us. The entry into force of more restrictive regulations and the digitalization of our services are an opportunity for CICLAT TRASPORTI AMBIENTE Società Cooperativa to remind our customers and the industry of our integrity in one of the most important areas of modern life – data protection. Should you have any questions or comments regarding this policy, please contact us at ambiente@ciclat.ra.it.

SCOPE OF APPLICATION – This Data Privacy Policy applies to the entire CICLAT TRASPORTI AMBIENTE Società Cooperativa Organization. It defines the conduct expected of every employee, officer, and manager of CICLAT TRASPORTI AMBIENTE Società Cooperativa when collecting, managing, and processing personal data of customers, suppliers, employees, contractors, and other third parties of CICLAT TRASPORTI AMBIENTE Società Cooperativa.

This policy is organized around three basic commitments:

  • fair and lawful collection and processing of Personal Data
  • respect for individual rights and choices
  • responsible management of Personal Data

The definition of Personal Data refers to any information relating to an individual and may include, among others: contact information (name, home and professional address, telephone, email addresses); personal information (date of birth, citizenship, photographs, electronic identification data such as cookies, IP addresses, and passwords); professional and employment information (education and training); financial details (tax identification data and bank account number). This policy defines the uniform and basic standards of CICLAT TRASPORTI AMBIENTE Società Cooperativa, applicable in the absence of more stringent rules that might be imposed by local laws. To operate in accordance with the Data Privacy Policy, internal implementation rules, guidelines, and training are provided, along with all necessary supporting documentation.

Basic commitments – data privacy policy

 

Fair and lawful collection and processing of personal data

Transparency regarding collected and used personal data

We inform individuals about the use of their Personal Data

When collecting Personal Data, CICLAT TRASPORTI AMBIENTE Società Cooperativa informs in a clear, honest, and transparent manner about the nature of the Personal Data collected and what it intends to do with them. The use by CICLAT TRASPORTI AMBIENTE Società Cooperativa of Personal Data for purposes other than those initially communicated is not authorized, unless adequate information is provided to the individuals concerned and, where applicable, consent for the intended use is given to CICLAT TRASPORTI AMBIENTE Società Cooperativa. In general, CICLAT TRASPORTI AMBIENTE Società Cooperativa is authorized to use Personal Data for secondary purposes when implementing internal controls and audits and complying with its legal and regulatory obligations.

Use of personal data only for specific and legitimate purposes

We collect and process Personal Data only if we have a legitimate reason to do so

CICLAT TRASPORTI AMBIENTE Società Cooperativa collects and processes Personal Data only to the extent that, alternatively, (i) valid and informed consent has been provided or (ii) this is required by legitimate business interests of CICLAT TRASPORTI AMBIENTE Società Cooperativa, such as entering into or performing a contract, making and receiving payments, performing contractual obligations, and complying with legal or regulatory commitments.

We allow consent given to be subsequently withdrawn

Any consent given by individuals for the collection and use of their Personal Data must be given freely and in response to a clear disclosure by CICLAT TRASPORTI AMBIENTE Società Cooperativa regarding the intended use of the data. Such consent is revocable at any time by the individuals themselves, without undue complications. The date, content, and validity of such consent must always be documented.

We adhere to the instructions provided by Data Controllers

When processing Personal Data on behalf of a customer or another third party (Data Controller), CICLAT TRASPORTI AMBIENTE Società Cooperativa will comply with the guidelines and instructions of the Data Controller, as well as this policy.

Data quality assurance

We collect and maintain up-to-date, adequate, relevant Personal Data that is not excessive in relation to the purposes

CICLAT TRASPORTI AMBIENTE Società Cooperativa collects and stores the minimum amount of Personal Data required for the initial intended purpose for which the data is used and ensures that, at all times, the Personal Data held remains relevant and adequate for the intended purpose. CICLAT TRASPORTI AMBIENTE Società Cooperativa will keep all stored data up-to-date and accurate and will ensure that it is rectified when requested.

We retain Personal Data only for as long as actually necessary

Personal Data is retained by CICLAT TRASPORTI AMBIENTE Società Cooperativa only for the period of time required by their intended purposes. Specific retention policies will define the time after which such data must alternatively be deleted, destroyed, or anonymized.

Respect for individual rights and choices

Respect for individual rights

We respond to any request or complaint submitted by individuals in connection with their Personal Data

CICLAT TRASPORTI AMBIENTE Società Cooperativa recognizes the rights of individuals to:
(i) Request access to their Personal Data collected by CICLAT TRASPORTI AMBIENTE Società Cooperativa and the reason why CICLAT TRASPORTI AMBIENTE Società Cooperativa holds it
(ii) Obtain a copy of their Personal Data held by CICLAT TRASPORTI AMBIENTE Società Cooperativa
(iii) Request the rectification or deletion of inaccurate or incomplete Personal Data
(iv) Withdraw at any time the consent given to CICLAT TRASPORTI AMBIENTE Società Cooperativa for the collection of their Personal Data, including the right to unsubscribe or opt-out of marketing communications and commercial publications from CICLAT TRASPORTI AMBIENTE Società Cooperativa.
CICLAT TRASPORTI AMBIENTE Società Cooperativa will respond to requests submitted by individuals exercising their rights within a reasonable period of time after the individual’s request or within any specific period required by applicable local laws. CICLAT TRASPORTI AMBIENTE Società Cooperativa will manage and analyze complaints submitted by individuals regarding any violation of the aforementioned rules or data privacy laws and will respond promptly to such complaints.

