Privacy and cookie policy

The Data Controller for the Data of Site users is CICLAT TRASPORTI AMBIENTE Soc. Cooperativa, with registered office in Ravenna, via Romagnoli n. 13.

The Company can be contacted at the following addresses: via email, at: ciclattrasportiambiente.privacy@ciclatpec.ra.it; via post, at the following address: Via Romagnoli, 13 – 48123 Ravenna

The Company has appointed a data protection officer, who can be contacted at the following addresses: via email, at: dpoitaly@sgs.com; via fax, at the number +39 02 70 12 46 92; via post, at the address SGS Italia SpA – Via Caldera, 21 (20153) Milan (MI) – for the attention of the Office

Following navigation of the Site by the user, CICLAT TRASPORTI AMBIENTE Soc. Cooperativa may process the following types of Data. Except as specified for data from cookies (necessary to allow the correct functioning of the site), the provision of personal data is always optional. However, failure to provide contact data will make it impossible to manage any requests.

Browsing the Site involves the receipt of cookies. Cookies are short strings of text that visited websites send to the user’s browser, where they are stored to be then retransmitted to the same websites during subsequent visits. While browsing a site, the user may also receive cookies on their computer from sites or web servers other than the one they are visiting (so-called “third-party” cookies). It is possible to distinguish between:

1. technical cookies, which allow activities related to the functioning of the Site to be carried out;
2. profiling cookies, used to analyze user behavior and potentially send advertising messages in line with the preferences expressed by the user during navigation

No profiling cookies are used.

The optional sending of emails through the Contact section or in any case through the addresses indicated on the website involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the request.

The optional sending of a complaint, in relation to facts and events of an abusive, offensive, or illegal nature occurring within the work environment or linked to it and in contrast with the principles of social responsibility of the SA8000 standard, or the sending of a report of unlawful conduct (whistleblowing) relevant pursuant to Legislative Decree 231/2001 or violations of the organization, management, and control model adopted by the Company, through the  Complaints or Conduct Reporting Form Unlawful or in any case through the addresses indicated on the website involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data included in the request which could also belong to special categories of data (formerly sensitive data).

User Data will be used by CICLAT TRASPORTI AMBIENTE Soc. Cooperativa for the following purposes and on the following legal bases:

1. as for data processed during navigation by cookies, to allow navigation of the Site and its fluid functionality; the legal basis for processing is the provision of services related to the Site in favor of users and the legitimate interest of the Controller to have a functional website;
2. as for data provided voluntarily by the user to request information, to allow the provision of services made available therein by the Company; the legal basis for processing is the necessity to execute a contract to which the data subject is a party or pre-contractual measures adopted at their request, or the legitimate interest of the Controller to provide information regarding its organization;
3. as for data provided voluntarily by the user to make a complaint or a report of unlawful conduct (whistleblowing), to manage the complaint and the report;

the legal basis for processing is the legitimate interest of the Controller to manage its activities in compliance not only with current regulations but also with the ethical principles and values underlying its organization; in the event that data belonging to special categories of data are also voluntarily provided (as they relate to health conditions, trade union membership, etc.), it is considered that the legal basis for processing is the necessity to fulfill obligations and exercise specific rights of the Controller or the data subject in the field of labor law and social security and social protection.

Finally, in specific cases, the Data provided may also be processed to:

• comply with any obligations provided for by current laws, regulations, or EU legislation, or satisfy requests from authorities. The legal basis for processing is the obligation for the Controller to comply with mandatory regulations;
• needs to defend the Controller’s rights in the context of any disputes, including in court. The legal basis for processing is the legitimate interest of the Controller to protect its

Data may be shared with:

1. subjects who typically act as data processors pursuant to Art. 28 GDPR, i.e., subjects who cooperate with the Company for the pursuit of the aforementioned purposes;
2. subjects, entities, or authorities to whom it is mandatory to communicate the Data by virtue of legal provisions or orders from authorities;
3. persons authorized by the Company, pursuant to Art. 29 GDPR, to process Data necessary to carry out activities strictly related to the provision of services, who have an adequate legal obligation

No transfer of data outside the European Economic Area is planned.

Data will be kept for the time strictly necessary to achieve the purposes of the processing, applying the principles of minimization and proportionality. In any case:

• as for the duration terms of Data processed through cookies, it is specified that the technical cookies used do not involve any retention of the data collected;
• as for processing carried out for the provision of a service, the Company will keep the Data for the period of time strictly necessary and in any case not beyond what is provided for and permitted by Italian legislation to protect its interests (Art. 2946 c.c. et seq.);

• as for data processed to manage a complaint or a report of unlawful conduct (whistleblowing), for the period of time strictly necessary to manage the request, in accordance with the provisions of the organizational systems adopted;
• as for Data processed to fulfill legal obligations, these will be kept until the time provided for by the specific obligation or applicable legal provision;
• as for data processed for the needs of defending the Controller’s rights, no longer than what is provided for and permitted by Italian legislation to protect its

Pursuant to Art. 15 et seq. GDPR, the data subject has the right to ask the Company for access to their Data, the rectification or erasure of the same, or to object to their processing, to request the restriction of processing in the cases provided for by Art. 18 GDPR, as well as to obtain in a structured, commonly used, and machine-readable format the Data concerning them, in the cases provided for by Art. 20 GDPR.

Requests should be addressed in writing to the Company at the contact details indicated above.

In any case, the data subject always has the right to lodge a complaint with the competent supervisory authority, namely the Garante per la Protezione dei Dati Personali, pursuant to Art. 77 GDPR, if they believe that the processing of their Data is contrary to current legislation.