privacyPOLICY

privacy POLICY ADC S.R.L. (artt. 12-14 Regulation UE n. 2016/679) May 2018

1. Who we are

1.1. ADC S.r.l. is a single member limited company, with its registered office in Milan, Galleria Unione n. 1, Italy Post. Cod. 20123 (Vat Number 07025900965) (hereinafter also "ADC" or the "Company").

2. Contacts

2.1. by ordinary mail to our office:

ADC S.r.l. - Union Gallery n. 1, Cap. 20123, Milan

or

by email to the address: adccom@legalmail.it

3. Our principles

3.1. ADC respects the privacy of the partners with whom it interacts;

3.2. Privacy, security and compliance with the data protection laws are central goal for ADC’s business. We have declined our privacy commitments and we respect them in everything we do.

4. Which personal data we collect

4.1. personal information: such as the name, address, telephone number, tax code, personal data of the legal representative and contacts of our partners;

4.2. financial information such as, the bank account or other banking information relating to our partners and which are necessary for the provision of our services;

4.3. telephone traffic data relating to the services provided under the interconnection agreement concluded with the partner (i.e. numbers, origination call, termination call, call duration);

5. Purposes for which ADC collects personal data and methods of processing these

5.1. Supplier’s personal data will be used by ADC for the following scopes:

a. management of orders and provision of the services contained in the interconnection agreement;
b. invoicing/payments;
c. management of technical failures of interconnection services;
d. fraud prevention;
e. fulfillment of contractual obligations under the law.

6. Communication of data processed within the interconnection agreement

6.1. Personal data may be brought to the attention of ADC's employees and/or collaborators, appointed as responsible and other authorized persons for the treatment, and communicated to the following entities:

a. to third-party companies entrusted by ADC to provide specific services during the executive phases of the specific service provided;
b. to third-party companies or consultant appointed for the installation, maintenance, updating and, in general, the management of ADC’s hardware and software;
c. all public or private entities, natural or legal persons (administrative, tax and legal consulting firms), if the communication may be considered as necessary or functional referred to the contractual obligations assumed in relation to the service provided, as well as obligations arising from the law;
d. all entities (including Public Authorithies and Law Enforcement Agencies) who have access to data under regulatory or administrative provisions;
f. emergency services;
g. other communication operators for the managing of the interconnection and roaming relationships.

7. Transfer of data to third countries

7.1. ADC may need to transfer your personal information to other companies or suppliers located in non – European countries;

7.2. In the event that ADC transfers the suppliers information to a non-EU country , the Company will comply with the principles set out in the above mentioned Regulation, operating in compliance with the Standard Contractual Clauses approved by the European Commission, in a way that guarantees that such information will be properly secured and protected and in case of presence of a legal agreement concerned with data transfer.

8. Data retention period

8.1. ADC will maintain the personal data obtained for the time required by law and in any case these data will be kept only for the necessary time and within the limits provided in accordance with the current legislation.

9. Data Controller and Data Protection Officer (DPO)

9.1. The data Controller is ADC S.r.l.;

9.2. The Personal Data Protection Manager designated by ADC S.R.l. are Mr. Leonardo Nardella and Mr. Lorenzo Galletti and can be contacted by ordinary mail at the registered office of ADC or by email at the following address adccom@legalmail.it. The list of external Controllers is available in any time and is provided by the Company.

10. Further Information

10.1. Data relating to telephone traffic will be processed in compliance with the current legislation.

10.2. Data relating to the location, necessary for the supply of certain services, will be processed in accordance with the current regulations, subject to the manifestation of specific consent, which may be revoked at any time.

11. Rights of the interested Parties

11.1. The Supplier has the right of access, at any time, of its personal data and to access it, to know its content, origin and method of processing, to request its updating, correction, cancellation, transformation into anonymous form or the blocking of the data processed in violation of the law.

11.2. Furthermore, the interested party is entitled to revoke the consent expressed and to oppose the processing of its data, by exercising the right to be forgotten and the portability of such data and to be acknowledged of the person appointed as Data Controller by the Company.

Milan, 25th May 2018

For any questions please send an email to privacy@adctelecom.it