Who is the Data Controller?
Data Protection Officer (“DPO”)
The Data Controller has appointed a Data Protection Officer (DPO) who can be contacted at the following email address: email@example.com.
What data do we collect?
Enel will collect the following personal data (hereinafter “Personal Data”):
Browsing data: during the course of their normal functioning, the IT and telecommunications systems, as well as the software processes that exist to ensure the proper functioning of the Website, collect certain data: for example, the access date and time, the pages visited, the name of the Internet Service Provider and IP address used to access the Internet, the internet address from which you connect to our Website, etc. The transmission of such data is implicit in the use of web communication protocols or is useful for the improved management and optimization of the data and e-mail sending system.
What is personal data processing?
Personal data processing refers to any operation or set of operations performed on personal data using automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Personal Data is processed by manual or automated means.
Purposes and legal basis of data processing
Your personal data is processed by Enel Italia manually and/or using IT and telecommunications tools. Enel Italia will process such data for specific purposes and only where there is a specific legal basis for doing so as laid down by current personal data privacy and protection legislation. Specifically, we will process your personal data only when one or more of the following legal bases have been satisfied:
- you have freely given your specific, informed, clear, and unambiguous consent to the processing of such data;
- the processing is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract;
- Enel Italia has a legitimate interest in processing such data;
- Enel Italia is legally obligated to process the personal data.
The following table sets out the purposes for which Enel Italia processes your personal data and the legal bases for doing so.
|Purpose of processing||Legal Basis|
|To enable users to use all the Website’s functions||Performance of a contract|
|To check the correct functioning of the Website||Performance of a contract|
|To ascertain responsibility in the event of computer crimes detrimental to the Website; detection, prevention, mitigation, or verification of fraudulent or illegal activities in connection with the services provided by the Website; implementation of security controls required by law||Legitimate interest|
|To respond to a query or request submitted by the data subject||Take steps at the request of the data subject prior to entering into a contract|
The provision of your personal data is necessary in all cases where the data processing is a legal requirement or when it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract. Any refusal may make it impossible for us to fulfil the purpose for which your personal data is collected.
However, the provision of your personal data is voluntary when required for any other purposes: in such cases, the absence of your consent shall have no impact on the completion of the contract. The obligatory or discretionary nature of the data provision shall be indicated at the time of its collection.
Who are the recipients of your Personal Data?
Your Personal Data may be available to the following entities for the purposes mentioned above:
- employees and collaborators who have been appointed Authorized Persons by the Data Controller in order to process the data, or Enel Group companies present within the European Union;
- third party companies or other entities, in their role as external data processors, which provide outsourced services to Enel Italia to enable the Website to function.
Where and for how long is your Personal Data stored?
Your Personal Data will be processed within the European Union and will be stored on servers located within the European Union. The same data may be processed in countries outside the European Union on the condition that an adequate level of data protection is guaranteed, as recognized by an adequacy decision by the European Commission.
Any transfers of Personal Data to non-EU countries in the absence of an adequacy decision by the European Commission will only be possible if Data Controllers and Data Processors involved provide adequate guarantees of contractual nature, including Binding Corporate Rules and Standard Contractual Clauses.
The transfer of your Personal Data to third countries outside the European Union, in the absence of an adequacy decision or other appropriate measures as described above, will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest. In these cases, we inform you that, although the Enel Group adopts operating instructions common to all the countries in which it operates, the transfer of your Personal Data may be exposed to risks related to the peculiarities of local legislation regarding the processing of Personal Data.
Any personal data processed shall be stored in accordance with the principles of proportionality and necessity and, in any case, until the purposes of the data processing have been completed.
What are your rights regarding Personal Data?
With respect to the personal data provided, in accordance with articles 15 – 21 of EU Regulation 2016/679 (GDPR), you have the following rights:
- to request access the data and request a copy;
- to request rectification;
- to request erasure;
- to obtain restriction of processing;
- to object to the processing;
- to receive the personal data in a structured, commonly used, and machine-readable format and to transmit such data to another controller without hindrance, where technically feasible.
We inform you that you have the right to object at any time to the processing of your Personal Data based on Enel Italia’s legitimate interest.
If you object to the processing of your Personal Data, the Data Controller shall refrain from further processing your Personal Data, unless the Data Controller demonstrates the existence of compelling legitimate reasons to proceed with the processing of said data, or unless it is required by the determination, exercise or defense of a legal claim.
To exercise your rights and to withdraw your consent, as well as for more information on your Personal Data, you can send an email to the Data Protection Officer of Enel Italia Srl at firstname.lastname@example.org, specifying the contents of your request in the subject line.
Please note that you have the right to file a complaint with the Data Protection Authority by submitting your complaint, as follows:
- by registered mail with return receipt to the Data Protection Authority at Piazza Venezia, 11, 00187 Rome, Italy;
- by certified email to the following email address: email@example.com.
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