Privacy Policy

Below is the key information on how we process your personal data.
(ex art. 13 EU Regulation 679/2016)

Who we are

The Data Controller is Brain Computing SpA, VAT number 06706551006
with headquarters in Via Gian Giacomo Porro, 8, 00197 Rome (RM), Italy

Your personal data will be processed by Brain Computing employees and collaborators belonging to the Administrative, Commercial and Technical functions. As part of the aforementioned functions, the sector managers also hold the role of data processing manager.
All Brain Computing employees and other natural persons who, based on the consent expressed by you, have access to your data, operate under the direct authority of the respective data processors, are appointed as persons in charge of processing personal data according to regulatory requirements in force and have received, in this regard, adequate operating instructions.
Any information related to the processing of your personal data can be requested via email to the following address privacy@braincomputing.com

How to contact us
Any information related to the processing of your personal data can be requested:

• via email to the following address: privacy@braincomputing.com;

alternately

• via PEC to the following address: braincomputing@pec.it

• by calling our Customer Service at one of the references listed on the  contact page  of the website  www.braincomputing.com
• via ordinary mail to the following address: Brain Computing SpA, Via Gian Giacomo Porro, 8, 00197 Rome (RM), Italy
  
  

Purpose of the processing

“We collect and process data that is necessary and relevant in relation to the purpose of the processing”
The principle of purpose establishes that the processing of personal data is legitimate in relation, precisely, to the purpose of the processing itself.
The data must be collected for specific, explicit and legitimate purposes, and then processed in ways compatible with this purpose. Establishing the purposes of the processing, and explaining them in communications to the interested party, helps to understand what is really necessary and not to collect superfluous data.

Our principles
We are committed every day to protecting your privacy, which together with security and compliance with personal data protection laws is central to us in our relationship with our customers.

The personal data we may collect about you
The personal data we collect and how we collect it depends on the products and services you purchase or activate, how you use them, and how you have interacted with Brain Computing, even if you are not a customer. In some cases we may receive them from third parties, if you have given consent to share them.
Brain Computing processes your personal data to:

• execute the signed contract and manage your requests
• own legitimate interests, such as fraud prevention, credit risk protection, maintaining security and improving the quality of services.
• fulfill a legal obligation, upon order of a public authority, in compliance with strict internal policies and procedures to verify from time to time the legitimacy of the order received (for example orders received from the judiciary in the context of the provision of mandatory services for prevention and detection of crimes).
• provide services beyond the execution of the contract, for example to send you commercial communications. In this case Brain Computing asks you for express consent which will be optional and which you can revoke at any time, even after the termination of the contractual relationship.
  
  

When we may collect your personal data
We may collect it when:

• purchase or use one of our products or services
• contact us for information or support through our support channels
• you register to purchase a product or activate a specific service
• you subscribe to newsletters or other services, including notification services
• you browse our site or other sites of the Brain Computing group
• you give consent to share your information with other companies, such as our business partners, or suppliers
• your information is publicly available

We use cookies (small text files in your browser) when you browse our site. For further details on them and how to deactivate them, see our Cookies Privacy

Types of data we can process

• Information such as your first name, last name, company name, telephone number and email
• Credentials (username and password), and hints or similar security information, used for authentication and access to the services
• Data deriving from cookies, web beacons and other similar technologies. For further details see our Cookies Privacy
• Browsing history. If you have given your consent via cookies or other channels. For further details see our Cookies Privacy
  
  

How we use your personal data
We may use and analyze your data for the following purposes:
– Provision of the service

Management of orders and supply of products and services

• Management of orders relating to the products and services you have purchased and update on the status of the order
• Provision of the product or service you have requested. It may include other services that use, for example, information about your location or that provide messages regarding changes to products or services
  
  

Billing/payments and customer support

• Managing payments and billing for the use of our products or services
• Answer any questions or reports about our network or products and services
  
  

Service messages
We may send you communications relating to our products and services that you have purchased or activated (for example for changes to contractual conditions, service interruptions or exceptional and emergency cases, such as in the event of natural disasters or other extraordinary events and situations, even in derogation of current legislation on the protection of personal data).

