DATA CONTROLLER
Octo Telematics S.p.A., with registered office at Via V. Lamaro no. 51 – 00173 Rome (hereinafter, “Octo” or the “Data Controller”), acting as Data Controller, will process your Personal Data in accordance with the applicable personal data protection legislation and this Privacy Notice.
DATA PROTECTION OFFICER (DPO)
The Data Controller has appointed a Data Protection Officer (“DPO”), who can be contacted at the following e-mail address: dpo@octotelematics.com.
SUBJECT MATTER AND METHODS OF PROCESSING
We hereby inform you that, in connection with the management of your call to our Contact Center, the Data Controller may process certain Personal Data concerning you, including: personal and identification data (name and surname, Tax Identification Number), contact data (telephone number, e-mail address), vehicle-related data, data relating to your insurance policy and insurance company, and voice recordings.
For the purposes of this Privacy Notice, processing of Personal Data means any operation or set of operations performed on Personal Data, including by automated means, in accordance with the applicable personal data protection legislation (GDPR). Your Personal Data will be processed using computerized and telematic tools.
Octo Telematics has implemented appropriate technical and organizational measures to ensure a level of security appropriate to the risk, in accordance with Article 32 of the GDPR.
PURPOSES AND LEGAL BASIS OF THE PROCESSING
Your Personal Data will be processed in order to enable the Data Controller to manage support and assistance requests in connection with the telematic services provided, on the basis that such processing is necessary for the performance of a contract to which you are party or in order to take pre-contractual steps at your request.
Personal Data are also processed in order to comply with applicable regulatory requirements and legal obligations to which Octo is subjected.
Further purposes include the recording of calls solely for the purpose of monitoring the quality of the services provided to users by the Contact Center or protecting the Data Controller in the event of disputes or complaints. Such processing is based on the Data Controller’s legitimate interest in protecting its business, ensuring the efficiency of its internal management system and protecting its rights and interests.
With specific reference to the qualitative analysis carried out through call recordings, the Data Controller has adopted measures aimed at minimizing the Personal Data processed, including anonymization procedures and the masking of identification data.
Failure to provide the Personal Data would make it objectively impossible to provide the assistance requested by you.
For processing activities based on legitimate interest, you have the right to object, at any time, to the processing of your Personal Data on grounds relating to your particular situation. Following your objection, Octo will no longer process such Personal Data unless there are compelling legitimate grounds for the processing which override your interests and rights, or the processing is necessary for the establishment, exercise or defense of legal claims.
RECIPIENTS OF PERSONAL DATA
Your Personal Data may be disclosed to:
- service providers whose activities are instrumental to the purposes set out above;
- other companies of the Octo Group for administrative and/or accounting purposes;
- authorities and/or public bodies to which Personal Data must be disclosed pursuant to mandatory provisions of law and/or for the establishment, exercise and/or defense of rights and/or legitimate interests.
TRANSFER OF PERSONAL DATA
Where recipients are located outside the European Economic Area (“EEA”), Octo ensures that the processing of Personal Data is carried out in compliance with applicable law. In particular, transfers will be based on an adequacy decision of the European Commission, on the Standard Contractual Clauses approved by the European Commission, or on another appropriate legal basis, in compliance with EDPB Recommendations 01/2020.
RETENTION PERIOD OF PERSONAL DATA
Personal Data processed for the purposes set out above will be retained in accordance with the principles of proportionality and necessity and, in any event, only for as long as necessary to achieve the purposes of the processing. Your Personal Data will be retained for 10 years. As for what regards specifically the call recordings, those shall be deleted no later than 90 days after the recording, without prejudice to any need for further retention for the purpose of protecting Octo’s rights, or for a shorter period if agreed between the parties.
RIGHTS OF DATA SUBJECTS
Pursuant to Articles 15 to 21 of the GDPR, in relation to the Personal Data provided, you have the right to exercise the following rights:
a) access your Personal Data and request a copy thereof;
b) request rectification;
c) request erasure;
d) obtain restriction of processing or data portability; and
e) object to processing.
In order to exercise your rights, or for any further information concerning your Personal Data, you may contact the Data Controller at the following e-mail address: dpo@octotelematics.com, specifying the subject matter of your request in the subject line.
Please note that, pursuant to applicable law, you may lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), with registered office in Piazza Venezia 11, Rome, e-mail: protocollo@gpdp.it.
