Privacy Policy

Privacy Policy Notice pursuant to Legislative Decree 196/2003 and Article 13 of European Regulation 679/2016 (GDPR)

TELEMA S.P.A. (VAT 00977120336), in the person of the legal representative pro tempore, with operational headquarters in Via Carlo d’Adda 9/A, Milan, Italy, and registered office in Via Salvoni, 60, Frazione Quarto, Piacenza, Italy, as Data Controller and company of Telema Group, belonging to Telema Holding S.r.l., informs you that, in compliance with Italian Legislative Decree 196/2003 and European General Data Protection Regulation 679/2016 (hereinafter ‘the GDPR’ or ‘the Regulation’), which regulates the protection and transfer of personal data, your personal data shall be processed in accordance with the aforementioned legislation and with the principles of fairness, lawfulness, proportionality of interests, transparency and the protection of your privacy and rights, for the purposes, with the methods and according to the terms stated below.

1- Purposes, methods and legal foundations of the data processing

This Privacy Policy applies exclusively to the online activities of this website and is valid for its visitors and users. It does not apply to data collected through channels other than this website. The aim of the Privacy Policy is to provide utmost transparency regarding the data that this website collects and uses.

Your personal data will be processed exclusively for purposes strictly connected, instrumental and necessary for the fulfilment of obligations inherent in your relations with our company, as detailed below.

The processing of personal data is performed by way of the operations indicated in Legislative Decree 196/2003 and Article 4, No. 2 of the GDPR, namely: collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The processing of personal data will be performed by the means of information technology by the Data Controller, appointed Processors and authorized parties operating under every precautionary measure to guarantee the security and confidentiality of the data.

The data will be conserved by the Data Controller and by Processors appointed by the Data Controller. The servers and/or instruments used to conserve your data are managed in compliance with the guarantees set out in the GDPR.

In any case, your personal data will be conserved and processed within the borders of the European Economic Area, and may be transferred out of such borders only under explicit consent and in compliance with the guarantees set in the GDPR. In order to guarantee an adequate level of protection and security, you, the Data Subject, may request at any time further information on the data and countries concerned by writing to the email address: privacy@telemait.com.
In particular, the data collected through this website, such as your name, surname, email address, company name and occupation, may be transmitted to companies of the Telema Group in order to provide the most efficient commercial management possible.

In the case of conferment by you of comments and/or personal data for the request of information and/or of specific user services (by way of example and not limited to: requests for commercial information, registration with our portal, subscription to our newsletter), such data is deemed voluntarily provided by the user at the moment of request of the service. By inserting a comment or other information on a page of the website, the user explicitly accepts this Privacy Policy.

This website may process some personal data according to the legitimate interests of the Data Controller as provided for by Legislative Decree 196/2003 and Article 6 of the GDPR.

The collected data will be used exclusively for the provision and for the time necessary for the provision of the requested service.

The information that the users of the website deem to make public through the services and tools made available to them are provided by the individual users knowingly and voluntarily, thus exempting this website from related liability regarding the violation of legislation. It falls within the responsibility of the individual user to obtain the necessary permission for the provision of the personal data of any third parties or contents protected by national and international legislation.

The data collected by the website during its operation is used exclusively for the purposes stated above and is conserved for the time strictly necessary for the performance of the specified activities. In any case, the data collected by the website shall not, for any reason, be provided to third parties other than those expressly authorised and designated, except under the legitimate request of judicial authorities and in cases exclusively provided for by law.

2- Nature of the collection of the data and consequences of failure to provide the data
As many other websites, this website makes use of log files in which information collected automatically is conserved during user visits. The information collected may include the following:
Internet Protocol (IP) address;
    - Type of browser and device settings used to connect to the website;
    - Internet Service Provider (ISP) name:
    - Date and time of the visit;
    - Entry (referral) and exit web page;
    - The number of clicks performed on the website.

The aforementioned information is processed automatically and collected exclusively in aggregate form for verification of the correct functioning of the website, for security reasons and for the legitimate interests of the Data Controller as provided for by applicable legislation.
For security reasons (e.g. for spam filters, firewalls and virus detection), the data collected automatically may include personal data such as the user’s IP address, which may be used, in accordance with applicable legislation, to block any attempt to harm this website or other users, or, in any case, any harmful or unlawful activity. Such data shall never be used for the identification or profiling of the user, but only for the protection of the website, of its users and of the legitimate interests of the Data Controller.

With the use or consultation of this website, visitors and users explicitly approve this Privacy Policy and consent to the processing of their data in relation to the purposes and methods indicated below, including any disclosure to third parties if necessary for the provision of a service. The provision of the data and therefore consent to the collection and processing of the data is optional. However, failure to give consent may lead to the impossibility to provide certain services and may compromise the browsing experience.
Consent for the use of your data for marketing and/or commercial purposes (e.g. the sending of e-mails and/or communications with promotional or commercial offers on goods and services) is optional and requires, in addition to the provision of your personal data, an explicit request from you to be made through the opt-in function present on the website.

