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The Data Protection Officer (DPO) pursuant to Art. 37 of the GDPR, can be contacted by writing to the PEC address privacyclouditalia@legalmail.it or to the address of the registered office indicated for the Data Controller, or to the telephone number 05751944401.
Clouditalia is the processing controller of the data provided and it is therefore responsible for any updates or alterations of the same, concerning communicated changes. In relation to the processing of your data, you may exercise the rights provided by Article 15 of European Regulation no. 2016/679, and, in particular, inter alia, you have the right:
- to obtain confirmation as to whether or not data concerning you are being processed, even if not yet recorded, and their communication in intelligible form
- obtain an indication:
- of the source of the personal data
- of the categories of personal data concerned
- of the period of storage of personal data or, if this is not possible, the criteria used to determine that period
- of the purposes and methods of processing
- of the logic involved in the case of processing performed using electronic tools
- of the identification details of the controller, processors and data protection officer in accordance with article 37
- of the entities or categories of entities to which the personal data may be communicated or that may come to know of them in the capacity of representative appointed in the State territory, processors or officers
- if the personal data are transferred to a third country or to an international organisation, the right to be informed of the existence of the appropriate safeguards in accordance with Article 46 relating to the transfer
- to obtain:
- the update, rectification or, where appropriate, completion of the data
- the erasure, pseudonymisation or block on data processed in violation of the law, including those whose storage are not necessary in relation to the purposes for which the data were collected or subsequently processed
- the restriction of processing of personal data relating to you or objection to their processing
- to object, in whole or in part:
- for legitimate reasons to the processing of personal data concerning you, even if for the purpose of the collection
- to the processing of personal data concerning you for the purposes of sending marketing material or direct sales or for the completion of market research or sales communication.
- to lodge a complaint with the supervisory authority
The erasure or modification of data will be carried out in line with the technical timescales scheduled for each of the services listed above. You may exercise the rights described above, by sending a request by recorded delivery to the following address: Clouditalia Telecomunicazioni Spa a Socio Unico – Via Piero Calamandrei 173 – 52100 Arezzo; or by certified e-mail to the address nimbus2011@legalmail.it.
Privacy Policy for website visitors
This Privacy Policy aims to describe the management methods of websites managed by Clouditalia Telecomunicazioni Spa a Socio Unico, in reference to the processing of personal data of users/visitors who consult it.
It is a privacy policy provided also in accordance with Art. 13 of European Regulation no. 2016/679, to those who connect to the aforementioned website.
The website indicated above is owned by Clouditalia Telecomunicazioni Spa a Socio Unico (hereafter “Clouditalia”).
The privacy policy is provided by Clouditalia only for websites belonging to it and managed by it and not also for other websites or sections/pages/spaces owned by Third Parties that may be consulted by users via specific links.
Please read this Privacy Policy carefully before sending any type of personal information and/or completing any electronic form found on the website itself.
The data processed and the processing purposes:
Browsing data
The IT systems and software procedures that operate this website acquire, during their normal operation, some personal data whose transmission are implicit in the use of Internet communication protocols.
This is information that is not collected to be associated with identified data subjects, but that, by its very nature, may, through processing and association with data held by third parties, allow for users to be identified.
This category of data includes IP addresses or domain names of computers used by users who connect to the website, addresses in URI (Uniform Resource Identifier) notation of the requested resources, time of the request, method used for submitting the request to the server, size of the file obtained in response, numerical code indicating the status of the response from the server (successful, error, etc.) and other parameters relating to the operating system and IT environment of the user.
These data are used for the sole purpose of obtaining anonymous statistical information on use of the website and to check its correct functioning and they are erased immediately after processing. The data may be used to ascertain liability in the case of hypothetical computer crimes to the detriment of the website: except in this circumstance, at present, the data on web contacts do not persist for more than seven days.
Data provided voluntarily by the user
The optional, explicit and voluntary transmission of your personal data to access certain services, or to make requests via e-mail, involves the subsequent acquisition by Clouditalia of the sender’s address or any other personal data, which will be processed solely to respond to the request or to provide the service.
Cookies
A cookie is a short text that a website you visit sends to your browser. It allows the website to store information regarding your visits, such as the preferred language and other settings. This facilitates your next visit and improves your browsing experience. Cookies play an important role. Without them, browsing the web would be a much more frustrating experience.
