Strada dei Parchi S.p.A., based in Via Giulio Vincenzo Bona n.105 – 00156 Rome, concessionaire for the management of the A24 and A25 freeways (Torano-Pescara and Rome-Teramo) by virtue of which – among other things – it provides in accordance with the law for the collection of freeway tolls, as the Data Controller, informs you that it will process your personal data for the purposes and in the manner indicated further on.
Processing of personal data means any operation or set of operations, whether or not involving automated processes, applied to personal data or sets of personal data, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, comparison or interconnection, restriction, erasure or destruction.
Personal data means any information relating to an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, with particular reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more characteristic elements of his or her physical, physiological, genetic, mental, economic, cultural or social identity.
Given the foregoing, we therefore inform you that personal data concerning you will be processed, including by extraction from public lists such as the P.R.A. (for vehicles registered in Italy) and the individual registers of the countries of origin (for vehicles registered abroad), such as: name, surname, address of residence, license plate and model of the motor vehicle owned.
Legal basis is to fulfill the toll collection obligations stipulated by the Highway Code (Art. 176 co. 11 to 17 of Legislative Decree 285/1992) as well as Articles 372 and 373 of its implementing regulation approved by Presidential Decree 495/1992.
These data will be processed with the support of paper, computer, even interconnected means for:
(a) to fulfill the purposes of law and contract, so as to verify the correctness of the mileage transits traveled and consequently calculate the correct toll collection in relation to the route traveled;
b) both independently report and give feedback to requests from the Police and the Judiciary regarding the commission of possible administrative offenses and criminal offenses;
(c) ensure safe conditions in the travel of the above highway sections.
The provision of data to the Writer with regard to the points indicated above under (a), (b) and (c) is to be understood as mandatory and does not require the provision of consent as it is underlying compliance with legal regulations.
Likewise, consent must be understood to be freely given for all contractual purposes at the time the user engages the section of highway assigned under concession to Strada dei Parchi S.p.A.
Data collected, processed, and organized in structured databases will not be disseminated and may be disclosed for the purposes specified above and within the limits set forth below:
- to the staff of Strada dei Parchi S.p.A. duly authorized in relation to the tasks assigned to the same and the purposes of the processing of personal data punctually considered;
- to external suppliers of goods and services, duly authorized and appointed as Data Processors;
- to professionals and consultants in legal, administrative, social security, health and insurance matters;
- Police forces and the Judiciary.
The processing of any sensitive data concerning you will involve data strictly pertinent to the purposes specified above and will be carried out in accordance with current legal regulations.
Data (both common and sensitive) will be retained for a period of time not exceeding that required by current legal regulations and for the fulfillment of the expressed purposes, or processed in aggregated and anonymized form for historical and/or statistical purposes.
The data contained in the RMPPs (toll non-payment reports) will be stored, communicated and made available to the other highway Concessionaires for the purpose of fulfilling their obligations under the Convention for the Interconnected Management of the South-Northwest and Northeast Highway Network dated November 12, 1992, as amended, who will process them as Data Controllers, for the sections under their jurisdiction.
These data are, also, processed by Movyon S.p.A. as the External Manager of the data processing service debtor users and recidivist users.
This data will be kept for as long as necessary to obtain toll payments and subsequently in the accounting records of the Writer in accordance with legal obligations on record keeping.
Your personal data will also be collected by Nexi S.p.A., again in its capacity as Autonomous Data Controller, for the purpose of charging the amount of the toll due to the above-mentioned Concessionary Companies, for the transits made on the sections under their respective jurisdiction. In this regard, appropriate information will be provided to you during the payment process.
Any images and videos containing personal data will be retained for a maximum of 72 hours, unless reports or events require their actual use, in which case the same will be retained and made available to the requesting authorities for as long as necessary for the investigations from time to time required by applicable laws and industry regulations.
We also inform you that your personal data will be collected, processed and stored in full compliance with the provisions of the current legal provisions, with the garrison of the security measures from time to time considered adequate and suitable to ensure the integrity, consistency, confidentiality and availability of the same.
Finally, we would like to inform you that Articles 15-22 of EU Regulation No. 679/2016 give data subjects the possibility to exercise specific rights towards the Data Controller, such as access, rectification, erasure, restriction of processing, withdrawal of consent, and portability of data concerning them.
The data subject also has the right to object to the processing. In the event that the right to object is exercised, the Data Controller reserves the right not to act on the application, and thus to continue the processing, if there are compelling legitimate reasons to proceed with the processing that override the interests, rights and freedoms of the data subject.
The above rights may be exercised with a request addressed without formalities to the Data Protection Officer of Strada dei Parchi S.p.A. at the following address: rpd.privacy@stradadeiparchi.it while the Data Processor of Strada dei Parchi S.p.A. for any other request is Lawyer Andrea Patrizi of Quorum Law & Tax Studio contactable at the following address: : apatrizi@qltlex.com
If you would like to contact the privacy offices of the other interconnected highway Concessionaires or learn about their respective Article 13 GDPR disclosures, you can find the addresses of their Data Protection Officers on their institutional websites by typing “Privacy Policy.”
We also inform you that should you feel your rights with reference to the protection of personal data have been infringed, you may lodge a complaint with the Guarantor Authority for the Protection of Personal Data with headquarters in Piazza di Monte Citorio n.121, 00186 Rome.
