1. Data Controller
The Data Controller for the personal data of Data Subjects is Logotel S.p.A. (hereinafter “Controller” or “Logotel”), with registered office at via Ventura 15, Milan, and can be contacted at privacy@logotel.it
2. Data Processed
Logotel will only process the data that you freely provide to us (such as name, telephone number, email address and company affiliation) in connection with your request or subsequent contacts.
3. Purpose of Processing
The personal data that you have provided will be processed for the following purposes:
1. To respond to your contact request;
2. To send you the newsletter or contact you directly to promote services that, based on your request or previous commercial relations with Logotel, may be of interest to you;
3. To comply with obligations imposed by law, regulation, EU legislation or by order of the Authority.
4. Legal Bases for Processing
The processing of your data for the purpose referred to in paragraph 3 point 1) is based on your implicit consent, which can be found in the spontaneous submission of your data as part of your contact request. With regard to the purpose referred to in paragraph 3 point 2), the legal basis for processing is the Controller’s legitimate interest in the commercial management of past, current or potential customers. Finally, with reference to the purposes referred to in paragraph 3 point 3), the legal basis for processing is the Controller’s legitimate interest in retaining such data to protect itself in the event of requests for information from authorities.
5. Retention Period
With regard to the purpose referred to in paragraph 3 point 1), the data will be retained for the time strictly necessary to respond to your specific request. As regards the purposes indicated in paragraph 3 points 2) and 3), your data will be retained for a period of two years from the last newsletter you read.
6. Nature of Data Provision
The provision of data by you is entirely voluntary; however, failure to provide it, or partial or inaccurate provision, could result in the impossibility of responding to your contact request.
7. Processing Methods
Your personal data is used for operations involving collection, recording, organization, storage, consultation, selection, use, deletion and destruction of data. Such personal data is also subject to paper-based, electronic and automated processing and stored in databases in such a way as to permanently ensure the confidentiality, integrity, availability and resilience of processing systems and services.
8. Access to Data
Your personal data may be accessed, for the purposes and within the limits indicated in this policy, by:
- Employees and/or collaborators of the Controller in their capacity as data processors and/or internal data controllers and/or system administrators;
- Third-party companies or other entities (e.g., website providers, hardware and software technical support personnel, etc.) that perform outsourced activities on behalf of the Controller, in their capacity as external data processors.
9. Data Recipients
Your personal data may also be communicated without your consent, always within the scope of the purposes seen above, (by way of example) to supervisory bodies, law enforcement agencies or the judiciary who will process them, at their express request, as independent data controllers for institutional purposes and/or pursuant to law during investigations and inspections.
10. Transfer and Location of Personal Data
Your personal data will not be disclosed or transferred to non-EU countries. The management and storage of personal data will take place on servers located within the European Union. Should it become necessary to transfer data to a non-EU country, the Controller will carry out the transfer on the basis of adequacy decisions approved by the European Commission or the adoption, by the Controller, of Standard Contractual Clauses prepared by the European Commission. It is understood that the Controller will update this policy and inform you if such transfers become necessary.
11. Rights of the Data Subject
As a data subject, you have the following rights, subject to specific limitations:
- To obtain confirmation as to whether or not personal data concerning you is being processed;
- Where processing is taking place, to obtain access to your personal data and information relating to the processing as well as to request a copy of the personal data;
- To obtain the rectification of inaccurate personal data concerning you and the completion of incomplete personal data;
- To obtain, where one of the conditions set out in Article 17 of the GDPR exists, the erasure of personal data concerning you;
- To obtain, in the cases provided for in Article 18 of the GDPR, the restriction of processing;
- To object, in the cases provided for in Article 21 of the GDPR, to the processing of data: in case of objection, the personal data will no longer be processed, unless there are legitimate grounds for processing which override the interests, rights and freedoms of the Data Subject or for the establishment, exercise or defense of legal claims;
- To receive the personal data concerning you in a structured, commonly used and machine-readable format and to request their transmission to another controller, if technically feasible.
You also have the right to lodge a complaint with the competent supervisory authority, namely the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), in the event that you believe that the rights listed above have been violated, according to the procedures indicated on the Authority’s website accessible at: www.garanteprivacy.it.