We undertake to safeguard your privacy and protect the personal data you entrust to us, in accordance with the principles of transparency
- correctness - fairness.
New Information on Privacy and the Protection of Personal Data
Drafted in compliance with arts. 13 and 14 of EU Regulation 679/2016 (GDPR) and in re-placement of the previous Information provided pursuant
to art. 13 of Legislative Decree no. 196/2003, the Italian Data Protection Act.
This information is inspired by the principle of
, as provided for in art. 12 of the European Regulation on the protection of personal data. It is there-fore designedtobe
concise, transparent, intelligible and easily accessible, so that the content is "
" to all the subjects it is aimed at, and with particular attention to cases in which it is aimed at subjects under the age of
Why are you reading this information?
are extremely valuable these days, so the new EU Regulation establishes that
information not only has a key role to play, but must also be dynamic, subject to changeand
updated constantly to guarantee data subjects correct, timely
regarding the processing of their personal data.
Maximum attention must be paid, but we should have NO FEAR, because personal data must be able to circulate as widely aspossible,in
complete safety and security: this is in EVERYONE's in-terest!
In order to effectively contextualise this information, it should be noted that the use of any type of communication network,withoutexception
- including the cellphone or cable network - is a process that leaves traces that extend far beyond the scope of the data
processed by Guglielmo Srl., the object of this document. These traces are spread through the device used and throughout
the systems of the networks involved, and in certain cases are also simple to intercept on the partofexternal systems.
Therefore, connection to a network, such as Internet in particular, must never be considered asa "private"action in
any of its aspects, regardless of the activities of Guglielmo.
Guglielmo Srl. collects different data depending on the type of location and client
The analyses conducted by Guglielmo focus on data relating to the device used to access the network, the transmission of which is
implicit in the use of Internet communication protocols, and the collection of which, in certain cases, is obligatory under the
terms of the law governing Internet connections. These data are anonymous, but they may be linked with those provided by
the user at the registration stage.
Other data can be collected, also at the request and on behalf of "third-party" clients
Object of the Information
The information provided here regards your personal data
– both those collected up to now and those that will be acquired in the future in relation to the con-tractual relationshipsenteredinto
by Guglielmo WiFi, who takes
responsibility for processing
in its capacity as
Data Controller, in compliance with the regulation referred to above and the confidentiality obligations our activity is inspired by.
Data Controller and Contact Data
Data Controller is
Guglielmo S.r.l., headquartered in Barco di Bibbiano (Reggio Emilia), in Via G. Falcone 12.
The company may be contacted by:
TELEPHONE: +39 0522 243811
PEC REGISTERED E-MAIL: firstname.lastname@example.org
An updated list of Data Processors (if appointed) is available at the address indicated above.
Purposes of the processing of personal data.
Please note that the data you provide, personally or by filling in and electronically sending the forms presented during the provision of our services, will be processed for institutional purposes, purposes connected with or instrumental to our activity and in compliance with legal obligations. Specifically, data are processed for the following purposes:
To perform services requested by the user, specific to Guglielmo S.r.l.'s business activity, such as Internet connection, or specific services designed to offer an improved internet browsing experience.
- Mandatory requirements provided for in the regulations in force governing Internet access
- To exercise the rights of the Data Controller, for example the right to defend their case in court
Automated Processing - Profiling
based on reasoning and criteria defined by our third-party clients. This profiling is always and irreversibly aimed at grouping cases together, never to identifying individual cases. The specific information on the users is processed by the system in real time and is automatically and irrecoverably erased; it is used for the sole purpose of extracting anonymous statistical information on the use of the service and to make sure it is functioning correctly.
Information we collect from third parties
In certain cases, the Guglielmo platform interfaces with external data sources to complete profiling and apply the adequate policies to each device. In these cases, data have been collected by other bodies, so you could consult the information they provide. Also in this case, the Guglielmo platform processes data in real time, immediately and irreversibly erasing them once they have been aggregated.
Methods of processing
The data you provide us with will be processed with the aid of the appropriate electronic tools and by software platforms
, equipped to guarantee security and confidentiality, for reasons strictly connected to the purposes of processing; any changes to or destruction of data, and prevention to avoid unauthorized changes or destruction, are managed by the same infrastructure, in ways always strictly connected with the purposes of processing. All the analyses underlying the services offered are carried out in real time, in accordance with one of the hallmark features of the Guglielmo platform. Data are therefore aggregated instantly, whether they relate to profiling activities or user segmentation, and are irreversibly destroyed.
HHuman operators intervene only in the event of a technical problem, and this intervention is strictly controlled using authentication and tracking procedures. Because of how they are memorised, the data cannot be traced to individuals or users, and there are no activities contemplated that allow for the copying or alteration of the data.
Place of processing
The data collected are processed on the company premises and in a data centre
separate from the company premises, in the cloud managed by a third-party provider and on machines in operation at third-party clients who manage the structure where the service is provided. Operations for the maintenance and development of the Lumen platform are carried out from the operating offices of the company.
Communication and Dissemination
Guglielmo S.r.l. - the Data Controller undertakes not to divulge personal data to third parties, except, in certain cases, to our client, who manages the structure where our platform is activated, in order to offer the services provided for.
Storage of Data (or Storage Mechanism)
Personal data will be stored
Guglielmo S.r.l. y your data will be stored for the length of time strictly necessary for and instrumental to their future use if contemplated by law and connected with the specific service requested by the client.
Instead of being erased, data may still be stored, but will be anonymised.
using the methods indicated above, for the minimum period of time provided for by law or by contract. At the end of your contractual relationship with
Provision of Personal Data
It is not mandatory to provide your data. However, failure to provide the data requested will make it impossible to establish or continue a relationship and, in certain cases, make it technically impossible to provide the specific WiFi connection service.
The processing of data instrumental to complying with these obligations is necessary to properly manage the relationship, and it is mandatory to provide them for the purposes indicated above. The Data Controller wishes to inform you that failure to accurately provide any of the mandatory information may make it impossible for the Data Controller to guarantee the processing is carried out properly.
RIGHTS OF THE DATA SUBJECT: i.e. Your rights
The aim of the points below is to draw your attention to a series of rights the regulation governing privacy and the protection of personal data has established in order to effectively safeguard your personal data.
Pursuant to article 7 of the Italian Data Protection Act (as far as it remains compatible), and pursuant to articles 13, para. 2, letters (b) and (d), and articles 15- 22 of the Regulation, data subjects are herewith informed that when they entrust their personal data to Guglielmo S.r.l., they may exercise the following rights, free of charge and without any formal restrictions:
Access to, rectification and/or erasure of personal data (right to be forgotten)
This is the right to request from Guglielmo S.r.l., in its capacity as Data Controller, access to
of personal data or restrictions on the processing
of personal data regarding the data subject, or to object to the processing
thereof, in the cases contemplated.
Right to data portability (art. 20)
The user has the right to request complete documentation
regarding the processing of his or her personal data provided to Guglielmo S.r.l. in its capacity as Data Controller. In other words, if the data subject intends to request the services of a "manager" other than Guglielmo S.r.l., he or she has the right to request, and to obtain all the personal data previously provided.
Right to object art. 21
Right to withdraw consent and lodge a complaint
The data subject has the right to withdraw the consent given at any time. This operation must be as easy as giving consent for the processing of data. At the same time, the data subject has the right to lodge an official complaint with the Data Protection Supervisory Authority, following the procedures and indications published on the official website of the Authority: www.garanteprivacy.it
For further information, consult the indications of the Data Protection Supervisory Authority, available at this link: