INFORMATION NOTICE FOR THE PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), we hereby inform you of the following.

This Privacy Notice of the Brivio & Viganò Group describes the types of personal information we collect about our customers, business partners, suppliers, and, in general, every individual or entity with whom we come into contact, the ways we may use it, and the parties to whom we may disclose it. The notice also outlines the measures taken to safeguard your personal information. Furthermore, we explain how you can request us to (i) access or modify your personal information in our possession, (ii) withdraw the consent you previously granted, (iii) opt-out of receiving certain communications, and (iv) address any questions you may have regarding our privacy practices.

JOINT DATA CONTROLLERS

The Joint Data Controllers of personal data are B&V Holding S.p.A., headquartered at Via Bernini 12/14, 20865 Usmate Velate (MB), Tax Code and VAT No. 07184960966; Brivio & Viganò Logistics S.r.l., headquartered at Via Borgo Palazzo 31, 24125 Bergamo (BG), Tax Code and VAT No. 04867640965; Autotrasporti Brivio & Viganò S.r.l., headquartered at Via San Carlo Borromeo 24, 23873 Missaglia (LC), Tax Code and VAT No. 01169070131; Brivio & Viganò Service S.r.l., headquartered at Via Bernini 12/14, 20865 Usmate Velate (MB), Tax Code and VAT No. 13047640969; and Orange Service S.r.l., headquartered at Via Bernini 12/14, 20865 Usmate Velate (MB), Tax Code and VAT No. 12104590968, represented by their respective Legal Representatives (hereinafter also referred to as “We” or the “Brivio & Viganò Group”).

For the purposes of processing explicitly indicated in this notice, they act jointly as Joint Data Controllers pursuant to Article 26 of the GDPR (hereinafter collectively referred to as the “Joint Controllers”) or individually as independent Data Controllers.

BRIVIO & VIGANÒ GROUP DATA PROTECTION CONTACT

Contactable at the administrative headquarters of B&V Holding S.p.A. – email: privacy@brivioevigano.it.

INFORMATION COLLECTED

We may collect personal information from customers, business partners, suppliers, and, in general, any individual or entity with whom we interact (e.g., name, contact details, and payment information) in connection with various activities, such as (i) use of Brivio & Viganò Group websites and applications, (ii) shipping activities, including deliveries and pick-ups, (iii) shipment tracking requests or responses to inquiries, (iv) events we participate in, (v) promotions and other offers, and (vi) calls or web chats (e.g., with customer service) that may be recorded.

The types of personal information we may collect include:

Contact details of individuals and entities (e.g., name, company name, physical address, email address, and phone or fax number);
Shipping information (e.g., contact details associated with the shipment such as the name, residential or business address, email address, and phone number of the sender, recipient, and/or neighbor; proof of delivery signature; customer account number; information provided to us enabling access to locations where we provide service; and information about the content of certain shipments, insofar as an identifiable person can be associated with it);
Information that allows us to verify a person’s identity;
Names, email addresses, and phone numbers of other individuals to whom we are asked to send information;
Information provided in response to surveys;
Username, password, and other credentials used to access Brivio & Viganò Group products and services;
Content and other data published on the official social media pages of the Brivio & Viganò Group and information (e.g., email address and other data you agree to share) collected through apps, tools, widgets, and plugins on social media associated with the Brivio & Viganò Group (including third-party login services such as “Login with Facebook” or interaction buttons provided by the LinkedIn social network);
Images and videos captured by the surveillance systems installed;
The geographic location of the user’s mobile device, in the case of using certain features of the shipping/delivery apps used by the Brivio & Viganò Group;
Payment information (including credit card details or online payment service numbers and billing address) and financial information (e.g., bank account numbers);
Tax code, in cases where you request products or services for which such data is required;
Other personal information that may be provided to us for the purchase of a product or service from the Brivio & Viganò Group.

To provide our services, we also receive personal information about consumers from our customers. The Brivio & Viganò Group may receive personal information from third parties, including public databases, social media, or third-party partners such as analytics or marketing service providers.

When we pick up or deliver a shipment, or provide other services, we may collect data on physical location. This includes, for example, identification data of the actual location associated with a physical address through information such as GPS data, geographic coordinates, latitude and longitude data, and images of various locations.

