
Information pursuant to art. 12-14 of EU Regulation 679/2016 (“GDPR”) on the processing of personal data carried out as part of the participation in the STEP FuturAbility District visit path
STEP is an “Inspired by Fastweb + Vodafone” project. We therefore inform you that Fastweb S.p.A. — with registered office in 20139 Milan, Piazza Adriano Olivetti, 1 — is the “owner” 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 in STEP.
The security of your data is important to us and we want you to feel protected and informed at all times.
We want our relationship with you to be based on transparency and trust. We believe these are fundamental values and we uphold them to give you the best during your STEP experience.
STEP is an interactive experience. In order to get in touch with the environment around you, it will be necessary to use the “STEP FuturAbility District” APP through your smartphone or through the smartphone that will be provided to you. You can use the APP even without the need to register. In this 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 readiness for the future and for the ongoing digital transformation. Your data will be processed anonymously by us for statistical purposes only. If you have registered, you can access your MySTEP reserved area accessible through the APP or through our website steptothefuture.it to save your FuturAbility and check out at any time all the contents saved during your STEP experience. This contents will be stored for 2 years after the last login to the APP.
What permissions do we need?
The STEP APP will request geolocation permissions and will use your position, only inside STEP, to interact with the exhibits via Bluetooth.
In addition, at the beginning of the journey, you will also be asked for permission to use the smartphone camera and your consent to take, only if you wish, a selfie that will allow you to generate an avatar that represents your digital ego through the use of Artificial Intelligence tools.
What data do we process?
The data we process are:
If you are under 18 years old or you are part of a school group visiting, we do not ask you to register but we only collect your e-mail address to send you your 'FuturAbility' and the tips tailored for you. In this case, we keep your data for a maximum of 72 hours after from the date of the visit; after this period of time, your data will be automatically deleted;
For what purposes?
The personal data indicated above may be processed for the following purposes:
The consent for the data processing described in point 3) is optional and not necessary for the purpose of enjoying the experience.
The treatments described in points 4) and 5) above are optional and not necessary for the purpose of using the experience and will allow you to receive informational or commercial communications from STEP and Fastweb. At any time you can still decide whether to give or revoke each individual consent.
What legal bases?
The processing of your personal data for purposes 1) and 2) finds a legal basis in the execution of the contract signed with the purchase of the ticket.
With reference to purposes 3), 4) and 5), the provision of your personal data is optional and is based on your explicit consent, always revocable and not necessary for the purpose of enjoying the experience. In any case, there will be no consequences in case you deny or withdraw your consent (however, the operations carried out before the withdrawal of the consent remain valid and lawful). Please bear in mind that communications may be sent via e-mail, text messages, APP notifications, telephone and you can always exercise the right to object, as indicated below.
Which modalities?
The data will be processed, manually and/or automatically, in compliance with privacy legislation, the principles of correctness, lawfulness, transparency and protection of your privacy, your rights as well as appropriate security measures to prevent unauthorized or illegal processing and the accidental destruction or loss of data.
With reference to the selfie that you can decide to take by giving your consent, we specify that this will be processed by Artificial Intelligence algorithms in compliance with current regulations (Reg. EU 2024/1689 and EU Reg- 2016/679) and the principles of minimization and transparency and in any case with the application of technical and organizational measures suitable to guarantee a level of security appropriate to the risk. Your personal data will never be used to train Artificial Intelligence algorithms.
For how long?
Who can we communicate your data to?
In order to provide the service through the APP, we use a selected external provider that manages the operation of the APP (Clonwerk S.r.l. Via Parenzo 2 20143 Milan). In order to generate your avatar, we have the collaboration of NTT DATA Italia S.p.a, Technological Partner of STEP (Via Ernesto Calindri 4 Milan)
We may also communicate your data:
Your data will not be disclosed to other parties inside or outside the European Union.
The security and correct storage of your data are essential to us,in order to prevent unauthorized or illegal processing of your data and their accidental destruction or loss. This is why the treatments are carried out in compliance with appropriate security measures, by Fastweb, as the owner, by its external data processors (e.g. the provider of the APP).
What are your rights?
You have the right to request access to your personal data, their rectification and deletion, the restriction of the processing concerning you and to object to the same treatments in accordance with the provisions of articles 15 ss. of EU regulation no. 679/2016.
As mentioned above, with respect to information processing for promotional and commercial purposes - purposes 4) and 5) - you have the right to object and revoke consent at any time, without this affecting the lawfulness of the processing based on the consent given before the revocation, independently by accessing your MySTEP reserved area through the APP or through our website steptothefuture.it, or by contacting the points of contact indicated below.
You also have the right to send a complaint to the Personal Data Protection Authority. You will find the procedures indicated on the Guarantor's institutional website.
Who can you contact?
You can manage your consents and your oppositions in your MyStep reserved area through the APP or through our website steptothefuture.it
In any case, for the exercise of all your rights, please consider that the headquarters of Fastweb S.p.A. is located in Piazza Adriano Olivetti 1, 20139 Milan and that you can write to the following addresses: Fastweb Ufficio Privacy Piazza Adriano Olivetti 1, 20139 Milan - Email address: privacy@fastweb.it. Based on art. 37 of EU regulation no. 2016/679, we have also appointed a Data Protection Officer. Their contact details are: email - dpo@fastweb.it, address Piazza Adriano Olivetti 1, 20139 Milan