INFORMATION TO CUSTOMERS

PURSUANT TO ARTICLE 13 OF LEGISLATIVE DECREE no. 196/2003
(PROTECTION OF THE PERSONS AND OTHERS REGARDING THE TREATMENT OF OF PERSONAL DATA.)
Dear Customer,
With the coming into force of Legislative Decree no. 196/2003, that repealed law 675/1996 and all the regulations consequent on it, establishing - Instructions for the protection of persons and others regarding the treatment of personal data", as controller of the treatment, we provide you with the following information considering the use of personal data.

TYPE AND SORUCE OF THE PERSONAL DATA
The personal data in possession of BTicino S.p.A. Owner of the  data are:

  1. provided by you or persons known even incidentally, in the performance of the activities agreed by contract;
  2. acquired from third parties;
  3. acquired from publicly accessible data bases. 

The categories of personal data acquired are: identifying, administrative, accounting and IT; in any case the individual  categories will be determined automatically from the data acquisition sheets prepared for the purpose with regard to the various services provided by the writer.

It mus be noted finally that the Owner will be able to acquire data and information regarding energy consumption through the home automation system and the objects connected to BTicino.

PURPOSE OF THE TREATMENT TO WHICH THE DATA IS DESTINED
The personal data is treated as part of BTicino S.p.A.'s normal activity and for the following purposes:

  1. In performance of the legal, precontractual and contractual obligations relative to the activities connected to the performance of our institutional tasks i.e. for the performance of legal and contractual obligations.
  2. Purposes connected with the obligations provided for by law, regulation and community regulations as well as the instructions issued by authorities legitimated by the law for the purpose and by supervisory and control bodies.
  3. Purposes strictly connected and instrumental in the management of relations with Customers in the sphere of the activities carried out by BTicino S.p.A. as per the Company bylaws and the law; 
  4. Purposes that are functional for the activities of BTicino S.p.A. The following activities fall into this category:
    1. detection of the level of satisfaction at the quality of the services provided to customers and the work done by BTicino S.p.A. carried out directly or through the agency of specialised companies through personal or telephone interviews, questionnaires etc.
    2. sending marketing,sales and promotional advertising regarding the activities and services of the Owner and third parties through automatic means, such as emails and messaging as well as traditional methods such as telephone contact with the operator.
    3. processing and analysis of the aggregate data regarding hourly energy consumption as measured by the BTicino home automation system with an eye to optimising the energy balance and the development of innovative solutions. 
    4. Analysis for the tracing of errors generated by the  DoorEntry app, by way of example the following information will be gathered: the version of the operating system installed on the smartphone; make and model of the smartphone; technical details that help to find the error generated.

 

THE NATURE OF THE DATA CONFERMENT AND CONSENT The conferment of data is obligatory for the procedures necessary and sanctioned by the law;it is however optional but necessary to allow the use and/or utilisation of the activities/services/performances provided by the controller, as well as with regard to the conclusion of the specific contractual relationship and the fulfilment of the obligations deriving therefrom; it is also optional but necessary in terms of other purposes pursued by the controller and shown in (4). Any refusal to confer data could in fact mean:

It should be clarified and recalled that for objectives (1) (2) (3) for just the data involved and strictly sufficient and necessary for the existence of the relationship fall into the hypotheses of exemption for the request for consent pursuant to art.24 of Legislative Decree no. 196/2003; otherwise, in the cases indicated in (4), points a) and b) consent is requested and, in its absence, it will not be possible to treat the data for the above mentioned aims; consent is not however requested for the aims referred to in (4) points c) and d), because the activity involves the collection of aggregate data that is treated in anonymous form (i.e  it cannot be traced back to he interested party).

METHOD OF TREATINGTHE DATA
Personal data is treated with manual, IT and electronic instruments with logics that are strictly linked to the objectives indicated in such a way as to guarantee the security and reserved nature of the data itself.

TIMES FOR KEEPING THE DATA
As far as the objectives indicated in (1) (2) (3) are concerned, the time for keeping the data is that indicated by the specifically applicable regulations (to which, therefore, express reference is made), particularly with reference to the tax-related regulations; as far as the objectives in point (4) a), the time for the treatment of said data shall be at the most twice the duration of the contractual relationship existing between the parties starting from the termination of said relationship.

CATEGORIES OF SUBJECTS WHO CAN RECEIVE THE DATA
For the carrying out of BTicino S.p.A. activities  your data can be communicated to:

It should be noted that the data relative to energy consumption, acquired and treated for the objectives in point (4) c) can be communicated to third parties always in aggregate form and therefore cannot be traced to the interested party.
Communication of the data to the third parties indicated above, other than the Owner, responsible parties, inside but also outside the company structure, those charged with the treatment, specified and appointed pursuant to art. 29 and 30 of Legislative Decree no. 196/2003 and subsequent amendments and supplements respectively, is possible after express consent except cases where communication is legally required or it is necessary for  implementing obligations deriving from the contract you are party to or to fulfil, before its conclusion, your specific requirements.

BTicino S.p.A. enlists various entities as its outsourcers for some data treatment; subjects belonging to the categories to whom the data can be communicated will treat the information as responsible parties pursuant to law, as part of the existing contractual relationship. A detailed list of these companies is also available from our registered office.
The area where this data can be communicated is not just in Italy and its islands but also outside it and limited to the European Union except for any communications inside the group, but again with the precautions and guarantees pursuant to articles 42 and 43 of Legislative Decree no. 196/2003 the possibility of divulging the data to indeterminate parties is not contemplated..

RIGHTS OF THE INTERESTED PARTIES, REFERRED TO IN ARTICLE 7 OF LEGISLATIVE DECREE No. 196/2003

We would inform you that art. 7 of the legislative decree in question gives every person interested in the treatment of personal data concerning him or her specific rights.
In particular, pursuant to art. 7, the interested party can also obtain confirmation of the existence or otherwise of personal data regarding him or her, even if not yet recorded, and its communication in an intelligible form. The interested party has the right to obtain the indication: a) of the origin of the personal data; b) the aims and modes of the treatment, c) the logic applied in the case of treatment carried out with the aid of electronic instruments; d) the identifying details of the Owner, the responsible parties and the representative assigned pursuant to article 5, point 2. e) of the entities or categories of entities to whom the personal data can be communicated or that might learn of it as the designated representative in the territory of the State, responsible party or charged party.   The interested party has the right to obtain a) the updating, rectification or,  when they are interested, additions to the data; b) the cancellation, transformation into anonymous form, or blocking of data processed in violation of law, including that that does not need to be kept for the purposes for which the data it was collected or subsequently processed. c) certification that the parties to which the data have been transferred or disseminated have been notified of the operations specified in points a) and b), also regarding their content, except for the case where notification proves impossible or requires the use of means clearly disproportionate to the right being protected the interested party has the right to contest in part or fully: a) for legitimate reasons, the treatment of the personal data regarding him/her even if it is pertinent to the purpose of its collection; b) the handling of personal data which pertains to him/her for the purpose of sending advertising materials or direct sales materials, for the completion of market research or for commercial communication.

OWNER, RESPONSIBLE PARTY AND PRIVACY COMMUNICATIONS

Owner of the treatment is:
BTicino S.p.A.
Viale Borri, 231
21100 Varese - Italy

The person responsible for the reply pursuant to and for the purposes referred to in art. 8 of Legislative Decree n. 196/2003, is the acting Marketing Director of BTicino S.p.A., with address of record for the office at the offices of the writer.

Communications can be made in writing by sending a enquiry to:

An updated and complete list of the managers is available at the BTicino S.p.A. registered office.