1. THE DATA PROCESSOR OF YOUR DATA
The Data Processor of your personal data is: DB ELETTRONICA TELECOMUNICAZIONI S.P.A., with registered office in Padua, via Maestri del Lavoro 20/1, taxpayer ID and Padua Company Register No. 00710830282, share capital € 270,000.00, in the person of its pro-tempore legal representative.
2. WHY WE PROCESS YOUR PERSONAL DATA
Depending on the products or services you plan to use from time to time, as stated above, we will process certain data rather than others. In principle, the following data will be processed, depending on the specific circumstances:
Your identity data(e.g. first name, last name, language and country from which you interact with us, agreement details, etc.);
Connection, geolocalisation and navigation data(e.g. if you interact with us using your cellular phone);
Commercial information (e.g. if you have subscribed to our newsletter);
Data concerning your tastes and preferences (e.g. if you use our social pages).
Please bear in mind that when we ask you to provide your personal data to us to allow you to use some of our services, some fields will be marked as required because we need these data to deliver the service or product you requested and to enable you to access the requested function. Therefore, these data are needed to ensure that we fully meet our obligations arising from the agreement we entered into with you or to comply with our obligations pursuant to the provisions under the applicable laws or regulations. Failure to provide such data may prevent you from being registered as a user or receiving such services or products or using the requested function.
Depending on the services, products or functions you may request from time to time, your personal data will be processed for the purposes as outlined below:
- Performance of purchase or service agreement. This purpose requires your data to be processed as shown below:
Contacting you to send you updates and information about the products or services you purchased. Managing any returned items after purchase and managing enquiries regarding the availability of goods.
- Fulfilling your requests through customer support service channels.
We will only process the data strictly necessary to handle or fulfil your request.
- Marketing purposes.
This purpose requires your data to be processed as shown below: If you subscribe to our Newsletterand give your consent for marketing and profiling purposes, we will process your personal data to manage your newsletter subscription and send you customised information about our products or services by using different means of communication, including email or SMS.
As a result, please consider that this type of data processing requires your user or customer profile to be analysed in order to establish your preferences and, therefore, decide which products and services best suit your style when we send you such information. For example, based on your purchase and navigation history, we will recommend you products which, in our opinion, may be of interest to you.
You may cancel your subscription to our Newsletter at any time at no cost by accessing the “Newsletter” section of our website as well as by following the instructions given in each communication.
To launch promotional actions (e.g. to hold competitions or forward your list of saved items to the email address you specified).
Posting publicly shared pictures or images on our website or social network channels, subject to your explicit authorisation.
- Quality and usage analysis to improve our services
Please be aware that if you access our website, the underlying IT systems will, during the course of normal operations, collect some of your personal data, the transmission of which is implied in the use of Internet communication protocols. This information will not be collected for the purpose of identifying you, but may lead to your identification if, for example, is combined with other data held by third parties. This category of data includes the IP address and domain name of your computer, addresses in URI (Uniform Resource Identifier) notation of the resources requested, time of request, method used to submit the request to the server, size of the file received in response, numerical code representing the status of the response provided by the server and other metrics related to your operating system.
We use these data solely for anonymous analytical and statistical purposes to monitor usage of our website and its smooth running. These data may be used to investigate and establish liability in the event of cybercrimes against the Services.
- Recruitment purposes
If you complete the “work with us” section on our website or send us your curriculum vitae, please be aware that your data will be processed for staff recruiting purposes only.
3. WHAT ARE THE LEGAL BASES FOR PROCESSING YOUR DATA?
The legal basis for processing your personal data will also depend on the purpose of the specific processing procedure, as outlined in the table below:
- Performance of purchase or service agreement. We need to process your data to ensure performance of the sales or service delivery agreement we entered into with you.
- Customer support We believe we have a legitimate interest in responding to your enquiries and requests for advice using the different contact methods available. We feel you will also benefit from the processing of such data insofar as it allows us to provide you with appropriate support and to answer your questions appropriately. If you contact us, specifically for matters regarding your order or the product/service you purchased, then processing will be required for the purposes of sales agreement performance. If your request relates to the exercise of the rights as shown below or complaints pertaining to our products or services, then the legal basis for the processing will arise from the need to comply with the obligations we are required to meet under applicable law provisions.
- Marketing The legal basis for processing your data for marketing purposes lies in the consent given by you, such as when you accept to receive commercial information or when you give your consent to participating in promotional activities or having your pictures posted on our social network channels. We will also use your consent for the purpose of associating your data with those posted on the social networks so as to show you customised adverts based on your tastes, habits and navigation patterns. Subject to your consent, we may carry out profiling activities (creation of individual or group profiles) using the information we have about you (navigation patterns, purchase preferences and history) and the personal data you provided, such as age group and language, since we believe the processing of such data to be to your advantage as it allows you to benefit from a better user experience and access information based on your own preferences. If you give your consent for marketing purposes, we will be able to send you customised promotional communications.
- Usage and quality analys. Subject to your consent, we may analyse website usage and the level of user satisfaction. This processing procedure will also prove to your own advantage as it aims at improving user experience and delivering a better quality service.
- Recruitment purposes The legal basis for processing your data for recruitment purposes is the consentyou give us when you complete the “work for us” section of our website or send your curriculum vitae.
4. HOW LONG WE WILL RETAIN YOUR DATA
The retention periodof your data will depend on the purpose of the underlying processing, as shown below:
- Performance of purchase or service agreement.
Your data will be processed to the extent as necessary to manage the purchase of products or to provide the services requested by you, including any returned items, complaints or disputes connected with the purchase of a given product or the supply of a given service.
- Customer support
Your data will be processed to the extent as necessary to fulfil your request.
Your data will be processed until you unsubscribe from our newsletter.
The data collected with your consent for profiling and marketing purposes will be retained for a period of 8 years, upon expiration of which they will be automatically erased or de-identified in a permanent and irreversible manner.
- Usage and quality analysis
Your data will be processed on an occasional basis during a certain action or survey on quality or until your navigation data are de-identified.
- Recruitment purposes
Your data will be processed for a period of 2 years.
5. WHO WE SHARE YOUR DATA WITH
- Companiesdistributing our products.
- Financial institutions.
- Technological service providers.
- Logistic, transportation and delivery providers and partners.
- Customer support service providers.
- Marketing and advertising providers and partners.
- Consultants and freelancers.
To ensure service efficiency, some of the aforesaid providers are based outside the European Economic Area in countries that do not provide the same level of data protection as the one provided by the European Union. In such cases, your data will at any rate be transferred with appropriate guarantees and in compliance with data security provisions. Your personal data may also be accessed for processing purposes by our duly authorised personal. The relevant authorisation is issued based on the actual need to access your data for the discharge of the required tasks.
6. YOUR RIGHTS TO THE DATA YOU PROVIDE
We will keep your personal data confidential and ensure that you will be allowed to exercise your rights. You may exercise your rights entirely free of chargeby sending us an email to email@example.com, simply stating the reason of your request and the right you intend to exercise. If proof of your identity is deemed as necessary, we may ask you to produce a copy of a document certifying your identity. More specifically, regardless of the purposes or legal bases under which we process your data, you are entitled to the following rights:
- Obtain access to your personal data held by us and seek rectification, erasure, limitation of and objection to their processing if such processing is carried out in an automated manner based on consent or for contract performance;
- Withdraw your their consent to the processing of your data at any time without affecting the lawfulness of the processing based on the consent given prior to any such withdrawal;
- Lodge a complaint with the Supervisory Authority governing the protection of personal data.