Privacy policy

Enerbrain S.r.l. with registered office in Strada alla Villa d’Aglié 26, Turin (Italy), VAT No. IT11249860013, in its capacity as data controller (“Controller” or “Enerbrain”), informs you of the following with regard to the processing of your personal data carried out through the website www.enerbrain.com (“Website”), in accordance with applicable legislation on the processing of personal data and, in particular, Article 13 of EU Regulation No. 2016/679 (General Data Protection Regulation “GDPR”).

 

  1. Data subject to processing 

For the purposes set out in this Privacy Policy, Enerbrain will process data that the GDPR defines as “personal data”, i.e. any information relating to an identified or identifiable natural person (“data subject”).

In particular, Enerbrain will process the following data:

a. Browsing data

The computer systems and software procedures used to operate the Website (which also includes a section for activating a demo of an app) may acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by its very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or the domain names of the devices used by users who connect to the Website, the URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment.

These data are used for the sole purpose of obtaining statistical information on the use of the Website and to check its correct operation, to allow the correct provision of the various functions you have requested, and to ascertain possible liability in the event of hypothetical computer crimes to the detriment of the Website or third parties; except in this case, these data are deleted after 7 days.

With regard to personal data collected via cookies, we invite you to read our Cookie Policy.

b. Personal data you voluntarily provide us with

We collect your personal and contact information that you voluntarily provide us with, such as your first name, last name, e-mail address, telephone number, city of origin, company, position held, and information contained in your curriculum vitae (in the case of an application sent to a dedicated e-mail address): (i) to respond to your requests for information sent via the « Contact Us » form on the Website, (ii) to allow you to subscribe to our Newsletter, (iii) to provide you with a demonstration of the features and functionalities of the application developed by and owned by Enerbrain, (iv) to provide you with access to the download area of the Website and its contents, (v) to allow you to send us your application by writing to the dedicated email address.

 

  1. Purposes and conditions of lawfulness of processing

Your personal data will be processed for the following purposes and on the basis of the following lawful processing conditions:

I. Allowing navigation on the Website and monitoring its correct functioning. Such processing is necessary for the performance of a contract or of pre-contractual measures taken at your request.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is that you will not be able to browse the Website.

II. Managing and responding to your requests (including technical assistance) related to our products/services, received via the “Contact Us” form on the Website. Such processing is necessary for the performance of a contract or of pre-contractual measures taken at your request.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of following up your requests.

III. Provide you, at your request, with a demonstration of the features and functionality of the application developed by and owned by Enerbrain. Such processing is necessary for the performance of a contract or of pre-contractual measures taken at your request.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the inability to activate a demo account for the Enerbrain application.

IV. Allow you to access the download area of the Website and its contents. Such processing is necessary for the performance of a contract or of pre-contractual measures taken at your request.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of accessing the download area and its contents.

V. Allow you to send us your application by writing to the appropriate e-mail address in the Contacts section of the Website. Such processing is necessary for the performance of a contract or of pre-contractual measures taken at your request.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of managing your application.

VI. To send you newsletters and commercial communications relating to Enerbrain products and/or services or those of other entities related to Enerbrain (“Enerbrain Group”), as well as to carry out market research through automated (such as e-mail and SMS) and traditional (such as paper mail and operator calls) contact methods. This processing is based on your specific consent, which you may revoke at any time.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of sending you newsletters and commercial communications, as well as carrying out market research.

VII. If you are already our customer, your email address (provided at the time of sale) may be used for sending commercial communications for direct sales and/or promotion of products/services similar to those you have already purchased (“soft spam”), unless you object to receiving such communications: your objection may be expressed during the purchase process or, subsequently, at any time, using the appropriate link at the bottom of each email or by writing to privacy@enerbrain.com. Such processing is necessary to pursue Enerbrain’s legitimate interest in promoting its services and/or products to its customers; Enerbrain has taken the view that this legitimate interest does not affect your rights and freedoms.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of sending you commercial communications relating to products/services similar to those you have already purchased.

 

VIII. Measuring your satisfaction with the quality of products and/or services provided by Enerbrain (so-called customer satisfaction). Such processing is necessary to pursue Enerbrain’s legitimate interest in improving the quality of the products and/or services rendered; Enerbrain has taken the view that this legitimate interest does not affect your rights and freedoms.

You are not obliged to communicate your data for the above-mentioned purpose, but the consequence, if you do not communicate your data, is the impossibility of detecting your degree of satisfaction with the quality of the products and/or services rendered and with the activity carried out by Enerbrain.

IX. Exercising or defending a right in or out of Court. Such processing is necessary to pursue Enerbrain’s legitimate interest in exercising or defending its rights; Enerbrain has taken the view that this legitimate interest does not prejudice your rights and freedoms.

