Privacy Policy

Objects

The purpose of this Privacy Policy is to describe the methods of management of the Portal https://www.numeroblu.it (the “Portal“), owned by NUMERO BLU SERVIZI S.P.A. – Registered and Administrative Office, Via di Monte Carmelo, 5 – 00166 Rome, VAT/C.F./R.I. RM 08898571008 – R.E.A. 1125501, Share Capital: 120,000 Euro, fully paid up, with reference to the processing of personal data of the Users consulting it.

This Privacy Policy constitutes the Information Notice provided, pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter also the “Regulation“), to Users who connect to the Portal. The Information Notice is provided only for the Site and not for other websites that may be consulted by the User through links.

The Information Notice takes into account the contents of Recommendation No. 2/2001 that the European Authorities for the protection of personal data gathered in the “WP 29” Group, established by Art. 29 of Directive No. 95/46/EC, adopted on 17 May 2001 to identify certain minimum requirements for the collection of personal data online, and, in particular, the methods, timing and nature of the information that data controllers must provide to Users when they connect to web pages, regardless of the purpose of the connection.

Users are required to read this Privacy Policy carefully before submitting any personal information and/or filling in any electronic form on the Portal.

For the use of specific services by Users, specific information will be provided from time to time and specific consents to the processing of their personal data will be requested, where necessary. This information is provided only for the Portal and not for any other websites that may be consulted by the User via links.

NUMERO BLU SERVIZI S.P.A. may amend the content of these Privacy Rules at any time by publishing the new version on the Portal or on its own corporate website. All new privacy terms and conditions shall be effective on the date of publication.

Data Controller

NUMERO BLU SERVIZI S.P.A. – Registered and Administrative Office, in Via Monte Carmelo, 5 – 00166 Rome, P.IVA/C.F./R.I. RM 08898571008 – R.E.A. 1125501, Share Capital: 120.000 Euro, fully paid up, is the Data Controller for the processing of the personal data of the Users who access the Portal. The Data Controller manages the Portal and processes the data of the Users who navigate within it and/or access the following Sections:

“Reserved Area”, for consulting the Qualitative Reports of the CRM Applications and the Telephone Quantitative Reports of the Service ;

“Careers”, for sending job requests;

“Contact us”, for sending messages and communications.

The Data Controller guarantees to comply with the provisions of the Regulations, the Privacy Code and the provisions of the Privacy Guarantor. All information and requests, pursuant to art. 7 of the Privacy Code and articles 15 to 22 and 34 of the Regulation, may be made by contacting the customer service of NUMERO BLU SERVIZI SPA: tel. 800120412, or by writing to: privacy@numeroblu.it.

NUMERO BLU SERVIZI S.P.A collects, manages, stores, and deletes the personal data of the Users of the Portal, availing itself of the collaboration of internal and external Data Processors and Persons in charge of the processing, appointed for this purpose, in compliance with the provisions of the law and regulations.  The complete list of Data Processors and Persons in charge of Processing may be obtained by writing to

NUMERO BLU SERVIZI SPA customer service: tel. 800120412, or by writing to: privacy@numeroblu.it.

Data Protection Officer (DPO)

NUMERO BLU SERVIZI S.P.A Data Controller of personal data collected from Users of the Portal – in compliance with Articles 39 et seq. of the Regulation – has appointed as “Data Protection Officer”, Ms. Kathryn La Rocca, whose contact details are as follows: kathryn.larocca@numeroblu.it.

Place of data processing

The processing of the Users’ personal data, acquired by browsing the Portal, takes place in Italy, through servers located at the aforementioned head office of NUMERO BLU SERVIZI S.P.A. and other secondary offices; and is handled only by the technical staff of the Office in charge of data processing, or by any persons in charge of occasional maintenance operations.

Data are processed on the basis of their storage in computer files kept at the Company, access to which is limited to maintenance procedures in compliance with the provisions of Appendix B of the Privacy Code. No data processed through the Portal is communicated or disseminated.

