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Privacy notice
Notice under Article 13 of Regulation (EU) 2016/679 (GDPR) for visitors to the www.smartways.it website, for those who contact us or request a trial reading, and for customers and users of the enerdata platform. For cookies, the Cookie Policy applies.
01Data controller
smart ways S.r.l.s., Via Donizetti 30, 20122 Milan, VAT no. 09223910960, contatto@smartways.it.
02Website visitors
Data processed
The browsing data collected by the website's systems: IP address, date and time, pages requested, browser type and operating system.
Purposes, legal basis and retention
Operation and security of the website, on the basis of legitimate interest (Art. 6(1)(f) GDPR). The data is kept for up to 12 months, unless it is needed to establish unlawful acts.
Cookies
Cookies and measurement tools, including the measurement of advertising conversions, are described in the Cookie Policy and are activated only with consent, where required.
03Contact requests
Data processed
The data entered in the contact form (first and last name, email, phone, company, number of meters, purpose and message) and the data of those who write to us or phone us.
Purposes, legal basis and retention
Replying to the request and, if requested, preparing an offer, as pre-contractual measures (Art. 6(1)(b) GDPR). The data is kept for 12 months from the last contact, unless a contract follows. Name and email are needed to reply. The form is protected by reCAPTCHA (section 7).
04Trial reading
Data processed
The meter's model, modem phone number, serial number and K factor entered in the form, the IP address of the request, the outcome and the data of the reading.
Purposes, legal basis and retention
| Purpose | Legal basis | Retention |
|---|---|---|
| Performing the requested reading and showing its outcome | Request of the data subject (Art. 6(1)(b) GDPR) | 12 months |
| Security and abuse prevention: limits on requests per IP address and log of the readings | Legitimate interest (Art. 6(1)(f) GDPR) | 12 months |
Whoever requests the reading confirms that they are authorised to read the meter. The form is protected by reCAPTCHA (section 7).
05Customers and users of the enerdata platform
Data processed
- identification and contact data of users and of the customers' contact persons;
- login credentials for the platform;
- usage data: IP address, date and time of logins, operations performed;
- support requests;
- customers' billing data.
Purposes, legal basis and retention
| Purpose | Legal basis | Retention |
|---|---|---|
| Account management, provision of the services, support and operational communications (outcomes, summaries, reminders) | Performance of the contract (Art. 6(1)(b) GDPR) | Term of the contract and 12 months after |
| Invoicing and accounting and tax obligations | Legal obligation (Art. 6(1)(c) GDPR) | 10 years (Art. 2220 of the Italian Civil Code) |
| Security, abuse prevention, logging of logins and operations | Legitimate interest (Art. 6(1)(f) GDPR) | 12 months |
06Data processed on behalf of customers
Meter readings, master data and the data acquired from the portals for the platform's customers are customer data: when they contain personal data, for example of plants, meters or SIMs registered to natural persons or sole proprietorships, smart ways processes them as data processor (Art. 28 GDPR), under the supply contract. The controller is the customer, to whom requests concerning rights over this data should be addressed.
07Recipients and transfers
The data may be disclosed to:
- hosting and email providers, based in the European Union, which process it on behalf of the controller;
- Google, for the reCAPTCHA anti-bot service that protects the website's forms;
- iubenda, for managing cookie consent;
- the telephone operators that carry the calls to the modems, as independent controllers;
- consultants and authorities, where required by law.
The data is not disseminated. It is transferred outside the European Economic Area only with the safeguards of Art. 44 et seq. GDPR, for example for Google's reCAPTCHA service.
08Rights
Access, rectification, erasure, restriction, portability and objection to processing based on legitimate interest; withdrawal of consent at any time, where consent is required. These rights are exercised by writing to contatto@smartways.it. The right to lodge a complaint with the Garante per la protezione dei dati personali, the Italian data protection authority (www.garanteprivacy.it), remains.
No decisions are made based solely on automated processing. Changes to this notice are published on this page, with the date of the last update.