Cookies, as defined by the Provision of the Privacy Guarantor (No. 229 dated 8 May 2014) can be of two types:
1) Technical Cookies: technical cookies are those required for providing electronic communication or for information services expressly requested by the subscriber or the user. They are not used for other purposes and are normally installed directly by the owner or manager of the website.
They can be divided into navigation or session cookies, which ensure normal browsing of the website (for example, allowing users to make a purchase or log into restricted areas); analytics cookies, which are similar to technical ones when used directly by the manager of the website to collect aggregate information on the number of users and on how they visit the website; functional cookies, which allow the user to browse the website according to a series of selected criteria (e.g., language, products selected for a purchase) in order to improve the service provided.
The installation of these cookies does not require the users’ prior consent, notwithstanding the obligation to provide the information notice pursuant to art. 13 of the Privacy Code.
2) Profiling cookies: profiling cookies aim at outlining user profiles and are used to send advertising messages in line with the preferences expressed while browsing the net. Given the particular invasiveness of these devices, European and Italian standards have established that users must be suitably informed about their use and express their consent.
How does Clouditalia use cookies?
Technical cookies
This refers to cookies used specifically for the proper functioning and use of our sites. The use of so-called session cookies (which are not stored permanently on the user’s computer and disappear when the browser is closed) is strictly limited to transmitting the session identifiers (consisting of random numbers generated by the server) necessary to enable the secure and efficient navigation of a site. The so-called session cookies used on Clouditalia sites avoid the use of other informational technologies that could compromise users’ privacy and don’t allow for the acquisition of the user’s personal identification data.
Analytics cookies
In order to understand how our visitors use a site, we employ services offered by Google and Google Analytics to collect, aggregate and analyse data in order to better understand the website’s modes of use. These cookies only collect anonymous data and have a limited shelf life. The information collected is used, for example, to track and analyse site usage, improve its functionality and choose content and layout more accurately in order to meet the visitor’s needs. If for any reason you would prefer that these specific cookies were not activated, Google provides a free downloadable opt-out add-on for all major browsers (see. https://tools.google.com/dlpage/gaoptout). The absence of these cookies may affect some of the website’s features.
Cookie profiling
These are cookies used to send advertising messages in line with the preferences expressed by the user while web browsing. They can be delivered by our servers or by third parties through our website. Companies that offer or advertise their products through this site may assign cookies to the users’ terminals. The categories of cookies and the personal data processing method used by these companies are regulated according to the information supplied by these compagnie.
How to deny and delete cookies
Most browsers outline, usually in the help menu, how to accept or not accept new cookies, how to make sure the browser notifies you when you receive a new cookie and how to disable cookies altogether, denying, in this way, consent for the use of the same. In addition, you can disable or delete similar data used by browser add-ons, such as Flash cookies, by changing the add-on’s settings or by visiting the manufacturer’s website. The delivery of all cookies, both first and third party, can be deactivated entirely by changing your browser’s settings. It is worth noting, however, that this could make certain sites unusable as you would be blocking cookies essential for the website’s functionality. Each browser has different settings for disabling cookies, below are links to the relevant instructions for common browsers.
Processing methods
Personal data are processed using automated instruments (e.g. electronic procedures and media) and/or manually (e.g. hardcopy) for the period of time strictly necessary for fulfilling the purposes for which the data were collected. In any instance, they will be processed in compliance with the applicable standards in force.
Clouditalia complies with the standards in force to prevent the loss of data, illicit or improper use and unauthorised access.
Optional data provision
In addition to that specified for navigation data, users/visitors are free to provide their personal data. Failure to provide data may make it impossible to provide the requested service.
Legal obligations
The personal data indicated above can be processed to fulfil legal obligations for a set period of time. Personal data can be processed to ascertain responsibility in the event of computer crimes to the detriment of the website or of investigations by the Judicial Authorities. In such a case, the period for which these data are stored depends on the duration of the investigations.
Telephone fundraising pursuant to art. 13 of Italian Law Decree 149/2013 and processing of personal and sensitive data
Dear Customer, This is to inform you about the legislative changes concerning fundraising for SMS and telephone campaigns promoting political participation.
