Notice pursuant to articles 12-14 of EU Regulation 679/2016 ("GDPR") on the processing of personal data carried out within the context of participation in the STEP FuturAbility District visit experience
STEP is a project "Inspired by Fastweb + Vodafone". We therefore inform you that Fastweb S.p.A. – with registered office in 20139 Milan, Piazza Adriano Olivetti, 1 – is the "controller" of the personal data processing that, pursuant to EU Regulation No. 679/2016 (the "Regulation"), we carry out to offer you the best possible experience at STEP.
The security of your data is important to us and we want you to always feel protected and informed.
The relationship we want to have with you is based on transparency and trust. For us these are fundamental values that we put into practice to give you the best during your STEP experience.
STEP is an interactive experience. In order to interact with the environment around you, it will be necessary to use the "STEP FuturAbility District" APP through the smartphone that will be provided to you. You can also use the APP without needing to register. In that case, the information you provide during the visit cannot be traced back to you individually.
All the data collected through the APP during your visit will allow you to discover your "FuturAbility", i.e. your propensity toward the future and toward the ongoing digital transformation. The advice we have designed for you will be processed by us anonymously for statistical purposes only. If you have registered via the link sent by e-mail after collecting your e-mail address, you can access your reserved MySTEP area, accessible through the website steptothefuture.it, and consult your FuturAbility at any time along with all the content saved during your STEP experience, which will be retained for a period of 2 years from the date of the visit.
What permissions do we request
At the beginning of the experience you will be asked for your consent to take, only if you wish, a selfie that will allow you to generate an avatar representing your digital SELF through the use of Artificial Intelligence tools.
What data do we process?
The data we process are:
For what purposes?
The personal data indicated above may be processed for the following purposes:
The processing described in point 4) is optional and not necessary for enjoying the experience.
The processing described in point 5) is optional and not necessary for enjoying the experience and will allow you to receive informational or commercial communications from STEP. At any time you can decide whether to give or revoke your consent.
What legal bases?
The processing of your personal data for purposes 1), 2) and 3) is based on the performance of the contract entered into with the purchase of the ticket.
With reference to purposes 4) and 5), the provision of your personal data is optional and based on your explicit consent, which is always revocable and not necessary for enjoying the experience. There are no consequences in case of your refusal or the revocation of the consent given (the activities carried out before the revocation of consent are considered valid and lawful). Please note that communications may take place via e-mail, SMS, APP notifications, and telephone, and you may always exercise your right to object, in the ways indicated below.
What methods?
The data will be processed, in manual and/or automated mode, in compliance with privacy legislation, with the principles of fairness, lawfulness, transparency and protection of your confidentiality, your rights, as well as with adequate security measures to prevent unauthorized or unlawful processing and the accidental destruction or loss of data.
With reference to the selfie you may decide to take by giving your consent, it is specified that this will be processed by Artificial Intelligence algorithms in compliance with the applicable regulations (EU Reg. 2024/1689 and EU Reg. 2016/679) and the principles of minimization and transparency, and in any case subject to the application of appropriate technical and organizational measures to ensure a level of security appropriate to the risk. Your personal data will never be used to train Artificial Intelligence algorithms.
For how long?
To whom can we communicate your data?
In order to provide the service through the APP, we rely on a selected external supplier that manages the operation of the APP (Clonwerk S.r.l., Via Parenzo 2, 20143 Milan). In order to generate your avatar, we rely on the collaboration of the partner NTT DATA Italia S.p.A., Technological Partner of STEP, with offices in Via Ernesto Calindri 4 in Milan.
We may also communicate your data:
Your data will not be communicated to other parties within or outside the European Union.
For us, the security and correct storage of your data are fundamental, also to prevent unauthorized or unlawful processing and the accidental destruction or loss of data. This is why processing is carried out in compliance with adequate security measures, by Fastweb, as controller, and by its external Data Processors (e.g. the APP supplier).
What are your rights?
You have the right to request access to your personal data, its rectification and deletion, the restriction of the processing concerning you, as well as to object to such processing as provided for in articles 15 et seq. of EU Regulation No. 679/2016.
As mentioned, with respect to informational processing for promotional and commercial purposes – purposes 4) and 5) – you have the right to object and to revoke your consent at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation, independently by accessing your reserved MySTEP area or through our website steptothefuture.it, or by contacting the points of contact indicated below.
You also have the right to lodge a complaint with the Data Protection Authority (Garante per la protezione dei dati personali). You will find the procedures indicated on the institutional website of the Authority.
Who can you contact?
You can manage your consents and objections independently through your reserved MySTEP area or through our website steptothefuture.it.
In any case, for the exercise of all your rights, please consider that the office of Fastweb S.p.A. is in Piazza Adriano Olivetti 1, 20139 Milan, and that you can send a communication to the following points of contact:
Fastweb Privacy Office, Piazza Adriano Olivetti 1, 20139 Milan - e-mail address: privacy@fastweb.it
In accordance with article 37 of EU Regulation No. 2016/679, we have also designated a Data Protection Officer. Their contact details are:
Fastweb DPO, Piazza Adriano Olivetti 1, 20139 Milan - e-mail address: dpo@fastweb.it
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