MEDIACARE NUMBER CUSTOMERS’ PRIVACY POLICY
Last update: May 2018
1. Introduction and acceptation of the Privacy Policy
Mediacare offers comunication services for companies and private customers.
Mediacare does its best to protect the privacy of all subjects that stipulate contracts with our business, with everyone that visits our websites and asks for informations.
The customers’ Privacy Policy applies to all of our company contracts, services and websites. The term “Customer” is referred to present customers, new customers (even potential customers), ex customers and website visitors, beneficiaries of our digital services, included marketing.
The Privacy Policy establishes how Mediacare protects its Privacy and describes the confidentiality practices of the company.
Mediacare offers multiple contracts, services and websites, for the different business purposes.
By accessing and utilizing Mediacare’s websites, stipulating a contract with the company or using our offered services, you accept and consent us to collect, use and share your data as described in the current Privacy Policy.
If you use the Mediacare website or its services, and/or stipulate a contract with us, you will automatically allow us to process your personal data.
Before using or sending your personal data through determined sections of the websites, in respect to a contract or as a part of our services, you will be asked to confirm the acceptance of our current Privacy Policy, even electronically, by checking on one or more boxes or by clicking “ACCEPT” or similar buttons.
By checking said boxes, by using our website or our services, you are allowing us to process, use and transfer your personal data as desribed in the current Privacy Policy.
The data in our possession that demonstrate that you accepted the current Privacy Policy, its date and all of its future changes are considered to be a final and written evidence of your consent.
The Privacy Policy contains:
- The informations that you must know about how we collect and use your data;
- What personal data we store about you;
- How we use the personal data that we might collect about you;
- For what purposes we use your personal data;
- why and with who we share your personal data;
- In which cases your personal data could be transfered abroad;
- How we protect the security and confidentiality of your personal data;
- the choices and the rights that you have in correlation to our use of your personal data;
- How you can contact us about our privacy practices and how you can excercise your rights.
The date of the last revision and update of our Privacy Policy is stated to the beginning of the document and it states the date in which it starts to take effects.
2. The informations that you must know about how we collect and use your data
- We collect and use your personal data to manage our business relationship with you, and also to answer your questions or complaints, to provide you with our products and services, to manage our contracts with you, to inform you about our products and services, our partners, promotions and events, to manage and upgrade our websites and services, to answer to authorities requests, to respect our legal and contractual obligations and for other legitimate business finalities. Mediacare does not share, sell, rent or exchange personal data with third parties for promotional purposes.
- Where you express your interest in obtaining further informations on the services, or registering to use our websites or other services, you provide our Company with personal contact details, such as name, company name, address, telephone number and e-mail address ("Mandatory contact details") to be able to contact you. Furthermore, when purchasing the Services, Mediacare may ask you for additional tax and billing informations, such as the invoice header and billing address of the organization that will use the Services ("Billing Data"), which are not considered personal data.
- We may ask you for some data that allows us to provide you with a Service, collecting it by telephone, by written / digital means or via the website.
- Where this is required by law and with your consent, we use cookies and other technologies to monitor the use of our websites and our services. To see the use of cookies and your rights in this regard, we have prepared a separate section at the bottom of this document.
- Where this is required by law and with your consent, we may use your data to conduct marketing, promotional and information activities and to perform business analisys, surveys about customers’ satisfaction or market researches and to perform direct marketing.
- We may share your personal data with other internal organizations, with other companies controlled by Mediacare, with thirds parties that elaborate data for us, and where said data sharing is required by law or in other situations, to the extent permitted by law. According to the applicable law, you have the right to access all the personal data that we hold about you, to modify, to erase or delete inaccurate data, to oppose, in every way and free of charge, to the processing of your personal data for direct marketing purposes. As well as other rights applicable by law.
- Using our website and services, as well as stipulating contracts with us, will constitute a consent to the processing and transfer of your personal data to other organizations situated outside the Eurpean economic area jurisdiction, which may provide a different protection level than your country.
- The current privacy policy is exclusively applied to the way that Mediacare manages your personal data. It doesn’t apply to other Companies, to other Companies websites, not even where the registration to said websites happened through Mediacare. If you show your personal data to other companies, they will be used and managed according to their personal privacy policies.
