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Privacy Policy ATM Milano Official app 

ATM MILANO APP
PRIVACY POLICY PURSUANT TO ARTS. 13 AND 14 OF EU REGULATION NO. 679/2016 (GDPR)
DATA CONTROLLER AND CONTACTS
The Data Controller is Azienda Trasporti Milanesi S.p.A. (ATM), with registered office in Foro Buonaparte 61, 20121, Milan (Italy). The Data Protection Officer, whom you can contact to exercise your rights under art. 13 and/or for any clarifications regarding personal data protection, can be contacted at the following email address: rpd@atm.it.

PURPOSE OF THE PROCESSING AND LEGAL BASIS
Personal data may only be processed for the following purposes:
1. registering on app ATM;
2. sending the newsletter regarding the events, initiatives, services, activities and conventions of the ATM Group;
3. sending confirmation and summary email regarding the purchase of membership/subscription;
4. sending emails regarding changes in the schedule of specific lines selected by the customer.
5. geolocation services, third party service maps and tracking.
The geolocation services, in the event of the user's consent, are active only when using the ATM Milano app. Geolocation is not saved by the ATM Group and is managed by third-party map providers:
- Google for Android systems (personal data processing information https://policies.google.com/privacy?hl=en-US)
- Apple for iOS systems (personal data processing information: https://www.apple.com/privacy/)
- Windows for Windows systems (personal data processing information: https://www.microsoft.com/en-us/trust-center/privacy)
- Firebase (personal data processing information: https://firebase.google.com/support/privacy?hl=en

The tracking service also allows to choose whether the ATM app can track the user's activities and has the purpose of improving its functionality.
The legal basis is consent for the purposes indicated in points 1), 2), 3) and 4). For the purpose referred to in point 5), there is a specific and not required consent, which allows the user to use all the functionalities of the ATM Milano app.
CATEGORIES OF DATA PROCESSED AND RECIPIENTS
Data processed are ordinary personal data. Personal data are processed by personnel authorized by the data controller and may be communicated to companies that provide goods and/or services related to the processing.

METHODS OF PROCESSING AND POSSIBLE TRANSFER OF DATA
The data are processed only for the purposes mentioned above- and according to the principles of lawfulness, correctness, transparency, accuracy, integrity and confidentiality established by the regulations in force. As a rule, personal data of interested parties are processed by means of computerized and automated tools in order to send communications and news including newsletters and other emails on which the data controllers are registered. The personal data collected will not be transferred outside the European Economic Area.

DATA RETENTION PERIOD
The data collected will be stored until the data subject requests withdrawal and erasure thereof; this will result in erasure from the app and newsletter. If the user wishes to unsubscribe from the newsletter (or the schedule information service for specific lines) but not from the app, he or she may go ahead and use the link available at the end of the newsletter (or the schedule information service for specific lines) under "unsubscribe".

DATA SUBJECT RIGHTS
All the rights of the data subject are guaranteed in accordance with the provisions of Articles 15, 16, 17, 18, 20, 21, 22 and 77 of the GDPR:
• right of access to personal data and all information on the processing carried out;
• right to rectification of inaccurate personal data and integration of incomplete personal data;
• right to erasure (‘right to be forgotten’);
• right to limit the processing of personal data;
• right to data portability;
• right to object to the processing of personal data;
• right not to be subject to a decision based solely on automated processing;
• right to lodge a complaint with the Italian Data Protection Authority in case a violation is thought to have been carried out.

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