This information notice takes inspiration also from Recommendation n. 2/2001 issued by EU Authorities concerning personal data protection. EU Authorities, joined in the Group created by art. 29 of Directive n. 95/46/CE, have adopted the Recommendation on May 17th 2001. Main purpose of this Recommendation is to define minimal requirements to gather on-line personal data and, specifically, modalities, timing and nature of information all treatment holders must provide when users connect to web pages, regardless of the purpose intended for the connection.
INFORMATION NOTICE AS PER ART. 13 LAW DECREE 196/2003
1 - DATA TREATMENT HOLDER
Electrica s.r.l., whose registered office is in Via Privata della Torre 24, 20127 Milano, VAT Number IT08357940157 (hereinafter “Electrica”), is the personal data treatment holder for all persons who have been or can be identified after having accessed the Electrica website.
2 - TREATMENT LOCATION
Treatment of all data connected to services of the website are managed in Electrica registered office as mentioned above. All data are accessed only by technical personnel deputed to data management.
3 - TREATEMENT PURPOSES
Personal data provided by the users when accessing Electrica website services are used for following purposes:
- to allow registration to the website and perform online purchases;
- to manage orders and all related activities;
- to manage any user request such as technical requests, commercial requests, questions on orders’ status and any request for information from a broader perspective;
- to manage accounting and administration or to fulfill any legal obligation.
User data will be handled to third parties only upon explicit permission by the user itself. This does not apply for any case in which data handling is mandatory by law or needed for any purpose enforced by law not having the explicit permission by the user. In such cases user data can be handled to third parties which will treat them autonomously and only for purposes mentioned above (f.i.: if the data are required by Police or Judiciary Authority or any other entitled body).
4 - MANAGED DATA TYPES
As per its normal operational specifications Electrica webserver, managed by a third party, is gathering some personal information implicitly shared within internet communication protocols.
In this category we can have IP addresses, domain names for the workstations used to access the website, addresses in URI (Uniform Resource Identifier) notation for all requested resources, date and time of the request, the numeric code with the answer from the webserver (OK, error, etc.) and other parameters with details on operating system and environment used.
These data are used with the sole purpose of gathering statistic data about usage of the website and to ensure it is working properly as designed. All this information is erased right after elaboration.
Data willingly provided by the users
Sending emails to email addresses linked to the website is allowing Electrica to acquire the email address of the sender, needed to reply, along with any other information which can be determined by the email itself.
Specific synthetic information will be provided through website pages built ad hoc for specific services required by the users.
No user personal data in this case is acquired by the website.
Cookies are not used to gather personal information nor the website is using persistent cookies of any kind or user tracking systems.
Usage of session cookies is strictly limited to manage session related information (mainly consisting in random numbers generated by the server) needed to allow a secure and efficient usage of the website. By doing this Electrica can avoid to use other computer techniques that can possibly harm the privacy or users’ navigation data allowing, at the same time, to not gather any personal user identification data.
5 - DATA SUPPLY
With the sole exception of navigation data, as described above, failing to provide all required data for registration is preventing from registering and, ultimately, from purchasing anything from the website.
However, even if not all required data are provided, it is possible to surf the website.
6 - METHODS OF TREATMENT
Personal data are treated with automated systems for the sole time needed to fulfill purposes for which they have been gathered. Specific security policies are met to prevent any data loss, any usage not allowed by the law and any un-authorized access.
However, Electrica cannot ensure that all security policies concerning website management and data transmission are limiting or excluding any unwanted risk to access or disclose data via devices belonging to the users themselves.
It is always needed for the user’s device to have specific and up-to-date software to enforce data and transmission protection both inbound and outbound. Also, the user’s internet provider should have adopted any needed precautions to enforce security of data transmission along the network.
7 - RIGHTS OF DATA SUBJECTS
According to article 7 law decree 196/2003, each user has the right to get from Electrica the confirmation of data treatment for any personal data which refer to him/her, even if yet not registered, and its handling in a well-readable form.
Furthermore, each user has the right to get from Electrica details concerning origin, purposes and modalities for the treatment of his/her personal data, also the rules applied in case data are treated by any electronic tool, all details concerning whom is responsible for the treatment, details of all categories and subjects to whom this data can be handled or who can become aware of the data being, for instance, responsible for data treatment.
Each user has also the right to get from Electrica:
- update, correction or integration of his/her personal data;
- deletion, anonymization or suspension or his/her personal data treated upon violation of law, including all data for which the conservation is not needed in relation to purposes that brought to data gathering or treatment;
- certification that all operations mentioned in points 1 and 2 have been brought to knowledge, even for that concerns the content, to all subjects to whom data have communicated or handled. This applies with exception of all cases in which such fulfillment is impossible or is implying a great deal of effort if compared to the protected right;
Each user has the right to oppose completely or in part:
- for any legitimate reason, to personal data treatment concerning any of his/her personal information; only if strictly connected to the data gathering purpose;
- to personal data treatment for any purpose related to channeling marketing material or related to direct marketing activities including marketing research and commercial communication.
To exercise above mentioned rights each user can send a specific written request to Electrica using a registered letter with acknowledgement of receipt to which a prompt reply will be provided. Alternatively, an email can be sent to the P.E.C. (certified email address) address firstname.lastname@example.org.
8 - LINK TO OTHER WEBSITES
Electrica is providing links to these websites with the sole purpose of helping the user in search activities, in navigating the website and to ease the link with other content. Using a link is not implying any recommendation or alert to access and navigate these websites, no guarantee is provided concerning content, services or goods sold via these websites.
9 - CONTENT
For further information on personal data treatment Electrica suggest to visit the Authority for personal data protection website which can be reached via this link: http://www.garanteprivacy.it/web/guest/home_en.
For further information on personal data treatment in Electrica please send an email to email@example.com.
10 - APPLICABLE LAW
The Code guarantees that personal data processing is carried out in respect of the fundamental rights and liberties, as well as the dignity of the interested party, with particular reference to the confidentiality, personal identity and right to the protection of personal data.
11 - MODIFICATIONS AND UPDATES
Last updated: 04/08/2017