INFORMATIVA SUL TRATTAMENTO DEI DATI PERSONALI RACCOLTI DURANTE LA CONSULTAZIONE DEL SITO INTERNET

INFORMATION ON THE PROCESSING OF PERSONAL DATA COLLECTED DURING THE CONSULTATION OF THE WEBSITE 

This information describes, in compliance with the provisions of the Privacy Code and Article 13 of EU Reg. n. 679/2016 (GDPR) the legal basis and purposes of the processing of data, including personal data, which is collected through the navigation of this site and is therefore directed to anyone who consults the website www.teleconsys.it 

DATA CONTROLLER. 

The data controller is 

TELECONSYS SpA 

Via Greenland, no. 31, 00144 Rome (RM) 
telephone number: (+39) 06 2039 6767 
fax number: (+39) 06 9291 2491 
email address: teleconsys.mail@postecert.it 

PURPOSE AND LEGAL BASIS OF THE PROCESSING 

1. The collection and processing of personal data is based on the consent of the interested party, expressed at the time of first access to the site www.teleconsys.it 
2. The data processing is aimed at allowing the correct use of the Site. 
   We take the aforementioned data for exclusive security reasons, or to have the traceability of internet browsing on a given day at a given time. The release of the aforementioned data is essential and, in case of refusal, you will not be allowed to access the site. 
3. The personal data provided by users when completing the forms are used in order for Teleconsys Spa to offer the information requested using the appropriate format or to evaluate spontaneous applications. 

TYPE AND NATURE OF THE DATA PROCESSED 

• Navigation data. 

Access to the site involves the recording of data used for the sole purpose of guaranteeing correct functioning. The data collected includes the IP addresses and/or domain names of the computers used by users who connect to the site, the addresses in URI ( Uniform Resource Identifier ) notation of the resources requested, the time of the request, the method used in submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user’s IT environment. 

These data are not collected for the purpose of associating them with identified subjects, however due to their nature they could allow users to be identified through processing and association with data held by third parties especially when it is necessary to ascertain responsibility in case of hypothetical computer crimes against the site. 

• Data provided voluntarily by the user 

The optional, explicit and voluntary sending of e-mails to the addresses indicated in the various access channels to the site and the compilation of the formats (masks) involve the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other data personal data included in the message. 
In this case, the data acquired will be processed exclusively to respond to user requests or to evaluate spontaneous applications. 

• Obligation or right to provide data. 

Apart from that specified for navigation data, the user is free to provide the personal data contained in the request forms or in any case indicated in contacts for the sending of communications or any documentation. 

Failure to provide data (e.g. personal data, e-mail address, telephone number), in such cases, makes it impossible to obtain what has been requested. 

CATEGORIES OF RECIPIENTS OF THE PERSONAL DATA COLLECTED 

The navigation data, associated with your user, can only be provided to judicial authorities in the event of their express request for investigations. 

The data are also visible, solely for technical analysis purposes related to computer security, to system administrators for the management of security events related to navigation. 

RETENTION PERIOD OF THE COLLECTED DATA 

The credentials with which the user was created, as well as the log files containing the traffic recorded according to the aforementioned methods, are deleted after the 72nd month from the last access made (Art. 24 Law L 20 November 2017, n 167). 

The data voluntarily provided by filling in the appropriate formats will be kept for the time necessary to achieve the purposes indicated in the previous paragraph. 

USER RIGHTS 

It is the User’s right to ask the Data Controller for access to personal data, rectification or cancellation of the same, limitation of treatment to only some of his data as well as to oppose their treatment and to exercise the right to portability. 

It is the User’s right to revoke the consent given at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation. 

It is the User’s right to lodge a complaint with the Guarantor for the protection of personal data, which is based in Rome at Piazza Monte Citorio n. 121, 00186 Rome (www.gpdp.it – www.garanteprivacy.it). 

INFORMATION FOR SUPPLIERS ON THE PROCESSING OF PERSONAL DATA, PURSUANT TO ART. 13 OF THE EUROPEAN REGULATION N.679/2016

This information is provided to you pursuant to art. 13 of the European regulation n.679/2016, which establishes rules relating to the protection of individuals with regard to the processing of personal data, as well as rules relating to the free movement of such data. 

The processing of your data will be based on principles of correctness, lawfulness and transparency and protection of your privacy and your rights, through the use of electronic and paper instruments. 

