Mile 21 Project
Privacy Notice pursuant to the art. 13 of the EU Regulation n. 2016/679

A. JOINT CONTROLLERS

The Joint Controllers are Altroconsumo Edizioni S.r.l. and Association Altroconsumo (hereinafter "Joint Controllers"), having both their registered office in via Valassina n. 22, Milan (Italy), e-mail: privacy@altroconsumo.it.

B. DATA PROCESSORS

The Joint Controllers have appointed EMISIA S.A., having its registered office in Antoni Tritsi 21
PO Box 8138, GR 57 001, Thessaloniki, Greece, info@emisia.com as Data Processor pursuant to the art. 28 of the EU Regulation n. 2016/679 (hereinafter “Data Processor”) in order to support the Joint Controllers in the elaboration and analysis of data as per point B below.  

C. WHAT PERSONAL DATA WE COLLECT AND WHEN AND WHY WE PROCESS IT

The Joint Controllers collect information about you when you subscribe to Mile 21 Project through the website (hereinafter “Project”).
The information the Joint Controllers collect directly from you is:
- your name and surname
- e-mail address.

However, while taking part to the Project, you will be likely to provide also the following non personal data:
producer of your vehicle, its’ model, powertrain type, engine displacement, engine power, battery capacity (for electric cars only), emissions standard, transmission type, 2WD-4WD, start and stop system availability, official CO2 emission values, official energy consumption value (for electric cars only) (hereinafter “Information”).

While filling your car with fuel, you may be likely asked to provide us also the following Information:
date of refueling/recharge, odometer, type of refueling/recharge (full tank or partial), amount of fuel/energy purchased, cost of refueling/recharge, place of refueling/recharge; 
type of rout (urban, rural or highway), hilly, average single trip length, speed on the highway, start and stop system usage, number of passengers, type of tires, day-time temperature, air conditioner/heater.

The Information will be processed by Processor separately from your personal data, in order not to be directly associated to you.

D. THE PURPOSE AND LEGAL BASIS FOR USING YOUR PERSONAL DATA

The purpose is to take part in the Project, collect data and information about fuel consumption and driving habits in order to accomplish the tasks provided by the European project Mile 21.
The legal basis od such processing is data subjects’ consent while registering to Project’s website.
Without providing personal data and the Information, the participation to the Project is not possible.
Moreover an additional legal ground of data processing is also Joint Controllers’ compliance to agreements executed pursuant to the legal obligations laid under the Project.

E. SHARING PERSONAL INFORMATION WITHIN JOINT CONTROLLERS AND WITH SERVICE PROVIDERS

Your personal information won’t be transferred to any Third Country and it will be shared only for the purposes listed in the present privacy notice with the following parties:
- the Data Processor as defined in the point B, in charge of the analysis only of the Information you provide.

F. RETENTION POLICY

The Project will last until August 2021 (hereinafter “End of Project”).
In order to complete all the tasks of the Project the Joint Controllers will store your personal data and Information for additional 24 months after the End of the Project. 
At the end of the above mentioned period, all your personal data will be erased.

G. SECURITY

The Joint Controllers implement and maintain appropriate technical and organizational security measure, policies and procedures designed to reduce the risk of accidental destruction or loss, or the unauthorized disclosure or access to personal information.

The measures the Joint Controllers and the Processor adopt, include the execution of confidentiality appointment of the employees and staff members and service providers; limiting the access to personal information; destroying the personal information when it is no longer needed for the purposes for which it was collected.
As the security of information depends in part on the security of the computer or device you use to communicate with the Joint Controllers and the security you use to protect user names and passwords, please take appropriate measures to protect this information.

H. DATA SUBJECTS’ RIGHTS

At any moment you can exercise the following rights writing to dpo@altroconsumo.it:
- to access personal information
- rectify or erase personal information
- limit the processing of your personal information
- object to how we use your personal information with regard to the organization of the Euroconsumers International Forum
- obtain a copy personal information
- lodge a complaint with your local Supervisory Authority, but we kindly ask you to attempt to resolve any issue with us before contacting your local Authority.
According to the art. 11 of the EU Regulation n. 2016/679, we may ask you to provide us further information in order to confirm your identity, otherwise we won’t be able to accomplish your request. If your request is manifestly unfounded, we may charge you a fee, where permitted by law.