Privacy Policy

Personal Data (or Data)
Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes an individual identified or identifiable.

Usage Data
This is information collected automatically through this Application/Website (also by third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application/Website, the addresses in URI (Uniform Resource Identifier) ​​notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User
The individual who uses this Application/Site who, unless otherwise specified, coincides with the Data Subject.

Data Subject
The individual to whom the Personal Data refer.

Data Processor (or Processor)
The individual, legal entity, public administration and any other body that processes personal data on behalf of the Data Controller, according to what is set out in this privacy policy.

Data Controller (or Controller)
The individual or legal entity, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures relating to the functioning and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application/Website
The hardware or software tool through which the Personal Data of Users are collected and processed.

Service
The Service provided by this Application/Website as described in the relative terms (if available) and on this website/application.

European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

Cookie
Cookies are Tracking Tools that consist of small portions of data stored in the User's browser.

Tracker
Tracker refers to any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allows tracking Users, for example by collecting or saving information on the User's device.

Legal references
This privacy statement has been prepared on the basis of EU Regulation 2016/679.
 

Unless otherwise specified, this privacy statement applies exclusively to this Application.

HMS Srl
Viale Monte Santo 1/3
CAP 20124 - Milano – (MI)
P.IVA e C.F. IT10825870966

Email address of the Data Controller: info@hms.autos

The Personal Data collected by this Application/Website, independently or through third parties, include the following: Cookies; usage data; email; forename; surname; telephone number; address; city. 
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application/Website.

Unless otherwise specified, all Data requested by this Application/Website are mandatory. If the User refuses to disclose them, it may be impossible for this Application/Website to provide the Service. In cases where this Application/Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory are invited to contact the Data Controller.

Any use of Cookies - or other tracking tools - by this Application/Site or by the owners of third-party services, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application/Site and guarantees that he has the right to communicate or disseminate them, releasing the Data Controller from any liability towards third parties.

Processing method
The Data Controller adopts the appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or electronic tools, with organisational methods and with logic strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Application/Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, couriers postal services, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of data processing
The Data Controller processes the Personal Data relating to the User in the event that one of the following conditions exists:

• the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorised to process Personal Data without the User's consent or another of the legal bases specified below, provided that the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• the processing is necessary to fulfil a legal obligation to which the Data Controller is subject;
• the processing is necessary for the execution of a task of public interest or for the exercise of public powers with which the Data Controller is invested;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and, in particular, to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Location
The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, you can contact the Data Controller.

The User's Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the processing location, the User can refer to the section relating to the details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organisation governed by public international law or constituted by two or more countries, such as, for example, the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

The User can verify whether one of the transfers described above takes place by examining the section of this document relating to the details on the processing of Personal Data or request information from the Data Controller by contacting the latter via the contact details indicated at the beginning.

Retention period
The Data are processed and retained for the time required by the purposes for which they were collected.
Therefore:

• Personal Data collected for purposes relating to the execution of a contract between the Data Controller and the User shall be retained until the execution of this contract is completed.
• Personal Data collected for purposes attributable to the legitimate interest of the Data Controller shall be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be erased. Therefore, upon expiry of this term, the right of access, erasure, rectification and the right to data portability can no longer be exercised.

Purposes of processing of the gathered Data

The User's Data is collected to allow the Data Controller to provide the Service, fulfil legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any malicious activity or fraudulent, as well as for the following purposes: displaying content from external platforms; managing contacts and sending messages; contacting the User; interacting with data collection platforms and other third parties; statistics and tag management.

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.
 

Personal Data is collected for the following purposes and using the following services:

Contact User

Contact via telephone
Users who have provided their telephone number may be contacted for commercial or promotional purposes related to this Application/Website, as well as to satisfy requests for support.
Personal Data processed: telephone number.

Contact form
By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the header of the form.
Personal Data processed: city; surname; email; forename; telephone number.

Mailing list or newsletter
By registering with the mailing list or newsletter, the User's email address is automatically added to a list of contacts to which email messages containing information, including commercial and promotional information, relating to this Application/Website may be sent. The User's email address could also be added to this list as a result of registering with this Application/Website or after making a purchase or using a service.
Personal Data processed: surname; email; forename.
 

Contact management and sending of messages
This type of service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These services could also allow the collection of data relating to the date and time of viewing of the messages by the User, as well as the User's interaction with them, such as information on clicks on the links inserted in the messages.
Personal Data processed: surname; email; forename.
 

Statistics 
The services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of User behaviour.


Analytics
Analytics is a web analysis service provided by Google LLC which uses Personal Data collected for the purpose of tracking and examining the use of this Application/Website, compiling reports and sharing them with other developed services.
Analytics may use Personal Data to contextualise and customise the advertisements of its own advertising network.
Personal Data processed: Usage data; tracker.
Processing location: https://policies.google.com/privacy?hl=en-US – Privacy Policy 

User rights
Users can exercise certain rights with reference to the Data processed by the Data Controller.
Specifically, Users have the right to:

• withdraw their consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data.
• object to the processing of their Data.The User can oppose the processing of his Data when it takes place on a legal basis other than consent. Further details on the right to object are set out in the section below.
• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
• check and request rectification. Users can check the correctness of their Data and request its updating or correction.
• obtain the limitation of processing. When certain conditions are met, Users can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than the retention thereof.
• have their Personal Data erased or removed. When certain conditions are met, the User can request the erasure of their Data by the Data Controller.
• receive their Data or have them transferred to another data controller. The User has the right to receive their Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its transfer without obstacles to another holder. This provision is applicable when the Data are processed using automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected thereto.
• make a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to objection
When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons connected with their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.


How to exercise rights
To exercise the User's rights, Users can direct a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case, within a month.

Cookie Policy
This Application/Website uses Trackers. To find out more, Users can consult the Cookie Policy.

Defence in court
The User's Personal Data may be used by the Data Controller in court or in the preparatory stages for its eventual establishment for the defence against abuse in the use of this Application/Website or related Services by the User.
The User declares to be aware that the Data Controller may be obliged to disclose the Data by order of the public authorities.

Specific information
At the request of the User, in addition to the information contained in this privacy policy, this Application/Website could provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System and maintenance log
For needs relating to operation and maintenance, this Application/Website and any third-party services used by it may collect system logs, i.e., files that record the interactions and which may also contain Personal Data, such as the User IP address.

Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application/Website as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details in its possession. Therefore, please consult this page frequently, referring to the date of the last modification specified below.

If the changes concern processing, the legal basis of which is consent, the Data Controller will collect the User's consent again, if necessary.