Purpose and Method of Processing

The Portal provides information about the company NUMERO BLU SERVIZI S.P.A. and the services it offers. In addition to navigation data, the Data Controller may process the data of Users, provided voluntarily, in the “Careers” or “Contact Us” Sections.

The User expressly authorises the Data Controller to use the personal data received for the following purposes

– account management of the “Reserved Area”, for consulting the Qualitative Reports of the CRM Applications and the Quantitative Telephone Reports of the Service present ;

– analysing and responding to job requests received in the “Careers” Section

– respond to messages received in the “Contact Us” Section,

The personal data provided by Users accessing the “Reserved Area”, “Careers” or “Contact Us” Sections are used solely for the purpose of performing the service and/or managing and/or taking charge of the request, and are communicated to third parties only when necessary for this purpose, in accordance with applicable laws and regulations. These data are not used for direct marketing purposes.

Personal data is processed by automated electronic means, with the aid of computer technology (e.g. using electronic procedures and media) and/or manually (e.g. on paper) for the time strictly necessary to achieve the purposes for which the data was collected and in accordance with the relevant statutory provisions. After that, the data are deleted.

Types of data processed

Navigation data

The computer systems and software procedures used to operate the Portal acquire, during their normal operation, some personal data (so-called log files) whose transmission is implicit in the use of Internet communication protocols.

This is information that is not collected in order to be associated with identified interested parties, but which by its very nature could, through processing and association with data held by third parties, allow Users to be identified.

This category of data includes the IP addresses or domain names of the computers used by Users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used to 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 User’s operating system and computer environment.

For any access to the Portal, regardless of whether or not a cookie is present, the Site may record the following information: browser type (e.g. Internet Explorer, Netscape), operating system (e.g. Windows, Macintosh), the visitor’s host and URL of origin, as well as data on the page requested. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and is deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the Site or third parties: except for this possibility, at present, data on web contacts are not stored permanently, unless requested by the User.

Data provided voluntarily by the User

The User may browse the Site without revealing his or her personal identity to the Data Controller. However, if the User chooses to provide his/her personal data, he/she consents to the collection and use thereof as described in these Privacy Policies.

Should the User, by connecting to this Portal, send – in an optional, explicit and voluntary manner – his/her personal data in the “Careers” section or by sending a message in the “Contact Us” section, this will entail the acquisition by the Data Controller of the sender’s address and/or other possible personal data, which will be processed exclusively to respond to the communication received.

By personal data provided voluntarily we mean

– personal data (name, surname, date of birth), identification data (tax code), location data (address, etc.), contact details (telephone data, email).

The Data Controller of the Portal’s Users does not process special data, as referred to in Article 9 of the Regulation.

Cookies

Cookies are not used for the transmission of information of a personal nature, nor are systems used for the tracking, identification and profiling of Users.

The use of c.d. cookies is strictly limited to the transmission of session identifiers (consisting of random numbers generated by the server) necessary to enable the safe and efficient exploration of the site and used for statistical purposes for the detection of monthly unique visitors. The cookie can be deleted by the surfer using the functions of his/her browser.

For further information please check the “Cookie Policy”.

Option of providing data

Apart from that specified for navigation data, the User is free to provide the personal data requested in the “Careers”, “Contact us”, “Reserved Area” section.

The personal data provided voluntarily in the “Careers” section or by sending a message in the “Contact Us” section are obligatory in order to obtain a reply from the Data Controller. Failure to provide them will prevent the possibility of forwarding the relative request in the appropriate section.

Failure to provide the data required to open the “Reserved Area” account prevents the Data Controller from providing the relative service to the Customer, as well as the fulfilment of contractual requirements.

It must be remembered that in certain strictly established cases (not subject to the ordinary management of the Portal) the Authority may request news and information, pursuant to Article 157 of Legislative Decree No. 196/2003, for the purposes of checking the processing of personal data. In these cases, a reply is compulsory under penalty of administrative sanction.

Scope of data communication

No personal data deriving from navigation on the Portal and processed to process requests sent by the User by accessing the “Careers” or “Contact Us” sections, or the “Client Area” is communicated or disseminated.

