GENERAL INFORMATION NOTICE PURSUANT TO ARTICLES 13 AND 14 OF EU REGULATION GDPR 679/2016 ON THE PROCESSING OF PERSONAL DATA FOR “CUSTOMER SATISFACTION” SURVEYS
Reduced information by Telsy to Business customers “PHYSICAL PERSONS” pursuant to data protection legislation in relation to “customer satisfaction” surveys
Dear Customer,
pursuant to Articles 13 and 14 of Regulation 2016/679/EU (General Data Protection Regulation, hereinafter referred to as GDPR), Telsy S.p.A, a company of the Telecom Italia S.p.A. group, hereinafter referred to as Telsy/Tim, provides you with this information regarding the processing of personal data. This notice is provided because the Company intends to submit you a questionnaire aimed at detecting your satisfaction with the technical and administrative services offered, with the main purpose of improving the services themselves.
The data controller is TIM S.p.A in relation to your data for commercial and reference purposes, and Telsy S.p.A in relation to the provision of the product/service you requested, and Microsoft Italia in relation to the customer satisfaction platform. A copy of Microsoft Forms’ privacy policy can be found at the following web address https://support.microsoft.com/it-it/office/privacy-e-conformit%C3%A0-9c1e3d75-1ae3-4587-adf6-616ed694e440
Categories of personal data processed for the purposes of the Customer Satisfaction process
In compliance with the principles of lawfulness, correctness, transparency, appropriateness, relevance and necessity as per Art. 5, paragraph 1 of the GDPR, as well as in accordance with Art. 6, paragraph 1, subparagraph b) concerning the execution of the contract.
The answers provided during the compilation, are collected by the Controller for the purposes indicated above. These data are not collected in order to be associated with identified data subjects. The Data Controller, in no way and for no reason, will carry out operations to interconnect the data in order to trace its identity through processing and association with other data held. It should be noted, however, that by virtue of answering particular profile questions, which could considerably narrow down the number of subjects, it could be possible to identify, albeit unintentionally, the data subject.
The Company, in its capacity as Data Controller, will process personal data collected automatically by the software or provided voluntarily when filling in the questionnaire only for purposes connected with and compatible with the performance of its Legitimate Interests as per paragraph f).
1) Purposes for which the processing of customer data is necessary and its legal basis
Your personal data, supplied by you and/or acquired also from third parties in the course of the contractual relationship
will be processed by TIM/Telsy for the following purposes related to the performance of the contract, including the pre-contractual phase pursuant to Art. 6); Par. 1); point b) of GDPR 679/2016
- installation, delivery and maintenance of products and/or equipment related to the requested service/product;
- implementation and technical maintenance, also remotely, to ensure the highest level of quality of equipment, computer/telematic systems and/or connections;
- assistance and management of any complaints and disputes;
- customer satisfaction survey.
2) Customer Satisfaction support by Telsy
Should you intend to use the on-line or telephone technical assistance service of the services provided by TIM or by its Telsy Manager, we hereby inform you that in order to carry out checks on correct functionality, technical data may be acquired from the personal computer or devices designated for communication, browser, e-mail addresses and relative configuration, which may be transmitted together with the ticket you send to TIM/Telsy Customer Care.
Your personal data may also be processed by TIM or by its Manager Telsy, for the pursuit of its own legitimate interest to the extent strictly necessary and proportionate to ensure the security of networks and information systems, for transmission within the TIM Group for administrative purposes, as well as to detect and combat conduct that does not comply with the contractual terms and conditions of service or that is malicious.
Your personal data may also be processed by TIM/Telsy for the purpose of asserting or defending its own rights in a court of law, as well as for the purpose of complying with the obligations provided for by laws, regulations or EU legislation and the provisions of the relevant supervisory authorities or other legitimate institutional entities.
The provision of your personal data is necessary for the achievement of the above-mentioned purposes; failure to provide them, or providing them in part or inexactly, may result in the impossibility of providing the services requested.
The answers given to the questionnaires will be forwarded by the Data Controller only in anonymous form for processing.
3) Additional processing purposes that may be pursued subject to the customer’s/ data subject’s consent
In the event that you have given your specific, free and informed consent at the time of activation of the service requested or subsequently, your personal data may be processed by TIM/Telsy, by means of automated contact methods (such as SMS, e-mail and web applications) and/or traditional methods (such as telephone calls with operator), for the purposes of sending advertising material, direct sales, market research and commercial communications relating to the products and services provided by TIM/Telsy or its partners. Again, for the same purposes and in the same manner, in the event that further specific consent has been given, TIM may contact the Data Controller/Legal Representative and/or Authorised Contact Person.
