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Privacy Policy for website visitors

This Privacy Policy has the objective of describing the procedures adopted for managing the Websites of Volkswagen Group Italia S.p.A., currently available at the corresponding addresses www.volkswagengroup.it  and www.modo.volkswagengroup.it with regard to the processing of personal data of users/visitors consulting them. 

This is a policy also provided pursuant to art. 13 of Legislative Decree 196/2003 – Privacy Code – to those accessing said website. 

The above-mentioned website is the property of Volkswagen Group Italia S.p.A. (a company subject to management and coordination by Volkswagen AG). 

The policy is provided by Volkswagen Group Italia S.p.A. (hereinafter also “VGI”) only for the above-mentioned website and not for any other Websites or sections/pages/space owned by Third Parties consulted by the user via specific links. 

Users/visitors are invited to carefully read this Privacy Policy before sending any personal information and/or filling in any electronic form on this website. 

Should users/visitors be requested, in order to access certain services, to provide personal data, this will be preceded by, on the pages relating to the individual services, a specific and detailed policy regarding its processing, in accordance with art. 13 of Legislative Decree 196/2003, specifying processing limits, purposes and methods. 

Type of data processed and processing purposes

1) Browsing data 
The computer systems and software procedures used to operate the Websites of Volkswagen Group Italia S.p.A. acquire, during normal operation, certain personal data which is then implicitly transmitted when using Internet communication protocols. 
This is information which by its very nature could, through processing and association with data held by third parties, allow users to be identified (e.g. IP addresses, domain names of computers used by users/visitors connecting to the Websites, etc.). 
This data is used solely for the purpose of acquiring statistical information (anonymous therefore) and to verify the correct functioning of the Websites. No data deriving from the web service will be communicated or disseminated, except to fulfil obligations required by the law, regulations or EU legislation. 

2) Data voluntarily provided by users/visitors 
Should users/visitors connecting to the Websites of Volkswagen Group Italia S.p.A. send their personal data to access certain services or to make requests via e-mail, such data shall be acquired by VGI and/or third parties together with which VGI could provide the service requested by the user/visitor; such data will be used exclusively to respond to the request, or to provide the service in accordance with this Policy and the specific privacy policies provided on accessing individual services. 
Personal data expressly provided by users/visitors will be communicated to third parties only should this be necessary to fulfil the requests of said users/visitors, without prejudice to the provisions of the specific policies of individual services.

2.1) Processing for profiling purposes 
With the express consent of the person concerned, VGI may use voluntarily provided data in order to improve the services offered, according to the needs of its customers and in order to obtain information on behaviour and commercial habits in the automotive or financial industry. 
Profiling activity, concerning individuals or groups, may be carried out by processing the customer's identification data, comparing the data identifying the persons concerned with the analytical information concerning their personal sphere (tastes, preferences, habits, needs and consumption choices). 
The data will be processed using electronic and telecommunication means. The processing methods will be pertinent to and not go beyond that necessary for the type of services rendered. 
For the processing of data for profiling purposes, it is necessary to acquire the express and separate consent of the person concerned, who is hereby informed that provision of the same is entirely optional and any refusal will not result in any consequences (other than preventing the processing of data for profiling purposes). 

2.2) Processing for direct marketing purposes 
With the express consent of the person concerned, VGI may use voluntarily provided data for direct marketing activities, to develop studies, research and market statistics; send promotional and informative material; carry out direct sales or for product or service placement; send commercial information; engage in interactive commercial communication. 
For the processing of data for direct marketing purposes, it is necessary to acquire the express and separate consent of the person concerned, who is hereby informed that provision of the same is entirely optional and any refusal will not result in any consequences (other than preventing the processing of data for direct marketing purposes). 
For certain forms of communication by e-mail, fax, automated calling systems and multimedia or text or other types of messages, the need for express and separate consent also derives from special provisions concerning unsolicited or remote sales communications (e.g.: art. 130 of the Privacy Code). Also in these latter cases, the provision of data is entirely optional and any refusal will not result in any consequences (other than preventing the processing of personal data). 

Processing methods

Processing is performed using automated tools (e.g. using electronic procedures and media) and/or manually (e.g. on paper) for the time strictly necessary to achieve the purposes for which the data was collected and, in any case, in compliance with applicable legislation. 