The personal data provided by Users who forward job requests, messages or the sending of informative material (newsletters, answers to queries, etc.) are used for the sole purpose of answering the queries received and performing the service or provision requested and are communicated to third parties only if necessary for this purpose. The personal data provided by Users will only be communicated to third parties in the event that such communication is necessary to fulfil the Users’ requests.

The User’s personal data are known, processed and managed by employees and possibly para-subordinate subjects of the Data Controller, specifically appointed for this purpose, in compliance with the applicable legal and regulatory provisions, as well as by internal and external Data Processors, specifically appointed, and their employees and collaborators in charge.

The User acknowledges and accepts that the Data Controller has the right to disclose personal data at the request of the Judicial Authorities, within the limits prescribed by law, as well as in cases of violation of the Privacy Rules, civil and criminal proceedings, also for violation of the rights of third parties, in order to protect the rights, property or safety of each User, pursuant to Articles 24 of the Privacy Code and 6 of the Regulations.

The Privacy Policy refers exclusively to the use and disclosure of data provided directly by the User. If personal data are communicated to others on other websites, the use and disclosure of the communicated data may be subject to other rules. NUMERO BLU SERVIZI S.P.A is not a party to and does not control the privacy policies or rules of third parties, and with regard to other surfing we inform the User that he/she is subject to the privacy rules of such third parties, if applicable. We invite the User to obtain information on this matter before communicating his/her personal data to others.

Marketing

The Data Controller does not sell, or transfer for a fee, the User’s personal data collected while browsing the Portal to third parties for marketing purposes, without the explicit consent of the User concerned.

The Data Controller may associate User data with information that will be collected by other companies in order to improve and personalize the services offered and the contents of the Portal.

Data transfer abroad

The personal data of the Portal User processed by the Data Controller and by each Data Processor, appointed for this purpose in accordance with the applicable Italian and Community regulatory provisions, are not transferred abroad to other European Union countries or Third Countries.

Rights of the interested parties

Transparent Communications: Pursuant to articles 15 -22 and 34 of the Regulation, the Users of the Portal, by contacting the customer service of Numero BLU Servizi spa: tel. 800120412, or by writing to: privacy@numeroblu.it can obtain all the necessary communications relating to the treatment in a concise, transparent, intelligible and easily accessible form, with simple and clear language, in particular in the case of information specifically intended for minors. The information is provided in writing or by other means, including, where appropriate, by electronic means. If requested by the interested party, the information can be provided orally, provided that the identity of the interested party is proven by other means. The Data Controller cannot refuse to satisfy the request of the interested party in order to exercise your rights, unless the Data Controller demonstrates that it is not able to identify the interested party. The Data Controller provides the interested party with information relating to the action taken regarding a request without unjustified delay and, in any case, at the latest within one month of receiving the request.

Except as prescribed in art. 12, paragraph 5 of the Regulation, the information is provided free of charge.

The right of the Data Controller to request documents certifying the identity of the person requesting the information referred to in Articles remains unaffected. 15-22 and 34 of the Regulation, in the event that it should have reasonable doubts about the identity of the natural person submitting the request pursuant to the applicable regulatory provisions, referred to above.

Right of access: the User expressly acknowledges that he has the right to obtain the indication:

• the origin and category of personal data;
• of the purposes and methods of the treatment;
• of the logic applied in case of treatment carried out with the aid of electronic instruments;
• of the identification details of the Data Controller, of the data processors and of the designated representative;
• of the subjects or categories of subjects to whom the personal data have been or will be communicated, in particular if they are recipients of third countries or international organizations, or who can learn about them as designated representative in the territory of the State, managers or agents ;
• the envisaged retention period of personal data, or, if not possible, the criteria used to determine this period;
• updating, rectification or, when interested, integration of data;
• the deletion of personal data, or the limitation of the processing of personal data concerning him or to oppose the processing;
• transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
• to know all the information available on the origin of the data;
• the existence of an automated decision-making process, including profiling, significant information on the logic, as well as the importance and expected consequences of such processing for the data subject.