Art. 13 of Italian Law Decree No. 149 of 28 December 2013, amended by art. 1, paragraph 1 of Italian Law No. 13 of 21 February 2014, establishes that the “fundraising campaigns conducted by telephone, SMS, or other related telecommunications methods are regulated by a self-created set of rules approved by telephone providers authorised to provide public electronic communication services, in accordance with the guidelines established by the telecommunications authorities. This fundraising method constitutes a charitable donation and the charge, carried out in whatever form by the entities providing telephone services, of the amounts allocated by their customers to the aforementioned campaigns are excluded from the application of the value added tax.” Following this provision and Resolution No. 56/15/CIR adopted by the telecommunications authorities, on 10 March 2016, the Data Protection Supervisor has adopted the provision concerning “fundraising pursuant to art. 13 of Italian Law Decree 149/2013 and sensitive data processing” – Provisions Registry No. 109 of 10 March 2016 – aiming at clarifying the methods for acquiring the consent of the interested parties and providing technical insights into the data processing related to the fundraisers in question. Due to their connection – even merely potential – between the donor and the beneficiary, the data resulting from fundraisers may reveal the opinions and political preference of customers who make these donations. Therefore, these are considered sensitive data, as defined in art. 4, paragraph 1, letter d) of the Italian Privacy Code and, as such, they have special guarantees, including the written consent of the interested party. With said provisions, the Data Processing Supervisor has provided for the possibility for telephone providers to acquire said consent from users through simplified methods. In line with that established by the Data Processing Supervisor, for fundraisers conducted via:
a) Sms As the personal data holder, the Provider will forward a message containing the request for your informed consent to the processing of your personal and sensitive data to your number from which the donation procedure was triggered. Your subsequent confirmation SMS constitutes, as far as this specific activity is concerned, a suitable method for expressing your consent to the processing of personal and sensitive data.
b) Phone calls from landlines As the personal data holder, the Provider will provide a voice message containing the request for your informed consent to the processing of your personal and sensitive data to your number from which the donation procedure was triggered through the pressing of a specific key. Your subsequent pressing of that specific key constitutes, as far as this specific activity is concerned, a suitable method for expressing your consent to the processing of personal and sensitive data.
Pursuant to art. 13 of Italian Legislative Decree 196/03, hereinafter the Privacy Code, the Provider, as the personal data holder, provides you with the disclaimer below concerning personal data processing in connection to donations to political parties via phone credit deduction/invoicing for which your written consent is required as described above.
1) Contractual purposes related to donations to political parties – Mandatory provision of data
Clouditalia will process your personal data, resulting from the donation to a political party via phone credit, for the sole purposes related to the handling of the donation. In particular, your data will be processed for the purposes connected to (i) your identification as a Clouditalia customer; (ii) charging the cost of your donation to your invoice or deducting it from your credit; (iii) customer support, as well as (iv) litigation management (v) notification of your donation to the chosen political party, including communication of your details (name, surname, residence address, date and place of birth) and amount donated, as established by Resolution 56/15/CIR of the telecommunications authorities. In addition to the purposes above, your data will be processed to meet all obligations provided by law, regulations and EU standards. As stated above, your personal data may include those identified as sensitive according to art. 4, letter d) of the Privacy Code. In such a case, Clouditalia will process these data only after obtaining your explicit consent through a simplified method, as described in the Data Processing Supervisor “Fundraising pursuant to art. 13 of Italian Law Decree 149/2013 and processing of sensitive data” – Provisions Registry No. 109 of 10 March 2016. Non-provision or the provision of partial or incorrect data and the consent to personal and sensitive data processing through a simplified method will make it impossible for Clouditalia to process the donation successfully.
2) Processing methods and logic
Personal data are processed with automated instruments (e.g. using electronic media and procedures) and/or manually (e.g. hardcopy) and in compliance with the applicable standards in force. In particular, Clouditalia informs you that your personal data: (i) will be stored for the period of time strictly necessary for fulfilling the purposes described above and, in any event, for the period provided by law; (ii) will be protected by the adoption of minimum security measures, which reduce the risk of data loss, unauthorised access, unauthorised processing or processing nonconforming to the purposes of their collection; (iii) only pertinent data necessary for pursuing the purposes above will be processed.
3) Categories of persons to whom the data may be communicated or that may gain knowledge of them as data holders or processors
In addition to Clouditalia employees, your personal data may be processed by third parties to whom Clouditalia entrusts some of the activities (or part of them) to pursue the purposes described in section 1). In such a case, these third parties will operate as autonomous data holders or will be appointed as data processors. Clouditalia will provide all third-party data processors with operational instructions, with particular reference to the adoption of minimum security measures to ensure data, which will be processed solely to respond to the request or to provide the service.