With this document, TCI Telecomunicazioni Italia S.r.l., headquartered in Saronno (VA), via Parma n.14 – Italy, titleholder of the following websites “www.tci.it”, “www.tcisaronno.it” e www.bluelightlink.com and iOS and Android Apps “TCI” e “BLL PLUS” describes the personal data processing modalities of the websites visitors. This is a statement in accordance with sections 2 and 3 of the EU General Data Protection Regulation (GDPR). The statement does not have any value for other websites, visited by users, connected to this one through links potentially included in pages of the aforesaid websites, held by TCI Telecomunicazioni Italia S.r.l..

TYPES OF PROCESSED DATA

1) Navigation Data
In general terms, it is possible to surf the website without providing any personal data. The website is composed by different sections, some of them require data entry, and others do not. IT systems and software procedures dedicated to the website performance are implicitly used for Internet communication protocols. These information could identify users/visitors through associations and elaborations of data owned by third parties (for example IP address, domains name of computers used from users/visitors who connected to the website, etc.) – by their very nature. This kind of data are mainly used for static information and in order to control the correct website performances. Data on website contacts are not stored after their elaboration, except for possible checks on computer-related crimes against the website. No data from the web service is communicated or disseminated.

For further details relating to cookies, visit the specific section.

2) Data provided by visitors on a voluntary basis
In case users/visitors, connecting to this website, send personal data for accessing to specific services, in other words for requests via email, TCI Telecomunicazioni Italia S.r.l. obtains the user’s address or other personal data, which will be processed just for answering to the request, it means for providing the service.
Personal data provided by users/visitors are communicated to third parties just when the communication itself is necessary for answering to the users/visors’ requests.

PURPOSE OF THE PROCESSING

TCI Telecomunicazioni Italia S.r.l. can process personal data for the following purposes:

1. Manage registration to the site and/or linked APPs, in addition to any connected activities or to access any specific or restricted website areas. Send e-mails necessary to register users to specific website and APP services, and keep account active (processing necessary for contract execution or pre-contractual activities) Manage Italian, European and International legislative requirements (accounting, administrative, fiscal, etc.) Manage any disputes (Legitimate Interest of the Titleholder)
2. Manage Italian, European and International legislative requirements (accounting, administrative, fiscal, etc.)
3. Manage any disputes (Legitimate Interest of the Titleholder)

For the purposes mentioned above, the consent of the users is not required.

PROCESSING METHODS

Data processing occurs through automatic tools (for example using electronic procedures and devices) and/or manually (for example hard copy) just for the period necessary for reaching the data acquisition purposes and in accordance with the current laws. Technical data are stored at the company’s offices that guarantee all the security measures included in the GDPR, and following measures.

OPTIONAL NATURE OF DATA PROVISION

Apart from what described for the navigation data, users/visitors are free to provide their own personal data. Failure to provide said data makes impossible to have what required.

COOKIES

We inform our Users that some pages of this website use technical or session “cookies” for customize the offered service, recognizing the User in case of following website visits (just if the consent has been provided after the opt-in requests).
We do not use cookie profiling or cookie for personal information dissemination.
If you prefer not to receive cookies, you can set your browser for receiving information about the used cookies and be able to decide if accept them or not.
It is possible also to refuse all cookies automatically, enabling the specific option in your browser. If the User decides not to accept cookies, problems could occur occasionally in the use of some pages of this website.
Further details in the cookies specific section in this website.

COMMUNICATION AND TRANSFER OF PERSONAL DATA

TCI Telecomunicazioni Italia S.r.l. does not transfer personal data outside the company, partners and affiliate. For technical-practical needs connected to the information processing, some personal data could be positioned in vendors and sub-vendors servers or just elaborated by third parties that acceded to the standards of TCI Telecomunicazioni Italia S.r.l. for the personal data protection.
Data could be communicated to the competent authorities, in accordance with law.

TITLEHOLDER, REPRESENTATIVES AND CATEGORIES OF PERSONS IN CHARGE

The titleholder of data processing is TCI Telecomunicazioni Italia S.r.l. – headquartered in via Parma n.14 Saronno (VA) – Italy.
Data are processed just by technical staff formally designated. You have the right to ask for the list of third-party data processors to the Titleholder.

For any enquiries, please send an email to: Info&Privacy

RIGHTS OF THE CONCERNED PEOPLE

People, which personal data are related to, have the right to obtain the confirmation of the existence or not of those data and to know content and source, to verify the accuracy or ask for the integration, update or correction in any moment (GDPR).
Following this article, you have the right to ask for the processed data cancellation, modification in in anonymous form or the block of them in violation of the law, as well as to object to the processing of data, in any case, for legitimate reasons.

GDPR

PERSONAL DATA PROCESSING STATEMENT IN ACCORDANCE WITH THE EU GENERAL DATA PROTECTION REGULATION (GDPR)

ASSUMPTION

According to the GDPR, TCI Telecomunicazioni Italia S.r.l. – headquartered in Saronno (VA) Italy, via Parma n.14 – as the processing titleholder, has to provide some information relating to the use of your personal and sensitive data.

