DATA PROTECTION REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL (GENERAL DATA PROTECTION REGULATION – GDPR)

Contact details of the Data Protection Officer
E-mail: dpo.of@openfiber.it

Pursuant to Article 13 of Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”), we hereby inform you that, during your navigation on our website (the “Site”), information and personal data (hereinafter referred to as “Data”) may be collected through so-called  “cookies’.

Coookies are small text files sent to your browser and stored on your device when you visit a website. They enable the Site to function properly and enhance its performance. Additionally, they may provide the website owner with information for statistical or advertising purposes, primarily to personalise the user experience by remembering preferences. By accepting this Cookie Policy, you consent to the use of cookies on the Site.

Purpose of processing

Through the Site, information and browsing data may be collected and processed via cookies to provide the user with the requested service. Below is a list of the technical and profiling cookies installed on the Site, along with a description of their purpose and the retention period of the information collected.

In certain cases, it may not be technically possible to disable these cookies, as they are essential for the proper functioning of the Site.

Statistics

The services described in this section enable the Data Controller to monitor and analyse traffic data, helping to track the User’s behaviour.

Facebook Ads conversion monitoring (Facebook pixel) (Facebook Ireland Ltd)

Open Fiber uses Facebook Ads conversion tracking (Facebook Pixel), a statistical service provided by Facebook Ireland Ltd. This service connects data from the Facebook ad networkNetwork In computer language, the term network defines a set of hardware and software devices which, when linked together, enable the exchange and sharing of resources, data or information. In a computer network, the devices that generate, route and terminate data are called network nodes. with actions taken on this website. The Facebook Pixel tracks conversions attributable to advertisements on Facebook, Instagram, and the Audience Network.

Personal Data Processed: Cookies; Usage Data:

  • Information on the use of the website
  • Device information
  • Location information
  • Socio-demographic information
  • Information about visitors’ interests
  • Information about interactions with advertisements


Data Retention Period: The retention period for Data collected by individual cookies is detailed in the schedule titled “Third-party Cookies.”

Purpose:

Statistics: The services described in this section enable the Data Controller to monitor and analyse traffic data, helping to track the User’s behaviour.

Place of the processing: Ireland

By accepting these cookies, you acknowledge that your personal data will also be processed by Facebook Ads as an independent Data Controller. Further information regarding this data processing by Facebook Ads can be found in their Privacy Policy

.

Google Analytics 4 (Google Ireland Limited)

Open Fiber uses Google Analytics 4 (hereinafter ‘GA4‘), a web analytics service provided by Google Ireland Limited (‘Google‘).

Google processes the Personal Data collected to evaluate the use of this Website, compile reports on user traffic, and share these reports with other services provided by Google.

Google may also use Personal Data to contextualise and personalise advertisements within its advertising network.

Personal Data Processed: Cookies; Usage Data:

  • Number of users
  • Sessions
  • Average session duration
  • Pageview
  • Source/Means
  • Geographical data (country – city)
  • Connection device (mobile – desktop – tablet)
  • Demographic data (age – gender)
  • Customised events (filling out contact form, coverage check, homepage scroll percentage, downloading individual files uploaded in the Press Kit section of the site)

Data Retention Period: The retention period for Data collected by individual cookies is detailed in the schedule titled “Third-party Cookies.”

Purpose:

  • statistics: The services described in this section enable the Data Controller to monitor and analyse traffic data, helping to track the User’s behaviour;
  • Accessing the statistics collected through these tools allows the Data Controller to identify areas for Website improvement and optimise the user experience across various sections of the Website.

Place of the processing: Ireland.

By accepting these cookies, you acknowledge that your personal data will also be processed by Facebook Ads as an independent Data Controller.  Further information regarding this data processing by Google Ireland Limited can be found in their Privacy Policy

.

Advertising

Some of the services mentioned below may use Tracking Tools to identify the User or employ behavioral retargeting techniques, which display personalised advertisements based on the User’s interests and behaviour, even when detected outside this Website. For further information, we recommend reviewing the privacy policies of the respective services.

In addition to the opt-out options rovided by the services listed below, you may opt-out by visiting the network Advertising Initiative opt-out page.

Users can also choose to disable certain advertising features through their device settings, such as the mobile device advertising settings or the general advertising preferences.

Microsoft Clarity (Microsoft Corporation. Redmond, Washington, USA)

Open Fiber uses Microsoft Clarity (“Clarity”) as a tool to analyse user behaviour, with the goal of understanding how users interact with the Website to improve their experience. Clarity is provided by Microsoft Corporation (“Microsoft”).

By default, Clarity masks users’ personal data before it is transferred to Microsoft’s servers.

Personal Data Processed: Cookies; Usage Data:

  • Click: the number of times a user clicks on a specific area of the website
  • Scrolling: how long a user stays on a certain section of the website.
  • Sessions: the number of times a user visits the website.
  • Heatmaps: a graphic representation of the areas of the website most clicked on or viewed by users.
  • Session Replay: the replay of a user session on the platform to analyse user behaviour on the website.
  • Funnel: the monitoring of the sequence of pages the user goes through on the website.

