Chat Service Privacy Policy
The following policy on the processing of personal data (hereinafter also referred to as “
Privacy Policy”) is provided by the Company in its capacity as
Data Controller of personal data collected through the chat service available through specific widgets on its websites (hereinafter “
Chatbox”, “
Chat” or “
Chat Service”) or which, through this service, are provided directly by users. The Company believes it is essential to protect users’ privacy and provides this Privacy Policy so that the user can make an informed choice when using the Chat.
In general, all personal data (hereinafter also referred to as “
Personal Data” and/or “
Data”) that the user provides to the Company through the Chat Service or that will be collected in the context of use of this service will be processed in accordance with the principles recognised by the applicable data protection regulation, such as the principles of transparency, fairness, lawfulness, data minimisation, purpose limitation and storage limitation, accuracy, integrity and confidentiality.
The Privacy Policy is divided into individual sections (hereinafter referred to collectively as “
Sections” and/or individually as “
Section”), each of which deals with a specific area, in order to allow a more immediate and easier reading and search of topics.
With reference to the processing of personal data related, more generally, to the use of the website and cookies, please refer to the specific Privacy Policy available at the following link:
https://www.sacmi.it/it-IT/corporate/Special-Pages/privacy-policy/Privacy-policy.
CONTACT DETAILS AND DATA CONTROLLER
The Data Controller is the Company as identified above in the header. If the Company has appointed the Data Protection Officer, the contact details will be available in the header.
PROCESSING PURPOSES AND PROCESSED PERSONAL DATA
The Data will be subject to processing by the Company, according to the limits set by the applicable legislation, for the following purposes:
The Personal Data processed through Chatbox belong to the categories indicated below.
Contact data, Chatbox usage data and any special categories of Personal Data
During the use of the Chat Service, the company may collect information such as: Data subject’s name, country and location, contact e-mail, IP address, Chat Service usage data.
Additional Data may be collected during Chat communication and may consist of data that the user voluntarily chooses to provide to the Company when using this service.
The Chat Service by its nature has free text fields where you can provide the Company with information that may contain Personal Data. Since these are free fields, you may choose to provide us (even inadvertently) with special categories of Personal Data such as data revealing political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the identification in a univocal manner of an individual, data relating to health or sexual life or sexual orientation. The Company asks you not to disclose any of these types of Data. Since the indication of such information is, as mentioned above, totally optional, should you choose to do so, the Company has the right to choose not to proceed with the processing of the entered data belonging to the particular categories indicated above, or to process such information only with your explicit consent and in compliance with current legislation.
Personal data referring to other persons
As mentioned in the previous paragraph, since the Chat Service has free text fields where you can send any type of message, these may actually contain Personal Data relating to other data subjects. In all cases in which you decide to share such Data with the Company, you will be considered as autonomous data controller and, as such, you will have to take all legal obligations and responsibilities. Therefore, in this regard, the user grants the Company the widest indemnity with respect to any dispute, claim, request for compensation for damage caused by processing, etc. by persons whose Personal Data have been forwarded by you in violation of applicable data protection regulations. Since, in such a case, the Company would not collect this information directly from the data subjects (but, indirectly, from you), you guarantee that such specific processing may be based on the consent of such data subjects or on another appropriate legal basis that legitimises the processing of the concerned information.
LEGAL BASIS OF THE PROCESSING, COMPULSORY/OPTIONAL NATURE OF DATA PROVISION AND CONSEQUENCES IN CASE OF FAILURE TO PROVIDE THEM
The provision of Data that are preceded by an asterisk (*) in the Chatbox is considered necessary and indispensable by the Company in order to be able to provide the Service.
The provision of Personal Data, and the related processing for the purpose of providing the
Service, is strictly functional to the Chat Service and therefore, to be able to manage and process the requests you spontaneously send. Consequently, failure to provide the Data requested for this purpose, or the ascertained incorrectness of those provided, may make it impossible for the Company to correctly process your request.
The provision of Personal Data, and the related processing for the purposes related to
Legal Obligations, is necessary for the Company to comply with the relevant obligations. When you provide Personal Data to the Company, the latter must process them in accordance with applicable laws which may include the storage and disclosure to the competent authorities for compliance with tax, customs or other obligations.
RECIPIENTS AND TRANSFER OF PERSONAL DATA
Personal Data will be disclosed to Sacmi personnel in charge of handling requests who are authorised to process the personal data contained therein in order to achieve the purposes previously indicated and who have committed themselves to confidentiality or have, in any case, received an appropriate legal obligation of confidentiality.
Personal Data may also be brought to the attention of third parties appointed as Data Processors, as they process Data on behalf of Sacmi, as the company providing the Chat Service platform. Some of your Personal Data may also be shared with recipients located in countries outside the EU or the European Economic Area. In this regard, the Company points out that the processing of your Personal Data by these parties will be carried out in compliance with applicable legislation. Therefore, transfers will be carried out by means of adequate guarantees, such as adequacy decisions, standard contractual clauses approved by the European Commission, accompanied by the simultaneous implementation of additional measures of a legal, technical and organisational nature or other guarantees aimed at providing adequate protection of Personal Data in line with the relevant European provisions. For further information write to the Data Controller at
privacy@sacmi.it.
Personal Data may, where required, be communicated to the competent financial offices, or to other Public Administrations, in accordance with the provisions of the laws in force. Personal Data are not intended for publication or dissemination.
STORAGE OF PERSONAL DATA
The Personal Data processed for the purpose of providing the
Service will be kept by the Company for the time strictly functional to the performance of the requested Service. More specifically, the requests collected through Chat and the Data contained therein will be kept only for the time necessary to allow the Company to identify the correct closure of the request. At the end of this period, the Data that allow the identification, even indirect, of a natural person (such as name, surname, e-mail, IP address) will be made anonymous and kept, in the form of aggregate data, for statistical purposes.
The Personal Data processed for the purposes of
Legal Obligations will be kept by the Company for the period provided for by specific legal obligations or applicable regulations.
YOUR RIGHTS AS DATA SUBJECTS
As Data subjects, you have the right, exercisable at any time, to: