Privacy Policy pursuant to Regulation (EU) 2016/679 on the protection of personal data

1. Subject

This privacy policy (“Privacy Policy”) is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (“GDPR”) to inform you about the processing of your personal data (the “Personal Data”), as detailed below.

2. Data Controller and Data Protection Officer

The processing of your Personal Data for the provision of the personalized consulting service in the electricity and gas sectors, available on this website and via phone, is carried out by the company Agente Unico S.r.l. (hereinafter also referred to as the “Company” or “Agente Unico“), with its registered office in Milan (MI), Foro Buonaparte n. 50 (ZIP Code 20121), VAT and Tax Code 12725400969, registered in the Milan Business Register under No. MI2680354.
Only with your specific consent, your Personal Data may also be processed, independently, by third parties you have authorized. For any information regarding the processing of Personal Data, as well as for exercising your rights, you may contact the Data Controller at the following email address: privacy@agente-unico.it, or contact the Data Protection Officer (DPO) designated pursuant to Article 37 of the GDPR at the following email address: privacy@agente-unico.it.

3. Types of Personal Data

The Personal Data covered by this Privacy Policy may be of different nature and origin. It is possible that you have previously authorized third parties to provide the Controller with your Personal Data for commercial contact purposes. You may also have provided information by filling out a specific form on this site and/or during telephone contacts made by the Controller following your specific consent or request to benefit from the consulting service offered by Agente Unico. The Personal Data processed in the context of the consulting activity offered by the Controller are:

  • personal and contact details (name, surname, date of birth, marital status, home address, mobile number, email address);
  • data related to the property for which the consulting service for the products offered by the Controller is requested (for example, property municipality, number of people living in the property, POD/PDR);
  • information related to your energy consumption;
  • information about your profession, education, and financial situation (existing loans, possible arrears);
  • information related to the electronic devices used, location, and consumption and browsing preferences. Additionally, the IT systems and software procedures for the functioning of this site automatically acquire some information, such as your IP address or other parameters related to your operating system. These are pieces of information that, by their nature, could, through processing and association with other data, allow your identification.

4. Purposes and Legal Basis of the Processing

The Personal Data are processed:

  • for the purpose of ensuring the enjoyment of the consulting service you requested through this site – in accordance with the related “Terms and Conditions of Use” – and/or by contacting Agente Unico directly via phone and/or through the callback form, as well as to respond promptly and correctly to your requests for information and assistance pursuant to Article 6(1)(b) of the GDPR;
  • to comply with the legal obligations to which the Controller is subject, for example in accounting and tax matters, in accordance with Article 6(1)(c) of the GDPR;
  • for the legitimate interest of ensuring the security and proper functioning of this site, or for administrative-accounting purposes in accordance with Article 6(1)(f) of the GDPR;
  • to assert or defend a right in court or in the preparatory phase of the proceedings, pursuant to Article 6(1)(f) of the GDPR.

Only with your specific, free, and informed consent, pursuant to Article 6(1)(a) of the GDPR, the Controller may:

  • enrich over time your Personal Data within their commercial database, using tools to monitor electronic communication networks such as cookies, tags, and other tools, to learn about your preferences, needs, consumption habits, and professional habits, and generally to carry out profiling activities, also through comparison and integration with data collected from third parties;
  • contact you via automated tools (e.g., automated calls and/or with an operator, SMS, push notifications, emails, instant messaging apps, social network messages) and non-automated tools (e.g., phone with operator, postal mail) to update you on offers for the Controller’s products and services;
  • contact you via automated tools (e.g., automated calls and/or with an operator, SMS, push notifications, emails, instant messaging apps, social network messages) and non-automated tools (e.g., phone with operator, postal mail) to update you on offers for products and services of third-party controllers;
  • communicate the Personal Data to third parties who have business relationships with the Controller, particularly financial companies, financial agents, energy suppliers, customer care service providers, and sales companies (contact centers, door-to-door, mall points, flagship), information and marketing firms, direct marketing companies, and list brokers. These parties will process the Personal Data for their own commercial contact purposes via automated tools (e.g., automated calls and/or with an operator, SMS, push notifications, emails, instant messaging apps, social network messages) and non-automated tools (e.g., phone with operator, postal mail).

Agente Unico may send you emails to promote goods and/or services similar to those for which you requested the consulting service, without your consent, but your right to object to such communications at any time remains intact.

5. Nature of the Provision of Personal Data and Consequences of Refusal

Providing your Personal Data is optional. However, some Personal Data are necessary for us to provide the consulting service you requested through this site and/or by contacting Agente Unico directly via phone and/or through the callback form, as well as to respond promptly and correctly to your requests for information and assistance pursuant to Article 6(1)(b) of the GDPR and to comply with legal obligations we are subject to. Failure to provide this information will prevent you from using the services offered by Agente Unico. The Company may request your consent to carry out further processing of your Personal Data. Failure to provide one or more consents requested will not prevent you from using the service offered by Agente Unico.

