PILOT PROJECT FOR ADVANCE TESTING OF NEW BREMBO INSPIRE APP

PERSONAL DATA PROCESSING DISCLOSURE 

- Pursuant to articles 13 –14 of Regulation 679/2016 on Personal Data protection-

Dear user,

with reference to the BREMBO INSPIRE App (hereinafter "App"), Brembo S.p.A. (hereinafter the "Company"), as data controller wishes to inform you, pursuant to Articles 13 and 14 of European Regulation 679/2016 on the protection of personal data ("GDPR"), also for the purposes of the Code for the protection of personal data (Legislative Decree 196/2003), of the following.

1. Purposes of processing and legal basis

The App has been developed by the Company for the purpose of:

a) Allow you, while driving your vehicle, to collect certain trip data in real time, using Bluetooth and GPS connectivity, and to receive technical feedback/reports on individual trips made in relation to your braking style, together with suggestions for improvement;

b) allow you to gain, through your braking performance, experience points that allow you to unlock and collect virtual vehicles to be displayed in the "Garage" section, or to compare yourself with other users who use the App on the basis of a ranking of your performance updated in real-time, in the "Ranking" section;

c) to send you by email, subject to your consent, newsletters and promotional/commercial communications on Brembo products and to take part in market research and any surveys on customer satisfaction in relation to such products.

For the purposes of points a) and b) above it is not necessary to obtain specific consent as the processing is necessary for the provision of the service offered by the App (art. 6.1 b) of the GDPR). For the purpose referred to in point c) your specific consent is required, which is optional; therefore, in case of lack of consent or subsequent revocation of the same, you will still be able to use and enjoy the services of the App, but you will simply not receive commercial and promotional communications from the Company.

In addition, we will use only the driving and braking data collected by the App, exclusively in aggregate form and pseudonymised, so as to exclude any analysis on the individual user, for analysis aimed exclusively at continuously improving the performance of our products and the development of new technologies, also with a view to sustainability. The legal prerequisite for such processing is the legitimate interest of the Company in ensuring the evolution of its products and offering users increasingly efficient, safe and quality products. If the conditions are met, you may object at any time and freely in the manner provided for in paragraph 6 below.

2. Type of personal data processed

The personal data collected by the App are listed below:

TYPE OF PERSONAL DATA PROCESSED	PURPOSES OF PROCESSING	LEGAL BASIS
Username/Nickname	The data will make you visible to other users in the ranking of your performance	Execution of the contract
E-mail address	You can register for the App the first time you log in and authenticate yourself on subsequent logins. In the case of registration via Facebook login, Google login or Apple ID, the email address will be made available by the social channel you have selected. By using the social login, you authorise the operator of the relevant platform to share the data with the Company and the Company to obtain the data from the social network you have indicated.	Execution of the contract Consent for use of social login
Password (created directly by you during registration)	To access the App.	Legitimate interest (security of the service)
Profile picture (if you wish, you may insert a picture to be associated with your profile)	If provided, the image will be uploaded in the profile section. If you register via Facebook login, Google login or Apple ID, the image will be made available by the social channel you have selected. By using the social login, you authorise the operator of the relevant platform to share the data with the Company and the Company to obtain the data from the social network you have indicated. The image will be displayed in the main sections of the App, such as "Profile" and "Ranking".	Legitimate interest (based on active spontaneous uploading of the image by the user)
Vehicle Make, Model and Type or alternatively and optionally, the vehicle’s number plate	To obtain information on the technical characteristics of the vehicle. As an alternative to entering the Make, Model and Type of vehicle, you may enter the number plate, which will be used exclusively to obtain the above technical information, by association with an external database: the number plate will then be immediately deleted.	Execution of the contract (as essential information for the proper working of the service)
Vehicle ID and Trip ID	This is a randomly generated alphanumeric code that does not contain any user identification information: it is necessary to match the braking data with the driving/braking report that the App will provide you with.	Execution of the contract
Vehicle location data generated by the GPS in the user’s device (latitude, longitude, altitude, speed, vehicle make/model)	In order to collect the necessary data on vehicle behaviour and braking, and to be able to provide you with reports on your driving and braking style.	Execution of the contract
Single trip scoring data and accumulated experience points	To enable you to participate in the rankings, to access the "Reward" section of the App according to the score you have achieved. The score is awarded according to the braking parameters (linearity, frequency and intensity) as further described in the Terms and Conditions of the App.	Execution of the contract
Bluetooth SSID	To allow the App to interface with the vehicle's Bluetooth. Saving the SSID is necessary in order to manage the starting at automatic monitoring (optional). Alternatively, if the vehicle is not equipped with Bluetooth, the departure and stopping of the monitoring will be available only in manual mode using the relevant feature. In case you fail to stop the trip monitoring, the App will send you a message to check whether the trip must be stopped or not.	Execution of the contract
IP address	To make the mobile device communicate with the App.	Execution of the contract

 

3. Processing methods

This data will be processed by the Company, in accordance with the GDPR and national legislation including any measures issued by the competent supervisory authorities, where applicable. The data shall be processed exclusively by specifically authorised personnel of the Company belonging to the functions closely involved in the process of managing the App and shall in no way be accessible, or in any case usable, even indirectly, by other company functions. The data shall be processed by means of software and systems dedicated to the above-mentioned functions in accordance with the principles of correctness, fairness and transparency laid down by the applicable legislation on the protection of personal data and protecting the confidentiality of the person to whom the data refer.