TELECONSYS SpA constantly adopts and implements the most useful and suitable measures to guarantee the protection of your data also in consideration of technological progress and the evolution of threats. 

1. Purpose and legal basis of the processing 
   TELECONSYS SpA collects from its suppliers, during the first contact phase, or for an initial purchase of a good or service, or for enrollment in the supplier register, only the data necessary for carrying out the commercial relations, in order to correctly execute the stipulated contracts or to fulfill the obligations deriving from pre-contractual negotiations, pursuant to article 6, letter b) of the GDPR. 
2. It also processes the data for the accounting purposes imposed by law, as well as for civil, fiscal or public safety legal obligations, pursuant to article 6, letter c) of the GDPR. 
3. Compulsory nature of the provision of data 
   The provision of data is indispensable for the correct execution of the existing contract between the parties, as it is strictly necessary for the normal execution of the services covered from time to time by the contract itself. 
4. Failure to provide data and/or any express refusal to process it will therefore make it impossible for the Data Controller to carry out pre-contractual or contractual activities. 
    
5. Categories of personal data processed 
   The data processed for the purposes referred to in point 1) do not include particular categories of personal data or personal data relating to criminal convictions and offences. 
6. Categories of recipients of personal data 
   The personal data collected for the aforementioned purposes may only be communicated to consultants of TELECONSYS SpA (e.g. lawyers, tax consultancy firms, experts in issues relating to the products and services purchased in order to better contribute to the business solutions of TELECONSYS SpA). Furthermore, the data can be communicated to banking institutions (for direct credit) and to shippers and/or customers (for the eventual delivery of material if the contract provides for it). 
7. The personal data stored in electronic archives can be viewed by clearly identified third parties on the occasion of certain assistance or maintenance interventions relating to the company IT system. The identity of these subjects can be requested at any time from the data controller indicated at the bottom of this statement. 
8. Methods of processing personal data 
   The data are processed exclusively by personnel in charge of processing relating to the purchasing, administration, finance structures, as well as to the structures specifically interested in the supply in question. 
9. The data will not otherwise be communicated or disclosed to third parties other than those already declared in this statement, nor transferred to other countries. 
10. The data will NOT be processed through automated decision-making or profiling processes or for other purposes than those previously expressed. 
11. Retention period of personal data 
    The personal data collected for the purposes indicated in the previous paragraph 1) will be processed and stored for the time necessary to fulfill these purposes. 
12. Starting from the date of termination of the contractual relationship, the data will be deleted, unless their conservation (e.g. invoices) is required by law, and for the time limits established by it. 
13. Rights that can be exercised 
    With reference to your collected data, TELECONSYS SpA reminds you that your rights include: 

• Right of access – Right to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to receive various information, including, the purpose of the processing, the categories of personal data processed and the period of conservation, the recipients to whom these can be communicated (article 15, GDPR); 
• Right of rectification – Obtain, without unjustified delay, the rectification of inaccurate personal data concerning you and the integration of incomplete personal data (article 16, GDPR); 
• Right to cancellation (or to be forgotten) – Obtain, without unjustified delay, the cancellation of personal data concerning you, in the cases provided for by the GDPR (article 17, GDPR); 
• Right to limitation – Obtain the limitation of processing, in the cases provided for by the GDPR (article 18, GDPR); 
• Right to portability – Receive personal data concerning you in a structured format, commonly used and readable by an automatic device and to obtain that they are transmitted to another holder without impediments, in the cases provided for by the GDPR (article 20, GDPR ); 

• Right to object – Oppose the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing (article 21, GDPR); 
• Right to lodge a complaint with the supervisory authority – Guarantor Authority for the protection of personal data, Piazza di Montecitorio n. 121, 00186, Rome (RM) emails listed below. 