The data provided may also be used to send invites to events organised by Telema S.p.A. or by other subsidiaries of the Telema Group.
This website also makes use of cookies. Regarding the handling of data via cookies, please click on the following link to read the relative Cookie Policy.

3 - Retention times
The Data Controller, appointed Processors and authorized parties will retain the data for the time necessary to fulfil the purposes stated above, and, in any case, for non more than 10 years from the termination of the business relationship, in cases provided for or required by applicable legislation.
Regarding the provision of your data for the receipt of commercial information, newsletters and periodic communications, your data will be retained until you unsubscribe from such service.

4- Communication and disclosure of the data
The personal data collected on the website will not be communicated, sold or transferred to third parties, except in cases provided for by law and without prejudice, in any case, to the communication of data to third parties expressly appointed to perform certain services, within the ambit of the activity of the Data Controller, and/or, in general, in its interests, acting in their capacity as autonomous data controllers and/or appointed processors, and without prejudice to the communication and/or disclosure of the data requested, in accordance with law, by police forces, judicial authorities, information and security organisations and other public entities for the purposes of the defence or security of the state or of the prevention, detection or prosecution of criminal offenses.
In particular, your personal data, for the purposes of the execution of the contract or of the services requested by you, and for the purposes stated above, may be communicated to the following parties:
    - All natural and legal persons (by way of example but not limited to: legal consultancies, subsidiaries belonging to the Telema Holding Group, couriers and shippers, data processing centres, IT consultants, suppliers, etc.) in cases where communication is necessary for the purposes stated above;
    - Our consultants and employees specifically appointed within the ambit of their duties.
    - IT platforms and providers for the sending of newsletters;
    - The Commercial Division of Telema S.p.A., which may contact the user regarding products or services in which interest has been expressed;
    - The Marketing Division of Telema S.p.A. for direct and indirect marketing communications.

The Data Protection Officer (‘DPO’), if appointed by the Data Controller Holder on a voluntary basis, as well as the names and number of appointed Processors may be subject to change. We therefore recommend consultation of the dedicated page on our website for updated information, using the link www.telemait.com, or by contacting +39 02 833821 or privacy@telemait.com.

5- Rights of the Data Subject
By calling the number +39 02 833821 or by writing to privacy@telemait.com, you may, at any time, exercise your rights, under the GDPR, as Data Subject in relation to the Data Controller. Such rights are summarized below for your convenience.
The data subject shall have the right to obtain confirmation as to whether or not personal data concerning you is or will be processed, and, where that is the case, its communication in an intelligible form.
The Data Subject has the right to obtain information on:

    - The origin of the personal data (with particular regard to data not collected from the data subject, and, in case of any data transfer to a third country, to the existence of adequate guarantees pursuant to Article 46 of the Regulation);
    - The purposes and the methods of the processing of the data;
    - The logic applied in case of processing carried out with the aid of electronic instruments;
    - The identity and the contact details of the Data Controller, appointed Processors, and, where applicable, of the Data Controller's Designated Representative;
    - The recipients or categories of recipients to whom the personal data may be communicated or disclosed Designated Representative within the state territory, appointed Processors and authorized partiesThe categories of personal data being processed;
    - The period of retention of the data and the criteria used to determine such period;
    - The existence of automated decision-making processes, with particular regard to profiling, and the logic applied by such processes;The right to obtain a copy of the personal data being processed.

The Data Subject also has the right to request:
a) The updating, rectification, or where it is in his or her interests, the completion of incomplete data;
b) The erasure, transformation into an anonymous form or restriction of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data has been collected or subsequently processed;
c) Notification that the operations referred to in letters a) and b) have been brought to the attention, also regarding their content, of those to whom the data has been communicated or disclosed, except in cases where such action proves impossible or involves the use of means manifestly disproportionate to the protected right;
d) The portability of data to other parties, for which an explicit request must be made by contacting +39 02 833821 or privacy@telemait.com.
e) Erasure of the data in our archives pursuant to Article 17, Point 1, Letters a) to f) of the

Regulation (with reference to the so-called ‘right to be forgotten’), by contacting +39 02 833821 or privacy@telemait.com.
f) To restrict the processing of the data pursuant to Article 18, Point. 1, Letters a) to d) of the Regulation.

The Data Subject has the right to object, in whole or in part, to the processing of data concerning him or her:
    - For legitimate reasons related to his or her particular situation, even if the processing is relevant to the purpose of the data collection;
    - Regarding the processing of personal data concerning him or her for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communications;
    - Regarding the processing of data referred to in Article 6, Point 1, Letters e) and f), including profiling, on the basis of such provisions.
    - Wherever the processing of data is based on the consent of the Data Subject, the latter has the right to revoke such consent at any time by making an explicit request through contacting +39 02 833821 or privacy@telemait.com.
    - The Data Subject also has the right to lodge a complaint with the relevant Supervisory Authority.
    - The aforementioned rights may be exercised by request addressed to the Data Controller or appointed party via telephone or e-mail to the addresses indicated above or also by registered letter with return receipt.