The Company adopts a number of technical, IT and organisational measures in order to guarantee an adequate level of security and processing according to the principle of data minimisation. In particular:

- the Company shall collect and process the braking data for the purposes referred to in points 1.a) and 1.b) above in pseudonymised form, i.e. not directly associated with any user identification data but only with a randomly created alphanumeric code that does not allow the direct identification of the user (Vehicle ID and Trip ID);

- To activate the driving monitoring, you can set up an automatic connection between the app and the Bluetooth or a manual connection every time gets into the vehicle: it is understood that you can deactivate the connection between the app and the Bluetooth at any time and thus stop the recording of driving/braking data;

- In addition, analysis activities for product improvement purposes will only be carried out on a reduced set of information, after aggregation and subsequent anonymization to ensure that such data can no longer be linked to the user.

4. Disclosure, data transfer and dissemination

The Company also uses third parties to provide certain services that involve the processing of personal data, including management and hosting services of the App. These third parties act as data processors, on the basis of specific and adequate instructions in terms of processing methods and security measures indicated in specific contractual documentation. Further information can be requested at the contacts listed below.

In the ranking drawn up periodically among App users (point 1.b) above), only the nickname, mark, model and typology of the vehicle and the experience points accumulated will be shared with other users.

The data will not be transferred outside the European Union and will not be disseminated.

5. Data retention 

The data will be kept for the period of time necessary to fulfil the above-mentioned purposes. In particular:

- The IP address of the device will be deleted immediately after each connection to the network;

- The main data on the App (such as your nickname, email, Bluetooth, profile photo, vehicle make and model, scoring data and experience points, Vehicle ID, etc.) will be retained as long as the App is not deleted by you using the "DELETE" function.

- The location data collected and then included in the travel reports will be stored, in pseudonymised form, in Brembo's data centre, for the purpose of research and development of new products and technologies, for one year only and will be anonymised thereafter.

- The reports of the individual trips made available to you (and the location data necessary to track back you trip that you can display within your own area) will be stored, in pseudonymised form, for a period of 5 years, in order to allow you to review, over time, the reports of previous trips and assess the driving/braking progress made; after 5 years, these reports will be deleted. It is understood that you may at any time decide to permanently delete individual trip reports even before this deadline using the specific function in the App.

6. Rights of the people concerned

Users who use the Application may exercise, in relation to the data processing described herein, the rights provided for by the GDPR (Articles 15-21), including:

▪ receive confirmation of the existence of your personal data and access to their content (access rights, Art. 15 GDPR);

▪ update, amend and/or correct your personal data, where applicable taking into account that part of the data is pseudonymised (right of rectification. Art. 16 GDPR);

▪ request the deletion or restriction of data processed in breach of the law, including data whose retention is unnecessary for the purposes for which the data were collected or otherwise processed (right to be forgotten, Art. 17 GDPR, and right to restriction, Art. 18 GDPR);

▪ withdraw the consent given, without prejudice to the lawfulness of the processing based on the consent given before the withdrawal;

▪ to receive a copy of the data in electronic format concerning him made in the context of the contract and to request that such data be transmitted to another data controller (right to data portability, Art. 20 GDPR).

Users may also object to the processing, in the cases provided for by the Regulation (right to object, Art. 21 GDPR).

These rights may be limited, for example if fulfilling your request would reveal personal data about another person, or if you ask us to delete information which we are required by law or have compelling legitimate interests to keep. In order to exercise these rights or to request further information on this policy, may contact the Data Protection Officer (DPO) by sending an e-mail to privacy.italy@brembo.it, or by post by registered letter with return receipt to the Company's registered office at the addresses indicated, to the address of the Data Protection Officer.

Users may also lodge a complaint with the Data Protection Authority competent, i.e. a German Supervisory authority (a list of which is available here), or the Italian Supervisor Authority (whose contact details are available here).

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws

7. Identity and contact details of the Data Controller and contact details of the Data Protection Officer 

The Data Controller is Brembo S.p.A. with registered office in Curno, via Brembo n.25 - 24035, telephone 035.6052111, in the person of the pro-tempore Legal Representative.

The Data Protection Officer can be contacted at privacy.italy@brembo.it.