The Google Action “Piano Banda Ultralarga” (the “Google Action“) 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 Google Action “Piano Banda Ultralarga” 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 “Google Action”.
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.
1. OBJECT OF THE TREATMENT
1.1 Browsing data
To ensure the correct use of the “Google Action” 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 Google Action “Piano Banda Ultralarga” tool, involves the acquisition of such data, as they are included in the communications with the Google virtual assistant.
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 “Google Action”), all data that passes through the Google Action “Piano Banda Ultralarga” 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 Google Action “Piano Banda Ultralarga” 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.
The data is processed solely to provide Google Action information services. In the absence of precise data relating to the street number, main object of research on the Google Action “Piano Banda Ultralarga”, 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 Google Action “Piano Banda Ultralarga” 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 functionality of the “Google Action”.
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 Google Action “Piano Banda Ultralarga” 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:
|Technical and navigation cookies
|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 “Google Action” 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:
- 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, firstname.lastname@example.org