3. What personal data will Medicare collect?
For the current Privacy Policy purposes, the term “Personal Data” includes any information that identifies you, that might be about you or used to identify you, and which you send on your account when you interact with us and/or is eventually collected by us when you browse on our websites, call our customer service, fill the orders or in other ways. During our work relationship, we may collect and process your personal data such as name, address, phone number, email and other contact details, as well as every other information about you that you can provide to us by:
- Visiting our websites and look at our products and services;
- Creating an account on our websites;
- Asking questions about our products and services or by contacting our customer care;
- Stipulating a contract with us and buying our products or services;
- Partecipating to discounts, surveys or other types of marketing campains organized by us;
- Subscribing to our newsletters and other promotional materials.
Personal data that you may provide.
The various types of personal data that we may obtain in regard to the cases listed above are:
- Your name, address and contacts (such as fixed number, phone number and fax, e-mail address);
- Contact details (such as name, address, function/role, phone number and fax, e-mail address);
- Provided services, included online services;
- Third parties names, e-mail addresses and phone Numbers that you may provide to us;
- Online account data such as username, password and other credentials used to access the products and services offered by Mediacare;
- Tax and Payment data such as bank data (IBAN), invoices and payment terms, also every other personal data used to complete or process the billing informations;
- Complaints, questions and opinions about our services;
- Social Security Number, where it is needed by certain products and services;
- Answers given to surveys.
Personal data gathered by automated means.
When you visit our websites or use our services, after you give us your consent where needed by law, we can collect personal data through automated means, so you won’t need to send them personally, using technologies such as cookies, web server logs, web beacons, online chats and similar technologies, as described below.
The types of personal data that we can gather when you visit our websites or use our services, to the extent permitted by law and, where requested, after obtaining your explicit consent, includes:
- The date and hour of the visit, the redirection link (the place from where a visitor got on our websites);
- The web browser type, the OS and device used;
- The IP address of the visitor (an unique number assigned to every PC that is connected to the internet that is given to identify it);
- The data relative to the call traffic or the Internet session when you use our phone services or internet, included the called numbers, the phone ID, the call duration and the data volume used during the internet session;
- Where relevant, data about the location that is generated during calls or internet sessions;
- The history of your contacts with our customer care.
Personal data collected by Third parties
Mediacare can also receive informations on customers by other means, such as third parties from where we buy informations, and add this informations to the Data that we already have about you. This helps us to keep up to date, amplify and analize the data in our possession, find new customers and create targeted advertisements to offer products and services that may interest you. We will make sure that every marketing campaign will be in line with the requirements imposed from the GDPR.
4. How do we use your personal data?
Mediacare will elaborate your personal data exclusively for the purposes described in the current Privacy Policy or as permitted by applicable law. The processing of your personal data from Mediacare for said purposes is based on your explicit consent or on your need to process your data for our common legitimate intrests, as said in the Art 9. Par. 2 commas (a) and (f) of the General Data Protection Regulation (UE) 2016/679 of April 27 2016 (“GDPR”).
Your personal data can be processed both by Mediacare and its associates, controlled and controlling, for the following purposes:
- To manage our relationship with you, as well as answer your questions or your complaints;
- Give whatever good, service or information that you requested about our products and services;
- Manage, operate, maintain and upgrade our websites and our services;
- Manage efficiently the relationship with our customer;
- Simplify the access to some interactive functions on our website or Services;
- Manage your accounts, orders, invoices and payments;
- Manage and provide post-selling services;
- Manage the accountings and taxes;
- Answer to requests from the administrative or judicial authorities;
- Act in respect of the laws and of the applicable regulations.
To provide personal data for said purposes is necessary and declining it would prevent Mediacare to manage the stipulated contract with you or to respect the legal and contractual obligations. With your consent where this is required by law, we can also use your personal data to:
- Keep improving the functioning of our website;
- Count how many people visit our websites, where they come from and for how much time and what pages they consult;
- Use your activity on our website to give you recommendations about our products and services that might interest you and to measure the performance of our advertisements;
- Register data relative to the browser, the OS and the device used, to be sure that we are offering you the best and most pleasing online experience from the moment that you access to our website;
- Provide you the access to informations and services about Mediacare on Internet;
- Examine the usage of the websites;
- To commercialize and improve the offered services;
- Conduct promotional campaigns, surveys and other marketing initiatives under the section "How do we use your personal data for marketing purposes?” as follows;
- Communicate other offers and discounts;
- Understand how you use our products and services to develop new and improved versions;
- Conduct researches and statistical analysis, such as monitoring how all of our customers use our network, our product and our services on an anonymous or business basis.