PURPOSE OF THE PROCESSING

Personal data collected from and images possibly sent by the concerned person are the object of the process, and are processed and used directly for:

1. ecution of obligations coming from the stipulated contracts with TCI Telecomunicazioni Italia S.r.l. and/or in compliance with specific concerned person requests, before the contract due date;
2. compliance of law obligations, regulations or community rules;
3. management of technical and/or business information requests submitted through the websites of TCI Telecomunicazioni Italia S.r.l.;
4. management of registration requests for the assistance portals (support.multiux.com), with the resulting access to published material and its free download;
5. further activities, relating to TCI Telecomunicazioni Italia S.r.l., made by phone, fax, sms, MMS, mail, email, automatic communication systems that are about the concerned person, who can approve or not them. These include the following activities:
   • market researches for measuring the concerned person satisfaction about the quality on offered services by TCI Telecomunicazioni Italia S.r.l.;
   • activities of business communication TCI Telecomunicazioni Italia S.r.l. products/services promotion and sell made directly or not, that means through specialized companies

PROCESSING DATA MODALITY

In relation to the specified purposes, data processing occurs through manual, computer, and telematics tools with logics strictly connected to the own purposes and, in any way, in order to guarantee data security and privacy.

APPROVAL

In accordance with paragraphs 1), 2), 3), 4), Your personal data processing and communication do not need Your consent because the process is necessary for the execution of obligations coming from the contract itself and/or for the execution of performances required by You and in compliance with the legal obligations.

Relating to the purpose in paragraph 5), data processing consent is necessary when data are collected for marketing purposes.

NATURE OF PROVISION

Data provision is discretionary and it is subject to the will of the person who wants to register himself to the company’s portals or wants to obtain the requested information. The missed data provision, strictly useful for the registration, entails the impossibility to complete itself and the consequent services consumption. Data not explicitly signed as mandatory can be easily allowed by interested people.

DATA COMMUNICATION AND DISSEMINATION

I dati potranno essere comunicati a soggetti terzi, durante l’esecuzione degli obblighi previsti dalla legge o dal contratto in essere tra le parti (es. Enti Pubblici, Autorità di controllo, Istituti Bancari, ecc.). I dati potranno inoltre essere comunicati a società collegate e/o controllate, sempre nell’ambito della fornitura e/o del contratto in essere. I dati non sono soggetti a diffusione.

TERMS OF DATA STORAGE

In order to ensure the compliance with the data processing principles of necessity and proportionality, the Titleholder has identified different data retention times, depending on the purpose.

To manage the contractual relationship between parties and or for law requirements, personal data are stored just for the time necessary and, in any way, no more than ten (10) years from the end of the relationship.

For the purpose of handling any disputes, personal data will be kept for the time striclty necessary for this purpose and, in any case, no later than the applicable limitation period.

Referring to the data processing for commercial and promotional communications, except for contact data, they are stored for a maximum period of five (5) years, except in case of missed processing consent.

TITLEHOLDER AND REPRESENTATIVES OF DATA PROCESSING

The Titleholder referred to this Informative is TCI Telecomunicazioni Italia S.r.l., headquartered in Saronno (VA) – via Parma n.14 – Italy.

For any communication, the Titleholder makes the following email address available: Info&Privacy

The Titleholder has and stores an up-to-date list of the elected representatives and it guarantees the acknowledgement of each representative at the previously mentioned place.

RIGHTS OF THE CONCERNED PERSON

The GDPR grants many rights to the interested person, entirely available here below:

1. e concerned person has the right to obtain the confirmation or not of the existence of personal data concerning him and their communication in intelligible form;
2. the update, correction, and the integration of data when interested;
3. the cancellation, modification in anonymous form or the block of processed data in violation of the law;
4. ottenere dal Titolare la trasformazione in forma anonima o il blocco dei dati personali trattati in violazione di legge
5. data in a common format, that can be easily transferred to another titleholder;
6. cancel the consent to the processing of personal data, for any of the purposes for which it was provided.

Furthermore, it is possible to submit a complaint to the Italian Data Protection Authority, if the interested person considers that a violation of personal data occurs.

COOKIE POLICY

Dear Visitor, we use only essential cookies to guarantee a good user experience on our website. Below, you can find the description of the cookie we use, what cookies are used for, and how you can change your preferences.

WHAT ARE COOKIES?

Cookies are small bites of information that are stored by your browser on your computer hard drive. Every time you revisit our website, your web browser sends these cookies back to us so we can customize your experience and better match your interests and preferences or simply we can facilitate your signing in to use our services.

WHICH COOKIES DO WE USE?

The cookie we use allows us to recognize each returning consumer and his relevant information, so he does not need to input the same information more than once. It also helps us to understand visitor traffic patterns through our website, so we can enhance the usability. Look at the type of cookie we use in our website.

