DATA PROTECTION POLICY
Pursuant to Art. 13 of EU Regulation 679/2016, as amended and supplemented (“GDPR”), as well as Italian and EU laws that complement it (“Applicable Privacy Law”), as amended and supplemented, we would like to share the information below as it pertains to your personal data (“Data”).
1 - DATA CONTROLLER
The Data Controller is Telespazio S.p.A., with registered office in Rome, Via Tiburtina no. 965, in the person of its pro tempore legal representative.
2 - PURPOSE OF DATA PROCESSING
The Data processing:
(a) allows the Data Controller to carry out those activities which are strictly connected and/or necessary to pursue statistical, commercial and promotional objectives, as well as to the update of all natural or legal persons personal data and the requests made from time to time, by the user, through the website http://www.telespazio.com/ (“Requests” and “Site”, respectively) and/or by e-mail. In order to access to some Site restricted pages, you may be required to enter your personal information for registration purposes;
(b) may also be related to activities providing commercial information, as well as to Data Controller and/or affiliates marketing services;
(c) is also related to statutory requirements set forth by the applicable national or EU legislations or regulations, as well as to instructions issued by competent authorities ,supervisory and control bodies.
3 - DATA PROCESSING
The Data processing:
(a) takes place according to methods and procedures strictly necessary for the fulfillment of the Requests and is carried out by means of operations or a series of operations, pursuant to Article 4, number 2 of the GDPR;
(b) is carried out with the support of electronic or automated means. Data are stored in paper and electronic archives located at the headquarters of the Data Controller, as well as in servers across Italy;
(c) is performed through the use of fax, e-mail or other remote communication means. The Data Controller also uses the same methods when sharing Data with third parties for the aforementioned purposes and objectives, as specified in point 6 below.
Processing is also carried out using “cookies” (i.e., Site-related information that the Site sends to the user's computer during browsing in order to capture and remember information to improve the Website).
The Website makes use of the following cookies:
- only technical cookies and, in particular:
- leonardocompany.com: WT_FPC, _ga, _gat];
- www.leonardocompany.com GUEST_LANGUAGE_ID, JSESSIONID, TS0197cb74, Local storage;
- gstatic.com: Channel ID;
- google.it: Channel ID;
- www.google.it Indexed database, Local storage, Service Workers, and cache storage space;
- analytical cookies made available by third parties, notwithstanding that: (a) tools are adopted to decrease cookie identification (for example, by masking significant IP portions), and (b) the third party undertakes not to cross-reference the information in the cookies with available data. In particular:
- Google-analytics.com: Channel ID.
4 - DATA PROVISION AND LEGAL BASIS FOR PROCESSING
Notwithstanding the data subject’s consent, the provision of personal data can be:
(a) mandatory, pursuant to a Law or Regulation, with reference to the purposes referred to in paragraph 2, letters (a) and (c), above;
(b) optional, with reference to the purposes specified in paragraph 2, letter (b), above. In this case, processing is carried out with the consent of the data subject, requested from time to time through specific pages of the site.
5 - REFUSAL TO DATA PROVISION
When the data subject refuse to provide Data or, where requested, to provide the necessary consent for processing:
(a) in cases foreseen in point 4, letters (a) and (c), the Data Controller may not be able to fulfill a request for an commercial order or service;
(b) in case foreseen in point 4, letter (b), the Data Controller may not be able to carry out the commercial and marketing activities concerning the services provided by the Data Controller and by the other affiliates.
6 - DATA COMMUNICATION
(a) Data may be disclosed - for the purposes foreseen in paragraph 2, letters (a) and (c), or pursuant to specific legal obligations - to other parties and, in particular, to consultants who assist the Data Controller for the fulfillment of the Requests (for example, legal and tax studies);
(b) furthermore, Data may be disclosed to affiliates for the purposes referred to in point 2, lett. (b).
7 - DATA DISCLOSURE
Data may be disclosed to third parties who perform specific tasks on behalf of Telespazio, for administrative matters (e.g., management of information systems, market research, delivery of correspondence, certification of financial statements), as well as to banks for the management of receipts and payments, to leasing, insurance and debt collection companies, , professional firms (legal and commercial) and external bodies for statistical or market research purposes. Data may also be disclosed to companies belonging to the Leonardo S.p.A. group, or to subsidiaries or affiliates, pursuant to Art. 2359 of the Civil Code (operating in Italy and abroad), which may proceed to processing operations for the pursuit of the same purposes for which data were collected, without needing the data subject consent.
8 - TRANSFER OF DATA ABROAD
Data may be transferred to Countries outside the EU for the purposes and objectives referred to in Article 7.
9 - DATA SUBJECT RIGHTS
9.1 - With regard to personal data in our possession, the data subject can exercise the rights foreseen by the Applicable Privacy Law. In particular, you may:
a) ask the Data Controller to confirm: existence of your personal data, origin of such data, logic and purpose of processing, categories of subjects to whom data may be disclosed, as well as identification details of Data Controller and Data Processors;
b) have the right to request access to personal data, as well as the data transformation into anonymous form, to exercise the right of objection, rectification, or eventually to erase and to have incomplete personal data completed or to obtain the restriction of processing;
c) oppose to the processing, in cases foreseen by the Applicable Privacy Law;
d) exercise the right to portability, within the limits established by Art. 20 of the GDPR;
e) revoke consent (if this is the legal basis necessary for processing) at any time without prejudice to the lawfulness of processing based on the consent given prior to revocation;
f) have the right to lodge a complaint with the European Data Protection Supervisor, following the procedures and the instructions published on the official website of the Supervisory Authority: www.garanteprivacy.it.
9.2 - Any amendment to, deletion of and limitation on processing carried out upon your request - unless this proves impossible or involves a disproportionate effort - will be notified by the Data Controller to each of the data subjects of whom personal data have been disclosed. Upon request of the data subject, the Data Controller may share the identity of the recipients.
9.3 - In order to exercise the rights as referred to in paragraph 9.1 above, as well as for any communication, request or notification regarding privacy data, you may send an email to Telespazio Data Protection Officer, at the following address:
- firstname.lastname@example.org, or
In order to be aware of changes or amendments to the privacy policies applied by Telespazio S.p.a., due primarily to regulatory changes, we recommend that you constantly review this document.