- Prevent and find scams and other crimes, recover debts or track who owe us amounts.
To provide personal data for marketing purposes is optional and the refusal will not have consequences on any Contract with Mediacare.
To offer you a better experience and to improve the quality of our services, to the maximum extent permitted by applicable law, we may combine the informations that you send us to the other informations that we can gather from you, from third parties or from other demographical public data.
Also, to help us improve our websites and our offered services, we collect our websites’ visitors data. For example, we know how many are the visitors of every page of our site, when they visited it, for how long and on what areas they were focused. We can share these informations with our advertisement agencies and other companies that offer us their goods and services on our websites. Neither you nor any other person can be identified by the informations that we share, since these are grouped informations and so it is anonymous data.
5. Why and with who do we share your personal data?
Our policies do not foresee giving, selling or distributing personal data that we collect from third parties outside of Mediacare, for the exception of when it is requested with explicit consent or when it necessary in accordance to the applicable law. According to what is mentioned above, we do share personal data with the following recipients:
- Controlled, controlling or Mediacare subsidiaries. We can share your personal data with other companies of the Mediacare group and also according to the purposes listed in the section ”How do we use your personal data?” upstated and described also in the section "Will my personal data be transferred abroad?" of this document.
- Third parties service providers. Your personal data may be shared with third parties providers, that work for us, in relation to managing services, data analysis, informatic assistence, financial and accounting services or other services. These service providers will have access and will elaborate personal data only on our behalf and following our precise instructions, and they will be bound by security obligations.
- Mediacare’s commercial partners. A list of partners that can be provided to customer on request, provided that there is a legitimate reason.
- Other data recipients. According to the purposes listed above or where it is provided by law, we may also need to share data to third parties such as banks and financial institutes, professionals, indipendent consultants, investors and/or current and potential buyers (according to a merging, acquisition or transfer that affects Mediacare or its subsidiaries or for the purpose of a corporate reorganization, for the sale of shares or activities or other changes concerning corporate control), administrative or regulatory authorities, courts, police forces.
Mediacare can also share informations, in response to a request adequately presented, to prevent and find criminal activities and prosecute offenders, when requested by the law, for example after an order of the court or in response to an amministrative or advanced question from the court. Mediacare can also give informations in order to protect national secuity. Anyway, Mediacare will act in accordance with the relevant laws about data security.
- Other telecommunication operators. In order to add their data in the telephone directories (with the data of our customers), Mediacare receives informations from other telecommunication operators about their customers. We also provide phone numbers to the directory enquiry services, unless the customer (BT or other authorized telecommunication operators) chosen to not be inserted in said directories.
>We can also share your personal data after your explicit consent (through contract or other legal means) to such assignment or where we believe that sharing is necessary or appropriate for our legitimate intrests (or those of the third parties with who we share the data), provided that the interests, fundamental rights and fundamental freedoms of the data subject do not prevail over them, in accordance with applicable law.
We can share with third parties also some grouped data, that is not personal, such as how the various customers use our Services or websites.
6. Will personal data be transferred abroad?
To process the contract that we have stipulated with you to offer you our Services or Websites, we may need to transfer your personal data to Mediacare’s subsidiaries and commercial partners or to other receivers as said in the section “Why and with who do we share your personal data?” situated both inside and outside of the European Economic Area (“EEA”), included countries that do not provide the same security level of the EEA for personal data.
In every case, we transfer personal data exclusively to receivers that offer a satisfactory security level or that follow the standards of Data protection rules, adopting the appropriate safeguard measures such as, by way of example and not exhaustive, relevant arrangements about the data transfer based on the agreement with Mediacare for the transfer inside the Group, based on the contract terms of the European Commission and the contract terms of non-EU countries, where necessary. By sending your personal data to Mediacare and by stipulating a Contract with us by visiting our website or using our services, you consent to any such transfer of data to said countries.
7. How is your data protected?
Mediacare has appropriate policies, technical and organizational measures to protect your personal data from any illegal or unauthorized access, from damages and illegal and unauthorized usage and distribution. We will use every reasonable precaution to grant our employees and personnel of our subsidiaries and controlling companies that have access to personal data to receive the necessary training.
8. For how much time do we keep your personal data?
For personal data, we follow a precise conservation policy in line with the legal and statutory requirements. To gather other informations about this subject, contact the Data Protection Office (“DPO”) of Mediacare Spa by using the e-mail address dpo@mediacare.it.
