Privacy policy

PRIVACY POLICY PURSUANT TO ART. 13 OF EU REGULATION 2016/679 regarding data processed through this website

We take data protection very seriously and would therefore like to inform you about how your data is processed and the rights you have under current data protection legislation, in particular EU Regulation 2016/679 (hereinafter also referred to as "GDPR").

1. Joint controllers

With reference to all the purposes set out in this policy, the joint controllers* pursuant to Article 26 of the GDPR are:

Belenergia S.p.A.,
Registered office: via G. Serbelloni, 5 – 20122 – Milan (MI)
Email contact: privacy@belenergia.com
Companies of the Belenergia group*

*The essential content of the agreement is made available to the data subject upon request at.

2. Categories of data subject to processing

The data processed by the Joint Controllers is exclusively 'personal data' (pursuant to Art. 4.1 of the GDPR).

In particular, the categories of personal data concerned may include, by way of example but not limited to:

Personal and identification data (including, but not limited to: name, surname, etc.);
Contact details (address, e-mail address, IP address, telephone number and similar data).
Data relating to any services provided.

3. Purposes covered by the consent of the data subject (pursuant to Article 6, paragraph 1 (a) of the GDPR)

Personal data may also be processed for specific purposes for which the data subject has given their consent.

a. Responding to requests or questions submitted and sent to the contacts indicated on this website, to receive information about our products and services, as well as sending quotations and requests for assistance.

The retention period for personal data, in relation to the purposes referred to in this section, is:

For purpose: a, until the request is fulfilled;

4. Recipients or categories of recipients of personal data (pursuant to Article 13(1)(e) of the GDPR) *

Within the scope of the above purposes, the Joint Controllers may communicate your data to:

· Offices and internal departments of the Joint Controllers themselves;

· Control and supervisory bodies;

· Companies and professional operators that provide IT services, including electronic data processing, software management, website management and IT consulting;

· Advertising and communication companies and agencies;

· Mailing companies and hosting providers, postal couriers and companies that perform the activities of enveloping and shipping the above-mentioned material and communications, and companies that perform document archiving activities.

* The complete and updated list of Data Controllers, Data Processors and Recipients (pursuant to Article 4.9 of the GDPR) is available at the offices of the Joint Controllers.

5. Recipients or categories of recipients of personal data (pursuant to Article 13(1)(f) of the GDPR) and transfer of data to countries outside the EU

The Joint Controllers inform you that they do not intend to transfer your data to countries outside the EU and the EEA for the purposes indicated above.

6. Rights of the data subject

The data subject, in relation to the personal data covered by this policy, has the right to exercise the rights provided for in the EU Regulation set out below:

right of access by the data subject [Article 15 of the EU Regulation] (consisting of the possibility of being informed about the processing of their personal data and, if necessary, receiving a copy thereof);
right to rectification of personal data [Art. 16 of the EU Regulation] (the data subject has the right to rectify inaccurate personal data concerning him/her);
right to erasure of personal data without undue delay ("right to be forgotten") [Art. 17 of the EU Regulation] (the data subject has, and will have, the right to have their data erased);
the right to restrict the processing of their personal data in the cases provided for in Art. 18 of the EU Regulation, including in the case of unlawful processing or contestation of the accuracy of personal data by the data subject [Art. 18 of the EU Regulation];
right to data portability [Article 20 of the EU Regulation], (the data subject may request their personal data in a structured format in order to transmit it to another Data Controller, in the cases provided for in the same article);
right to object to the processing of personal data [Article 21 of the EU Regulation] (the data subject has, and will have, the right to object to the processing of personal data in the cases provided for and regulated by Article 21 of the EU Regulation);
right not to be subject to automated decision-making [Article 22 of the EU Regulation] (the data subject has, and will have, the right not to be subject to a decision based solely on automated processing).

The above description does not replace the text of the articles cited therein, which are referred to in full here and which should be read in full in the final section of this policy.

With regard to the purposes for which consent is required, the data subject may withdraw their consent at any time and the effects will take effect from the moment of withdrawal, without prejudice to the terms provided for by law. In general terms, the withdrawal of consent is only effective for the future.

The above rights may be exercised in accordance with the provisions of the EU Regulation by sending an email to the addresses indicated in point 1.

In accordance with Article 19 of the EU Regulation, Belenergia shall inform the recipients to whom the personal data have been disclosed of any rectifications, erasures or restrictions on processing requested, where possible.

In order to allow for a more rapid response to your requests made in the exercise of the above rights, they may be addressed to one of the Joint Controllers at the contact details indicated in point 1.

7. Right to lodge a complaint (pursuant to Article 13(2)(d) of the GDPR)

If the data subject believes that their rights have been compromised, they have the right to lodge a complaint with the Supervisory Authority.

For further information on your rights and how to exercise them, please visit http://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/4535524 or send a written communication to the Data Protection Authority.

8. Possible consequences of failure to provide data and nature of data provision (pursuant to Article 13(2)(e) of the GDPR)

8.1 In the event of compliance with any legal or contractual obligations

Please note that if the legal basis for the processing purposes is a legal or contractual (or even pre-contractual) obligation, the data subject must necessarily provide the requested data.

Otherwise, it will be impossible for the Joint Controllers to pursue the specific purposes of the processing.

8.2 In the case of consent by the data subject

Please note that the above purposes have consent as their legal basis and that, in relation to these purposes, the data subject may withdraw their consent at any time and the effects will take effect from the moment of withdrawal, without prejudice to the terms provided for by law. In general terms, the withdrawal of consent is only effective for the future. Therefore, the processing that was carried out before the withdrawal of consent will not be affected and will remain legitimate.

