WEBSITE Browsing Information
This page describes the methods by which ENAV S.p.A. “ENAV” or (“Company”) handles the processing of personal data ("Personal Data") furnished or collected in connection with the consultation of this website ("Site") by physical or legal persons/visitors and users ("Interested Parties") as well as any additional information required by law, including information on the rights of the Interested Parties and the related activity.
This information is provided in compliance with Italian and European legislation regarding the protection of personal data set forth in Regulation (EU) No. 2016/679 of the European Parliament and of the Council of 27 April 2016 concerning the protection of individuals with regard to the processing of personal data and the free movement of such data ("Regulations") and any other applicable laws, and from time to time, regulating and implementing said Regulations in force ("Privacy") to the afore-mentioned Interested Parties, who interact with the ENAV web services in the Site and therefore do not apply to information collected by ENAV via channels other than this specific Site.
It should be noted that, according to the Regulation, processing means any operation or set of operations performed with or without the aid of automated processes and applied to Personal Data or sets of Personal Data, such as collection, registration, organisation, structuring, storage, adaptation or modification, extraction, consultation, use, communication by transmission, dissemination or any other available form, comparison or interconnection, limitation, deletion or destruction.
1. Identity and contact details
ENAV S.p.A. is the Data Controller of the Personal Data, with a registered office in Rome (Italy), Via Salaria No. 716.
The person in charge of protecting Personal Data is Data Protection Officer Devan De Paolis, who can be contacted at the following number: +39 06/81661 or by e-mail: email@example.com
The Personal Data Protection Manager is the point of contact for the Italian Data Protection Authority in matters relating to the handling of data, regarding the exercise of the rights of the Interested Parties in connection with the processing of their Personal Data.
2. Purpose and legal basis of the processing
ENAV will handle Personal Data of Interested Parties for specific purposes such as:
• providing services connected directly/indirectly to the Interested Parties, such as information services and/or assistance (via recordings and filling in the appropriate forms prepared within the Site);
• access, upon registration, to restricted areas (e.g. on-line services for pilots/reporters/professionals, access to pre-flight information);
• the subscription to newsletter services;
• the analysis of aggregated data regarding the behavior of the Interested Parties, also in connection with the consultation of the Site;
• the management of Personal Data sent by Interested Parties in connection with unsolicited applications or as part of the selection process carried out by means of the " Work With Us" Site attributable to ENAV S.p.A. and/or its subsidiary Techno Sky S.r.l., even after registration, by accessing the dedicated recruiting system;
• preventive measures and gathering information about abuses in fraudulent or harmful activities;
• collecting necessary and automatic data collection regarding Interested Parties dealing with the interaction on the Site (technical cookies).
Pursuant to current Privacy Policies, it should be noted that the reason for allowing the processing of Personal Data of Interested parties may therefore consist, depending on each case, in the need to provide feedback to the requests of the Interested Party (also in connection with purposes of contractual execution or pre-contractual measures), in complying with certain statutory provisions of primary or secondary status and of national or European Community sources regarding risks affecting the Data Controller, or in pursuing the legitimate interest of ENAV S.p.A.
3. The provision of Personal Data and the consequences of refusing to furnish them
The provision of Personal Data may be necessary to allow the pursuit of certain of the above-mentioned purposes, or those that are optional.
In cases where the transfer of Personal Data (in particular full personal data, e-mail addresses and, where required, telephone numbers) is necessary, the refusal to indicate such data makes it impossible to provide the following the requests of the Interested Parties or to furnish available services, or even to properly fulfill the obligations imposed upon the Data Controller pursuant to applicable legislation. There are no penalties for the failure to provide unnecessary Personal Data.
The Interested Parties will be informed of the nature of the required or optional provision of Personal Data, via the appropriate notices and material evidence of the necessary information.
4. Communication and disclosure of Personal Data
The Personal Data to be processed are accessible to processors, related to ENAV personnel and its subsidiaries, as well as to third parties who perform tasks and outsourcing services on behalf of ENAV (third party technical services, hosting provider, communication agencies, etc appointed as External Processing Managers of Personal Data whenever necessary.
The Personal Data may be checked for the purposes of updating, along with other data in the legitimate possession of ENAV, which had been previously provided by the individual and not in connection with consultating the Site.
The Personal Data of the Interested Parties will not be disseminated. In each case, the communication or disclosure of the information requested, is without prejudice, in accordance with the law, by law enforcement agencies, judicial authorities, intelligence and security agencies or other public entities for purposes of the public interest.
