Enel S.p.A. privacy policy pursuant to art. 13 of EU Regulation 2016/679 (“GDPR”)

DATA CONTROLLER

Enel S.p.A., headquartered at 137 Viale Regina Margherita, 00198, Rome, VAT number 15844561009 (hereinafter, “Enel” or the “Data Controller”), as the Data Controller, will process your personal data and that of your child within the scope of the “We Are Energy” Contest (hereinafter, also the “Contest”), in accordance with the applicable regulations on personal data protection and this privacy disclosure.

DATA PROTECTION OFFICER (DPO)

The Data Controller has appointed a Data Protection Officer (DPO) who can be contacted at the following email address: dpoenel@enel.com.

SCOPE AND METHOD OF PROCESSING 

Enel will process the personal data communicated by you or legitimately obtained by the Data Controller (“Personal Data”). Data for participation in the Competition.

• Data for participation in the Competition. Enel will process the Personal Data of the parent (full name, email address, phone number, etc.) for registration on the platform and account creation to participate in the Contest. It will also handle the data (first name, last name, age, etc.) of the minor enrolled in the project to allow them to play and compete in the Contest (hereinafter also the “Participant”).

If a profile picture is uploaded, Personal Data related to the uploaded photograph may also be processed (optional choice).

• Data for campus participation. If the Participant wins, Enel will further process the data of the parent and the Participant to manage participation in the We are Energy Campus, which will be held at Avigliano Umbro at the “I Ciclamini” facility. In any case, Enel will not process health data and data on the state of health of the Participants, except within the exclusive limits provided for by legal obligations.
• Browsing data. The IT and electronic systems and the software procedures used to operate the weareenergy2023.com website acquire, during their normal operation, some data (e.g. the date and time of access, the pages visited, the name of the Internet Service Provider and the Internet Protocol (IP) address through which you access the Internet, the Internet address from which you connected to our Website, etc.), the transmission of which is implicit in the use of web communication protocols or is useful for the better management and optimization of the data transmission and email sending system.

For the purposes of this policy, the Processing of Personal Data is intended as any operation or set of operations performed with the aid of automated processes and applied to Personal Data, such as the collection, registration, organization, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, diffusion or any other form of provision, comparison or interconnection, limitation, deletion or destruction.

We inform you that this Personal Data will be processed manually and/or with the aid of computerized and/or electronic means.

The Data Controller has implemented technical and organizational measures to ensure an appropriate level of security in line with the risk, as required by Article 32 of the GDPR, aimed at preventing and countering the loss of Personal Data, as well as unlawful or incorrect uses and unauthorized access.

The processing of the personal data requested is essential for participation in the Competition. Failure to provide data will make it impossible to participate in the Competition.

If successful, further processing of Participants’ personal data is required to enable their participation in the We are Energy Campus to be held at Avigliano Umbro at the “I Ciclamini” facility.

PURPOSE AND LEGAL BASIS OF PROCESSING 

Enel will process your Personal Data and the Participant’s Personal Data for the achievement of specific purposes and only in the presence of a specific legal basis provided for by the applicable law on privacy and personal data protection. Specifically, Enel will process your Personal Data and that of the Participant according to the purposes and legal bases listed below:

The provision of your and the Participant’s Personal Data is necessary in all cases where the processing carried out on the basis of a legal obligation or to execute a contract of which you are a party or due to the implementation of pre-contractual measures taken at your request. Any refusal by you could make it impossible for Enel to carry out the purpose for which the Personal Data is collected.

DATA RECIPIENTS

Your Personal Data and that of the Participant may be made accessible, for the purposes mentioned above:

To employees and partners of the Data Controller, duly appointed as authorized individuals for processing, or to Enel Group companies for carrying out organizational, administrative, financial, and accounting activities, duly appointed as data processors.

1. To third-party companies or other entities that carry out activities on behalf of the Controller to enable the functioning of the Website, or to perform other outsourcing activities as external data processors. Specifically, the data will be shared with La Fabbrica srl, acting as the Data Controller, responsible for managing and implementing the Website and supporting the Owner in organizing the Contest.
2. In case of winning, the Personal Data may be shared with the Enel Group company based in the participant’s country of residence or the participant’s country of residence, which may be outside the European Union; in this case, the data will be shared solely for the purpose of allowing the minor to participate in We are Energy event taking place in Avigliano Umbro, Umbria, Italy, at the “I Ciclamini” facility.

TRANSFER OF PERSONAL DATA

Your Personal Data and that of the Participant will be processed within the European Union and stored on servers located within the European Union. The same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, recognized by a specific adequacy decision of the European Commission.

Any transfers of Personal Data to non-EU countries, in the absence of an adequacy decision by the European Commission, will only be possible if adequate guarantees of a contractual nature are provided by the Data Controllers and Data Processors involved, including binding corporate rules and standard data protection contractual clauses.

The transfer of your Personal Data to third countries outside the European Union, in the absence of an adequacy decision or other appropriate measures as described above, will be carried out only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest. In these cases, we inform you that despite the fact that the Enel Group adopts operational instructions that are common to all the countries in which it operates, the transfer of your Personal Data could be exposed to risks related to the specific features of local legislation regarding the processing of Personal Data.

PERSONAL DATA RETENTION PERIOD

Personal Data processed for the purposes set out above will be kept in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been fulfilled. In all cases, the acquired data will be deleted within 5 years after the form is completed. Enel reserves the right to publish the list of winners in a dedicated gallery at the end of the competition. Personal data will be stored solely for the purpose of providing the opportunity to participate in new We are Energy projects.

RIGHTS OF THE DATA SUBJECTS

Pursuant to Articles 15 – 21 of EU Regulation 2016/679 (GDPR), in relation to the Personal Data communicated, you have the right to be able to carry out, on your behalf or on behalf of the underage Participant, the following activities:

1. access and request a copy thereof.
2. request a correction.
3. request cancellation.
4. obtain processing restriction.
5. oppose the processing.
6. receive in a structured format, commonly used and machine-readable, and transmit such data to another data controller without hindrance, where technically feasible.

For more information regarding your Personal Data, please contact the Personal Data Protection Officer at Enel, reachable at the following email address dpoenel@enel.com, clearly stating “Privacy” in the subject.

We remind you that it is your right to lodge a complaint with the competent authority for the protection of personal data.

If the Personal Data Protection Authority is appealed, you may lodge a complaint by:

1. hand delivery at the Guarantor’s offices (at the address provided below).
2. registered letter with acknowledgment of receipt addressed to: Authority for the Protection of Personal Data, Piazza Venezia, 11- 00187 Rome.
3. certified email to: protocollo@pec.gpdp.it.