Information on the processing of personal data pursuant to Articles 13 and 14 of EU Regulation 2016/679 addressed to Users of the water service, of water for sanitary use in the segments of sewerage, aqueduct and purification that compose it in whole or in part, managed by Acque Bresciane S.r.l.

Dear User,

in the light of the provisions of EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data (the “Regulation”) we hereby intend to inform you that Acque Bresciane S.r.l. (“Acque Bresciane” or the “Company”) with registered office in Via Cefalonia, 70 - 25124 Brescia, and administrative office in Rovato (Bs) Via XXV Aprile 18, Tax Code 03832490985, VAT No. 03832490985, R. E.A. 566755, enrolled in the Reg. Imp. of Brescia, is the Data Controller operating in the context of the provision of water service, in the segments of sewerage, aqueduct and purification that compose it in whole or in part, managed by the Company in the optimal territorial sphere of reference of Brescia.

The Data Protection Officer or Data Protection Officer (the “DPO”) lawyer Giudo Paratico can be contacted by e-mail at dpo@acquebresciane.it for all matters relating to the processing of personal data and the exercise of rights arising from the Regulations.

Processing will be based on the principles of correctness, lawfulness and transparency. The data will be pertinent, complete and not excessive in relation to the purposes for which they will be processed and will be collected and recorded only for the purposes indicated in this statement.

1. What data will be processed?

The personal data that will be processed are those that identify you as a User of the provision of water service, in the segments that compose it in whole or in part, carried out against you.

They may be disclosed by you in connection with:

• Accreditation/Access/Application of the channels present within the institutional website and this with particular reference to “On line Desk”, “Smart Desk” and “ABweb” application;
  filling in and transmission of forms or forms on the institutional website or through the QRCode present on the bills;
• Verbal or written communication using the “Customer Service” channel published on the institutional website;
• Access to the physical counters of Acque Bresciane S.r.l.'s offices;
• By means of correspondence (postal or email/pec channels) during the pre-contractual phase and the stipulation of the supply contract as well as for the execution of fulfillments and actions related to the execution of the contractual relationship.

Personal data subject to processing may include:

• identifying and biographical data (e.g., first name, last name, social security number, address, date and place of birth);
• contact data (e.g., telephone numbers, landline and/or mobile, email address/pec);
• supply data (e.g., supply type, POD, geographical coordinates of supply point, consumption);
• creditworthiness information (e.g., reminders, defaults, interest calculations, write-offs, repayment plans, foster care);
• credit information (credit application/report, type of contract, amount of credit, repayment method and status of application);
• financial data related to payments (e.g., IBAN), their periodic performance, debt exposure including residual debt, and accounting status of the relationship;
• data related to credit recovery activities or litigation, credit assignment;
• image-related data (e.g., photo on identity card, videotaped image in case of access to “Smart Desk”);
• voice recordings (e.g., emergency calls;
• other data attributable to the above categories (e.g. documentation proving ownership/possession of the property; cadastral data);
• any data related to health status for Your specific requests.

Personal data may also include:

• public data or data that can be known by anyone, subject to the limits and modalities established by Community legislation, laws, or regulations;
• data related to the performance of economic activities, subject to the current legislation on business and industrial secrecy;
• personal data used for credit risk assessment collected from databases and systems aimed at credit risk assessment.

We may also become aware by the competent bodies of special data (ex art. 9 of the Regulations) or in any case ask you for information for the purposes of access to subsidized rates and/or obtaining contractual conditions provided by law and/or service regulations. 

In case of failure to provide the aforementioned data, Acque Bresciane will not be able to apply the specific regimes provided.

2. For what purposes are your data processed?

Your personal data are processed for the following purposes:

(a) to fulfill the obligations required by the Law, a Regulation, Community Legislation, or an order of the Authority including independent sector Authorities (Arera);

b) to carry out pre-contractual activities and enter into the relevant contract, enabling the performance of obligations relating to the water supply, in the segments of sewerage, aqueduct and purification that make it up in whole or in part, including the fulfillments related to the performance of activities of an organizational, administrative, financial and accounting nature.

Your data are also processed in order to manage your requests related to the supply that is the subject of the contract (for example: connection requests, sewer or drinking water connection quotation requests, self-reading of water meters, complaints, requests for information, volutations, activation requests, takeovers, rectifications, data changes, online payments, deactivations, bill delivery and consultation, etc.). This, therefore, also in order to carry out the operations necessary for the management of complaints and/or service-related inquiries as well as to inform you of possible breakdowns, inefficiencies, scheduled supply interruptions and other events related to the water supply contract. Your personal data may also be processed in order to follow up on your possible authorization for debiting your account.

Your personal data may also be processed in the event that you need to handle a dispute with the Company, including the possibility of recovering debts in case of arrears.