– Improvement of the service

Improve and innovate our products and services
We collect anonymous and aggregate information to improve our products and services. None of these analyzes allow us to trace the customer individually nor are they carried out to contact customers for commercial purposes.

– Marketing and personalization of services

Marketing and commercial profiling
The processing of your personal data can only take place in the presence of specific and express optional consents that Brain Computing may expressly request from you, such as, for example, commercial consent, profiling and localization.

If you agree to give us these consents you can:

• always keep you informed about new products and services by sending commercial or direct sales communications, including through automated methods, such as by telephone, SMS, MMS, fax, ordinary and electronic mail, videos, wap/web banners, internet messaging or push notifications via app. You can always revoke this consent and choose not to receive our marketing messages through one of the specific revocation and/or opposition methods that will be represented in the relevant communications. The communications may also concern products and  services of Brain Computing  and commercial partners with which Brain Computing has entered into commercial agreements and market research and surveys
• also receive information on products and services of other companies that we believe may be of interest to you, provided that you have given specific consent to this effect and have not revoked it
• receive personalized offers based on how you use our products and services including, for example, information about calls and messages, location, etc.

Your consents and privacy settings can always be changed. To find out all the details on how to do this, go to the Revocation of consent, modification of privacy settings and right to object section.

We remind you that, in the event of revocation, the same will be implemented immediately but definitively operational within a maximum of 15 days from receipt, the technical time necessary for the alignment of all the information systems we use.

Non-commercial profiling
We may carry out non-commercial profiling for the purposes indicated below and may also be based on automated decision-making and data analysis processes which may prevent the signing of the contract or the activation of the services, as provided for in the general contract conditions.

How we share your personal data
We can share information about you, within the limits of the processing consents expressly granted by you and in general for the execution of the contract, with:

• partners or agents appointed for the sale and delivery of the products and services you have purchased or activated
• companies belonging to the Brain Computing distribution network, direct and indirect
• companies appointed to provide a service for Brain Computing
• companies that provide services for credit risk management and fraud control (such as data processing centers, banks, risk centers, debt collection companies, factoring companies and law firms)
• law enforcement agencies, government bodies, regulatory bodies, courts or other public authorities authorized by law
• a third party or body to which such disclosure is required to satisfy any applicable law or other legal or regulatory requirement
• emergency services (in the event of an emergency call – so-called NUE112), including the place of certification of the services
• commercial partners, in the event of the launch of joint promotions/offers, who are in any case responsible for compliance with applicable privacy laws
• companies that carry out acquisition, processing and processing services on behalf of Brain Computing of the data necessary for the use of the services
• companies that provide Brain Computing with services for the management of its information system
• firms and companies in the field of assistance and consultancy relationships
• companies that carry out market research aimed at detecting the degree of customer satisfaction
• companies that carry out control, audit and certification obligations of Brain Computing activities also in the interest of their customers and users
• banking institutions and credit card issuing companies
• other telecommunications operators, for the management of interconnection and roaming relationships

These subjects operate as Data Controllers or Data Processors who are appointed from time to time by Brain Computing.

Mergers and Acquisitions
In the event of mergers and acquisitions your data may be transferred to the merged company or the acquirer of our organization. You will still receive information.

Third parties we work with
If you have purchased products or activated Brain Computing services using a third party or a Brain Computing partner, it may be necessary to exchange information with these parties, for example to identify your order and be able to pay for the service directly to this third part.
If we have a contract with a third party provider who offers services on our behalf and who may have access to your data, that party may only process it to provide you with the requested services. These suppliers are appointed as Personal Data Processors and have signed a specific agreement on the matter with Brain Computing.

Transfer of your data abroad
The data processing takes place within the territory of the Italian Republic; however, in the event that any communication of data must necessarily be addressed to natural and/or legal persons located in a foreign country, the data may be transferred abroad, within the terms and limits set out in the articles. 45 and 46 of EU Regulation no. 2016/679 (GDPR).

How long do we keep your data
We keep your data for the necessary time required by law. If there are no legal requirements, we will do so in a manner consistent with the purposes of their collection and the consents you have given us.
We are required by law (for the legal limitation of rights and for the management of any disputes) to keep your data for 10 years from the termination of your contract. During this period, we may contact you to offer you Brain Computing services, unless you have revoked your consent to receive our marketing communications.
Traffic data may be stored for the purposes of investigating and suppressing crimes for a period of time established from time to time by specific laws that protect national security.
The following table indicates the retention terms in relation to the main treatments carried out by Brain Computing.

