Privacy Policy
Premise
In compliance with Regulation (EU) 2016/679 (the General Data Protection Regulation, or “GDPR”) and applicable local law (collectively the “Privacy Laws”), we drafted this document (hereinafter the “Privacy Policy”) in order to specify which personal data we collect, the purposes and the methods of processing of personal data, as well as the security measures we implemented in order to protect it.Navigation data
During normal operation, the systems running the App collect certain technical data necessary for Internet communication protocols. This information is not collected for identification purposes, but could lead to identification if combined with other data. Such data includes: user_ID, session_ID, car_ID, hotspot_ID, duration, viewing mode, vehicle type, language, subtitles language, voice, UI_accessibility.
No directly identifiable personal data (name, email, GPS location) is transmitted. Data is associated with a device identifier (user_ID) and a session identifier (session_ID), both generated locally on-device. All identifiers are UUID v4 values generated on-device and no biometric data or user account is involved. The user_ID is persisted on-device to correlate multiple sessions from the same user over time. The session_ID is generated on each app launch and does not persist beyond the current session. Data is transmitted via HTTPS to Google GA4 servers and is subject to the Google Privacy Policy.
Legal basis: legitimate interest in ensuring the security of user accounts and the proper functioning of the App.
Providing us with the aforementioned information is necessary to use the App and its services and functions. Your refusal to provide such information would prevent you from using the App or some of its services.Information collected using tracking technologies
Our App uses tracking technologies for statistical analysis.Type Name Duration First-party cookie N/A Third-party tracking technology Google Analytics for Firebase
https://firebase.google.com/support/privacy/60d Methods of processing and storage of data
We process your personal data using both automated and non-automated tools, always in compliance with the security requirements requested by applicable laws. Security measures are in place with all contractors to ensure protection and confidentiality of your personal data in accordance with the Privacy Laws.
We will retain your data only if necessary in order to comply with applicable law and regulatory obligations, to protect our rights, prevent fraud or enforce this Privacy Policy.Scope of disclosure
7.1 Internal and external disclosure of personal data
Your personal data will be processed internally only by people authorized to process it or by data processors. Personal data will not be disseminated. In particular, your personal data may be disclosed to service providers (both technical and professional) and legitimate recipients under applicable law.
All external parties act as data processors under written agreements ensuring compliance with the Privacy Laws, except where they act as independent controllers.
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 receiving your data will process it in compliance with this Privacy Policy and applicable Privacy Laws.5.2 Data transfer abroad
When we transfer your data to third party countries outside the EEA, please note that some of these jurisdictions may not guarantee the same level of data protection as within the EEA. In such cases, we will adopt adequate safeguards as provided under Articles 44 and following of the GDPR (e.g. the adoption of standard contractual clauses).Data subject rights
Without prejudice to the additional rights that your local laws may reserve to you, pPursuant to Articles 15-22 of the GDPR, you have the following rights, which Lamborghini and/or the Dealer are required to honor. The following are the most important rights you may exercise:
a. to obtain confirmation of whether Lamborghini and/or the Dealer holds your personal data;
b. to be informed of the source of your personal data, and of the purposes and methods of its processing;
c. to request the erasure, updating, correction, or integration of your personal data;
d. to request data portability;
e. to restrict or object to the processing of your personal data for legitimate reasons, including for commercial, advertising, or market research purposes;
f. to withdraw your consent at any time;
g. to lodge a complaint to the competent supervisory authority;
h. to obtain identification details of the data processors and the data controllers (e.g., the Italian Data Protection Authority – Garante per la Protezione dei Dati Personali).
You can exercise such rights by contacting us at the address specified in the section below or via the dedicated contact form at https://www.lamborghini.com/en-en/contact-us.
Furthermore, you can also lodge a complaint with the relevant data protection authority.- Data controller and Data Protection Officer
The data controller is Automobili Lamborghini S.p.A., with registered office in Via Modena 12, 40019 Sant’Agata Bolognese (BO), Italy. The Data Protection Officer (DPO) is domiciled in the data controller’s offices and can be contacted at the following email address: dpo@lamborghini.com.
