The Chatbot allows you to check the network coverage available to a specific address on the national territory; the address has to be part ot the BUL Plan.

In order to use the Chatbot service, users must provide the full address of the housing unit object of the search; it is not necessary to provide further data. In carrying out the requested service, Infratel Italia S.p.A. does not process any kind of personal data.

The sending of further data (other than the address of the housing unit) that can be classified as personal data, implies the processing of such data, as per the EU Regulation no. 2016/679 (the “GDPR”). The procedure is carried out by Infratel Italia S.p.A., as the data controller (the “Controller”).

All data provided by the user is transmitted to Google LLC which, through the Google Dialogflow service, translates the question posed by the user into an intelligible format for the Chatbot.

Below we provide information relating to the aforementioned processing of personal data pursuant to art. 13 of the GDPR.

The data will be processed using suitable tools to ensure the confidentiality, integrity and security of the data, in compliance with appropriate technical and organizational security measures provided for by the GDPR.

This information does not concern other treatments, carried out by third parties, which host the Chatbot service.

1. OBJECT OF THE TREATMENT

1.1 Browsing data

To ensure the correct use of the Chatbot services, as ordinarily required by current information technology protocols, no personal user data is acquired.

1.2. Additional personal data

The optional dispatch of personal data (other than the address object of research), while using the Chatbot tool, involves the acquisition of such data, as they are included in the communications with the Chatbot.

Notwithstanding the transmission of the data provided by the user to the Google Dialogflow (service used to translate the question posed by the user into an intelligible format for the Chatbot), all data that passes through the Chatbot and that is not necessary for the search of the address will be deleted as soon as the request is processed. This data will be excluded from any further processing.

The response times to the request can be calculated in the order of milliseconds or seconds, in the event of slowdowns.

2. LEGAL BASE

The Chatbot service is provided by the Data Controller in the performance of public interest tasks, in which it is invested as the implementing body of the ultra-broadband plan, pursuant to art. 6 par. 1, letter e) of the GDPR.

3. PURPOSE

The data is processed solely to provide Chatbot information services. In the absence of precise data relating to the street number, main object of research on the Chatbot, it will be impossible to provide any useful information to the user’s query.

The provision of further personal data is optional and not necessary for the use of Chatbot services.

4. STORAGE OF PERSONAL DATA

The Data Controller will not process personal data of users. Only the ones already specified (personal data connected to the address and street number object of research) will be possibly collected.

This data will be deleted as soon as the user’s request is processed.

5. DISCLOSURE, COMMUNICATION AND TRANSFER OF PERSONAL DATA

Personal data (other than the address object of research), like any data provided by the user, will be communicated to Google LLC (provider of the Google Dialogflow service) in order to recognize the the intent shared by the user and ensure the full Chatbot functionality.

The processing of data is conducted with the use of security measures suitable to prevent unauthorized access to data by third parties and to ensure its confidentiality.

The data will not be transferred outside the European Union. In case of transfer of personal data outside the European Union, adequate security will be guaranteed (for more information on the security guarantees of the service, visit https://cloud.google.com/security/ gdpr).

6. COLLECTION THROUGH COOKIES

Cookies are small text snippets that the visited websites send to the user’s device (for example computer, tablet, smartphone, notebook, etc.), that stores them. In the event of a new visit to the same site, the device re-transmits to the same sites the stored cookie. Cookies may be subject to prior consent.

During the use of Chatbot services, the information relating to navigation data received from the user’s device will be stored in “cookies” installed on that device.

Below more information on the cookies used:

Type	Cookie	Duration	Function/Description
Technical and navigation cookies	chatId	–	Unique key to identify the user’s browser (which remains anonymous) allowing the service to keep memory of the speech in progress

Other information relating to cookies can be found on the BUL site (one of the environments that host the Chatbot service). BUL Website.

7. RIGHTS OF THE INTERESTED PARTY

The interested party can exercise the following rights in relation to the processing of his personal data, by sending a specific request to: dataprotectionofficer@infratelitalia.it:

• obtain confirmation that personal data concerning him is being processed and obtain access to his personal data (Right of access – Article 15 of the GDPR);
• to obtain the correction of inaccurate personal data concerning him (Right of Rectification – Article 16);
• obtain the cancellation of your personal data, under certain conditions (Right to be forgotten – Article 17);
• obtain the limitation of treatment in certain cases (Right to limitation of treatment – Article 18);
• receive your personal data in a structured and commonly used format, readable by an automatic device, and transmit such data to another data controller in certain cases (Right to data portability – art.20);
• oppose at any time, for reasons connected with his particular situation, to the processing of personal data concerning it(Right to object – Article 21);
• revoke the consent expressed at any time (Conditions for consent art.7);
• lodge a complaint with the Guarantor Authority in the event that your rights are deemed to be infringed.

8. DATA PROTECTION MANAGER

Pursuant to art. 37 of the GDPR, the Data Protection Officer is Mr. Achille Molinari, who can be contacted at the following addresses: Viale America n. 201, 00144 – Rome, c.a. Data Protection Officer, dataprotectionofficer@infratelitalia.it