How we protect your data
We have specialized security teams who constantly review and improve measures to protect your personal data from unauthorized access, accidental disclosure or destruction.
Internet communications (such as email) are not secure unless they have been encrypted. Your communications may pass through a number of countries before being delivered, due to the nature of the internet.
Brain Computing takes no responsibility for any unauthorized access to or disclosure of personal data beyond its control. In this you are responsible for protecting your personal information and your account and not sharing it.
Our site may provide links to third-party sites. We cannot be responsible for the security and content of such sites. Therefore, make sure you read their privacy and cookie policies before browsing or entering personal information.
The same applies to any third-party sites or content connected to the use of our products and services.
Access through social media and use of the latter are subject to the terms and conditions and privacy policies.

Your rights
You can exercise at any time the rights guaranteed by law and listed below:

• via email to the following address:  privacy@braincomputing.com ;

or alternatively

• via ordinary mail to the following address: Brain Computing SpA, Via Gian Giacomo Porro, 8, 00197 Rome (RM), Italy

For further details you can also contact our Customer Service at the references listed on the Contact page of the website  www.braincomputing.com

· Right of access to your personal data
You can request a copy of your personal data in our possession through the channels indicated above or by writing via PEC to  braincomputing@pec.it

· Right to correct or update your data
To change your data you can contact us as indicated above.

· Right to data portability
You have the right to the portability of your personal data starting from 25 May 2018.
Data portability means the right to view your personal data provided to Brain Computing (such as personal or payment data, data relating to the offer) for purposes related to the management of the contract.
You can send the request using the methods indicated above or by writing via PEC to  braincomputing@pec.it .
The data will be available within a maximum of 30 days from the request.
If you are a corporate customer, since the Regulation is aimed only at natural persons, you can request the portability of your data only in the case of individual businesses and freelancers, solely through your company contact person.

· Right to delete data
We keep your data only for the time necessary to provide you with the service or for legal obligations. If you believe we are keeping it for longer than necessary, please first check that your contract with Brain Computing has ended.
If you have no longer been a customer for at least 6 months and do not have any active billing items and/or credit situations, frauds, complaints opened with Brain Computing, you can also request the manual deletion of your data, so as to no longer make them visible in the Brain Computing computer systems.
However, even in this case, we will not be able to permanently delete all your data for reasons of public safety.
You can send the request using the methods indicated above or by writing via PEC to  braincomputing@pec.it .
The data will be deleted within a maximum of 30 days from the request.

Withdrawal of consent, modification of privacy settings and right to object
You can always withdraw your consent and modify your privacy settings. In some circumstances you can object to our processing of some personal data.
To modify the commercial consent, even after the conclusion of the contractual relationship, you can:

• call our Customer Service at one of the references listed on the Contact page of the website  www.braincomputing.com
• email  privacy@braincomputing.com 
• write to Brain Computing SpA, Via Gian Giacomo Porro, 8, 00197 Rome (RM), Italy
• click on the “reject” link that you find in the newsletters we send you and/or in the additional specific web forms on the website  www.braincomputing.com

In the absence of express revocation, we will use your consent even after the termination of the service/contractual relationship.

In some cases we may send you marketing communications even if you are not a customer. This is because Brain Computing could purchase lists of potential customers who have given third parties consent to be contacted, unless their numbers are registered in the Opposition Registry ( http://www.registrodelleopposizioni.it ) 

To find out what cookies are and manage them.
To know all the details about cookies and find out how to disable them, consult our Cookies Privacy page.

To contact us and to make a report

• call our Customer Service at one of the references listed on the Contact page of the website  www.braincomputing.com
• email  privacy@braincomputing.com
• write to Brain Computing SpA, Via Gian Giacomo Porro, 8, 00197 Rome (RM), Italy

To lodge a complaint with the Privacy Guarantor,
you can contact the Guarantor using the methods found  here .
Any updates will be immediately available in this section of the site.