4) Revocation of specific consent given
Releasing your data for the processing purposes referred to in the preceding points may serve to improve our products and/or services and to notify you of updates that may be of interest to you. You may, however, check and revoke any consent you have given for such purposes at any time by accessing the dedicated company portals or by contacting the TIM/Telsy Customer Center or alternatively the TIM Customer Service by dialling free of charge the telephone numbers (+39) 191, 800.191.101 or (+39) 800.134.134.
5) Retention of personal data, including traffic data
TIM/Telsy will retain your personal data for a period of time not exceeding the purposes for which it was collected or subsequently processed, as well as for the period required by law for the purposes of
Administrative and/or statistical purposes, the handling of any complaints, disputes or criminal proceedings
Data relating to telephone and/or telematic traffic, if any, will be kept from the date of generation for the period established in the contracts you may have entered into and up to seventy-two months for the purposes of criminal law.
6) Methods and logic applied in the processing of personal data
The data will be processed manually and/or by means of computerised and telematic tools, with logics of organisation and processing of the data correlated to the purposes indicated above and, in any case, in such a way as to guarantee the security and confidentiality of the data and communications. In particular, the data will be processed to identify, at the time of the call in the context of assistance services, the type of customer, the relative contract and the equipment used, to enable the operator to respond effectively to requests
7) Data Controller, (DPO)Data Protection Officer and persons authorised to process data at TIM/Telsy
The Data Controller of your personal data is TIM S.p.A., with registered office at via Gaetano Negri, no. 1 – 20123 Milan.TIM has appointed a Data Protection Officer, who can be contacted at TIM at the following address: via Gaetano Negri, n. 1 – 20123 Milano; or by sending an e-mail to: dpo.clientibusiness.tim@telecomitalia.it.
The data controller of your data for the purposes of service provision, delegated by TIM, is Telsy S.p.A., with registered office at Corso Svizzera, no. 185 – 10149 Turin, and the DPO of Telsy can be contacted by sending an e-mail to: dpo.telsy@telecomitalia.it
Your personal data shall be processed by employees of TIM or Telsy in their capacity and/or capacity as Data Processors. Such employees have been appointed as authorised or responsible persons for the processing of personal data by TIM and have received adequate operating instructions in this regard.
8) Categories of third parties to whom data may be disclosed in their capacity as Data Controllers or who may become aware of such data in their capacity as Data Processors
In addition to TIM and Telsy employees, some processing of your personal data may be carried out by third parties, including Telecom Italia Group Companies, to which TIM entrusts certain activities (or part of them) in order to pursue the purposes of the service.
These third parties may also be established abroad, in EU or non-EU countries; in the latter case, the transfer of data is carried out by virtue of the existence of a decision of the European Commission on the adequacy of the level of data protection of the non-EU country or on the basis of the appropriate and suitable guarantees provided for by Art. 46 or 47 of the GDPR (e.g. signature of the EU SCC data protection “standard clauses” adopted by the European Commission) or of the further prerequisites of legitimacy for the transfer provided for by Article 49 of the GDPR (e.g. execution of the requested or existing contract, customer consent).
These parties will act as independent data controllers for the purposes of personal data processing legislation, or will be appointed as Data Processors pursuant to Art. 28 of the GDPR and are essentially included in the following categories: a) parties to whom TIM entrusts the construction and maintenance of equipment, IT/telematics systems and connections and/or the delivery, installation and maintenance of equipment and products; b) parties (e.g. call centres) to whom TIM entrusts the provision of and/or assistance to, as in the case of Telsy S.p.A.
9) Right of access to personal data and other rights
You have the right to obtain from the data controller confirmation as to whether or not personal data relating to you are being processed and, if so, to obtain access to the personal data and specifically, you may exercise the other rights provided for in Articles 15 to 22 of the GDPR (e.g. to request the origin of the data, rectification of inaccurate or incomplete data, restriction of processing, erasure or oblivion, data portability, as well as to object to the use of the data for legitimate reasons or withdraw consent for the purposes you have given.
You may invoke your rights by writing to the following e-mail address dpo.telsy@telecomitalia.it in the cases provided for Data subjects are also entitled to submit requests for the protection of their personal data, primarily by exercising their rights pursuant to Articles 15 to 22 of GDPR 679/2016 regarding the protection of personal data, both with the Data Controller, TIM/Telsy, and with the Data Protection Authority (a.k.a. Garante Privacy) in the cases provided for.
Information on this can be found at https://www.garanteprivacy.it/home/modulistica-e-servizi-online
This information notice has the value of notification for all interested parties and is published on Telsy’s corporate website and sent as a searchable link in the company’s official e-mails at the time of purchase.
TIM’s data protection policy for “PHYSICAL PERSONS” business customers
January 2024 Last Revision