6. Processing Methods

The processing of Personal Data will be carried out – according to the principles of fairness, legality, and transparency – using IT tools, manual tools, and/or telematics, with methods strictly related to the purposes of the processing and, in any case, ensuring the confidentiality and security of the data and compliance with the legal obligations. The availability, management, access, storage, and usability of the data related to you are guaranteed through the adoption of technical and organizational measures to ensure appropriate levels of security as per Articles 25 and 32 of the GDPR, as well as, with respect to the specific processing purposes identified by the data protection law, to ensure compliance with the safeguards provided by the Data Protection Authority and the relevant sector-specific regulations according to European Union and national law (e.g., provisions on commercial communications). Processing is carried out by authorized internal personnel of the Company who are trained in full compliance with Article 29 of the GDPR and Article 2-quaterdecies of Legislative Decree 196/03. In any case, the logical and physical security and confidentiality of the processed information will be guaranteed.

7. Storage of Personal Data

Personal Data will be stored only for the time strictly necessary for the purposes for which they were collected, in compliance with the minimization principle outlined in Article 5(1), letter c) of the GDPR, as well as the legal obligations that each data controller is subject to. If you decide to withdraw your consent, the Personal Data whose processing is based solely on the revoked consent will be promptly deleted or anonymized.

8. Scope of Personal Data Circulation

Personal Data will not be subject to dissemination (meaning providing knowledge of personal information to indeterminate subjects in any form, including making it available or accessible), except in cases where communication or dissemination is required by law, such as by police forces, judicial authorities, information and security agencies, or other public entities for defense, state security purposes, or the prevention, investigation, or repression of crimes.
If, following the consulting activity carried out by Agente Unico, the data subject decides to proceed with the purchase of one or more of the services/products presented, the Personal Data will be communicated (to concretely carry out pre-contractual and/or contractual measures requested by the data subject) to the partner providers of the said services/products involved from time to time. These partners are active in the following sectors:

  1. gas and electricity services and/or their intermediaries

The processing of your personal data is carried out within the territory of the European Union. With your specific consent, the Data Controller may communicate your Personal Data to the subjects referred to in letter h of paragraph 4, even located outside the European Union. These subjects will process your information for their own commercial purposes.
Some subjects may act on behalf of the Data Controller as data processors. Such transfers will occur to countries that guarantee an adequate level of protection according to the European Commission (e.g., Switzerland, Canada, Japan) or, in any case, after the adoption of adequate safeguards, such as the signing of Standard Contractual Clauses approved by the European Commission or the selection of subjects adhering to international programs for the free movement of data.

9. Data Subject Rights

You may, at any time, exercise the rights set out in Articles 15 to 22 of the GDPR, and in particular obtain:

  • confirmation of whether or not personal data processing is taking place, and access to the data and the following information: purposes of processing, categories of personal data, recipients and/or categories of recipients, storage period;
  • correction of inaccurate personal data concerning you and/or the completion of incomplete personal data, including by providing a supplementary statement;
  • deletion of personal data, in the cases provided for by the GDPR;
  • restriction of processing in the cases provided for by the applicable privacy law;
  • portability of your data, and in particular requesting the direct transmission of your data to another Data Controller.
    In addition, you have the right to withdraw, at any time, any consent given, without affecting the lawfulness of the processing based on the consent before its withdrawal, as well as the right to object, at any time, to the processing of Personal Data, pursuant to Article 21 of the GDPR. If you object to the processing of Personal Data for direct marketing purposes and for profiling activities related to such direct marketing, the processing will be immediately halted. We inform you that you can exercise the right to object to processing for marketing purposes even in relation to one or more specific contact channels (for example, you may choose to continue being contacted by the operator but not to receive SMS or emails). In any case, if the contact channel is not specified in relation to which the right is exercised, the opposition to the processing of Personal Data will be understood to extend to all communication methods used.
    If you believe that the processing of Personal Data is in violation of the Regulation, you have the right to lodge a complaint with the Data Protection Authority as provided for in Article 77 of the GDPR, or to seek appropriate judicial remedies. Requests for the exercise of your rights should be addressed to the contact details in paragraph 2 of this Privacy Policy. Any modification, deletion, or restriction of processing carried out upon your request or following the revocation of your consent – unless impossible or involving disproportionate effort – will be communicated by each controller to the other, as well as to each recipient to whom the Personal Data has been communicated.

Last updated: November 2024

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