Failure to give consent or partial consent may not guarantee the complete provision of services, with reference to the individual purposes for which consent is denied.

It should be noted that with regard to requests for information, although consent to the processing of personal data remains free and optional, it is necessary for the request to be processed. Therefore, the submission of the request or equivalent expression of will shall be considered as consent, which may always be withdrawn with the consequences described above.

When the data is no longer necessary, it is regularly deleted. If deletion is impossible or only possible with disproportionate effort due to a particular storage method, the data cannot be processed and must be stored in inaccessible areas.

9. Existence of automated decision-making (including profiling)

The use of purely automated decision-making processes is currently excluded, as detailed in Article 22 of the GDPR. If, in the future, it is decided to establish such processes for individual cases, the data subject will be notified separately if required by law or by an update to this policy.

10. Methods of processing

Personal data will be processed in paper, computerised and telematic form and entered into the relevant databases which may be accessed, and therefore become known to, by personnel expressly designated by the Joint Controllers as Data Processors and Authorised Persons for the processing of personal data, who may carry out consultation, use, processing, comparison and any other appropriate operation, including automated operations, in compliance with the provisions of the law necessary to guarantee, among other things, the confidentiality and security of the data as well as the accuracy, updating and relevance of the data with respect to the stated purposes.

Processing of data useful for navigation purposes

The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.

This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow users to be identified.

The information that may be collected includes IP addresses, the type of browser or operating system used, URI (uniform resource identifier) addresses, the domain name and addresses of websites from which access or exit was made (referring/exit pages), the time the request was made to the server, the method used and information on the response obtained, further information on the user's navigation on the site (see also the section on cookies) and other parameters relating to the user's operating system and IT environment.

This same data could also be used to identify and ascertain responsibility in the event of any computer crimes against the site.

Notice regarding children under 14 years of age

Children under the age of 14 may not provide personal data. Belenergia shall not be liable in any way for any collection of personal data or false statements provided by minors, and in any case, if such use is detected, Belenergia shall facilitate the right of access and deletion requested by the legal guardian or those exercising parental responsibility.

Changes and updates

This policy shows the date of its last update in its header.

Belenergia may also make changes and/or additions to this privacy policy as a result of any subsequent changes and/or additions to regulations.

Regulatory references on the rights of the data subject

Article 15

Right of access by the data subject

1. The data subject has the right to obtain from the data controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the following information:

a) the purposes of the processing;

b) the categories of personal data concerned;

c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

e) the existence of the right of the data subject to request from the data controller the rectification or erasure of personal data or the restriction of processing of personal data concerning him or her or to object to such processing;

f) the right to lodge a complaint with a supervisory authority;

g) where the data are not collected from the data subject, any available information as to their source;

h) the existence of automated decision-making, including profiling referred to in Article 22(1) and (4), and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the existence of adequate safeguards pursuant to Article 46 relating to the transfer.

3. The controller shall provide a copy of the personal data undergoing processing. Where the data subject requests further copies, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4. The right to obtain a copy referred to in paragraph 3 shall not prejudice the rights and freedoms of others.

Article 16

Right of rectification

The data subject shall have the right to obtain from the controller the rectification of inaccurate personal data concerning him or her without undue delay. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

Article 17

Right to erasure ('right to be forgotten')

1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her

concern him or her without undue delay, and the controller has the obligation to erase personal data without undue delay if one of the following grounds applies:

a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

b) the data subject withdraws consent on which the processing is based in accordance with Article 6(1)(a) or Article 9(2)(a), and where there is no other legal ground for the processing;

c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);

(d) the personal data have been unlawfully processed;

e) the personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).

2. Where the controller has made personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

(a) for exercising the right of freedom of expression and information;

(b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;

(c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);

d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

e) for the establishment, exercise or defence of legal claims.

Article 18

Right to restriction of processing

1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

c) although the data controller no longer needs the personal data for the purposes of the processing, the data subject needs them for the establishment, exercise or defence of legal claims;

d) the data subject has objected to processing pursuant to Article 21(1) pending verification of whether the legitimate grounds of the controller override those of the data subject.

2. Where processing has been restricted pursuant to paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3. The data subject who has obtained the restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction is lifted.

Article 19

Notification obligation regarding rectification or erasure of personal data or restriction of processing

The controller shall communicate any rectification or erasure or restriction of processing carried out in accordance with Article 16, Article 17(1) and Article 18 to each recipient to whom the personal data have been disclosed, unless this proves impossible or involves disproportionate effort. The controller shall inform the data subject of those recipients if the data subject requests it.

Article 20

Right to data portability

1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and

b) the processing is carried out by automated means.

2. When exercising their rights in relation to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one data controller to another, where technically feasible.

3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.

4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

Article 21

Right to object

1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on Article 6(1)(e) or (f), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information at the latest at the time of the first communication with the data subject.

5. In the context of the use of information society services, and without prejudice to Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject shall have the right, on grounds relating to his or her particular situation, to object to the processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

Article 22

Automated individual decision-making, including profiling

1. The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or similarly significantly affects him or her.

2. Paragraph 1 shall not apply if the decision:

(a) is necessary for entering into, or performance of, a contract between the data subject and a data controller;

(b) is authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject's rights and freedoms and legitimate interests;

3. In the cases referred to in points (a) and (c) of paragraph 2, the controller shall implement suitable measures to safeguard the data subject's rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and to contest the decision.

4. The decisions referred to in paragraph 2 shall not be based on the special categories of personal data referred to in Article 9(1), unless Article 9(2)(a) or (g) applies and suitable measures to safeguard the data subject's rights and freedoms and legitimate interests are in place.