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.

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

Dear User,

In light of the provisions of EU Regulation 2016/679 concerning the protection of natural persons with regard to the processing of personal data (the “Regulation”), we hereby inform you that Acque Bresciane S.r.l. (“Acque Bresciane” or the “Company”), with registered office at 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, registered in the Brescia Business Register, is the Data Controller for the processing carried out in the context of providing the water service, in the sewerage, aqueduct and purification segments that compose it in whole or in part, managed by the Company within the optimal territorial area of Brescia.

The Data Protection Officer (DPO), attorney Guido Paratico, may be contacted via email at dpo@acquebresciane.it for all matters relating to the processing of personal data and the exercise of rights deriving from the Regulation.

Processing will be carried out in accordance with the principles of fairness, lawfulness and transparency. Data will be relevant, complete and not excessive with respect to the purposes for which they are processed and will be collected and recorded solely for the purposes indicated in this notice.

1. What data are processed?

The personal data that will be processed are those that identify you as a User of the water supply service, in the segments that compose it in whole or in part, provided to you.

They may be provided by you on the occasion of:

  • Registration / Access / Use of the channels available on the institutional website, particularly “Online Desk”, “Smart Desk” and the “ABweb” application; completion and submission of modules or forms on the institutional website or through the QR code present on bills;

  • Verbal or written communication using the “Customer Service” channel published on the institutional website;

  • Access to physical service counters at the offices of Acque Bresciane S.r.l.;

  • Correspondence (postal or email/PEC channels) during the pre-contractual phase and at the signing of the supply contract, as well as for the execution of obligations and activities related to the contractual relationship.

Personal data processed may include:

  • identification and personal data (e.g. name, surname, tax code, address, date and place of birth);

  • contact data (e.g. landline and/or mobile telephone numbers, email/PEC address);

  • supply-related data (e.g. type of supply, POD, geographic coordinates of the supply point, consumption);

  • solvency information (e.g. reminders, unpaid amounts, interest calculation, cancellations, repayment plans, credit lines);

  • credit information (credit request/relationship, contract type, credit amount, repayment methods and status of the request);

  • financial data relating to payments (e.g. IBAN), their periodic trend, debt exposure including residual balances, and accounting status of the relationship;

  • data relating to debt collection activities or disputes, credit assignments;

  • image-related data (e.g. photo on identity card, video recordings in case of access to “Smart Desk”);

  • voice recordings (e.g. emergency intervention calls);

  • other data attributable to the categories above (e.g. documentation proving ownership/possession of property; cadastral data);

  • possible data relating to health status for specific requests made by you.

Personal data may also include:

  • public data or data accessible to anyone, within the limits and methods established by EU law, laws or regulations;

  • data relating to the performance of economic activities, in compliance with legislation on business and industrial secrecy;

  • personal data used for credit risk assessment collected from databases and systems aimed at evaluating credit risk.

We may also become aware, through competent authorities, of special categories of data (under Article 9 of the Regulation) or may request such information for access to reduced tariffs and/or contractual conditions provided by law or by service regulations. If such data are not provided, 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 comply with obligations established by law, regulations, EU legislation, or orders of authorities including independent sector authorities (ARERA);

b) to perform pre-contractual activities and conclude the relevant contract, allowing the execution of obligations related to the water supply service, in the sewerage, aqueduct and purification segments that compose it in whole or in part, including obligations connected with organizational, administrative, financial and accounting activities.

With regard to managing the contractual relationship, your data are also processed in order to manage your requests related to the supply covered by the contract (for example: connection requests, quotations for sewer or potable water connections, water meter self-reading, complaints, information requests, transfers of contract, activation requests, takeover requests, corrections, data modifications, online payments, deactivations, delivery and consultation of bills, etc.).

This also includes activities necessary to manage complaints and/or requests for information relating to services and to inform users of possible faults, service disruptions, planned supply interruptions and other events related to the water supply contract.