1. Identity and contact details of the Data Controller 
   The Data Controller is: 
2. TELECONSYS SpA 
   via Groenlandia, no. 31, 00144 Rome (RM) 
   telephone number: (+39) 06 2039 6767 
   fax number: (+39) 06 9291 2491 
   email address: privacy@teleconsys.it 
    
3. Identity and contact details of the Data Protection Officer (RPD/DPO) 
   The Data Protection Officer is: 
   Avv. Arianna Ori 
   via Greenland, n. 31, 00144 Rome (RM) 
   telephone number: (+39) 06 2039 6767 
   fax number: (+39) 06 9291 2491 
   email address: privacy@teleconsys.it 

The Data Controller 
TELECONSYS SpA 

INFORMATION FOR CUSTOMERS ON THE PROCESSING OF PERSONAL DATA, PURSUANT TO ART. 13 OF THE EUROPEAN REGULATION N.679/2016

This information, pursuant to article 13, GDPR (in short, “Information”), is provided by TELECONSYS SpA, in its capacity as Data Controller. 

The processing of your Data will be based on principles of correctness, lawfulness and transparency, with logic strictly related to the purposes indicated and, in any case, in order to guarantee the security and confidentiality of the data through the use of suitable procedures to avoid the risk of loss, unauthorized access, illicit use and disclosure. 

1. Identity and contact details of the Data Controller 
   The Data Controller is: 
   TELECONSYS SpA 
   via Groenlandia, n. 31, 00144 Rome (RM) 
   telephone number: (+39) 06 2039 6767 
   fax number: (+39) 06 9291 2491 
   email address: privacy@teleconsys.it 
2. Identity and contact details of the Data Protection Officer (RPD/DPO) 
   The Data Protection Officer is: 
   Avv. Arianna Ori 
   via Greenland, n. 31, 00144 Rome (RM) 
   telephone number: (+39) 06 2039 6767 
   fax number: (+39) 06 9291 2491 
   email address: privacy@teleconsys.it 
3. Purpose of the processing for which the personal data are intended and related legal basis 
   Your personal data will be processed: 

• without the need for consent (article 6, letter b, c, f GDPR), for the following purposes: 
• respond to pre-contractual activities following first contact data provided by the customer during preliminary meetings; 
• fulfill the contractual obligations relating to: 
• supply of hardware and software products and related assistance and maintenance activities; 
• provision of professional services, delivered remotely and in monitoring mode, on customer systems, through TELECONSYS SpA resources and/or qualified partners; 
• application development services and related technical assistance; 
• hosting services for applications that customers install on the TELECONSYS SpA infrastructure; 
• disclosure of information regarding upgrades of the services covered by the contract as elements of potential interest; 
• comply with the provisions of laws and regulations (national or community), or execute an order from judicial authorities or supervisory bodies to which the Data Controller is subject; 
• exercise the rights of the Owner, in particular, that of defense in court; 

1. with your consent (article 6, letter a, GDPR), for the following purposes: 
2. forwarding of information on the organization of events, meetings, conventions, seminars or the distribution of informative and promotional material, the sending of newsletters and publications aimed at dissemination; 
3. management of surveys and questionnaires, also relating to the degree of customer satisfaction; 
4. acquisition of images, during shows and events to which he is invited, and relative use both in paper and electronic form on social channels in the context of advertising and institutional communications for the promotion of the company, without prejudice to the absolute prohibition of their use in contexts that jeopardize their personal dignity and decorum. 
5. Mandatory or optional nature of the provision of data 
   The provision of data for the purposes referred to in the previous section (a) is mandatory. The lack of data and/or any express refusal to process it will make it impossible for the Data Controller to carry out pre-contractual activities or the assignment conferred. 
6. The provision of data for the purposes referred to in section (b) above is optional, with the consequence that you may decide not to provide your consent, or to revoke it at any time, without jeopardizing the provision of the requested service. 
7. Categories of personal data processed 
   Within the scope of the purposes of the processing highlighted in the previous paragraph 2), mainly “common” personal data will be processed, concerning, for example, name and surname, tax code, residence, domicile, email address o PEC, telephone and fax number, etc. 
8. TELECONSYS SpA never comes into possession of data that the Regulation defines as “particular” such as, for example, the state of health or data of a judicial nature 
9. Categories of recipients of personal data 
   For the purposes of the processing referred to in paragraph 2) section (a) above, the personal data you provide may be made accessible: 
10. to employees and collaborators of the Data Controller, in their capacity as authorized data processors; 
11. to third parties who carry out outsourced activities on behalf of the Data Controller, in their capacity as data processors (consulting companies for support on vertical services, accountants firms for administrative and tax obligations, law firms for specific aspects of the contracts between the parties, vendor technicians appointed where necessary for maintenance and assistance on the systems covered by the contracted service, vendors for the specific activation of software licenses and vendors for customer care services such as hardware and software maintenance of services provided by TELECONSYS SpA); 
12. to judicial or supervisory authorities, administrations, public entities and bodies (national and foreign). 
13. Should you express your consent to the use of personal data for the purposes referred to in the previous paragraph 2), section (b), the same may be made accessible to the subjects indicated in the previous points (i), (ii), and ( iii). 
14. Storage and transfer of personal data abroad 
    The management and storage of personal data takes place locally in Italy and in any case using cloud services on servers located within the European Union in full availability of the Data Controller and/or third-party companies in charge, duly appointed as data processors. 
15. The transfer of data abroad to non-EU countries is not foreseen and is not carried out. 
16. Your personal data will not be disclosed (with the exception of images for which explicit consent has been provided, collected during events and shows organized by the company, which may be published on the TELECONSYS SpA website). 
17. Retention period of personal data 
    The personal data collected for the purposes indicated in the previous paragraph 2), section (a) will be processed and stored for the entire duration of the use of the service (contractual relationship). 
18. Starting from the date of termination of this relationship, for any reason or cause, the data will be deleted, unless their conservation is required by law, and for the time limits established by it. 
19. The personal data collected for the purposes indicated in the previous paragraph 2), section (b) will be processed and stored for the time necessary to fulfill these purposes. 
20. Rights that can be exercised 
    With reference to your collected data, TELECONSYS SpA reminds you that you can exercise the following rights: 