We may also keep your data for the time needed by Mediacare to pursue our legitimate business intrests, respect our legal obligations, resolve disputes and enforce our agreements.
9. What happens when you give us personal data about third parties?
If you gave us personal data about third parties, you declare, ensure and promise to have acted by the limits of the applicable laws of data protection and that you have obtained the consent for all personal data provided to Mediacare for us to process it as described in the current Privacy Policy.
10. How can you update or delete your personal informations?
In accordance with and by the applicable laws of data protection, you have the right to access personal data that we hold about you and ask to correct or delete inaccurate data. You can excercise said rights by contacting us as described in the section "What are your rights about data protection terms?" as follows.
From the moment that a customer signs a new contract with Mediacare, a private area will be created, where, by accessing it, you can see and modify your personal data. To ensure that the data that we hold about you is always accurate, you can update your personal data when it changes or you can send us a request in the section "What are your rights about data protection terms?" as follows. If you close your account we can, for limited time periods and according to applicable law, hold some personal data to satisfy legal obligations or for some other appropriate finalities, the recovery of outstanding debts or to resolve legal disputes.
From the moment that you ask to be excluded from certain marketing offers, you will be, according to the applicable law about data protection, added to an internal elimination list (or lists), to ensure that your request will be answered.
11. How do we use your personal data for marketing purposes?
We can use your personal data to conduct marketing, promotional and information activities and to perform business analysis, surveys or market researches, as well as direct market purposes in general, also by sending notifications about website updates, informations about our services that might intrest you, initiatives and events by mail, e-mail, phone, fax, text messages, MMS or other electronic means.
However, we will contact you by this means exclusively by following the GDPR requisites and/or in compliance with the relevant legal requirements.
If you do not wish to receive marketing informations, you can tell us by e-mail or by using the option “UNSUBCRIBE” that you can find in these communications.
12. How do we use your personal data for monitoring and registering calls?
When you call us, the calls may be registered for personnel traing purposes and for service quality control, and as evidence of a commercial transaction, in accordance with the applicable law. This will be notified to you by a registered message before your call is assigned to a staff member. The calls registered for this purpose will be kept safe, will not be shared outside our Company Group, if not for operative means, and they will be deleted according to our policies and to all pertinent legal means.
13. How do we use minors personal data?
We do not consciously gather data from anyone who has less than 18 years, neither we allow them consciously to register to our websites or services.
14. What are your rights about data protection?
According to applicable law about data protection, you have the rights to:
- Get the confirmation of the existence, and ask for a written copy, of the personal data that Mediacare holds about you;
- Get every inaccurate information about you to be modified and corrected;
- Get personal data that we hold about you deleted, blocked or removed;
- Withdraw your consent where relevant, without prejudice to the lawfulness of the process carried out on the basis of its consent before its revocation;
- Limit the processing we perform in relation to your personal data;
- Receive the personal data that you provided us in a structured format, for common use and suitable for automatic reading, to give the data to a processing manager;
- Oppose to your data use for marketing purposes and other promotional activities, as stated in the section "How do we use your personal data for marketing purposes?” as stated above;
- Where you think that the personal data processing violates the applicable law about personal data protection, lodge a complaint to a Supervisory Authority, in the particular Member State in which you reside or usually work, or in the place where said violation happened.
If you wish to exercise any of your rights, send a written and signed request to Mediacare as described in the section “How to contact us?” below.
15. What happens if you visit a linked website?
The informations gathered by third parties websites that you may access through our website are not covered by our current Privacy Policy and are governed by the terms applied to your relationship with the third party subject; Mediacare does not accept any responsibility related to third parties websites.
16. How can we update the current Privacy Policy?
We reserve the right to review the current Privacy Policy in every moment. Where it is appropriate or required by law, we will inform you through an adequate communication on our services or websites or by e-mail (to the extent that we have your e-mail address). We invite you to periodically see the current Privacy Policy to be always informed about our data practices. Up in the header of the document we will always report date of the last Privacy Policy update. Continuing to use our Services or Websites and partecipating to Mediacare events constitute acceptance of the updated Privacy Policy. If you do not accept the new Privacy Policy, you must stop using the services.