Data Retention Period: The retention period for Data collected by individual cookies is detailed in the schedule titled “Third-party Cookies.”

Purpose:

  • statistics: The services described in this section enable the Data Controller to monitor and analyse traffic data, helping to track the User’s behaviour.
  • Accessing the statistics collected through these tools allows the Data Controller to identify areas for Website improvement and optimise the user experience across various sections of the Website.

Place of the processing: [Microsoft Data Centres located in Western Europe, Netherlands]

By accepting these cookies, you acknowledge that your personal data will also be processed by Facebook Ads as an independent Data Controller.  Further information regarding this data processing by Google Ireland Limited can be found in their 

Privacy Policy

.

Data Retention Periods

Your data will be processed for the time strictly necessary to achieve the aforementioned purposes and/or to comply with regulatory obligations.

How Data Are Used

In relation to the stated purposes, the processing of information collected through the installation and use of cookies will be carried out using appropriate paper-based, electronic, and/or telematic tools. This processing will be in strict accordance with the aforementioned purposes and will ensure the security and confidentiality of the information and Data..

Scope of Data Circulation

The Data may be processed by third-party companies that perform activities on behalf of the Data Controller, acting as external data processors (for example, suppliers or consultants who manage and/or assist in the management or maintenance of the electronic and/or telematic tools we use, for the time strictly necessary to ensure optimal service performance).

Your data will only be accessible to those staff members of these companies who need access to it in connection with their roles or duties within the company. Such personnel will be appropriately instructed to prevent the loss, destruction, unauthorised access, or improper processing of the Data.

Without your explicit consent, the Data Controller may disclose your Data to supervisory authorities, judicial bodies, and any other entities to which disclosure is mandatory under the law (pursuant to Art. 6(b) and (c) of the GDPR).

Data Dissemination

Your data will not be disclosed to any unspecified third parties.

Browser Settings. Cookie Management Procedure and Direct Link to the Dedicated Browser Section

We inform you that you can also manage your preferences regarding the use of Cookies on the Site through your browser settings. You can do so by following the specific instructions for modifying or managing these settings, available at the following links:

With regard to third-party cookies—i.e. cookies from websites or web servers used for purposes specific to those third parties—Open Fiber clarifies that it does not have control over the characteristics of these cookies. Therefore, we encourage users to visit the Privacy Policypages of the respective third parties (listed below), where they can provide or refuse consent to the installation of those cookies.

Data Controller and Data Protection Officer

The Data Controller is Open Fiber S.p.A., with registered office in Largo Guido Donegani 2 – 20121 Milan, Italy, VAT No. 09320630966.

Open Fiber has appointed a Data Protection Officer (  DPO) pursuant to Article 37 of the GDPR, who can be contacted for matters concerning the processing of your Data at the following address: dpo.of@openfiber.it.

Exercise of rights

We inform you that, as a Data Subject (“Data Subject”), you have the right to exercise your rights under the GDPR, including the following:

  • The right, pursuant to Art. 15 of the GDPR, to obtain confirmation as to whether or not Data relating to you are being processed and, if so, to access the Data and the following information (i) tthe purposes of the processing; (ii) the categories of Data concerned; (iii) the recipients or categories of recipients to whom the Data have been or will be disclosed, particularly if they are in third countries or international organisations;
    (iv) where possible, the expected retention period of the Data or, if not possible, the criteria used to determine this period; (v) the existence of the Data Subject’s right to request rectification or erasure of the Data, restriction of its processing, or to object to its processing from the Data Controller;
    (vi) the right to lodge a complaint with a supervisory authority, pursuant to Art. 77 ff. of the GDPR; (vii) if the Data were not collected from the Data Subject, any available information about their source; (viii) the existence of automated decision-making processes, including profiling, as referred to in Art. 22(1) and (4) of the GDPR, and, at least in such cases, meaningful information about the logic involved, as well as the significance and potential consequences of such processing for the Data Subject; (ix) the right to be informed of the existence of appropriate safeguards as defined in Article 46 of the GDPR regarding the transfer of Data, if they are transferred to a third country or international organisation;
  • The Data Subject shall also have the right (where applicable) to exercise their rights under Articles 16-21 of the GDPR, including the Right to rectification, the Right to be forgotten, the Right to restriction of processing, the Right to Data portability, and the Right to object.

We inform you that Open Fiber is committed to responding to your request no later than one month from the date of its receipt. This deadline may be extended depending on the complexity or number of requests, and Open Fiber will inform you of the reason for any extension within one month of your request. The outcome of your request may be provided to you in writing, either in hard copy or electronic form.

Methods of Exercising Rights

The Data Subject may exercise the aforementioned rights at any time and request an updated list of data processors by sending a request to the following email addresses: privacy@openfiber.it.

Last updated: 28/04/2023