Privacy policy

ETESIA S.r.l., with its legal headquarters at Via Adolfo Ravá, 106 – 00142 Rome – VAT number 17853431009, represented by its legal representative pro tempore, as the data controller (also referred to as the “Controller”), in accordance with Article 13 of Legislative Decree 196/2003 (“Privacy Code”), provides users visiting the Open Communication website (hereinafter also referred to as the “website”) with information regarding the processing of their data.

Data Processed and Purposes

Navigation Data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified individuals, but 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 IP addresses or domain names of computers used by users connecting to the site, URI (Uniform Resource Identifier) addresses of requested resources, 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 server’s response (successful, error, etc.), and other parameters related to the user’s operating system and IT environment. These data are used solely to obtain anonymous statistical information on the use of the website and to check its correct functioning. The data could also be used to ascertain responsibility in case of any computer crimes against the website.

Cookies
The site uses only technical cookies. For all details, please refer to the cookie policy available on the website.

Data Provided Directly by the User
Personal data provided voluntarily by the user (for example, when requesting information or clarifications by writing to the email addresses listed or when filling out the checklist on the site) are used solely to respond to any requests made and to fulfill pre-contractual and/or legal and/or contractual obligations arising from the established legal relationship. Specific information is provided in the forms and sections of the site dedicated to particular services that require the user to provide data. The user who provides data referring to third parties acts as an independent data controller and therefore assumes all obligations and responsibilities under the Privacy Code regarding their processing, guarantees that they have acquired and process the data of third parties, if transmitted, in compliance with the relevant legislation, and indemnifies ETESIA S.r.l. against any claims, disputes, and requests for compensation related to the provision of third-party data.

Nature of Data Provision
Except for navigation data, which are necessary for the operation of IT and telecommunication protocols, the provision of personal data by users is free and optional. However, failure to provide such data will make it impossible to respond to requests.

Processing Methods
Data processing is carried out using IT tools. Data are stored in electronic archives with the adoption of the minimum security measures required by law. Data will be processed only by authorized personnel (who have been specifically appointed as data processors or privacy officers) and stored for the time strictly necessary to fulfill the requests of the data subject and in any case in compliance with legal terms.

Location of Processing
For the processing of data related to the services of the website, the Controller uses servers located within the European Union.

Communication and Disclosure
The collected data will not be disclosed, sold, or exchanged with third parties without the express consent of the data subject, except in cases where communication to third parties (companies providing IT supply and support services) is necessary to comply with legal obligations or fulfill obligations arising from the existing relationship with the data subject, or where such third parties (falling within the indicated category) act as data processors. The data subject may request the Controller to provide the list of appointed data processors.

Rights of the Data Subject
The data subject may at any time exercise the rights under Article 7 of Legislative Decree No. 196 of June 30, 2003, by contacting the data controller via email at contatti@etesia.cloud. The text of Article 7 is reproduced below.

Article 7 of Legislative Decree 196/2003
1. The data subject has the right to obtain confirmation of the existence or absence of personal data concerning them, even if not yet recorded, and their communication in an intelligible form.
2. The data subject has the right to obtain information on:
a) the origin of the personal data;
b) the purposes and methods of processing;
c) the logic applied in case of processing carried out with the aid of electronic tools;
d) the identification details of the controller, data processors, and the designated representative under Article 5, paragraph 2;
e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of them as designated representatives in the State, data processors, or authorized personnel.
3. The data subject has the right to obtain:
a) the updating, rectification, or, when interested, integration of the data;
b) the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, including those whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
c) certification that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except where this proves impossible or involves a manifestly disproportionate effort compared to the right protected.
4. The data subject has the right to object, in whole or in part:
a) for legitimate reasons, to the processing of personal data concerning them, even if relevant to the purpose of collection;
b) to the processing of personal data concerning them for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication.

The law grants the data subject certain tools for protection, the description of which can be found on the website of the Italian Data Protection Authority (Garante per la protezione dei dati personali) at the following link: http://www.garanteprivacy.it/home/diritti/come-agire-per-tutelare-i-nostri-dati-personali.