Company
Geolocation policy
Information on the use of smart geolocation labels for shipped packages

EU Regulation 679/2016 provides for the right to the protection of personal data concerning natural persons. In compliance with this regulation, our Company informs you of the following:

Purpose and legal basis of data processing: 
The processing of data relating to shipped packages is intended to enable Persico Group companies and its collaborators and/or partners to carry out the following activities:


 

  • Daily geolocation of packages for corporate organization purposes and protection of company assets, from which the geolocation of one or more workers NOT employed or under the direction of Persico may be indirectly deduced.

     

We inform you that, in relation to the aforementioned purpose, data processing may be carried out without the consent of potential data subjects, as it is carried out for our legitimate interest, consisting in managing any delays in goods shipped to the recipient customers, as well as protecting those goods themselves, given their particular value (Article.6.1.f GDPR).


Data processing methods: 
Data processing is carried out electronically through anonymous data collection by the Apple device network twice a day during the shipping process. 
Under no circumstances will the data be processed to monitor the activities of workers at the contracted carriers accompanying the shipped package.


Data dissemination and transfer: 
The data will not be disseminated in any way and, unless required by law, regulation, or EU legislation, or due to technical requirements related to servers and/or IT platforms (in which case, subject to the guarantees set forth in Articles 45 et seq.), will not be transferred outside the EEA.


The parties to whom your parcel geolocation data may be disclosed are the following:

  • Competent authorities, in compliance with legal obligations
  • Professionals, for the purpose of studying and resolving any legal issues relating to the performance of the contract.

     

In this regard, we inform you that:

• Disclosure of data to the categories of parties referred to in point 1 is a legal obligation with which the Data Controller must comply;

• Disclosure of data to the categories of parties referred to in point 2 may be necessary to protect their respective rights in court..


The joint data controllers are: 
Persico S.p.A. with registered office at via Guglielmo Marconi n.7/9, 24027 Nembro (BG), Tel. +39 035 4531711 – e-mail: info@persico.com and Persico Marine S.r.l. with registered office at via Lombardia n.4, 24027 Nembro (BG), Tel. +39 035 520627 – e-mail: info@persicomarine.com



The content of the joint controllership agreement is available upon request. 
Data is not shared with the employer of the individual(s) accompanying the package, except for reasons related to challenging the proper performance of the transport contract.
Data is not shared with the employer of the individual(s) accompanying the package for any purpose of covert monitoring of workers' activities.


Persico's Data Protection Officer (DPO): can be contacted at dpo@studiomlippa.it, tel. 030-2944317.

The internal contact for the processing of your personal data at Persico is: Giuliana Gamba or the provisions of EU Regulation 679/2016, at our company headquarters, at the email address giuliana.gamba@persico.com, Tel. 035-4531696.

Data retention period: 
Geolocation data is overwritten every 5 minutes.
Data collected twice a day is retained no longer than the date the package is delivered to the recipient, unless further retention requirements arise in connection with any disputes regarding the proper performance of the contract or theft/loss of the shipped package.

Complaints
You may lodge a complaint with the Italian Data Protection Authority in any case of unlawful processing of your data. 
You may exercise your rights to access, rectification, erasure, limitation, and objection, as set forth in Articles 15, 16, 17, 18, 19 e 21 of EU Regulation UE 679/2016 by contacting in writing: Persico Marine S.r.l. with registered office in via Lombardia n.4, 24027 Nembro (BG), Tel. +39 035 520627 – e-mail: info@persicomarine.com.