Web privacy policy & Cookies

This Privacy Policy aims at to describing how this Site is managed with regard to the use of cookies and other tracking tools (hereinafter referred to for simplicity as “cookies”) and the processing of personal data of users/visitors who use the website.

It is provided pursuant to Regulation 2016/679/EU (General Data Protection Regulation – hereinafter GDPR), Article 122 of the Personal Data Protection Code (Italian Legislative Decree 196/03, the Privacy Code) and the General Provision of the Italian Data Protection Authority of 8 May 2014 on cookies, as supplemented by the Italian Personal Data Protection Authority Guidelines of 10 June 2021 on cookies and other tracking tools, for those who connect to the site: https://www.telsy.com/.

This Privacy Policy is provided only for the above-mentioned site (hereinafter referred to as “Site” or “this Site”) and any sub-domains, but not for other websites that may be consulted by the user via links.

The above website is owned and managed by TELSY S.p.A.

TELSY S.p.A. ensures compliance with legislation regarding data protection, in line with the provisions of the Telecom Italia Group Code of Ethics.

Users/visitors are asked to read this Privacy Policy carefully before submitting any personal information and/or filling in any electronic form on the Site and, in general terms, before using the Site.

Type of data processed and purpose of processing

  1. Browsing and device data

The computer systems and the software procedures used to operate this Site, during their normal operation, acquire some technical data: IP address; domain names of the computers used by users who connect to the Site; identifier, brand, model and other parameters relating to the operating system of the device; the code indicating the status of the response given by the server, type of browser, the identifier of the individual session with timestamps of the beginning and the end of the browsing session, possible identifier of the account and of the activities carried out on the Site, etc..

In particular, the use of the information received through the compilation forms for the request to download multimedia files (images, documents, videos, etc., if present), is limited to monitoring the traffic to this Site in relation to the email addresses from which such requests come. In addition, the “Careers” section includes the identification information of the user who fills in the fields provided, together with any file uploads.

This data is only used to check that the Site is working properly, for statistical purposes and, subject to consent, for profiling purposes (if applicable). The data itself is stored for a period of time not exceeding the achievement of the purposes for which they are collected or subsequently processed, as well as for the period provided for by law for administrative purposes, the management of complaints, disputes, computer crimes against the Site or criminal proceedings.

No data from the web service will be disseminated.

  1. Cookies

2.1 General information on cookies

Cookies are small text strings (file) that websites visited by users send to their devices (usually to browsers or smartphones), where they are stored and then transmitted back to the same sites each time they visit using the same device. In addition, each website may allow the transmission of third-party cookies, i.e. cookies generated by websites other than the one the user is visiting (through objects on it such as banners, images, maps, sounds, specific links to web pages of other domains).

Depending on their duration, a distinction is made between session cookies (i.e. cookies that are temporary and automatically deleted from the device at the end of the browsing session by closing the browser) and persistent cookies (i.e. cookies that remain stored on the device until they expire or are deleted by the user).

Cookies serve several purposes. They are primarily used to carry out the transmission of a communication or to provide the service requested by the user. More specifically, they enable and optimise the operation of the website, perform computer authentication and prevent abuse, monitor sessions, improve the user’s browsing experience, for example by maintaining the connection to reserved areas while browsing through the pages of the site without having to re-enter the User ID and password and storing specific information about the users themselves (including preferences, type of browser and computer used). They may also be used (anonymously, if third-party) to carry out aggregate analysis on the operation of the site, the number of users and how they visit the site.

The above-mentioned cookies are called technical cookies (their use does not require the user’s consent), since without them some of the operations mentioned above could not be carried out or would be more complex and/or less secure.

On the other hand, if the cookies are used for additional purposes, typically for (i) analysing behaviour, also by tracking the authenticated user through the use of different devices, and sending personalised promotional/advertising messages (called profiling cookies) and/or (ii) obtaining statistics in aggregate form on the number of users and on how they visit the site (called analytics cookies), the user’s consent is required (unless the third-party analytics cookies have been anonymised). In fact, before these cookies are sent to your device, in accordance with current legislation, when you access the home page or any other page of the site, a banner is immediately displayed in the foreground with a minimal information notice on the use of cookies and the request for consent, which the user can give (by clicking on the “Accept” button) or refuse (by clicking for example the “X” or “Continue without accepting” button at its top right). Alternatively, the user can click on the preferences management panel (also known as the CMP – Cookie-consent Management Platform) to specifically set consent based on the desired cookies.

In any case, cookies can only be read or modified by the website that generated them; they cannot be used to retrieve any data from the user’s device and cannot transmit computer viruses. Some of the functions of cookies may also be performed by other technologies; therefore, in the context of this web privacy policy, the term “cookies” refers to cookies and all similar technologies.

2.2 Use of first-party cookies on this Site

This Site may use session cookies and persistent cookies.

