ADS Assembly Data System SpA. (hereinafter, ADS), with registered office in Pomezia, Via Laurentina Km. 23.000, pursuant to art. 13 of Legislative Decree n. 196/2003 “Personal Data Protection Code” (hereinafter, the “Code”), provides the Information concerning the processing of personal data in relation to the electronic communication services provided to the User. For what not expressly provided, the provisions of the legislation in force shall apply.
1 – PURPOSE OF THE PROCESSING
The User’s personal data are processed for the following purposes: a) purposes strictly related to the delivery, activation, use and maintenance of the HotSpot and signing of the Agreement; the management of claims and disputes; technical assistance; sending of information and communications concerning the service. This processing also and more specifically concerns the work done by ADS direct and indirect distribution network. The provision of data for such purposes is required for the activation of the Agreement with the User and for its proper management and, therefore, in the absence of some or all of the data necessary for these purposes, it may not be possible to activate the Agreement, the correct and complete activation of the HotSpot and the proper use of the same; b) purposes related to the activity of ADS and / or third-party companies that are its business partners and consisting of: market research, economic and statistics analyses; marketing services, sending advertising/informative/promotional materials and participation in initiatives and offers to reward the Users; interactive commercial communications; identification of consumption habits and trends, improvement of the Agreement and satisfaction of specific User’s requirements. These activities may concern the agreements of ADS or its business partners and can also be performed through an automated calling system, without the intervention of an operator, by mail, including electronic mail, fax and text and MMS messages.The consent to the processing of data and communication to the persons listed below for the above purposes is optional and may be revoked at any time by the User. This, however, without prejudice to the provisions of art. 130, paragraph 4, of the Code; c) purposes related to the fulfilment of obligations under Community and national legislation, in particular laws, regulations and implementable and urgent measures, the protection of public order, the investigation and suppression of crime. In relation to these objectives, one could receive, also at variance with the current regulations regarding the protection of personal data, “institutional” text messages, which may be sent in exceptional or emergency situations related to disasters, natural disasters or other situations of grave and imminent danger to the population. No specific consent is requested for this type of personal data use.
2 – METHOD OF TREATMENT – PRIVACY PURSUANT TO ART. 13 OF LEGISLATIVE DECREE N. 196, JUNE 30, 2003
The User’s data processing is carried out with both manual and electronic or automated tools by ADS and/or third parties that ADS will appoint as responsible and/or processors. The data is kept for the time prescribed by the Code and the regulations. As for the traffic data made by the User, ADS informs that: a) the processing of traffic data necessary to the possible investigation and prosecution of crimes will be made for a period not exceeding the time limits provided by law; b) data processing for service marketing purposes will be performed for the periods provided by law or by contract; c) location data other than traffic data, necessary for the provision of certain services, will be treated in accordance with current regulations, i.e. upon manifestation of specific consent, revocable at any time. Refusal or failure to manifest one’s consent to the processing of personal data for such purposes does not imply withdrawal of previously provided consent.
3 – CATEGORIES OF PERSONS TO WHOM DATA MAY BE DISCLOSED OR TO WHOM DATA CAN BECOME KNOWN DUE TO THEIR POSITION AS LIABLE OR RESPONSIBLE PERSONS
To achieve the above purposes, ADS may need to communicate, in Italy and abroad, including countries outside the European Union, the User’s personal data to third parties, in fulfilment of legal obligations or for conducting activities relevant to the provision of the required services and/or, where applicable, to other companies for the pursuit of the purposes referred to in subparagraph b art.1. These entities belong to the following categories: public authorities and supervision and control authorities; parent and subsidiary companies affiliated to ADS; persons who perform technical or organizational tasks on behalf of ADS; persons who perform services for data acquisition and processing necessary for Users to use services ; entities that provide services for the management of ADS information system; entities engaged in broadcasting, mailing, transporting and sorting of communications to the concerned person; entities engaged in assisting the User (e.g. call centre etc.); entities engaged in data storage and data entry; persons studying and/or providing advisory and assistance services, also legal; persons who carry out market research aimed at determining the level of User’s satisfaction; entities engaged in the promotion and sale of products and services; persons that carry out inspection, auditing and certification of the activities carried out by ADS also in the interest of the Users; persons who provide services for credit risk management and fraud control (such as data processing centres, banks, risk authorities, debt collection companies, law firms); Banks and credit cards issuers; ADS commercial partner. The persons belonging to the above categories shall process personal data as data processing managers or officers or agents, when specially appointed for that purpose by ADS. Personal data may also be available to ADS employees and/or consultants that carry out activities involving the processing of User’s data for the above purposes; these persons shall be specially appointed by the Proprietor as data processing Managers or Officers.
4 – DATA PROCESSING PROPRIETOR AND RESPONSIBLE OFFICERS
The proprietor of the User’s data processing is ADS Assembly Data System SpA. with registered office at Via Laurentina Km 23.000, 00040 Pomezia (RM).The User’s personal data shall be handled by customer Care, Sales, Marketing, Invoicing and Technical/Operational Departments.
5 – RIGHTS OF THE INTERESTED PARTY
In accordance with Art. 7 of the Code, the User has the right, among others, to know, at any time, his personal data and how it is used, as well as to update and supplement it, or request its cancellation, blocking and object to its treatment, if carried out in violation of the law. The rights referred to in art. 7 may be exercised upon request of the User in respect of ADS in the manner disclosed by the Customer Service.