Respect for individual choices

We respect the right of customers to object to the use of their Personal Data or opt-out of receiving direct marketing communications

When using Personal Data for marketing purposes, CICLAT TRASPORTI AMBIENTE Società Cooperativa will inform individuals in clear and simple language about the use of their data for such purposes. CICLAT TRASPORTI AMBIENTE Società Cooperativa respects the right of its current and potential customers to:
(i) Receive marketing communications from CICLAT TRASPORTI AMBIENTE Società Cooperativa only if explicit and specific prior consent has been provided, when required by applicable laws, or if CICLAT TRASPORTI AMBIENTE Società Cooperativa can demonstrate that it is authorized to send such communications for its legitimate business purposes
(ii) No longer receive any marketing communications if CICLAT TRASPORTI AMBIENTE Società Cooperativa has received a specific preference setting, an opt-out, or an objection to the use of such data for marketing purposes.

Safeguarding the use of sensitive personal data

CICLAT TRASPORTI AMBIENTE Società Cooperativa recognizes that certain categories of Personal Data are particularly sensitive and require a higher level of protection. Sensitive Personal Data includes information regarding personal health, biometric and genetic data, religious and political opinions, racial or ethnic origin, criminal records, and any other information specifically protected by applicable and current privacy laws.
CICLAT TRASPORTI AMBIENTE Società Cooperativa collects and processes such sensitive Personal Data only when absolutely necessary within one of the following circumstances:
(i) Explicit consent has been given by the individual
(ii) The use is necessary for CICLAT TRASPORTI AMBIENTE Società Cooperativa to comply with employment laws or other legal obligations or to protect the health of a specific individual (such as in the case of a medical emergency).
CICLAT TRASPORTI AMBIENTE Società Cooperativa implements appropriate procedures and safeguards to limit access to sensitive data only to appropriate persons and to prevent unauthorized access, use, and dissemination.

Responsible data management

Adoption of appropriate security measures

We adhere to appropriate technical and organizational security measures to protect Personal Data

CICLAT TRASPORTI AMBIENTE Società Cooperativa implements adequate security measures to ensure the confidentiality, integrity, and availability of Personal Data and to prevent the risk of unauthorized or unlawful access, alteration, destruction, or loss of confidentiality of such data. Protection measures are based on impact assessments that take into account the risk to the individual in relation to the specific Personal Data stored by CICLAT TRASPORTI AMBIENTE Società Cooperativa. The aforementioned measures include security and organizational measures adapted to the type of processing and the nature of the data to be protected. CICLAT TRASPORTI AMBIENTE Società Cooperativa will promptly inform individuals of any privacy breach that has compromised their Personal Data and will notify such incident to the relevant authorities, as required by applicable laws.

We ensure that our suppliers or partners also adopt appropriate and equivalent security measures

CICLAT TRASPORTI AMBIENTE Società Cooperativa requires its suppliers or subcontractors to fully comply with the privacy policies of CICLAT TRASPORTI AMBIENTE Società Cooperativa and any applicable data protection and privacy legislation and to maintain adequate technical and organizational security regimes to protect Personal Data.

We ensure that our employees maintain the confidentiality of Personal Data processing

CICLAT TRASPORTI AMBIENTE Società Cooperativa limits access to Personal Data to its employees or suppliers who need to perform specific activities in relation to such data. Adequate awareness, training, and confidentiality obligations are in place to ensure that Personal Data is not shared with or disclosed to unauthorized persons, including other employees of CICLAT TRASPORTI AMBIENTE Società Cooperativa who do not need to access such Personal Data.

Guarantee of adequate protection for international transfers

When Personal Data is transferred, we ensure that we have taken the necessary measures to protect it before the transfer itself

CICLAT TRASPORTI AMBIENTE Società Cooperativa transfers Personal Data across national borders within or outside CICLAT TRASPORTI AMBIENTE Società Cooperativa only when (i) this is justified for business purposes and (ii) safeguards exist to ensure that Personal Data continues to be protected at least at the same level of protection required by the jurisdiction of origin.

Minimization of risk impacts for data subjects

If processing may involve a high risk for individuals, we conduct a Data Protection Impact Assessment

CICLAT TRASPORTI AMBIENTE Società Cooperativa conducts a Data Protection Impact Assessment to identify the risks that the processing of Personal Data by CICLAT TRASPORTI AMBIENTE Società Cooperativa could cause to the privacy rights of individuals, in order to eliminate or reduce such risks.
The aforementioned Data Protection Impact Assessments will be part of any development of new services or business opportunities and acquisitions by CICLAT TRASPORTI AMBIENTE Società Cooperativa.