Privacy Policy
Enel Global Trading processes personal data in compliance with the applicable data protection law (Article 13 of Regulation (EU) 2016/679 - “GDPR”) and the privacy notice herein.
Data Controller
The controller of the personal data is Enel Global Trading S.p.A., with its registered office in viale Regina Margherita 125, 00198 Rome, Italy VAT no. 15844561009, tax no. 05918271007 (“Enel Global Trading” or “Enel”).
Data Protection Officer (DPO)
Enel Global Trading has appointed a Data Protection Officer (DPO) who can be contacted at the following e-mail address: dpo.eneltrade@enel.com.
Purpose and Method of Processing
Enel Global Trading will process the personal data provided or legitimately collected, belonging to the following categories:
Browsing data: during the course of their normal functioning, the IT and telecommunications systems, as well as the software processes that ensure the proper functioning of the website, collect certain data: the access date and time, the pages visited, the selected language, the IP address used to access the Internet, etc. The transmission of such data is implicit in the use of web communication protocols or is useful for the improved management and optimization of the data and the website.
Identification and contact details: first name, last name, e-mail address, telephone number, the content of the message sent by the user and any other personal data you may have provided during your interactions with Enel Global Trading or when you register on the website’s private area. We may also ask the job position of the reference contact of the company interested in the Enel Global Trading’s business to best address the requests on the basis of the company’s organization.
Cookies: Information about cookies is available in the section containing our cookie policy.
For the purposes of this privacy policy, the processing of Personal Data means any operation or series of operations carried out on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Please note that such Personal Data will be processed manually and/or with the support of IT or data transmission devices.
Enel Global Trading has adopted technical and organisational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 of the GDPR, aimed at preventing and counteracting the loss of Personal Data, as well as unlawful or incorrect use and unauthorised access to data.
Purposes and legal basis of processing
The following table lists the purposes for which the personal data will be collected and processed by Enel Global Trading, as well as the legal basis of processing.
|
Purposes |
Legal basis |
|---|---|
|
Fulfilment of pre-contractual, contractual and tax obligations and for any further activities instrumental to the signing of the contract with the Client, including any support and ancillary services required |
Performance of a contract/precontractual activities |
|
Allow the use of all the features of the website and check its correct functioning |
Performance of a contract |
|
Reply to questions or process users’ requests, for example those submitted compiling the forms available on the website, or through other channels |
Performance of a contract |
|
Send newsletter containing industry news regarding the sector in which Enel Global Trading operates |
Performance of a contract/Legitimate interest |
|
Carrying out of market research, direct sales, including by telephone, for the placement of products or services, for commercial communications or marketing activities. These activities may be carried out by sending advertising, informative or promotional material, by traditional means (e.g. paper mail) or automated means (e.g. SMS, e-mail) |
Consent/Legitimate interest |
|
Carry out, by identified companies of the Enel Group (such as Enel Energia S.p.a., Enel X S.r.l, Enel X Financial Services S.r.l., ,Enel X Way S.r.l., Enel X Way Italia S.r.l, Enel Green Power SpA, Enel Green Power Italia s.r.l.)[LE(L1] of market research, direct sales, including by telephone and e-mail, for the placement of products or services, for commercial communications or marketing activities. These activities may be carried out by sending advertising, informative or promotional material, by traditional means (e.g. paper mail) or automated means (e.g. SMS, e-mail) |
Consent |
| Conduct surveys concerning Enel Global Trading’s business (e.g. customer satisfaction) | Legitimate interests |
| Send invitations to events, projects or initiatives organized or participated by Enel Global Trading |
Legitimate interests |
| To ascertain responsibility in the event of computer crimes detrimental to the website; detection, prevention, mitigation, or verification of fraudulent or illegal activities in connection with the services provided by the website | Legitimate interests |
The provision of personal data is necessary in all cases where the processing is carried out on the basis of a legal obligation, in order to perform a contract or the execution of pre-contractual measures adopted at request. The refusal to provide personal data may make it impossible for Enel Global Trading to process the request.
The provision of personal data is voluntary for the pursuit of additional purposes, and the failure to provide your consent in relation to them will have no consequences (ex. on the business relationship with the client).
It is always possible to object to the communications regarding events, surveys, newsletters and other informative or commercial content, by sending a request to the contact details available in the section “Data subjects’ rights” of this privacy notice.
Recipients of personal data
Your personal data may be made available to:
a) To subjects which shall receive such data on the basis of the regulation in force;
b) to employees and contractors of other Enel Group Companies in compliance with the present privacy notice, or other subjects which carry out outsourcing activities on behalf of Enel Global Trading (ex. management of the website, processing of the data collected through the website, etc.), in their capacity as data Processors.
Data transfers
Your personal data will be processed and stored within the European Union. The same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, recognized by a specific adequacy decision of the European Commission.
Any transfers of Personal Data to non-EU countries, in the absence of a European Commission adequacy decision, will only be possible if data Controllers and data Processors involved provide adequate guarantees of contractual nature, including Binding Corporate Rules and Standard Contractual Clauses.
The transfer of your personal data to third countries outside the European Union, in the absence of an adequacy decision or other appropriate measures as described above, will be made only if you have explicitly consented to it or in the cases provided for by the applicable data protection law and will be processed in your interest. In these cases, we inform you that, although Enel Global Trading adopts operating instructions common to all the countries in which it operates, the transfer of your personal data may be exposed to risks related to the peculiarities of local legislation regarding the processing of personal data.
Data retention period
The personal data processed for the abovementioned purposes will be retained in compliance with the principles of proportionality and necessity and deleted or anonymized after the retention period. For example, the navigation data such as the IP address will be processed for the duration of your navigation session and can be retained for few days in order to ascertain any liability in case of unlawful use of the website. Registration data will be stored until the account will be disactivated or cancelled.
For more information about cookies, you can consult our cookie policy.
In case your consent is required for any processing, the related data will be stored until the fulfilment of the purposes of processing, or until the withdrawal of the consent.
Data subject rights
Pursuant to the data protection law, you have the following rights on your personal data:
a) to request access and a copy of your data
b) to request rectification
c) to request erasure
d) to obtain restriction of processing
e) to object to the processing
f) to receive the personal data in a structured, commonly used, and machine-readable format
Some rights may not apply in relation to the specific processing. In any case, you have the right, at any time, to object to the processing of your personal data for the purpose of pursuing Enel Global Trading’s legitimate interests. In this case, the processing will be stopped, except where Enel Global Trading’s legitimate interests prevail on the interests of the data subject.
To exercise your rights, or withdraw any consent given for the processing of personal data, you can write an e-mail to gtportal.privacy@enel.com specifying in the subject of the request “Enel Global Trading – Data subject’s rights”.
It is your right to submit a complaint to the competent data protection Authority, which in Italy is the Garante per la Protezione dei Dati Personali. For more information you can visit the Authority’s website at the following address: https://www.garanteprivacy.it.