Your personal data may also be processed to implement your authorization for direct debit payments and to guarantee access to reduced tariffs and/or contractual conditions provided by law or service regulations.

c) to send non-commercial communications regarding the promotion of the Company’s institutional image — such as initiatives, events, projects, awareness campaigns, institutional anniversaries and similar activities — aimed at informing and promoting knowledge of the Company’s activities, its public role and its contribution to the territory.

These communications may take place through any communication channel, although the Company will always use the one it considers most appropriate, without marketing purposes, and users may choose their preferred communication channel.

d) to manage any legal disputes with the Company, including the possibility of debt recovery in case of default.

3. On what legal basis are your data processed?

With reference to purpose (a), the legal basis for processing your personal data is the fulfilment of legal obligations to which the Company is subject. Providing data for this purpose is mandatory.

With reference to purpose (b), your data are processed based on the necessity to conclude and execute the supply contract, as well as to fulfil administrative, accounting and tax obligations arising from it. For creditworthiness verification activities, the legal basis may also be the legitimate interest of the Company to prevent fraud and economic damage.

Providing the data for these purposes is necessary for the stipulation and management of the contract.

With reference to purpose (c), the legal basis is the legitimate interest of the Company to inform users about its institutional activities and initiatives relevant to the community. Providing data for this purpose is optional and users may object at any time.

With reference to purpose (d), the legal basis is the legitimate interest of the Company to protect its rights, including in court proceedings and debt recovery activities.

4. How are your data processed?

Your personal data will be processed both in paper form and through electronic, IT and telematic tools, ensuring appropriate security and confidentiality measures.

Communications may occur through various channels: email, telephone, fax, MMS (Multimedia Messaging Service), SMS (Short Message Service) or other means.

Data will not be subject to decisions based solely on automated processing, including profiling, that produce legal effects or significantly affect the data subject, except where required by law or regulations issued by competent authorities (e.g. ARERA decisions on average annual consumption forecasts).

5. To whom do we disclose your data?

The subjects or categories of subjects who may become aware of the data or to whom the data may be communicated, as independent controllers or authorized processors, include:

  • entities entrusted with activities connected with processing (IT service companies, call centers, contractors for works or services) and companies of the Group within existing corporate contractual relationships;

  • postal services, banks and banking service companies;

  • competent authorities (e.g. ARERA, Brescia Area Office, Revenue Agency), Single Buyer, Energy and Environmental Services Fund, consulting companies, banks and insurance companies, debt collection agencies, law firms, accounting firms and labour consultancy firms.

Your data will not be disclosed to unspecified parties.

6. How long do we keep your data?

Your data will be stored for the time necessary to achieve the purposes for which they are processed or to comply with legal obligations, in particular:

  • contract-related data, complaints and/or reports/information requests: 10 years from termination of the contract or last contractual fulfilment;

  • emergency call recordings: 5 years from January 1 of the year following the recording;

  • solvency index: 5 years.

In case of litigation, retention periods may be extended up to 10 years from the final resolution of the dispute.

7. What are your rights?

Under the Regulation, you have the right to request from the Data Controller:

  • confirmation of whether your personal data are being processed and access to them (right of access);

  • correction of inaccurate personal data or completion of incomplete data (right of rectification);

  • deletion of data in the cases provided by Article 17 of the Regulation (right to erasure);

  • restriction of processing in the cases provided by Article 18 (right to restriction);

  • receipt of the personal data you provided in a structured, commonly used and machine-readable format and transmission to another controller (right to data portability), where applicable.

You also have the right to withdraw consent at any time where given and to object to processing based on legitimate interest.

To exercise your rights, you may send a request:

According to the Regulation, Acque Bresciane will not charge fees for handling such requests unless they are manifestly unfounded or excessive.

The Company may request additional information to verify the identity of the requester.

Without prejudice to any other administrative or judicial remedy, you also have the right to lodge a complaint with a supervisory authority (in Italy: the Italian Data Protection Authority – Garante per la protezione dei dati personali) if you believe that processing violates the Regulation.

Further information is available at:
http://www.garanteprivacy.it

In any case, Acque Bresciane invites users to contact the Company through the channels indicated above before contacting the supervisory authority, so that any disputes may be resolved promptly and amicably.