3. On what basis is your data processed?

The processing of your personal data, provided by you for the purposes referred to in paragraph 2, letter a), constitutes the fulfillment of a legal obligation, while for those in paragraph 2, letter b), it is an indispensable condition for the purposes of entering into a contract with the Company, as well as the management of the ensuing obligations, such as those of a fiscal, accounting and administrative nature, the billing of consumption, the management of your requests relating to the supply and the possible credit recovery activity, as well as to allow you access to subsidized rates or the obtaining of contractual conditions provided. Your refusal to provide such data will result in the impossibility of providing the supply service to you or, in any case, obtaining the contractual conditions indicated above.

The above may be done by any means of communication, it being understood that the Company will always use the one it deems most suitable to achieve the purpose, without prejudice to the possibility for you to choose your preferred means of communication without any marketing purposes.

Personal data are also processed to ensure your access to subsidized rates and/or the obtaining of contractual conditions provided by law and/or the service regulations.

With respect to solvency or creditworthiness, the legal basis is the conclusion/execution of the contract or the legitimate interest of the Controller in preventing economic damage and fraud.

The possible processing of your data in case of defense of a right in court and in connection with related prodromal activities is based on the legitimate interest of the Company in the protection of its rights.

4. How is your data processed?

Your personal data will be processed both with the use of paper media and with the help of electronic, computer and telematic tools, ensuring the use of appropriate measures for the security and confidentiality of such data.

For communications we may use various channels: electronic mail, telephone, telefax, Mms (Multimedia Messaging Service) or Sms (Short Message Service) messages or other.

The data will not be subject to decisions based solely on automated processing, including profiling, that produce legal effects or that affect the Data Subject in a similar significant way; this is without prejudice to the fulfillment of legal or regulatory obligations imposed by the competent Authorities in this regard (see Arera Deliberations regarding the forecasts of average annual consumption of the user).

5. To whom do we communicate your data?

The subjects or categories of subjects who may become aware of the data or to whom the data may be communicated, as autonomous owners or managers authorized by Acque Bresciane, are the following:

• subjects in charge of the execution of activities related and instrumental to the processing (IT service companies, call centers, contractors in charge of the execution of works or services) and companies of the Group within the framework of existing corporate contractual relationships; 
• post offices, banking institutions, banking service companies;
• Competent Authorities (e.g. ARERA, Brescia Area Office, Revenue Agency), Single Buyer, Cassa per i Servizi Energetici e Ambientali, Consultancy Firms, Banking and Insurance Institutions, Credit Recovery Companies, Law Firms, Accountants and Labor Consultancy Firms.

Your data will not be disseminated, that is, made available to unspecified parties.

6. How long do we keep your data?

Your data will be kept for as long as necessary to achieve the purposes for which they are processed or to fulfill legal obligations and in particular:

• in relation to data related to the contract, complaints and/or reports/enquiries, for 10 years from the termination/last performance related to the contract or from the time of termination of the statute of limitations.
• telephone records of emergency response calls for 5 years from January 1 of the year following the year in which the record was made.

The solvency index for 5 years.

In case of litigation, all of the above retention periods may be extended up to 10 years from the settlement of the litigation.

7. What are your rights?

The Regulations give you the exercise of specific rights, including those to request from the Data Controller:

• confirmation as to whether or not your personal data is being processed and, if so, to obtain access to it (right of access);
• The rectification of inaccurate personal data, or the integration of incomplete personal data (right of rectification);
• the deletion of the data itself, if there is one of the reasons provided for in Article 17 Regulations (right of deletion): if the data are no longer necessary in relation to the purposes for which they were collected or processed, have been processed unlawfully, must be deleted in order to fulfill a legal obligation, or if you have revoked your consent or object to the processing and there is no overriding legitimate reason;
• to obtain the restriction of the processing of your data, if there is one of the grounds provided for in Article 18 of the Regulation (right to restriction);
• to receive the personal data you provide in a structured, commonly used and machine-readable format, and to transmit it to another data controller (right to portability), where applicable.

In addition, You have the right to revoke consent to the processing of Your data if given, at any time, without prejudice to the lawfulness of the processing based on the consent given before revocation, and to object at any time to the processing of personal data concerning You (right to object).

To exercise your rights, you may send a request, by paper mail to Via XXV Aprile 18, 25038 Rovato (BS), or by e-mail to privacy@acquebresciane.it, or by fax to 030/7714270.

Pursuant to the Regulations, Acque Bresciane is not authorized to charge you for complying with any of the requests listed in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive in nature. In cases where you request more than one copy of your personal data or in cases of excessive or unfounded requests, Acque Bresciane may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to comply with the request. In these eventualities Acque Bresciane will inform you of the costs before processing the request.

Acque Bresciane may request additional information before processing requests if it needs to verify the identity of the individual making the request.

Without prejudice to any other administrative or jurisdictional recourse, you will also have the right to lodge a complaint with a supervisory authority (for Italy: the Garante per la protezione dei dati personali), if you believe that the processing concerning you is carried out in violation of the Regulation. Further information is available on the website http://www.garanteprivacy.it.

In any case, Acque Bresciane is interested in being informed of any grounds for complaint and invites you to use the contact channels indicated above before referring to the supervisory authority, so that any disputes can be prevented and resolved in an amicable and timely manner.