The following information is provided pursuant to Article 13 of EU Regulation 2016/679 (hereafter, the “Regulation”) to users who contact the Call Centre service of BFT S.p.A. This document supplements the short statement provided verbally to the user during a telephone call.
DATA CONTROLLER
The Data Controller is the company, BFT S.p.A. with registered office in via Lago di Vico, 44, Schio (Vicenza), Italy (hereafter “Bft” or the “Company”).
DATA PROTECTION OFFICER (DPO)
The Somfy Group of which the Company is part has identified a Data Protection Officer pursuant to Article 37 of the Regulation that can be contacted at the following email address: dpo@somfy.com
CATEGORIES OF DATA PROCESSED
The data subject to call centre activities are identification data (in particular, forename and/or corporate name in the case of a company, surname, landline and/or mobile number and address, e-mail address) plus any additional information that the user may provide to the operator during the resolution of problems or questions raised by the same user to the customer assistance team.
PURPOSES OF THE PROCESSING
The user’s personal data, freely communicated and acquired in relation to the Company’s activities, will be legally and correctly processed for the following purposes:
a) after-sales support;
b) questionnaire on the level of customer satisfaction with the call centre service, along with the assistance received by the assistance centre.
c) only if specific consent is provided will personal data will be processed - through the use both of automated contact systems like e-mail, MMS (multimedia messaging service) or SMS (short message service) and calls without the intervention of an operator and through traditional means such as by post or through calls with the intervention of an operator - for the sending of commercial offers relating to and/or connected with the Company’s products and/or services and for the sending of publicity material relating to said products or services or commercial communications or for the sending of market research including for the purposes of gauging user satisfaction (“marketing purposes”);
d) only if the user grants specific consent may the data be used for profiling activities, including market research and the sending of surveys and questionnaires aimed at determining the usage preferences of the products and/or services offered in order to improve them and ensure better satisfaction of users’ needs. If consent is received for profiling, the Company shall use the data to provide profiled marketing activities using both the automated and computerised and traditional means specifically indicated in point c).
During the telephone call, the user shall be informed prior to the recording of all or part of the conversation through a brief, pre-recorded voice message. If you do not choose to end the call, you will be deemed to have agreed to the principle of “continue call/consent” to recording
LEGAL GROUNDS FOR PROCESSING
The legal basis for the processing pursuant to point a) is the fulfilment of a contractual obligation and/or satisfaction of a request for assistance expressed by the user.
The legal grounds for processing based on the purposes set out in point b) is the legitimate interest of Bft, pursuant to Article 6 sect. 1 par. b) of the Regulation, ascribable in particular to the need to improve the services offered to the user, with particular reference to the management of after-sales assistance.
The legal grounds for processing based on the purposes set out in points c) and d) is the consent provided by the user, pursuant to Article 6 sect. 1 par. a) of the Regulation, by pressing any digit on the telephone keypad, or howsoever freely expressed, as communicated by telephone.
WITHDRAWAL OF CONSENT AND OBJECTION TO PROCESSING
At any time, the user can oppose the processing as per point b) as well as revoke his/her consent to data processing as per points c) and d) after having given his/her consent:
• by calling the call centre on [06 96 706 706];
• by expressing his/her objection to the telephone operator, who shall make a note of it;
• by sending a simple request to the e-mail address privacy@bft-automation.com;
• by using the specific link at the bottom of the page of any advertising e-mail sent by Bft.
PROCESSING PROCEDURES AND RETENTION
The data will be processed using both paper and computer media. Specific safety measures have been adopted to prevent loss of data, illegal or incorrect usage and unauthorised access.
NATURE OF THE CONFERRAL OF DATA AND CONSEQUENCES OF REFUSAL TO RESPOND AND FAILURE TO PROVIDE CONSENT
Conferral of data for the purposes indicated in point a) is mandatory: the data are necessary for the use of the services of Bft and the withholding of consent will make it impossible for the user to benefit from the Company’s services.
Conferral of data for the purposes indicated in point b) is optional, but necessary for managing quality control over the service provided and, possible, to formalise, accept and manage requests made by the user. If personal data is not supplied, it will be impossible for Bft to follow up on users’ requests.
Providing data for the purposes under points c) and d) is optional. Refusing consent for the purposes under points c) and d) will have no consequences on the provision of services, as is the also the case with the exercising of the right to object to the processing of one’s data under point b).
COMMUNICATION AND DISTRIBUTION OF DATA
Data processing is carried out by persons, both internal and external, duly authorised to do so and who are both bound by confidentiality and have received adequate operating instructions.
For the execution of these activities, Bft makes uses of third companies which act on its behalf under the terms of contracts which designate such third parties as Data Processors, pursuant to Article 28 of the Regulation. The list of external Data Processors may be consulted by making a simple request to the e-mail address privacy@bft-automation.com
The data subject to call centre activities will not be distributed under any circumstances.
TRANSFER OF DATA ABROAD
The call centre activities will be carried out exclusively in Italy.
Users’ data and those collected following telephone conversations with operators may be communicated, for the same purposes indicated, to other companies within the group of which Bft is a member or to companies within the Somfy Group, of which Bft forms part (hereafter, the “Group”), including with registered offices in non-EU countries. The Group has adopted appropriate safeguards for the transfer of your data, by drafting specific “Binding company rules” in compliance with the Regulation which you may consult by submitting a simple request to the e-mail address privacy@bft-automation.com
RETENTION OF DATA
The personal data collected by Bft are kept and/or used by it for periods that differ according to the purposes for which they were collected.
In particular, the processing of personal data for the purposes indicated in points a) and b) will have a duration equal to the period necessary for providing the service requested and, in any case, no longer than 3 months from collection thereof – without prejudice to the exercising of any right to object by the data subject for the purposes under point b) – plus the further period stipulated by the regulations in compliance with obligations under civil and tax law and for the exercising or defence of a right in legal proceedings.
The processing of personal data in reference to the purposes as per point c) shall be valid for 24 months starting from the date when consent is given, unless withdrawn by the user.
The processing of personal data in reference to the purposes as per point d) shall be valid for 12 months starting from the date when consent is given, unless withdrawn by the user.
Recordings containing evidence of the consent freely granted by the user for the purposes under points c) and d) will not be kept for longer than strictly necessary for the fulfilment of legal obligations or the establishment, exercising or defence of a right in legal proceedings.
At the end of this period of data processing, the latter shall be deleted or rendered permanently anonymous.
RIGHTS OF THE DATA SUBJECT
The rights pursuant to articles 12 et seq. of the Regulation (including, purely by way of example, the right to ask the data controller for access to personal data and the rectification or erasure thereof or the restriction of processing or to object to processing, the right to withdraw consent and to lodge a complaint with the supervisory authorities) by submitting a simple request to the e-mail address e-mail privacy@bft-automation.com
A user may withdraw consent at any time for the purposes under letters c) and d) and object to the user of his/her data for the purposes indicated in letter b) according to the procedures described above.