17. How to contact us?
For every question about the current Privacy Policy, or if you wish to apply your rights by means of applicable law about data protection, you can contact us through our Website or by registered mail at:
Ufficio Data Protection Office
Mediacare Spa
Viale Parioli, 13
00197 Roma
You can contact us on the e-mail
dpo@mediacare.it
COOKIE POLICY
Statement
Cookies are made by portions of code installed inside the browser that help the owner to distribute the services according to the described purposes.
Some of the cookies installation purposes may, also, need the User’s consent.
Technical and data analysis cookies
Cookies have the function to allow the execution of activities strictly bound to the functioning of this online space. Technical Cookies used by the owner can be divided in the following sub-categories:
- Browsing cookies, through which we can save the browsing preferences and optimize the user’s browsing experience;
- Analytics Cookies, through which we can gather statistical informations about the browsing modes of the users. Said informations are processed in group and are anonymous;
- Functionality Cookies, even from third parties, used to activate specific functions of this online space and are necessary to provide the service or to make it better.
Said cookies do not need the user’s consent to be installend and used.
Other types of cookies or third parties instruments that may use them.
Some of the services listed below may not require any consent from the user or they may be used directly by the owner depending on what described without help of third parties.
If the following instruments include services managed by third parties, these could in addition to what specified and without knowledge of the owner perform user’s tracking activities. To get more detailed informations we suggest to consult the privacy policies of the listed services.
These services allow interactions with social networks, or with other external platforms, directly from the pages of this Application.
The interactions and the informations acquired from this application are however subject to the user’s privacy settings of each social network.
If there is a service installed to interact with social networks, it is possible that, even for users who are not using the service, it will still collect data about the traffic of the relative pages where it is installed on.
+1 Button and Google+ social widgets (Google Inc.)
The +1 Button and Google+ social widgets are services used to interact with the social network Google+, provided by Google Inc.
Collected personal data: Cookies and usage data.
Place of processing: Designated Countries Privacy Policy
Linkedin’s button and social widgets (LinkedIn Corporation)
Linkedin’s button and social widgets are services for interacting with LinkedIn’s social network, provided by LinkedIn Corporation.
Collected personal data: Cookies and usage data.
Place of processing: Designated Countries Privacy Policy
Facebook’s Like button and social widgets (Facebook Inc.)
Facebook’s Like button and social widgets are services for interacting with Facebook’s social network, provided by Facebook Inc.
Collected personal data: Cookies and usage data.
Place of processing: Designated Countries Privacy Policy
Twitter’s Tweet button and social widgets (Twitter, Inc.)
Twitter’s tweet button and social widgets are services for interacting with Twitter’s social network, provided by Twitter, Inc.
Collected personal data: Cookies and usage data.
Place of processing: Designated Countries Privacy Policy
Zandesk Chat Button
Place of processing: USA Privacy Policy
How can I control Cookies installation?
In addition to what stated in this document, the user can manage its preferences about cookies directly from the browser to block for example third parties that may install them. Through the preferences of the browser it is also possible to delete cookies that may have been installed in the past, including the cookie that is imediately installed when you give consent to allow cookies on the website. It is importat to note that by disabling all cookies, the website correct functioning may be compromised. You can find informations on how to manage Cookies in your browsers in the following liks: Google Chrome, Mozilla Firefox e Microsoft Windows Explorer.
In the case of services offered by third parties, the User can excercise his right to oppose the tracking by inquiring on the privacy policy of the third party, through the opt out link if it is explicitely provided or by contacting them directly.
By following what stated before, the Owner informs you that the User can use the section “Your Online Choices”. Through this service it is possible to manage the tracking preferences of most advertising tools. The Owner, therefore, suggests to the users to use said resource in addition to the other informations provided in this document.
Since the cookies installation and other tracking systems are operated by third parties through services used inside this online space you can’t technically be controlled by the owner, every specific mention to installed cookies and tracking systems from third parties is considered to be indicative. To get more informations, you can consult the privacy policy of any third party services listed in this document.
Given the complexity of the technologies which cookies are based on and on their integration widely spread across the web, it is suggested for the user to contact the Owner if he wants to receive any kind of in-depth information about the function and usage of cookies and other uses for exaple how third parties may operate them through this website.
The present document is referred to every web space (websites, platforms, web instruments, etc) owned by the Data Controller.
To get more informations about the tools related to a specific website you can contact:
Ufficio Data Protection Office
Mediacare Spa
Viale Parioli, 13
00197 Roma
Pec: mediacare@pec.it