PRIVACY STATEMENT


PRIVACY STATEMENT

Pursuant to art. 13 of Legislative Decree no. 30.6.2003 n. 196, Clouditalia Telecomunicazioni Spa a Socio Unico, based in Arezzo in v. Calamandrei 173, as holder of personal data, by its legal representative, informs you that any eventual personal data provided can be processed by Clouditalia, directly or through third parties, in observance of contractual provisions and obligations and to comply with any other obligation laid down by law, regulation or Community legislation. 

"Processing of personal data" shall mean any operation concerning the collection, registration, organization, storage, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, erasure and distribution of such data, including the combination of two or more of these operations. Data will be processed with suitable tools in order to guarantee their privacy and safety. Data treatment can also be done by automated tools to store, manage and transfer the data itself. 

Clouditalia is the Data Controller, therefore it is responsible for the update or modification of provided data in respect to any reported change. With regard to the processing of personal data, a data subject may exercise the rights provided for under Art. 7 of Legislative Decree no.196/2003. Specifically, a data subject has the right to:

  • obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in intelligible form;
  • be informed:
    • of the source of the personal data;
    • of the purpose and methods of the processing;
    • of the logic applied to the processing, if the latter is carried out with the help of electronic means;
    • of the identification data concerning the data controller, data processors and the representative designated as per Section 5, Comma 2;
    • of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State's territory, data processor(s) or person(s) in charge of the processing.
  • obtain:
    • updating, rectification or, where interested therein, integration of the data;
    • erasure, anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
    • certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
  • object in whole or in part:
    • on legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
    • to the processing of personal data concerning him/her where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

Data erasure or modification will be performed in compliance with the technical times envisaged for each aforementioned service. The data subject can exercise the aforementioned rights by sending a registered letter to the following address: Clouditalia Telecomunicazioni Spa a Socio Unico, Via Pietro Calamandrei 173, 52100 Arezzo.

Privacy Policy for site visitors

This Privacy Policy applies to Clouditalia’s family of Web sites and governs data collection and usage at all Clouditalia sites and services.

This notice is given pursuant to art. 13 of Legislative Decree 196/03 - Code for the protection of personal data - to whoever is accessing that site.

The above site is owned by Clouditalia Telecomunicazioni Spa a Socio Unico (“Clouditalia”).

Please note that this policy applies only to Clouditalia Web sites and Web sites that carry the Clouditalia brand, and not to other companies' or organizations' Web sites to which we link.

Please read the complete Clouditalia Privacy Policy before submitting any personal information and / or complete any form on this website.

Processed data and purposes:

Browsing data

Systems and software procedures used in this website collect, during their normal operation, some personal data needed in the Internet protocols.

Such data might - through processing and association with data held by third parties - identify users.

This category of data includes IP addresses or computers domain names, URI (Uniform Resource Identifier) , the time of the request, the method used to submit the request to the server, the size of the file obtained in reply, the numerical code of the status of server reply (successful, error, etc.) and other systems and computers parameters.

These data are used only to obtain anonymous statistics on site usage and to check it works properly and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site: except for this possibility, the data on web contacts do not persist for more than seven days.

Data Collection

Personal data provided by a user in order to access certain services or to make requests by e-mail, will be used by by Clouditalia exclusively for the provision of the service.

Cookie

A cookie is a small text sent to your browser from a web site. It allows the website to store information about your visit, such as your preferred language and other settings. This can facilitate your next visit and increase the usefulness of the site in your favor. Cookies are important. Without them, the use of the Web would be a much more frustrating.

Cookies, as defined by the Act of the Privacy (Nr. 229 of May 8, 2014), can be of two types:

1) Technical Cookies: those used for the transmission of an electronic communication, or to provide the service. They are not used for any other purposes and are usually installed by the website owner or operator.

They can be browsing or session cookies, which guarantee the normal navigation and use of the website (for example allowing purchases or restricted areas login); analytics cookie, similar to technical cookies when used directly by the site operator to collect aggregate information on the number of users and their browsing habits; functionality cookies, which make browsing easier (for example saving the language, preferred products …) in order to improve the service.

For these cookies, prior consent of the user is not required, but there is the obligation to provide the information pursuant to art. 13 of the Code.

2) Profiling Cookies: designed to create user profiles and used in order to send advertising messages based on the users’ preferences. Given the impact that such cookies can have on users’ privacy, Italian and European laws require that users are properly informed 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.

  • Microsoft Internet Explorer
  • Google Chrome
  • Apple Safari
  • Mozilla Firefox
  • Opera
  • Processing methods

    The treatment is done through automated processes (eg. using electronic procedures) and / or manually (eg on paper) for the time necessary to achieve the purposes for which the data were collected, however, in compliance with regulations in force.

    However, Clouditalia observes the current regulations in order to prevent the loss of data, illicit or incorrect use and unauthorized access.

    Optional provision of personal data

    Apart from navigation data, users / visitors are free to provide their personal data. In lack of them, the request might be impossible to fulfill.

    Data processing due to legal obligations

    All the above data may also be processed in order to comply with legal obligations, according to the timeframe set by regulations. Processing may also be requested in order to ascertain responsibility in case of computer crimes against the site and in any case of judicial investigation. In this case, storage time depends on the duration of the investigation activities.


    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 confidentiality and security.