Things Mobile, based at Piazza Luigi di Savoia, 22 - 20124 - Milan – Italy, VAT 09882960967 ("Company"), is a reseller of international mobile and/or landline electronic communication services.
Things Mobile S.r.l. sells a Sim card called "Things Mobile" which ensures the reception/transmission of mobile data for the exclusive use of IOT ("Internet of Things") applications on fixed and mobile goods, such as appliances, vehicles, transport tools, video surveillance tools and other connectable products ("Services").
In accordance with article 13 of Italian Law Decree no. 196/2003 and subsequent amendments concerning the “Personal Data Protection Code" (hereinafter the "Code"), Things Mobile S.r.l.hereby provides the following information.
1. Purpose of the processing of personal data:
All data provided to or acquired by Things Mobile S.r.l.for the performance of its business and/or contractual relationships with its Customers, service providers and suppliers shall be strictly processed for the following purposes: a) compliance with the obligations set out by laws, rules, and provisions of indipendent authorities and supervisory and control bodies; b) fulfillment of pre-contractual and contractual obligations strictly related with the management of the relationships in place with Customers, service providers and suppliers; c) execution of marketing, promotional, advertisement, and market research activities, including through other companies.
2. Methods for processing personal data:
The data relating to services provided by Things Mobile S.r.l.shall be processed in accordance with the applicable regulation. Data will be processed manually (on hard copy) and/or electronically or telematically, by ways of data/traffic organizational and processing logics related to the above purposes and so as to ensure the safety and the confidentiality of the data and communications. As part of the telephone support services, data are managed by means of IT systems designed to allow the operator to identify the type of contract in place at the time of the call in order to efficiently and accurately meet the support requests.
Cookies are small text files that your browser saves on your computer hard drive. Each time a user visits the website www.thingsmobile.com, the browser re-sends the cookies in order to allow Things Mobile S.r.l.to offer personalized navigation, which reflects the interests and preferences of users and facilitates access to Things Mobile services. Cookies are used to improve the services and can be used to allow users to use the services requested via the website www.thingsmobile.com. By way of example, cookies may be used to manage and save items in the basket on the online store; to allow users to access secure areas of the website www.thingsmobile.com and to avoid having to login at each access; and/or to save any user actions in the sequence of pages visited during a same visit session on the website www.thingsmobile.com. Things Mobile S.r.l.declares that most browsers allow you to erase cookies from your computer hard drive, block acceptance of cookies or receive a warning before cookies are saved.
4. Compulsory and voluntary data:
Some data is essential for the fulfillment of legal and/or regulatory obligations, and to allow acceptance of the General Terms and Conditions of Contract and other Contractual Terms by Customers and their correct execution and management. Therefore, a refusal to grant the data shall make it impossible to stipulate the contract and execute the contractual relationship with Customers. The data are collected and processed with reference to: a) provision of electronic communications services and any other related services; b) delivery, activation and maintenance of the products, services and/or equipment offered to the public; c) billing of traffic carried out by the Customers, other fees and any additional services; d) management of complaints and disputes; e) fraud prevention and management of delayed payments or non-payments; f) protection of credit and possible debt recovery either directly or through third parties; g) transfer of credit to authorized companies; h) fulfillment of obligations pursuant to laws, regulations and measures related to purposes concerning law enforcement, civil defense and the investigation and prosecution of crimes.
Things Mobile S.r.l.may acquire information on the reliability and timeliness of payments, directly or through third parties, from archives or public records and credit information systems. The data shall be stored by Things Mobile S.r.l.for the time necessary for the performance of activities related to the perfection of the contractual relationship with its Customers and for the management of requests for access to data.
The user's refusal to provide personal data that is not mandatory but nonetheless instrumental to the execution and management of the contracts will have no consequence other than the impossibility to perform one or more operations related to the said data.
Any refusal to grant and consent to the processing of data relating to the performance, including through other companies, of marketing, promotional, advertising or market research activities shall not have any consequence except for precluding the sending of the relevant advertising and/or promotional materials.
5. Traffic data processing and storage:
In accordance with article 123 of the Code, all data relating to phone and/or telematic traffic shall be saved: a) for a maximum of six months for invoicing and/or payment collection purposes unless longer storage time is needed for settling any disputes, including in court; b) for the length of time set out in contracts for the marketing of electronic communication services and/or the supply of value added services. Pursuant to article 123, paragraph 3, of the Code, the data on telephone traffic and data carried, can be processed by Things Mobile S.r.l.with prior consent of the Customer, expressed following the first use of services through the use of Things Mobile and/or using automated means (by phone, text message, MMS, fax, e-mail and web applications, including
6. Individuals to whom the personal data may be disclosed:
In the pursuit of the aforementioned purposes, parts of data processing may be processed by Things Mobile S.r.l.and its employees, as well as by third parties based in Italy and/or abroad, including non-EU countries. In particular, data may be disclosed to public or private entities delegated under current legislation with public functions and that are legitimate recipients of communications set out by law and/or regulations.
Said personal data can be communicated to subsidiaries, parent companies and affiliates of Things Mobile.
If needed, personal data can also be communicated to: a) parties assigned with technical and organizational tasks on behalf of Things Mobile srl; b) providers of data acquisition and processing services required to let customers utilize Things Mobile S.r.l.services; c) any party directly or indirectly involved in the sale network of Things Mobile; suppliers of transfer, packing, transport, and distribution services for the sending of any communication of Things Mobile; d) entities to which Things Mobile S.r.l.contracts out customer servicing, advertising, promotional and sales activities; e) providers of data entry and filing services; f) suppliers of market researches and surveys aimed at assessing the degree of customer satisfaction; g) entities engaged in the promotion and sale of Things Mobile S.r.l.products and services; h) any parties to which Things Mobile S.r.l.provides VAT and social security numbers for assessing whether customer data are exact and valid; i) parties in charge of credit risk management and of fraud monitoring and prevention and parties who supply economic and commercial information, including those that manage information systems for the assessment of trustworthiness and payment dependability; l) companies processing data for the purpose of invoicing, printing, sending of invoices and/or accounting documents to customers; m) other electronic communication providers who are the holders of non-geographic numbers, for the management of interconnection and roaming services on behalf of whom Things Mobile S.r.l. provides for the invoicing service and, in some cases, the related debt collection; n) postal operators in charge of the shipping of the Things Mobile (including the telephone numbers provided by the Clients, to be reported on the shipping documents if necessary).
7. Data dissemination:
8. Rights of access to data:
The parties to whom data refer are entitled, pursuant to article 7 of the Code, to obtain at any time the confirmation of whether their personal data exist, to know the content and origin thereof, and to determine the correctness or request the integration, update, correction, deletion or anonymization thereof.
9. Data Recipient and Processor:
The Data Recipient is Things Mobile S.r.l. with registered office at Piazza Luigi di Savoia, 22 - 20124 - Milan - Italy. Any applications pursuant to article 7 of the Code are to be addressed to Things Mobile S.r.l., Via Biron 102, 36050 Monteviale (VI) - Italy. The name of the Data Processor is available at request. At the Company personal data shall be processed by the employees specified in a specific list under the direction of the Data Processor.