Furthermore, when the user visits websites, uses apps, or interacts with tools, widgets, or plugins associated with the Brivio & Viganò Group, certain information may be collected through automated means, such as cookies and web beacons. The information we collect in this way includes IP address, unique device identifier, browser features, device characteristics, operating system, language preferences, referral URL, information on actions taken, and dates and times of activity. A cookie is a text file that websites send to a visitor’s computer or other internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A web beacon, also known as an internet tag, pixel tag, or transparent GIF, links web pages or apps to web servers and can be used to transmit information to a web server. Through these automated collection methods, the Brivio & Viganò Group collects and stores clickstream data that indicates usage behavior. We may link certain data elements collected through automated means, such as your browser information, with other information collected about you, to know, for example, if you opened an email we sent you. Additionally, we use third-party analytics tools to collect information about visitor traffic on our websites or company networks. Your browser can tell you how to communicate receipt of certain types of cookies or how to limit or disable other types of cookies. However, we remind you that without cookies, you may not be able to fully enjoy all the features of our websites or services. Both we and third parties (e.g., our advertising networks) may collect personal information about visitors’ online activities over time and across third-party websites when they use our website or social networks.

The Brivio & Viganò Group collects session analytics information, including browsing behavior, click patterns, keystroke sequences, and pages visited, when the user visits company websites or social networks. We and our third-party service providers may also collect, record, and analyze interactions with the website or social network chat feature. This information helps us understand the online activities of our customers, identify usage patterns, provide customer assistance and support, improve website functionality, and fix any errors. This information is also useful to our expert teams in designing better experiences for you.

Third-party app, tool, widget, and plugin providers on the company websites and social networks, such as the Facebook “Like” button, may use automated means to collect information about your interactions with these features. This information is subject to the policies or privacy notices of those providers.

We process names, email addresses, and phone numbers of other individuals to whom we are asked to send information based on the assumption that the person who provided them has obtained them in compliance with applicable law. If this assumption is incorrect, please do not ask us to send information to third parties on your behalf.

To provide services, or to enable the use of our website and social networks, we may need your information, such as addresses for package delivery or your IP address. Additionally, we may be legally required to acquire certain information, such as in the case where a package contains hazardous materials. If such information is required and you do not provide it, we may not be able to offer you our services.

In accordance with applicable law, we may obtain your consent separately before collecting information through automated means such as cookies or similar devices. For more information about the cookies and similar devices we use, please refer to our Cookie Policy available on the website www.brivioevigano.it.

METHOD OF USE OF THE COLLECTED INFORMATION

The legal bases on which we collect, use, transfer, or disclose your personal information are (i) the performance of the contract entered into, (ii) marketing purposes, improvement of our services, and other legitimate business interests such as worker and company asset security, (iii) compliance with legal obligations, and (iv) protection of your vital interests and those of others.

We may process your personal information based on your consent, where required by law. If we ask for your consent, we will inform you of the purposes for which your information is expected to be processed. Please note that if you decide to withdraw your consent, you will not be able to participate in our programs, services, and initiatives to which you have consented, nor benefit from them. We may also use the information we acquire about you in other ways, for which we will provide specific notice at the time of collection.

PURPOSES OF USE OF THE INFORMATION COLLECTED BY THE CO-CONTROLLERS

We may use the information collected for:

Picking up, delivering, and tracking shipments;
Providing products and services requested by users (e.g., logistics services, supply chain management, customs clearance, and financial brokerage services);
Processing and collecting payments;
Providing customer support and responding to users’ requests, questions, and comments, as well as communicating with them;
Sending users tracking updates (directly from the Brivio & Viganò Group and/or our business partners) and helping them select the most convenient delivery options;
Creating and managing user accounts;
Offering users products and services that we believe may be of interest to them;
Providing communications about users’ participation in special events, programs, surveys, contests, prize draws, and other offers or promotions;
Allowing you to post on our blogs and interact with the Brivio & Viganò Group through social media and other third-party platforms you use (such as communication and instant messaging platforms);
Sending information to users’ contacts, if requested;
Processing compensation claims received in relation to our services;
Managing, evaluating, and improving our business (including the development of new products and services, managing our communications, assessing the efficiency of our sales, marketing, and advertising, analyzing and improving our products, services, websites, and social networks, ensuring the security of our networks and information systems, conducting accounting, auditing, billing, reconciliation, and collection activities, as well as improving and maintaining the quality of our services for customers, suppliers, partners, etc.);
Conducting data analysis (including market and consumer research and analysis, trend analysis and profiling, financial analysis, and anonymization of personal information);
Protecting against fraud and other prohibited or illegal activities, claims for damages, and other liabilities, as well as detecting and preventing them;
Complying with legal obligations and our applicable policies;
Assert, exercise, and defend legal rights;
Monitor and report compliance issues.

