Privacy Policy Notice

The data provided to Telami srl, through the website at www.telami.it (hereafter the "Site") when using the services provided by Telami (hereafter "Services"), will be processed in compliance with the regulations on the protection of personal data (GDPR EU Regulation 2016/679 and Italian Privacy Code). Telami informs users of the following.

1. Data Controller

1.1. The Data Controller of personal data is TELAMI Srl, with registered office in Milan (20133 - Italy), Via Canaletto 10, registration number in the Milan Companies Register and VAT number 10072090961 (hereafter "TELAMI" or "Data Controller"), phone number +39.02 56569860 and fax number +39.02 56569860, info@telami.it.

2. Nature of the processed data and purpose of the processing

2.1. The personal data processed are exclusively of users who have reached the age of majority, where personal data refers to any information about an identified or identifiable natural person, directly or indirectly by reference to any other information.

The data processed are those provided by the user to the Data Controller when registering for the newsletter service and/or requesting the provision/activation of a Telami Service and/or when sending communications to Telami via email or through a dedicated form, such as name and surname, date of birth, email address, postal address, phone number, as well as data collected by Telami during browsing on the Site, such as IP address, information obtained through cookies.

2.2 The data will be used for the following purposes:

1. A) for the execution of the requested Services, for compliance with legal obligations and community regulations, as well as for the exercise of rights in court;

1. B) for the promotion, via email, phone calls with an operator, SMS, MMS of commercial offers related to and/or connected with Telami Services, as well as for sending advertising material exclusively concerning Telami products or services, as well as for conducting market research and sending free samples or promotional gifts of modest value;

1. C) for analyzing consumer habits and choices, creating a profile of the user based on the information and preferences expressed during browsing the Site or during the use of the requested Services, for sending personalized advertising communications via email, SMS, MMS, postal mail, and operator-assisted phone calls.

The profiling activity identified in section 2.2C will not produce legal effects on the user nor will it personally concern them, except for the communication and promotion of personalized offers.

3. Mandatory/optional nature of data provision

3.1 The provision of the data requested at the time of activating the Services for the purposes identified in section 2.2A above is mandatory, as it is strictly necessary for the provision of the requested Services and compliance with legal obligations. Refusal to provide the data will prevent Telami from completing the process of providing the requested Services and/or complying with legal obligations.

3.2 The provision of the data requested for the purposes identified in sections 2.2B, 2.2C above is optional.

Refusal to consent to the purposes outlined in sections 2.2B, 2.2C will not affect the provision of the Services. Users can still use Telami's Services.

Users may oppose processing for the purposes outlined in sections 2.2B, 2.2C either immediately by not giving consent during the activation of the newsletter service or additional Services, or at a later time by sending an email to info@telami.it. Users, at the time of activating the Services, check boxes to consent to the use of the data identified above for the specified purposes; if users do not check a particular box, it will be considered that they have not allowed to processing for that purpose.

4. Processing methods

4.1 Users' data will be collected online during the activation of the requested Services, through the comparison of elements or parts of information, or through the use of email.

4.1 Users' data will be collected online during the activation of the newsletter service or additional Services. The processing of users' data will be carried out through operations such as recording, consulting, communicating, storing, and deleting, primarily using electronic and manual means, ensuring the adoption of appropriate measures to protect the security and guarantee the confidentiality of the data processed .

  

provision of the requested Services and all other external parties collaborating with Telami and who need to be made aware of the data to properly fulfill Telami's obligations arising from the supply contract for the Services;

1. c) Public Authorities in the performance of their institutional functions, within the limits provided by laws and regulations.

Users' data will not be disseminated.

The Data Controller has appointed Data Processors. An updated list of all Data Processors can be requested at the following email address dpo@telami.it. Telami may periodically update the list.

4.3 Users' data, stored electronically/magnetically/digitally, is stored and archived on a server located in the United States; personal data stored in paper form will be archived in appropriate registers and/or files whose storage will be guaranteed by placing them in appropriate containers, stored in suitable premises. Telami declares that data recorded on its server and/or in suitable premises are protected against the risk of intrusion and unauthorized access and that it has taken security measures to guarantee the integrity and availability of the data and protect the areas and places of data storage and accessibility.

In particular, the company hosting our server is duly certified according to the Privacy Shield.

4.4 Personal data will be processed by employees and/or collaborators of Telami who act as data processors or authorized personnel, within their respective functions and according to the instructions provided by Telami.

5. Data disclosure

5.1 Users' personal data may be communicated to certain subjects appointed by Telami to provide the requested Services and to comply with legal obligations.

Data may be communicated to:

1. a) individuals, companies, or professionals providing accounting, administrative, legal, tax, and financial assistance to Telami, consultancy and collaboration services;

1. b) parties appointed and/or authorized by Telami to perform activities or parts of activities related to the
2. User Rights

6.1 Users (hereafter "data subjects") have the right to obtain confirmation of the existence of their personal data and the purposes of processing at any time. Users also have the right to request the updating, rectification, deletion, or blocking of data and to refuse its use, in whole or in part.