• Right of access – Right to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to receive various information, including, the purpose of the processing, the categories of personal data processed and the period of conservation, the recipients to whom these can be communicated (article 15, GDPR); 
• Right of rectification – Obtain, without unjustified delay, the rectification of inaccurate personal data concerning you and the integration of incomplete personal data (article 16, GDPR); 
• Right to cancellation (or to be forgotten) – Obtain, without unjustified delay, the cancellation of personal data concerning you, in the cases provided for by the GDPR (article 17, GDPR); 
• Right to limitation – Obtain the limitation of processing, in the cases provided for by the GDPR (article 18, GDPR); 
• Right to portability – Receive personal data concerning you in a structured format, commonly used and readable by an automatic device and to obtain that they are transmitted to another holder without impediments, in the cases provided for by the GDPR (article 20, GDPR ); 

• Right to object – Oppose the processing of personal data concerning you, unless there are legitimate reasons for the Data Controller to continue processing (article 21, GDPR); 
• Right to lodge a complaint with the supervisory authority Guarantor Authority for the protection of personal data, Piazza di Montecitorio n. 121, 00186, Rome (RM). 

• The above rights can be exercised by means of a written request to be addressed to the headquarters of the Data Controller or to the e-mail address indicated in paragraph 1) of this information. 

1. Processing methods 
   The processing of your personal data is carried out by means of operations also with automated tools such as: 

• the collection, registration, organization, structuring, conservation, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of making available, the comparison or interconnection, limitation, deletion or destruction of data. 

• In any case, the logical and physical security of the data and, in general, the confidentiality of the personal data processed will be guaranteed, implementing all the necessary technical and organizational measures to guarantee their security. 
• Your personal data will not be subjected to any type of profiling or subjected to an automated decision-making process. 

Rome, 24 May 2018 – Subsequent update of 02/08/2019 for DPO appointment 

The Data Controller TELECONSYS SpA 

INFORMATION ON THE PROCESSING OF PERSONAL DATA COLLECTED FOR MARKETING ACTIVITIES 

TELECONSYS SpA, as owner of the treatment of personal data, informs you pursuant to art. 13 of the European Regulation n. 679/2016 (hereinafter, “GDPR”) that your data will be processed in the manner and for the purposes indicated below. 

In this regard, the Data Controller invites you to read this information carefully, as it contains important information on the protection of personal data and on the security measures adopted to guarantee confidentiality in full compliance with the GDPR. 

