Following Regulation (EU) 2016/679 (‘GDPR’), Eni S.p.A. (‘Company’ or the ‘Data Controller’) is providing the following information regarding the processing of personal data to inform users (‘User’ or ‘Users’) of the eni.com/enirewind website (‘Website’) of its data protection policy and how the personal information of Users is collected and managed during browsing on the Website and for the use of its services.
Identity and contact details of the Data Controller
The Data Controller is Eni Rewind S.p.A. - Company subject to the direction and coordination of Eni S.p.A., with registered office in San Donato Milanese (MI), Piazza Boldrini 1 (20097), which can be contacted through the CONTACT US form.
Contact details of the Data Protection Officer
The Company has appointed a Data Protection Officer, who can be contacted at the email address firstname.lastname@example.org.
Purpose of processing and legal basis of processing
a. Purposes provided for by law and necessary for the provision of services - processing required to fulfil a contractual or legal obligation to which the Data Controller is subject or to implement a specific request made by the Data Subject.
The User’s personal data may be processed without their consent in cases where this is necessary to comply with obligations deriving from laws, regulations, codes or procedures approved by authorities or other competent institutions.
The User’s personal data will also be processed for purposes relating and/or connected to the provision by the Company of services for the browsing of the Website, and specifically:
- to provide the services requested by the User when browsing the Website, including the collection, storage and processing of data to deliver the services and their subsequent operational and technical management; Specifically, filling in the CONTACT ME form entails the collection of personal and contact data to enable the Company to respond to the questions and/or reports raised;
- to manage relations with third-party authorities and public bodies for purposes related to particular requests, compliance with legal obligations or particular procedures.
This data – which is required to deliver the service – will also be processed electronically, stored in specific databases, and used strictly and exclusively for browsing the Website. Given that providing the User’s personal data for these purposes is necessary to maintain and deliver all the services connected to browsing the Website, failure to provide such data will make it impossible to offer the specific services in question.
c. Defence of legal claims
In addition, the User’s personal data will be processed whenever necessary to establish, exercise or defend the legal claims of the Data Controller or other companies under Eni’s control.
d. Legitimate interest of the Data Controller
The Data Controller may process, without the User’s consent, the personal data collected in the following cases:
- during mergers, disposals or transfers of business units, to carry out operations necessary for due diligence activities and in preparation for the transaction. It is understood that only the data necessary for the purposes mentioned above will be processed, in the most aggregate/anonymous form possible;
- for the aggregate and anonymous analysis of the use of the services accessed, to identify user habits and propensities, to improve the services provided and to meet specific user requirements, or to prepare initiatives for improving the services provided.
- analysis of Eni Rewind’s brand positioning and reputation on the web (web listening). This includes, in particular, identifying and assessing what is being said about Eni Rewind and its activities/customers on the publicly accessible websites to understand the market sentiment, intent, mood and trends and the needs of Eni Rewind’s stakeholders’ and thereby improving the services offered by the Company. The above takes place through keyword searches without identifying users.
Recipients of the personal data
In pursuit of the purposes indicated in point 3, the Data Controller may communicate the User’s personal data to third parties, such as those belonging to the following organisations or categories of organisations:
- police forces, armed forces and other public authorities, to comply with obligations set out by law, regulations or EU legislation. In such cases, there is no obligation under applicable data protection legislation to obtain the Data Subject’s prior consent to these communications.
- Eni Spa, which will act as Data Processor to support the provision of the services offered by the Website and the management of cookies.
- IT service providers
The Data Controller guarantees that they will take the utmost care to ensure that the communication of the User’s personal data to the recipients mentioned above only involves the data necessary to achieve the specific purposes for which they are intended.
The User’s personal data is stored in the Data Controller’s database and processed exclusively by authorised personnel. Said personnel will receive specific instructions on the methods and purposes of the processing. The data will not be disclosed to third parties except as provided above and, in any case, within the indicated limits.
Finally, we remind that the User’s personal data will not be disseminated, except in the cases described above and/or the cases required by law.
Transfer of personal data outside the EU
As part of the contractual relationship between Eni, Eni Rewind S.p.A and its subsidiaries, and between the subsidiaries themselves, for some of the purposes indicated in point 3, the User’s personal data may be transferred outside of the EU, also through inclusion in databases shared and managed by third parties, whether or not within the perimeter of control of Eni and Eni Rewind S.p.A. The management of the database and the processing of such data are bound to the purposes for which they were collected and are carried out in full compliance with the privacy and security standards set out in the applicable data protection laws.
In every instance when the User’s personal data is transferred internationally outside of EU territory, the Data Controller will take all contractual measures necessary and suitable to ensure an adequate level of protection of their personal data, under the contents of this notice on the processing of personal data, including the Standard Contractual Clauses approved by the European Commission.
Period of data retention
The data will be stored for a period not exceeding the time necessary to fulfil the purposes for which it was collected or subsequently processed in compliance with legal obligations.
Rights of the Data Subjects
As a Data Subject, the User has the following rights over the personal data collected and processed by the Data Controller for the purposes indicated in point : (i) the right of access, in particular to request at any time confirmation of the existence of the User’s personal data in the Company’s archives and the making available of this information in a clear and intelligible form, and the right to know the origin, logic and purpose of the processing with express and specific indication of the Data Supervisors and Processors and the third parties to which the User’s data may be communicated; (ii) the right to have their data updated and rectified (except for subjective data), to have superfluous data erased or anonymised, and to block processing and have their data definitively erased in the event of unlawful processing; and (iii) where the conditions are met, to restrict processing and data portability. The law also grants Data Subjects the right to complain to the Italian Data Protection Authority if the User becomes aware of a violation of their rights under applicable personal data protection legislation.