The types of first-party cookies generated and transmitted by this Site are:

  • “Technical” cookies, used to: a) customisation of the user interface (e.g. to record the preferences expressed by the user such as language, currency, page display format, connection area); b) better usability of the site and its audio-visual content; c) the proper functioning of the connection (e.g. routing the user’s requests between multiple servers in an appropriate manner) . 2.3 Analytics cookies provided by third parties

TELSY S.p.A. doesn’t make use of web measurement services provided by third parties to collect aggregate/statistical information on the number of users and on how they visit this Site.

2.4 Third-party cookies

This Site also allows the transmission to the user’s device of third-party cookies with which TELSY S.p.A. cooperates. TELSY S.p.A., as a technical intermediary, sends these cookies, but does not have control and access to the information provided/acquired.

For these cookies, it is possible to consult the information of the third parties by clicking the link of third parties listed below.

The cookies of third parties consist of the following categories:

    1. cookies of social media, which manage cookies to enable, via plug-ins, the sharing of content between “logged in” members of the same social media network. The social media with which the Site interacts, for the sole sharing of pages of the Site itself, are:

Facebook

Cookies: https://facebook.com/policies/cookies

Privacy: https://facebook.com/about/privacy/update

Twitter

Cookies: https://help.twitter.com/en/rules-and-policies/twitter-cookies

Privacy: https://twitter.com/en/privacy

LinkedIn

Cookies: https://www.linkedin.com/legal/cookie-policy

Privacy: https://www.linkedin.com/legal/privacy-policy

2.5.   Cookie coding criteria and retention times

The semantic coding criteria and retention periods for each cookie are:

Cookie Name Cookie Functionality Retention Time
NID Technical Cookie – Secure connections only 6 months
__Secure-3PAPISID Technical Cookie – Secure connections only 13 months
__Secure-3PSID Technical Cookie – Secure connections only 13 months
__Secure-3PSIDCC Technical Cookie – Secure connections only 12 months
cb-enabled Functionality Cookie – Samesite connections only 12 months
pll_language Functionality Cookie – Only secure samesite connections 12 months

 2.6 Managing your cookie preferences

Cookies can be managed by the user through their browser.

  1. Browser settings

The user/visitor can manage cookie preferences through the functionalities present in common browsers (Internet Explorer, Mozilla Firefox, Google Chrome, Apple Safari), which allow users to delete/remove cookies (all or some) or to change the settings of the browser itself in order to block the sending of cookies or to limit it to specific sites (as opposed to others). It is possible to find out how to configure the browser settings (usually accessible from the ‘Tools’ bar) by going to the ‘Support’ web pages of the providers of these browsers (which can also be found using a common search engine).

Disabling cookies does not in itself preclude the use of the Website’s services; however, if all cookies, including technical ones, are deleted/blocked, some operations cannot be performed or will be more complex and/or less secure, such as, performing activities within the website’s Restricted Areas (in fact, cookies make it possible to carry out and maintain user identification during the session).

  1. Data provided voluntarily by users/visitors

If users/visitors connect to this Site and send their personal data in order to access certain services, or to make requests by e-mail or filling out web-forms, this involves the acquisition by TELSY S.p.A. of the sender’s address and/or any other personal data, which will be processed exclusively for the purpose of responding to the request, i.e. for the provision of the service.

Personal data provided by users/visitors will only be disclosed to third parties if such disclosure is necessary to fulfil the requests of users/visitors.

Processing methods

Processing is carried out by means of automated and telematic tools and/or manually for the time strictly necessary to achieve the purposes for which the data were collected and, in any case, in accordance with the relevant legislation in force.

 Optional provision of data

Apart from what is specified for browsing data, users/visitors are free to provide their personal data. Failure to provide said data may only result in the impossibility of obtaining what has been requested.

Data Controller, Data Protection Officer and categories of persons authorised to process data at TELSY S.p.A.

The Data Controller is TELSY S.p.A., with registered office in Corso Svizzera 185, 10149 Torino; phone number: +390117714343. TELSY has appointed a Data Protection Officer, who can be contacted at TIM by writing to the following address: via Gaetano Negri, 1 – 20123 Milan, Italy; or by sending an email to dpo.telsy@telecomitalia.it.
An up-to-date list of the Data Protection Officer’s contact details can be found at www.telsy.com.

The data of users/visitors of this Site will be processed by employees of TELSY S.p.A., who have been appointed as persons authorised to process personal data and have received appropriate operating instructions in this respect.

Rights of the data subjects

Users/visitors have the right to access their data at any time and to exercise, as far as applicable, 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 the right to be forgotten, data portability, as well as the right to object to the use of the data for legitimate reasons) by sending an e-mail to the following address dpo.telsy@telecomitalia.it. Finally, users/visitors have the right to lodge a complaint with the Data Protection Authority.

 

TELSY S.p.A.

Edition: September 23, 2022