Unica Privacy e Cookie Policy
 

1. Premise
   Whenever you use the “Lamborghini Unica” app or its services (hereinafter the “App” and the “Services”, we collect information about you and your personal data. In compliance with the General Data Protection Regulation n. 679/2016 (“GDPR”) and the applicable local law (collectively the “Privacy Laws”) we drafted this document (hereinafter the “Privacy Policy”) in order to specify which personal date we collect, the purposes and the methods of processing of personal data as well as the security measures we implemented in order to protect them.
    
2. Source of data and purposes of processing
   2.1 Navigation data
   During their normal functioning, the systems running the App collect some of your personal data whose conveyance is necessary for the usage of the Internet communication protocols. Such information are not collected for identification purposes, but may lead to your identification if, for example, they are combined with data collected by third parties. Such data include your device’s IP address and domain name, URI (Uniform Resource Identifier) addresses of the requested resources, time of the request, request method, size of the file received, standard response codes, and other parameters related to your operating system. We use such data exclusively to retrieve anonymous statistical information on the usage of the App and to monitor its correct functioning. Data may be used to ascertain responsibility should any computer crime relating to the Services occur.
   
   2.2 Registration information and further information
   Usage of the App requires the creation of a personal account. Upon creation of the account, you are asked to fill in the following information:
   • First and last name,
   • Email address,
   • Phone number.
      
   Using the App, you may also provide us with:
   • Additional personal information (including mailing address, data of birth, picture, job, language, hobbies, etc.)
   • Vehicle information (including VIN, model, date of purchase, etc.),
   • Information related to the usage of our products and services (including custom settings, purchase history, etc.).
   Should you want access to the list related to closest dealer:
   • Geolocation data (your own device's geographic location on a map)
      
   Should you collect, process and provide us with information related to third parties, you need to comply in accordance with the Privacy Laws and, therefore, provide such third parties in advance with information on the processing and record their free and express consent, if necessary.
   
   2.3 Purposes of processing
   Providing us with the aforementioned information is necessary in order to create an account, and thus use the App and its services and functionalities. Your refusal to provide us with such information would prevent you from using the App or some of its services. Providing us with additional information, such as uploading a picture, not strictly related to the creation of an account is discretionary. Your refusal to provide us with such information will not prevent you from using the App and its services. Collection of the abovementioned information is connected to the pursuance of the legitimate interest of Automobili Lamborghini S.p.A.  to provide services through the App, save for the case in which a picture is uploaded for which we will ask your prior consent.
   
   2.4 Additional purposes of processing
   Subject to your consent, we will use the information you provided us with also for purposes other than those listed above. Such additional purposes include marketing purposes related to market research and the shipping of promotional material on products, services events offered by us by means of both automated tools (email, sms, mms, fax, autoresponder) and non-automated tools (mail, phone). Subject to your express consent, we will use the information related to your location (geolocation data) for the sole purposes of allowing you to access the list of dealers closest to you.
   Providing the information for the above mentioned purposes is discretionary. Your refusal to provide us with such information will not prevent you from using the App, but it would prevent us from pursuing the above mentioned purposes, for example preventing us to show the nearest dealer or from emailing you with advertising. You will be free to revoke your consent to the collection and processing of personal data, including for marketing and market research purposes, or choose the means through which receive such marketing material, by changing your account settings or emailing us at privacy@lamborghini.com or at the Data Protection Officer’s email dpo@lamborghini.com.
   
   2.5 Information collected using cookies and other technologies
   Our App uses cookies and other information reading and archiving technologies on the user’s device for example for the purpose of statistical analysis. We do not use cookies which have the capability to run programs on your devices nor send viruses, or that allow any kind of control on your devices.
   In accordance with the provision issued by the Italian Data Protection Authority on May 8, 2014, please be informed that we implemented tracking technologies (analytics) on our App for the purpose of, for example, collecting statistical and aggregate information on the number of users and how such users use the App.
   Our App does not use profiling cookies, either first-party or third-party, with the purpose of creating profiles related to users and used for the purpose of sending and showing advertising messages consistent with the preferences expressed by the user during his/her usage of the App.
   Please find below a table listing the cookies used by our Services.

   Type	Name	Duratation
   First-party cookie	N/A
   Third-party cookie	Google Analytics for Firebase https://firebase.google.com/support/privacy/	60d

3. Methods of processing and storage of data
   We process your personal data either with both automated and non-automated tools, and in any case in compliance with the security requirements requested by applicable laws. Security measures include contractual instruments with all contractors (e.g. service provider) or agent in order to ensure protection of security and confidentiality of your personal data in accordance with the provisions set forth by the Privacy Laws.
   
   Your personal data will be kept as long as your account will be active. After the deletion of your account, we will keep your personal data only if necessary in order to comply applicable law and regulatory obligations, to protect our rights, prevent frauds or enforce this Privacy Policy. With specific reference to the protection of our rights before the competent courts, please note we shall retain personal data for a period of ten years from the date of the deletion of the account, as provided for by the ten-year prescription period set forth in article 2946 of the Italian Civil Code. 
    
4. Scope of disclosure
   4.1 Internal and external disclosure of personal data
   Your personal data will be processed internally only be people authorized to the processing or data processors. Personal data will not be disseminated. In particular, your personal data may be disclosed to the following type of external entities: service providers (both technical and professional) and legitimate recipients under applicable law. Should we be subject to a reorganization or takeover of the company or parts of it, we will disclose your data to third parties involved in the process. Each third party involved in such a process which will receive your data may use such data in compliance with this Privacy Policy. You can contact us at the addresses specified in article 6 below in order to obtain an updated list of the processors, as well as the recipients of your personal data.
   
   4.2 Data transfer abroad
   We may transfer your personal data outside Italy to third parties located in the European Union. Such transfer is free since all countries of the European Union ensures an adequate security level.
   However, we may transfer your data also to third party countries, not belonging to the European Union which do not guarantee the same security level, for the purposes specified above. Please note that such data transfer to third party countries will always comply with the Privacy Laws, i.e. subject to your consent, if necessary, or by implementing of any and all further measures which may be required in order to ensure the safety of the transferred data. Such measures include possible agreements based on the standard contracting clauses developed by the European Commission.
    
5. Data subject rights
   You can exercise your rights under the Privacy Laws at any time, including e.g. access the data, check its content, source, accuracy, request updates, changes, deletion, object to the processing or  restrict the processing, or request data portability. You can exercise such rights by contacting us at the address specified in section 6 below.
    
6. Data controller and processor
   The App and the Services are managed by Automobili Lamborghini S.p.A., with registered office in Via Modena 12, 40019 Sant’Agata Bolognese (BO), Italy, email: privacy@lamborghini.com which acts as data controller. The Data protection officer is domiciled in the Data controller’s offices and can be contacted at the following email address: dpo@lamborghini.com.