Optional nature of the provision of data

Except for that specified for browsing data, users/visitors are free to provide their personal data. Failure to do so may only involve the impossibility to obtain that requested. 
Data Controller, Processor and Categories in charge of processing 
The Data Controller and Processor is Volkswagen Group Italia S.p.A. with registered office in Verona, Viale G.R. Gumpert 1. 
In addition to VGI employees, the processing of personal data may also be performed by third parties, to which the company assigns certain activities (or part thereof) connected with or instrumental to processing or provision of the services offered. In this case, said parties will operate as autonomous controllers, co-controllers or will be appointed data processors or persons in charge of processing. 

Rights of data subjects

The subjects to whom personal data refers have the right, at any time, to obtain confirmation of the existence or otherwise of said data and to know its content and origin, verify its accuracy or request its integration, updating or rectification (art. 7 of Legislative Decree 196/2003). 
By virtue of this article, users have the right to obtain confirmation of the existence or otherwise of personal data concerning them, even if not yet recorded, and communication of the same in an intelligible form. 

They also have the right to obtain information concerning the following aspects: 
(a) origin of personal data; 
(b) processing purposes and methods; 
(c) logic applied in the event of processing with the aid of electronic tools; 
(d) identification details of the data controller, data processor and the designated representative pursuant to article 5, para. 2; 
(e) subjects or categories of subjects to whom personal data may be communicated or who may become aware of the same in their capacity as designated representative in State territory, data processors or persons in charge of processing. 

Users also have the right to obtain: 
(a) updating, rectification or, when interested, integration of data; 
(b) cancellation, transformation into anonymous form or blocking of data processed in violation of law, including data whose retention is not necessary in relation to the purposes for which it was collected or subsequently processed; 
(c) certification that the operations pursuant to points a) and b) have been brought to the attention, also as regards their content, of those to whom the data has been communicated or disseminated, unless this requirement proves to be impossible or involves a manifestly disproportionate use of resources compared to the right protected. 

Finally, users also have the right to object, in whole or in part: 
(a) for legitimate reasons to the processing of personal data concerning them, even if pertinent to the collection purpose; 
(b) to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communications. 

The rights provided for by art.7 of Legislative Decree 196/2003 may be exercised by writing to Volkswagen Group Italia S.p.A. – Group Press & P.R. – Viale G.R. Gumpert, 1 – 37137 Verona. 

Changes to the Privacy Policy

This Privacy Policy may be subject to change over time – also in relation to the entry into force of new industry regulations, the updating or availability of new services or technological innovations – and therefore the user/visitor is invited to periodically consult this page.

Acceptance of cookies

Certain Websites of Volkswagen Group Italia S.p.A. use cookies or markers, which are technically packets of information sent by a web server (in this case, from this website) to the Internet browser of the visitor/user and automatically stored by the latter on the personal computer. These are automatically resent to the server on each subsequent access to the website. Therefore, for full fruition of such Websites, we recommend that you configure your browser to accept the receipt of cookies. 
Please note that by default almost all web browsers are set to automatically accept cookies. Visitors/users can nevertheless modify the default configuration. As stated above, disabling or deleting cookies, however, could preclude optimal fruition of certain areas of the website or impair the use of services subject to authentication. 
If users/visitors wish to decide case by case whether or not to accept cookies, they can also configure their browser to generate an alert whenever a cookie is saved. 
The cookies used are both persistent (i.e. they remain stored, until expiry, on the hard drive of the personal computer of the user/visitor) and session-based (i.e. they are not stored permanently on the user's/visitor's computer and disappear when the browser is closed). 
Cookies are used to facilitate browsing the website and its proper fruition, to facilitate access to services that require authentication (avoiding users having to re-enter authentication credentials on each access to services), for statistical purposes, in order to know which areas of the website have been visited, as well as, in certain cases, for optimal management of advertising pages and space or to deliver content and advertising in line with choices made by the user. 
Session cookies are used in order to transmit session identifiers required to allow safe and efficient exploration of the website. Session cookies used in the Websites of Volkswagen Group Italia S.p.A. avoid using other information technology techniques potentially dangerous for user/visitor browsing confidentiality and are also used to improve service delivery. 
In addition, cookies can be of the website (used, for example, to know the number of pages visited within the site itself) or of third parties (i.e. generated by other Websites to deliver content on the website being visited). The Websites of Volkswagen Group Italia S.p.A. may use anonymous third-party cookies in order to manage advertising messages in a dynamic and advanced manner. The most popular browsers provide the ability to block third-party cookies, accepting only those of the website itself. Moreover, certain companies that generate cookies on third party Websites offer the possibility to disable and/or inhibit in a simple and intuitive manner only their own cookies, even when these are anonymous, i.e. do not involve recording personal identification data (such as, for example, the IP address). 

Cookie's source: 
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