in compliance with the provision of the European Regulation on the protection of personal data 2016/679, by Legislative Decree June 30, 2003, n. 196 c.d. Privacy Code and Legislative Decree 10 August 2018, n. 101 whose objective is to protect the fundamental rights and freedoms of individuals, in particular the right to the protection of personal data, we inform you about the methods of processing the personal data of users who interact with the Ebike-Alp-Experience website of Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively, starting from the address www.ebike-alpexperience.eu, on their rights and how they can exercise them. These methods do not concern other external websites that may be connected via links to this website.
1. Purpose of the treatment
The entire Service provided by means of the App (hereinafter "App") and the Ebike Alp Experience web portal aims to direct the user in the search for content around the alpine cycle path that will wind through the paths of the Italian-Swiss Alps aiming to create a network of all the entrepreneurial realities of the territory in a single cluster and guarantee a single physical place for potential users where they can get to know the territory, program their experience and discover the “Alp e-xperience” open to everyone thanks to the use of pedal-assisted mountain bicycles.
In particular, the aforementioned objective is pursued through the processing of the user's personal data with the aim of:
a) allowing the user to register on the App and on the web portal and then employ the functions reserved for registered users; the personal data collected for the purpose in question are: Name, Surname, e-mail address.
b) identifying the device on the map near the cycle path if the user decides to enable the geolocation function; the personal data collected for the purpose in question are solely those relating to the geolocation of the mobile device.
With specific reference to the processing of personal data for the purposes referred to in point a), the legal basis of the processing lies in the preparation or execution of a contract in favor of the data subject, in compliance with Article 6, letter b of the GDPR.
With respect to the processing of personal data referred to in point b), the legal basis of the processing lies in the prior and informed consent of the interested party specifically given for each individual purpose, in compliance with Article 6, letter a of the GDPR.
2. Processing methods
The processing is carried out with the aid of electronic or automated means and transmitted through telematic networks. The Holder of the treatment adopts adequate technical and organizational measures to guarantee an appropriate level of security with respect to the type of data processed.
The Holder of the treatment is the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Luganese Regional Development Authority, respectively, with the headquarters in Piazza Città di Lombardia, 1 - 20124 Milan.
4. Data Protection Officer (DPO)
The Data Protection Officer (DPO) of the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively, can be contacted by sending an email to: firstname.lastname@example.org
5. Type of data processed
6. Optional provision of data
The user can voluntarily provide personal data in communications sent to the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively, through the contact details indicated on this website. Failing to provide certain data in requests for information or sending suggestions and reports, may only result in the impossibility of obtaining an answer to what is requested or reported.
7. Communication and dissemination of personal data
The data collected is processed exclusively by the staff and collaborators of the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively. These data are processed, in the role of Data Processor in compliance with art. 28 of the Regulation, by Lombardia Informatica S.p.A., which carries out the management and maintenance of information systems on behalf of the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively. Some processing operations may also be carried out by other third parties, to which the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, respectively, entrusts certain activities, or part of them, functional to the provision of services. These additional subjects, designated as Data Processors, are required by the Italian and Swiss Lead Partners of the Interreg IT-CH 2014/2020 E-BIKE project, the Lombardy Region and the Lugano Regional Development Authority, Data Processors, by contract or other legal deed under the law of the EU or of the Member States, to comply with the appropriate obligations regarding the protection of personal data through operating instructions, with particular reference to the adoption of adequate technical and organizational measures, in order to be able to guarantee the confidentiality and security of data pursuant to art. 32 of the Regulation. Besides of these hypotheses, the data will not be disclosed to third parties or disseminated, except in the cases specifically required by national or European Union law.
8. Transfer of personal data to countries outside the European Union
The data collected and processed are not transferred to companies or other entities outside the EU territory.
9. Data retention period
The anonymized navigation data remain available for statistical processing for 400 days. They are never deleted from the servers, unless explicitly requested (to be sent in the manner described in point 11. "Rights of interested parties" of this information). The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the website.
10. Rights of interested parties
Users can exercise the rights referred to in Articles 15 and following of EU Regulation 679/2016, where applicable; among these, the right to request the rectification or cancellation of the registration data, the limitation of the processing or to oppose the processing, in the foreseen cases. Requests for the exercise of these rights must be sent to the e-mail address email@example.com for the attention of the pro tempore Director, or by registered mail to the Italian and Swiss Lead Partners of the Interreg IT project- CH 2014/2020 E-BIKE, Lombardy Region and Lugano Regional Development Authority, Piazza Città di Lombardia 1, 20124 Milan for the attention of the pro tempore Director of the General Direction for Sport and Youth. Furthermore, it is always possible to exercise the right to file a complaint with the competent Supervisory Authority.