 

  1. Processing methods

The processing of your personal data will be based on the principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimization, accuracy, integrity and confidentiality, in accordance with the GDPR and current national legislation on the protection of personal data. Your data will be processed with the support of computer and telematic means and are protected by adequate security measures to ensure confidentiality, integrity and availability.

 

  1. Data retention time

We only retain personal data for as long as is necessary for the purposes for which it was collected or for any other legitimate related purposes. Therefore, if personal data are processed for two different purposes, we will keep those data until the purpose with the longer retention period ends. In any event, we will no longer process personal data for that purpose whose retention period has expired.

Personal data which are no longer necessary, or for which there is no longer a legal basis for their storage, are irreversibly anonymised (and can thus be stored) or securely destroyed.

Browsing data are deleted after 7 days, except in the case of criminal investigations by judicial authorities.

Personal data processed to fulfil any contractual obligation (including technical assistance) may be retained for the duration of the contract and in any case for no longer than 10 years, in accordance with the statute of limitations provided for by law.

Personal data processed to provide you with a demonstration of the features and functionalities of the application may only be stored for the period of time necessary to provide you with this service and for the following 6 months.

Personal data processed to enable you to access the download area of the Website and its contents may be retained for the entire duration of the contractual relationship, where established, or only for the period of time necessary to respond to the request and for 6 months thereafter, in the absence of marketing consent (with respect to which the retention period referred to below applies).

The personal data processed to manage your application will be kept for 6 months from the date of collection.

Personal data processed for marketing purposes may be retained for 24 months from the date on which we last obtained your consent or until you exercise your right to deletion, whichever is earlier. If you withdraw your consent such data will no longer be processed for this purpose.

The personal data processed to detect your degree of satisfaction with the quality of the products and/or services provided and with the activities carried out by Enerbrain may be stored for the entire duration of the contractual relationship.

If it is necessary to process data for judicial purposes, it will be retained for as long as possible claims may be pursued by law.

 

  1. Categories of data recipients

All the data collected and processed may be communicated exclusively for the purposes specified above to:

  • employees, collaborators and consultants of the Data Controller or of the other entities of the Enerbrain Group, in Italy and abroad;
  • subjects who carry out activities of management and archiving of documentation relating to relations with Enerbrain’s customers;
  • subjects that provide services for the management of the computer system of Enerbrain;
  • companies that provide direct e-mail marketing services;
  • companies that provide cloud services;
  • entities that carry out control, audit and certification of the activities carried out by Enerbrain;
  • authorities and judicial bodies;
  • third party companies or other subjects who carry out activities in outsourcing on behalf of the Data Controller.

You can request a list of the data controllers and further information about the recipients of your personal data by writing to the address privacy@enerbrain.com.

 

  1. Data transfer abroad

The Data Controller stores personal data on servers located within the European Union.

In some cases, personal data collected through the Website may be transferred to certain non-EU countries in connection with specific requirements related to the location of certain Enerbrain service providers. In this case, where the third country is not the recipient of an Adequacy Decision of the European Commission, Enerbrain undertakes to ensure adequate levels of protection and safeguards, including contractual safeguards, in accordance with applicable rules, including the stipulation of standard contractual clauses as per Article 46(2)(c) of the GDPR, supplemented by additional measures necessary to ensure that the level of protection of personal data is equivalent to that of the EU.

 

  1. Rights of the data subject

As a data subject, you have the right to access the data and specifically the right to obtain from the Data Controller confirmation as to whether or not personal data concerning you are being processed and to obtain access to the personal data and the following information: the purpose of the processing, the categories of personal data, the categories of recipients to whom the personal data have been or will be communicated, when possible, the storage period. You also have the right to obtain a copy of the personal data being processed from the Data Controller.

In addition, you have the right to obtain from the Data Controller: the rectification of inaccurate personal data concerning you without undue delay and the integration of incomplete personal data; the deletion of personal data (where one of the reasons provided for in Article 17 of the GDPR exists); the restriction of processing; the portability of data to another data controller. You also have the right to object to the processing of your personal data (at any time, if the purpose of the processing is direct marketing or profiling) and the right to lodge a complaint with the supervisory authority (the Data Protection Authority – Garante per la protezione dei dati personali).

 

  1. How to exercise your rights

The aforementioned rights may be exercised by sending a written communication to Enerbrain, by sending an e-mail to the e-mail address privacy@enerbrain.com, or by sending a registered letter with return receipt addressed to Enerbrain at the following address: Strada alla Villa d’Aglié 26, Turin (Italy).

 

  1. Data Controller

The Data Controller is Enerbrain S.r.l. with registered office in Strada alla Villa d’Aglié 26, Turin (Italy), VAT number IT11249860013, e-mail address info@enerbrain.com.

 

  1. Changes to this Privacy Policy

Enebrain reserves the right to make changes to this Privacy Policy at any time, by informing you of them on the Website. We therefore invite you to consult this page regularly. This Privacy Policy was last updated on: October 2021.