Privacy Policy

The purpose of this document is to describe the procedures for managing access to this site, in relation to the processing of personal data of users/visitors who consult it.

Wind Tre S.p.A. (hereinafter Wind Tre) guarantees compliance with the legislation on the protection of personal data, pursuant to and for the purposes of European Regulation no. 679/2016, the Code on the protection of personal data (Legislative Decree no. 196/2003) as amended by Legislative Decree 101/2018, consistently with the requirements of the Code of Ethics of the Wind Tre Group.

The information is provided only for this website and not for any other websites that you may consult through links (hereinafter referred to as ‘Links’), also present within this site itself, but which lead to sites of which WindTre is the Data Controller.

Data Controller, Data Processors and Authorised Persons.
The Data Controller is Wind Tre S.p.A. with registered office in Monte Rosa 91, 20149 Milano
The updated list of Data Processors is available upon request. Within Wind Tre S.p.A., personal data will be processed by the employees of the company divisions indicated in the aforementioned list. These employees act as authorised persons under the direct authority of the respective Data Processor.

Your data may be communicated to third parties in fulfilment of a legal obligation.

Data Controller, Data Processors and Authorised Persons.
The Data Controller is Wind Tre S.p.A. with registered office in Largo Metropolitana 5, 20017 Rho (MI).
The updated list of Data Processors is available upon request. Within Wind Tre S.p.A., personal data will be processed by the employees of the company divisions indicated in the aforementioned list. These employees act as authorised persons under the direct authority of the respective Data Processor.

Your data may be communicated to third parties in fulfilment of a legal obligation.
Wind Tre works with law enforcement agencies and other public entities and public authorities to enforce the law, the rights of other users and third parties, including their intellectual property rights. Therefore, your personal data may be disclosed, by way of example, to public entities where this is necessary for purposes of defence, state security, prevention, detection or repression of crimes, in compliance with the rules governing this matter. These public subjects also have the right to request and obtain your personal information if this is necessary or appropriate for investigations or assessments relating to the commission of fraud, computer fraud, violation of intellectual property rights, acts of hacking or other illegal activities, which could expose Wind Tre or our Users to legal, civil or criminal liability.

Type of data processed and purpose of processing

Navigation data
The computer systems and software procedures used to operate this portal acquire, during their normal operation and for the sole duration of the connection, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information, by its very nature, could, through processing and association with data held by third parties, make it possible to identify visitor users (e.g. IP addresses), the domain names of the terminals used, the URI (Uniform Resource Identifier) notation addresses of the requesters, the time of requests, etc. These data, which are deleted immediately after processing, are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation. Data on web contacts are not stored for more than seven days, except in the case of computer crimes against the sites. No data resulting from the service will be communicated or disseminated.

Cookies
In line with the principle of transparency that governs the relationship with our users and in compliance with current legislation, with particular reference to the Provision of the Authority for the Protection of Personal Data (hereinafter the ‘Authority’) ‘Identification of simplified procedures for the provision of information and the acquisition of consent for the use of cookies’ of 8 May 2014, we also inform you about the types, purposes and methods of use / management of cookies sent while browsing on websites operated by Wind Tre.

What are cookies?
Cookies are small text strings that are sent by a website to the browser used by the user for browsing, stored on the device (e.g. Computer, Tablet, Smartphone, etc.) and retransmitted to the same site the next time the user visits. Usually a cookie appears as a string containing at least the name of the website from which the cookie originates, the ‘duration’ of the cookie, and a value, which is usually a randomly generated unique number. 
On the basis of the entity in charge of managing the cookies sent by a website, two types of cookies are distinguished
- first-party’ when they are managed directly by the owner and/or publisher of the Wind Tre S.p.A. website; 
- third-party’ when the cookies are managed by parties unrelated to the website visited by the user.
The use of cookies or similar techniques will take place in full compliance with the provisions of Article 122 of the Personal Data Protection Code, as amended by D. Lgs. 101/2018 and by the Provision of the Guarantor Authority ‘Identification of simplified procedures for the information and acquisition of consent for the use of cookies’ of 08 May 2014, which identify the lawfulness of such technologies for certain legitimate purposes, relating to the technical storage for the time strictly necessary for the transmission of the communication or to provide a specific service requested by the User, who can always oppose the processing of his/her Data for the purposes specified above. 
In fact, the User, who is informed in advance pursuant to Article 13 of the EU Regulation 679/2016 and of the Privacy Code and subsequent amendments and additions, will have the possibility to accept all cookies, to be informed about the use of a cookie or to proceed to deactivate even all cookies by autonomously modifying the settings of his or her navigation program (also called ‘browser’). 
If cookies are rejected, the quality or functionality of the Site pages may be reduced.
Below are instructions for managing cookies with reference to the most popular browsers:
- Internet Explorer
- Mozilla Firefox
- Google Chrome 

First-party cookies 
Cookies play an important role in web browsing. We use cookies to improve and facilitate the user experience by, for example, storing certain information about the browser used by the user (e.g. language, country, shopping cart, etc.) and avoiding the need to re-enter this information on subsequent visits to the site. Wind Tre uses first-party profiling cookies to track the online behaviour of users of the websites it manages for its own marketing purposes.