5. Transfer of Personal Data Abroad
The management and storage of Personal Data takes place via servers located within the European Union and the European Economic Area. Currently, the servers in question are located in Italy.
In any event, it is understood that whenever deemed necessary, ENAV will have the right to transfer Personal Data to third party countries with respect to the European Union. In this case, in the absence of a suitability decision by the European Commission, ENAV ensures that the transfer of Personal Data to third party countries with respect to the European Union will take place in accordance with applicable laws stipulating, if necessary, agreements that guarantee a level of adequate protection and/or adopting standard contractual clauses provided by the European Commission or only in the presence of another requirement in compliance with applicable Italian and European legislation
6. Personal Data Retention Period
The Personal Data collected in connection with the consultation of the Site, used exclusively for the purposes indicated above, are in principle stored for the strictly necessary time period to achieve the purposes for which they were collected and processed. This includes the duration of the services requested and, even upon termination, for the performance of all legal obligations connected or derived from them.
In the event that the Interested Party has granted explicit consent in relation to some of the services used, the related processing will last until such consent has been revoked.
It is however understood that, once the purpose of the processing as been completed, or in the case of exercising the right to object to such processing or revocation of the consent granted, the holder will still be entitled to continue to store the Personal Data, in whole or in part, for certain purposes, such as to establish or defend a legal claim in court.
7. Data processing methods Personal
In compliance with the provisions of Article 5 of these Regulations, the Personal Data processed is:
• handled in a lawful, correct and transparent manner with respect to the Interested Party;
• collected and recorded for specified, explicit and legitimate purposes and is further handled in a manner compatible with these purposes;
• adequate, relevant and limited to what is necessary for the purposes for which they are processed;
• accurate and updated when necessary;
• handled so as to ensure an adequate level of security;
• stored in a form which permits data identification for a time period not to exceed the achievement of the purposes for which it has been processed.
• Personal Data is processed with automated [and non-automated] electronic storage devices. The electronic storage of Personal Data is carried out on secure servers located in areas with controlled access and equipped with restricted access and specific technical and organizational security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access, as well as to guarantee the confidentiality of the Interested Party to whom the Personal Data refers.
8. Rights of the Interested Parties
The Interested Party's rights are provided for by the Regulations and exist precisely:
1) to obtain confirmation of whether or not the handling of Personal Data concerning him/her and, if so, to gain access to said data and to all the information related to the handling itself;
2) to obtain the modification of inaccurate Personal Data without undue delay and to integrate that, which is incomplete, also by providing an additional declaration;
3) to obtain the deletion of his/her Personal Data without undue delay if:
• the data is no longer necessary with respect to the purposes for which it was collected or processed;
• the data has been processed unlawfully;
• the data must be deleted for compliance with a legal obligation;
• consent has been revoked;
• there is opposition to said processing;
4) to obtain handling limitations of Personal Data under one of the following assumptions:
• the Interested Party contests the accuracy of the Personal Data during the period necessary for ENAV to verify its accuracy;
• its processing is illegal and the Interested Party is opposed to the deletion of his/her Personal Data, requesting instead that its use be limited;
• Personal Data is necessary for determining or exercising the Interested Party’s right to a legal claim in court, even if ENAV no longer requires its storage for processing purposes;
• the Interested Party is opposed to its handling, pending verification regarding the possible prevalence of ENAV’s legitimate reasons, when compared to those of the Interested Party;
5) the portability, and therefore to receive it in a structured format, in common use and readable by an automatic device, Personal Data relating to him/her and to transmit such data to another data controller, unimpeded by ENAV, within the limits set forth by Article 20 of the Regulations;
6) to object, in whole or in part, to the handling; within the limits set forth by Article 21 of the Regulations;
7) to revoke, at any time, his/her consent, provided that the revocation of consent does not affect the lawfulness of the handling based on the consent granted prior to said revocation;
8) to submit a complaint to the Italian Data Protection Authority (for more information please visit their website: www.garanteprivacy.it).
The afore-mentioned rights may be exercised by means of a request sent to the Data Controller or the person in charge of Personal Data Protection referred to in section 1) above, with the following procedures:
By email to the following address: firstname.lastname@example.org
via certified email to the following address email@example.com
via a registered, return-receipt letter sent to the following address: ENAV S.p.A., Via Salaria No. 716 - Rome (Italy)