In addition, we use the information collected online through cookies, web beacons, and other automated means for purposes such as: (i) personalizing user visits to our websites or social networks, (ii) distributing content (including advertising) tailored to the interests of our users and in line with their usage patterns on our websites and social networks, (iii) improving website functionality and user experience, (iv) debugging, identifying, and correcting errors that affect the functionality of our website, (v) providing customer support and assistance, and (vi) managing our business. We may integrate the data collected through automated means with location information (e.g., postal code) to provide content that may be of interest to you. We also use this information to diagnose technical and service issues, manage our websites and social networks, identify users, and collect demographic information about them. We use clickstream data to determine usage habits and how we can personalize our websites and social networks to better meet the needs of our users. Our websites and social networks are not designed to respond to “Do Not Track” requests from browsers.

INFORMATION SHARED

The data will be processed exclusively by the employees of the business functions of the Brivio & Viganò Group responsible for achieving the purposes outlined above, who have been expressly authorized to process the data and have received adequate operational instructions.

We do not sell or otherwise share your personal information, except as outlined in this Privacy Policy. To provide our pickup and delivery services, the Brivio & Viganò Group shares shipping information with third parties such as couriers, recipients, and third-party payers. These third parties are not authorized by us to use or disclose the information, except as necessary to provide services on our behalf or to comply with legal obligations.

We may also share the personal information we obtain with our affiliates, dealers, resellers, and joint marketing partners. These entities, collectively referred to in this document as “Business Partners,” may use the information for the purposes described in this Privacy Policy. We may share location data with our Business Partners and other third parties for purposes such as improving services based on location and developing accurate and up-to-date maps.

The information collected through third-party apps, tools, widgets, and plug-ins (e.g., those obtained through third-party login services or related to your use of the Facebook “Like” button) is gathered directly by the providers of these features. This information is subject to the privacy policies of the feature providers, and Brivio & Viganò is not responsible for their information practices.

Many of our clients rely on us for the supply of their distribution chains, either partially or entirely. Through our shipping and logistics units, we manage these logistics chains, focusing on their optimization, shipping goods, and providing commercial and intermediary services for our clients in Italy. For the provision of shipping and logistics services, we may collect, use, and disclose personal information about our clients’ customers. In these cases, we process the information based on our contract with our client.

We may also disclose information about you: if required by law, regulations, or legal proceedings (such as a court order or subpoena); in response to requests from government agencies, e.g., law enforcement; if we believe the disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer your personal information in the event of the sale of our company or any part of it, or assets (including cases of corporate restructuring, dissolution, or cessation of business).

DATA RETENTION

Your personal information will not be stored for a period longer than necessary for the purposes for which it was acquired or as required by applicable retention policies and/or laws. Our data retention policies reflect the limitation periods set by national law for the Brivio & Viganò Group.

DATA TRANSFERS

We do not transfer your data to third countries outside the European Economic Area (EEA) (e.g., USA). If, for the use of specific services or IT applications, we become aware that your data will be transferred to countries outside the European Economic Area, we will ensure that the transfer of personal data occurs in accordance with the provisions of the GDPR, Title V, Articles 44 and onwards. In particular, the transfer must take place to a third country deemed adequate under Article 45 of the GDPR, in accordance with the decision of the European Court of Justice, or, for third countries not subject to an adequacy decision, the transfer must occur based on Standard Contractual Clauses, under Article 46 of the GDPR, after ensuring that the third country provides an adequate level of protection for personal data.

PERSONAL DATA PROTECTION METHODS

We implement administrative, technical, and physical safeguards to protect the personal information you provide from accidental destruction, loss, alteration, unauthorized access, disclosure, or misuse. Despite the measures taken to ensure that only authorized individuals can access our facilities and systems, the information on the exterior of a package or letter may be visible.

YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATIONS

The data subjects are granted the rights under Articles 15 to 22 of GDPR 679/2016. In particular, the data subject has the right to access their data (Article 15), request correction, updating, or completion (Article 16), and deletion (Article 17), limit the use of their data by the Data Controller (Article 18), obtain a copy in a structured, commonly used, and machine-readable format (Article 20), and object to the processing when applicable (Articles 21 and 22). These rights can be exercised as long as the processing is not mandatory due to legal or regulatory provisions. Requests to exercise these rights should be addressed to the Data Protection Officer at the Co-Controller of the processing B&V Holding S.p.A. at the following email: privacy@brivioevigano.it. If the data subject is not satisfied with the response to their requests, they may file a complaint with the Italian Data Protection Authority, based in Rome, Piazza Venezia n. 11, www.gpdp.it. A citizen of another European Union member state has the right to contact their national data protection authority.

The Co-Controllers of the Processing:

B&V Holding S.p.A.

Brivio & Viganò Logistics S.r.l.

Autotrasporti Brivio & Viganò S.r.l.

Brivio & Viganò Service S.r.l.

Orange Service S.r.l.