The Data Controller provides a copy of the personal data being processed. In case of further copies requested by the data subject, the Data Controller may charge a reasonable fee based on administrative costs. If the interested party submits the request by electronic means, and unless otherwise indicated by the interested party, the information is provided in a commonly used electronic format.

The User always has the right to lodge a complaint with the Guarantor for the protection of personal data.

If personal data is transferred to a third country or to an international organization, the interested party has the right to be informed of the existence of adequate guarantees pursuant to Regulation (EU) 2016/679.

Right of rectification: the User has the right to obtain from the Data Controller the rectification of inaccurate personal data without justified delay, as well as the integration of incomplete personal data.

Right to cancellation: the User has the right to obtain from the Data Controller the cancellation of personal data concerning him without unjustified delay and the Data Controller has the obligation to cancel personal data without unjustified delay, where the conditions exist by the Regulation, by the Privacy Code and by the provisions of the Privacy Guarantor.

Right to Limitation of Treatment: the User has the right to obtain from the Data Controller the limitation of treatment when one of the following hypotheses occurs: a) the interested party disputes the accuracy of personal data, for the period necessary for the Data Controller to verify the accuracy of such personal data; b) the processing is unlawful and the interested party opposes the cancellation of personal data and instead requests that their use be limited; c) although the Data Controller no longer needs it for processing purposes, personal data are necessary for the data subject to ascertain, exercise or defend a right in court; d) the interested party has opposed the processing pursuant to article 21, paragraph 1 of the Regulation, pending the verification of the possible prevalence of the legitimate reasons of the Data Controller with respect to those of the interested party.

Right to data portability: the User has the right to receive the personal data concerning him/her provided to a Data Controller in a structured, commonly used and machine-readable format and has the right to transmit such data to another Data Controller without hindrance from the Data Controller to whom you have provided them.

Right to Opposition: the User has the right to object at any time, for reasons related to his particular situation, to the processing of personal data concerning him, including profiling. The Data Controller refrains from further processing the personal data unless he demonstrates the existence of binding legitimate reasons for proceeding with the processing which prevail over the interests, rights and freedoms of the interested party or for the assessment, exercise or the defense of a right in court. If personal data are processed for direct marketing purposes, the interested party has the right to object at any time to the processing of personal data concerning him carried out for these purposes, including profiling insofar as it is connected to such direct marketing, to be understood as any data processing for the purpose of sending advertising material or direct sales or for carrying out market research or commercial communication.

No spam

The Data Controller of the Portal and its Users do not tolerate “spamming”, i.e. the unwanted and unsolicited sending of material and information of a commercial and advertising nature. The Data Controller periodically carries out an automatic check of the messages and can use manual filters to check for the presence of spam, viruses, attempts to acquire personal data, to carry out other illegal activities or to transmit illegal or prohibited content, but not permanently archive messages sent through these tools. The emails sent to the Data Controller will not be archived permanently, the email address will not be used for marketing purposes, nor will it be transferred or sold.

Reserved Area of the Portal

The login and password are the only “key” that allows the User to access the “Customer Area” section. The User is advised to use complex numbers, letters and special characters and not to disclose this information to third parties. If the User decides to provide the login and password or personal information to third parties, you will be responsible for all acts performed with the use of your account. If you lose control of your password, you may no longer be able to control how your personal information is used and you may be subject to legally binding actions taken on your behalf. Therefore, if for any reason the password should be compromised, it is necessary to report it to the Data Controller in order to change it immediately.

Safety

The Data Controller guarantees the security of Users’ personal data in compliance with art. 32 of the Regulation.

Principles of pertinence and non-excessive treatment.

The User’s personal data will be processed in compliance with the principle of pertinence and non-excess with respect to the purposes pursued. Personal data will be kept for the time strictly necessary for the purposes pursued with the processing of the same.

Right of Complaint

The User expressly acknowledges that the processing of data by the Data Controller is subject to the control of the Guarantor for the protection of personal data, to which any and all complaints regarding the collection, management and processing of data in the compliance with the Privacy Code.

Prohibition of Profiling

The data of the users of the portal are not subject to profiling or treatment through an automated decision-making process.