This Information is intended to be provided to interested parties who consent to receive communications regarding promotional, commercial and advertising activities on Teleconsys Spa events, initiatives or partnerships 

1. OWNER OF THE TREATMENT

TELECONSYS SpA 
Via Groenlandia 31, 00144 Rome (RM) 
telephone number: (+39) 06 2039 6767 
fax number: (+39) 06 9291 2491 
email address: privacy@teleconsys.it 

2. PERSONAL DATA SUBJECT TO PROCESSING

The Owner wishes to inform you about the products, services, promotions and commercial events offered. 
Due to the commercial communications that he intends to address to you, the Data Controller collects and processes the following personal data: 
a) name, surname, address, city, postal code, telephone number, e-mail address; 
b) profession and company to which they belong 

3. PURPOSE AND LEGAL BASIS OF THE TREATMENT

The personal data you provide when completing the collection form will be processed for the following purposes: 

1) direct marketing: carry out marketing activities, such as compiling statistics and market research, sending you our newsletter or other information and promotional material relating to Teleconsys activities, products and services. These communications will be made via e-mail. It should be noted that the Data Controller collects a single consent for the marketing purposes described here, pursuant to the General Provision of the Guarantor for the Protection of Personal Data “Guidelines on promotional activities and the fight against spam”, of 4 July 2013; if, in any case, you wish to oppose the processing of your data for marketing purposes carried out with the means indicated here, you can do so, at any time, according to the methods set out in point 6 of this information; 

2) analysis and reporting: carry out analysis and reporting activities connected to the promotional communication systems, such as, for example, the detection of the number of e-mails opened, the clicks made on the links present within the communication, the type of device used to read the communication and the related operating system. 
3) marketing by third parties (with data communication): sending promotional and commercial communications via e-mail, advertising material relating to offers of services/products, reporting of company events, as well as carrying out market studies and statistical analyzes by third parties with respect to the Data Controller, to whom the data is communicated. 

The legal basis for the processing of your data for the purposes referred to in points 1) and 3) is art. 6.1.a) of the GDPR, i.e. your consent. 
The legal basis for the processing of your data for the purpose referred to in point 2) is art. 6.1.f) of the GDPR, i.e. the legitimate interest of the Data Controller in the management and monitoring of its direct marketing activity. 
The provision of your personal data for the purposes referred to in point 1) is optional, but failure to provide it would make it impossible for Teleconsys to provide you with the requested service (White Paper). 
The provision of data for the purposes referred to in point 3) is optional, with the consequence that you may decide not to provide your consent, or to revoke it at any time, without prejudice to the provision of the requested service. 

4. CONSERVATION PERIOD

Personal data are kept only for the period necessary for the purpose for which they are processed or within the terms established by applicable national and community laws, rules and regulations. In any case, consistently with the provisions of the applicable legislation, your data will not be kept for a period exceeding 24 months starting from your provision. At the end of this period, your data will be permanently deleted or made anonymous. 

5. RECIPIENTS OF DATA PROCESSING AND TRANSFER

Your data may be shared with: 
1) subjects acting as data processors and/or sub-processors; 
2) persons authorized by Teleconsys to process personal data who are committed to confidentiality or have an adequate legal obligation of confidentiality. 
3), in case of release of your explicit consent, third parties to whom the data are communicated. 

Your data will not be transferred outside the European Union. 

6. WITHDRAWAL OF CONSENT AND RIGHTS OF THE INTERESTED PARTY

We remind you that pursuant to art. 7.3, GDPR, you have the right to revoke your consent at any time by sending a communication to TELECONSYS SpA via Groenlandia, n. 31, 00144 Rome (RM), or by sending an e-mail to privacy@teleconsys.it. In any case, the withdrawal of consent does not affect the lawfulness of the treatment based on the consent before the withdrawal. 

You also have the right to ask the Data Controller at any time to access your personal data, to rectify or cancel them or to oppose their treatment, you have the right to request the limitation of treatment in the cases provided for by art. 18 of the GDPR, as well as to obtain the data concerning you in a structured format, commonly used and readable by automatic device, in the cases provided for by art. 20 of the GDPR. 

Requests can be sent to the email address privacy@teleconsys.it. 
We also remind you that you always have the right to lodge a complaint with the competent supervisory authority (Guarantor for the Protection of Personal Data), pursuant to art. 77 of the GDPR, if you believe that the processing of your data is contrary to the legislation in force. 

7. CHANGES
   The Owner reserves the right to update the information at any time and make users aware of it through the use of the most appropriate tools, for any further information or question it is possible to contact the Owner at the email address privacy@teleconsys . it or the Data Protection Officer Avv. Arianna Ori at the email address: dpo@teleconsys.it