6.2 Users' rights are listed below. Specifically:

6.2.1 The data subject has the right to obtain confirmation as to whether or not personal data concerning them is being processed, and, if so, to obtain access to the personal data and the following information.

6.2.1 The data subject has the right to obtain access to the personal data and the following information. The data subject has the right to be informed of:

1. a) the identity and contact details of the data controller and, if applicable, the data controller's representative;

1. b) the contact details of the data protection officer, if applicable;

1. c) the categories of personal data, their source, the purposes of the processing to which the personal data is subject, and the legal basis for processing;

1. d) any legitimate interests pursued by the data controller or third parties;

1. e) any recipients or categories of recipients of the personal data;

1. f) if applicable, whether the data controller intends to transfer personal data to a third country or an international organization and whether an adequacy decision by the Commission exists, or a reference to the appropriate safeguards or other means to obtain a copy or if they are available.

6.2.3 In addition to the above information, the data controller must provide the data subject with the following further information:

1. a) the period for which personal data will be stored or, if not possible, the criteria used to determine that period;

1. b) the existence of the right to request access, rectification, or erasure of personal data from the data controller, or restriction of processing concerning them, or to object to processing, as well as the right to data portability;

1. c) if processing is based on user consent, the existence of the right to withdraw consent at any time, without affecting the legality of processing based on consent before its withdrawal;

1. d) the right to lodge a complaint with a supervisory authority (Data Protection Authority);

1. e) the existence of automated decision-making, including profiling, and, where such automated decision-making produces legal effects concerning them or similarly significantly affects them, relevant information about the logic involved, as well as the significance and consequences of such processing for the data subject.

6.2.4 The data subject has the right to object, at any time, to the processing of personal data concerning them:

1. a) for reasons related to their particular situation, including profiling;

1. b) where personal data is processed for direct marketing purposes, including profiling to the extent that it is related to such direct marketing.

6.2.5 The data subject has the right to:

1. a) obtain from the data controller without undue delay the rectification of inaccurate personal data concerning them. Taking into account the purposes of processing, the data subject has the right to have incomplete personal data completed, including by providing a supplementary statement;

1. b) receive personal data concerning them that they have provided to Telami, in a commonly used electronic format that is easy to read, and have the right to transmit such data to another data controller without interference;

1. c) obtain from the data controller the erasure of personal data concerning them, and the data controller is obliged to erase personal data without undue delay if one of the following reasons applies:

- the personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

- the data subject withdraws consent on which processing is based, and there are no other legal grounds for the processing;

- the data subject objects to processing and there are no overriding legitimate grounds for processing;

- personal data has been unlawfully processed

;

- personal data must be erased to comply with a legal obligation under European Union or member state law to which the data controller is subject;

1. d) obtain from the data controller the restriction of processing.

6.3 To exercise the rights mentioned above and receive information about the parties to whom the data has been communicated or who may become aware of the data while acting as data processors or authorized personnel, users can contact Telami by sending a request using the contact details provided above.

The data controller will provide information on the action taken on the data subject's request without undue delay and no later than one month after receiving the request. This period can be extended by another two months if necessary, taking into account the complexity and number of requests. The data controller informs the data subject of any extension within one month of receiving the request, stating the reasons for the delay. If the data subject makes the request by electronic means, the information will be provided electronically, where possible, unless otherwise requested by the data subject.

7. Processing time

7.1 Personal data will be processed concerning the purpose mentioned in section 2.2.A for a period no longer than necessary for the execution of the requested Services and compliance with legal, tax, and accounting obligations in effect, and, in any case, for a period no longer than 10 years after the end of the aforementioned obligation (as per applicable provisions regarding prescription).

7.2 Personal data will be processed concerning the purposes outlined in section 2.2.B (marketing/promotional activities) for a period not exceeding 24 months from the date consent was given for personal data processing.

7.3 Personal data will be processed concerning the purposes mentioned in section 2.2.C (profiling activities) for a period not exceeding 12 months from the date consent was given for personal data processing.

7.4 At the end of the processing period, data will be deleted or permanently anonymized.

8. Legal basis for processing

8.1 The legal basis for processing will be constituted by user consent, compliance with a contractual requirement, and legal provisions.

9. Updates to the Privacy Policy

9.1 This Privacy Policy is subject to occasional revisions. Telami will notify users of any changes made to the data processing terms by publishing the changes on the Website. If required by applicable law, users will have the opportunity to consent to any new data processing. If the user refuses, their data will not be processed according to the changes in the new privacy policy.

10. Transfer to non-EU countries

10.1 Personal data is transferred to the United States, as some data processors have their server infrastructure there.

10.2 The European Commission has made an "adequacy decision" regarding the United States' data protection laws.

Transfers to the United States will be protected by adequate safeguards, particularly the Privacy Shield, more information at https://www.privacyshield.gov/European-Businesses, or the use of standard contractual clauses adopted or approved by the European Commission, a copy of which can be obtained from www.garanteprivacy.it or www.garanteprivacy.it/web/guest/home/footer/contatti .