PHONE CALL RECORDING PRIVACY POLICY pursuant to art. 13 of EU Regulation no. 679/2016 (European Data Protection Regulation (GDPR))

DIRECTA SIM, data controller ("Controller" or "Directa") with registered office in Via Bruno Buozzi, 5 - 10121 Turin, informs you that it uses the personal data in its possession in compliance with the provisions of the GDPR and that such use is based on principles of fairness, lawfulness, transparency and protection of confidentiality of the person to whom the data refer (“Data Subject”).

1. LAWFULNESS, PURPOSE, LEGAL BASIS OF THE PROCESSING AND NATURE OF THE DATA

The personal data collected directly from the Data Subject are those provided during the contact phase of the Data Controller's Customer Service, i.e. collected as part of the commercial, technical, contractual and customer care assistance services with the help of computer tools.
The data collected by Directa as part of the services indicated above, with particular reference to the recording of conversations, are processed - in accordance with the principle of lawfulness as per art. 6 lett. a) of the GDPR - in the context of its activity for the pursuit of the following purposes:

a) provide the requested services and manage customer relations, manage any disputes / complaints made by the interested party;
b) comply with the requirements of national and EU regulations, as well as with the provisions issued by the Supervisory and Control Bodies;
c) quality control of the assistance services offered directly by Directa to verify the effectiveness of the assistance service and properly guide the training of the persons in charge of the treatment.

During the phone call, the user will be notified in advance about the start of registration through a short information note issued by staff or by recorded voice. If he does not intend to interrupt the phone call, the principle of "continuation of the phone call / consent" to the recording is expressed.
The of the personal data for these purposes is not mandatory, but necessary to manage the quality control of the service provided and possibly to formalize, accept and manage the requests submitted by the Data Subject. The refusal to provide the data makes it impossible to perform what was requested.

2. PROCESSED DATA

The subject of processing is personal data that generally consist of elements of personal identification collected directly from the data subjects.
The data will remain confidential and will not be disclosed to third parties for purposes other than those listed in paragraph 1.

3. CATEGORY OF SUBJECTS TO WHOM THE DATA MAY BE COMMUNICATED - DISSEMINATION

The personal data collected will not be disclosed and may be communicated to companies contractually linked to Directa within and outside the European Union, in order to fulfil the purpose for which they were collected. For the pursuit of these purposes, the Controller may communicate the personal data received to:

companies associated with it,
third parties, specifically appointed as data processors, who will process the data with the sole purpose of ensuring the performance of services by the Controller, through the provision of instruments, applications, technical infrastructure and evaluation platforms,
personnel of the Controller who carry out processing activities in their capacity as subjects authorised by said Controller,
authorities responsible for matters of the fulfilment of legal obligations and/or provisions of public bodies, upon request.

The subjects in the above categories (the first three paragraphs) act as data processors, or operate in total freedom as autonomous data controllers. The list of such subjects is available from the office of the Controller or by writing to directa@directa.it

4. DATA TRANSFER TO A THIRD COUNTRY AND/OR AN INTERNATIONAL ORGANISATION AND GUARANTEES

Personal data will not be transferred abroad (inside or outside the European Union) on the initiative of Directa. However, the servers of some third-party suppliers of services may be physically located abroad (as in the case of server providers, for example). In such cases, the transfer of data abroad will take place exclusively within the scope of and in compliance with current legislation.

5. METHODS OF PROCESSING – DATA STORAGE AND PLACE OF PROCESSING

Personal data are processed automatically and manually, using methods and tools designed to ensure maximum security and confidentiality, by persons specifically mandated in compliance with the provisions of arts. 28 and 29 of the GDPR.
In accordance with the provisions of art. 5, par. 1, letter e) of the GDPR, the personal data of the data subject are stored in a form that allows identification for a period of time not exceeding the achievement of the purposes for which the data were collected and subsequently processed and, in any case, no later than 10 years after termination of the relationship, for compliance with regulatory obligations but not beyond the period set by law for the prescription of rights.

6. THE RIGHTS OF DATA SUBJECTS

The data subject may exercise his/her rights as set out by the GDPR by contacting DIRECTA SIM, with registered office in Via Bruno Buozzi 5 - Turin, directly to the following e-mail address: directa@directa.it or the Data Protection Officer (DPO) at the following address: alessandra.viglino@directa.it . The data subject has the right, at any time, to:

obtain access to his personal data from the Organisers and request information regarding the purposes, categories of personal data processed, the recipients to whom the personal data will be communicated, including any recipients in third countries, the period of retention of personal data or, where this is not possible, the criteria for its definition, the existence of an automated decision-making process, including profiling;
rectify, delete or limit the processing of personal data. If the data subject has given his consent to the processing of personal data concerning him for one or more specific purposes, he may revoke his consent at any time;
be informed of the existence of appropriate safeguards with regard to the transfer of his data to a third country or an international organisation;
request the portability of personal data: in this case, the Organisers will provide the personal data of the data subject, in a commonly used structured format that is readable by automatic device, transmitting them to another data controller, if requested;
oppose, for reasons related to his particular situation, the processing of personal data even if such processing is based on special needs of the joint controllers. The joint controllers therefore refrain from further processing unless they can prove: 1. the existence of legitimate binding reasons that prevail over those of the data subject, or, 2. the existence of an assessment, exercise or defence of a right in court;
not be subject to a decision based solely on automated processing, including profiling, which produces legal effects or which has a similar significant effect on his person;
lodge a complaint with a supervisory authority if the data subject considers that the processing of his or her personal data is in breach of the provisions of the GDPR, without prejudice to any other administrative or judicial recourse.

THE DATA CONTROLLER

DIRECTA SIM
Via Bruno Buozzi, 5
10121 Torino
+39 011 0884141
P.I. 06837440012
directa@directa.it