ESSENTIAL COOKIES

We use essential cookies in order to enable you to receive the services that you request through our website. Without these cookies, the required services cannot be provided. For example, these cookies may be used to:

• Allow you to access secure areas of our website without logging-in into the service continuously;
• Remember your previous actions (such as completing an online form) when navigating back to a page in the same session.

COOKIES & OTHER
INFORMATION READING/STORAGE TECHNOLOGIES

Possiamo utilizzare cookies (file di testo di piccole dimensioni trasferiti dal server Web al computer dell’utente) e altre tecnologie di lettura e/o archiviazione di informazioni sul dispositivo dell’utente come fingerprinting, email tracker o Clear GIF/Beacons, il cui scopo è informare il server riguardo agli accessi dell’utente a quella determinata pagina Web, e di altre eventuali notizie che ricava dai parametri leggibili del sistema tramite funzioni contenute nella pagina Web, per personalizzare e facilitare l’esperienza di navigazione degli utenti e, in alcuni casi previo loro consenso, per arricchire la profilazione degli utenti per fini pubblicitari e/o commerciali.  I cookies possono essere “temporanei” (o di sessione, sono cancellati al termine del collegamento) o “permanenti” (restano memorizzati nel disco fisso dell’utente, a meno che l’utente stesso non li cancelli).

The cookies used by our websites and our apps are divided into the two types as identified by the Italian DPA (“Privacy Authority”) with the General Provision “Cookies” dated 8 May 2014, whose statements are followed by the Owner as it concerns the information and need/modality of getting the consent. Notably, this advice represents also the extension of the concise banner already displayed when connecting to the website and/or when the APP is installed.

For all the websites regulated by this policy, here below please find the details of the used cookies/other profiling technlogies.

On the basis of the above mentioned Italian DPA‘s Provision, our websites and apps use:

“Technical Cookies” necessary to the operation of the website/APP and/or to the supply of a service requested by the User. This category of cookies includes the analytics implemented by the Owner of the website to gather aggregated information on the number of users and on the way they visit the website.

CMS COOKIE

“Profiling Cookies” personally owned and/or of third parties, they are potentially aimed at creating/enriching profiles of the User and used to send and/or show the advertising messages in line with the User’s preferences shown when surfing the Internet. To use this kind of Cookies the User’s consent (optional) is always necessary. The User can choose which profiling cookies or other technologies such as fingerprinting/Clear GIF/Profiling Beacon to authorize. When it is a matter of “third parties” cookies or technologies, in other words installed/used on the website by third parties other than the Owner, the User gives or denies the consent directly to the Owner of the cookie and/or the specific technology, to which the Owner makes a connection through a simple link.
The following profiling/not technical cookies and/or other technologies like beacons/Clear GIF/fingerprinting are used:
– di terzi

KIND OF PROPRIETARY COOKIE	TECHNICAL NAME OF COOKIES	AIM	FURTHER INFORMATION
Facebook	Cookie Facebook	Cookie to include in the Website pages the social buttons of Facebook	https://www.facebook.com/about/privacy/
Twitter	Cookie Twitter	Cookie to include in the Website pages the social buttons of Twitter	https://twitter.com/privacy?lang=en
Google	Cookie Google+	Cookie to include in the Website pages the social buttons of Google+	http://www.google.it/intl/it/policies/technologies/cookies/
Google	Cookie Video Embedding Youtube	Cookie to allow to watch videos from Youtube	http://www.google.com/policies/privacy/
Google	Cookie Google Analytics	Cookie for Google Analytics service	https://support.google.com/analytics/answer/2700409?hl=it
ShinyStat	Cookie ShinyStat	Cookie for ShinyStat service	https://www.shinystat.com/it/informativa_privacy_generale.html

It is also possible to manage/deactivate the cookies directly from the browser settings.
To have further information concerning how to set up the preferences on the cookies’use through your browser, please have a look at the instructions:

• Internet Explorer
• Firefox
• Chrome
• Safari

To oppose to the use of profiling tools other than cookies (like beacons/Clear Gif/email trackers) please refer to the following email address: Info&Privacy

The use of further lasting cookies and session cookies (that are not persistently stored on the computer by the User and that disappear when the browser is closed) is strictly limited to the transmission of session identifiers (consisting in random numbers generated by the server) necessary to allow the safe and efficient exploration of the website. The so called session cookies used by the website prevent the use of other computer techniques potentially prejudicial for the privacy on the user’s browsing and they don’t allow the acquisition of the user’s personal information.

RIGHTS OF THE USERS

Those subjects the personal datas refer to have the right to obtain in every moment the confirmation about the existance or not of such datas and to know their content and their origin, to verify their correctness or to ask for their integration, updating or correction (Legislative Decree nr.196/2003, art.7).
As provided for by the mentioned article, people have the right to ask for the cancellation, modification into anonymous form or the blockage of the datas processed in breach of the Law. People have as well the right to oppose to the datas processing in any case, for legitimate reasons. The requests have to be forwarded to this email address: Info&Privacy