Third Party Cookies
While browsing our websites, it is possible that some cookies that do not belong to our domains may be sent (so-called ‘Third Party cookies’) when, for example, users visit a page that includes content from a third party website. Some Third Parties may send, by means of sites managed by Wind Tre S.p.A., cookies that allow us to understand the habits and preferences expressed by users while browsing, in order to allow the latter to adapt the advertisements shown on our websites. Some types of cookies, managed by Third Parties, also allow us to obtain aggregate statistical information regarding visits received and browsing habits, in order to improve the usability and performance of our websites. For the sake of clarity, Wind Tre S.p.A, provides below a list of the types of Third Party cookies that may send cookies while you are browsing our sites and the relevant descriptions and pages/websites where you can consult the information regarding the use of such cookies and refuse to consent to their sending. What cookies do we use?
Below is a description of the types of first-party cookies sent from the www.windtrebusiness.it website.

Technical Cookies
Technical cookies are essential for the proper functioning of certain sections of the Website and are used to allow users to navigate normally and to take advantage of the services available on our Websites, without which the latter could not function properly. Our Websites use or may use, also in combination with each other, the following categories of technical cookies, subdivided according to the classification proposed in the Opinion 04/2012 on the exemption from consent for the use of cookies issued by the Article 29 Working Party within the EU Persistent cookies that allow, for example, to remember any actions performed by users (e.g. completion of a form) when returning to the previous page of a session. Session cookies that are sent to the users‘ device/browser to meet technical and functional requirements (e.g. transmission of session identifiers needed for authentication to restricted areas) but are not stored persistently on the users’ computer and are deleted at the end of the ‘session’ by simply closing the browser. Below is a description of the types of third-party cookies sent by the www.windtrebusiness.it website.

Analytics Cookies
These cookies are used by the Site www.windtre.it to collect and analyse aggregated and anonymous information for statistical analysis on access and visits to our website in order to improve its performance and design.

For this purpose, the Site uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses ‘cookies’, which are text files placed on the terminal equipment of the person concerned to allow statistical analysis in aggregate form. Google Inc. is the relevant data controller.

Method of Processing
The Personal Data acquired, are processed through the use of paper, computer or telematic tools and only for the time strictly necessary to achieve the purposes for which such Data have been collected, in compliance with the provisions on the confidentiality of Personal Data contained in the GDPR, Legislative Decree no. 196/2003, as amended by Legislative Decree 101/2018 and in the applicable sectoral Measures issued by the Italian Data Protection Authority.

Wind Tre S.p.A. guarantees that the security and confidentiality of your Personal Data will be protected by adequate protection measures, in accordance with the provisions of art. 32 of the GDPR, in order to reduce the risks of destruction or loss - even accidental - of the Data, unauthorised access, or processing that is not permitted or does not comply with the purposes of collection.

The persons to whom the Personal Data refer have the right, pursuant to Articles 15 to 22 of the EU Regulation, to obtain, at any time, confirmation of the existence or non-existence of their Personal Data, to know its content and origin, to verify its accuracy or to request its supplementation, updating or rectification. Pursuant to the aforementioned articles, you have the right to request the deletion, transformation into anonymous form or blocking of Data processed in violation of the law, to oppose in any case, for legitimate reasons, their processing. Any requests pursuant to Articles 15 to 22 of the European Regulation should be addressed to the following addresses:

Wind Tre S.p.A. has appointed a Data Protection Officer, who can be contacted at the e-mail address dataprotectionofficer@windtre.it.

*****

Wind Tre S.p.A. reserves the right to make changes to the Site, this Web Privacy Policy and Cookies wherever published on the Site, at any time.
When consulting, the user must always refer to the published text as the current version.
Changes will become effective when they are published on the Site.
Continued use of the Site by the user, following a change, will be considered as acceptance of the change.
All users may check at any time, by connecting to the Site, the latest version of the Web Privacy Policy and Cookies as updated from time to time by Wind Tre S.p.a.