INFORMATION ON THE PROCESSING OF PERSONAL DATA (EU REGULATION 2016/697)

The Wi-Fi Internet browsing service for citizens is made by the Municipality of Verona in collaboration with AGSM Lighting Srl (hereinafter also "AGSM Lighting" or the "Companyto").
Your authentication through the'application "Verona SmartAPP" and the consequent transmission of your personal data are necessary for the use of the navigation service and the additional services connected to it.

1. Data Controller and Data Protection Officer The Data Controller is AGSM Lighting Srl with registered office in Verona, Lungadige Galtarossa 8, (hereinafter the "Owner").
The data protection officer can be contacted at the address: dpo@agsm.it
2. Purpose of the processing and legal bases The personal data that can be processed consists mainly of the data you provide to AGSM Lighting directly or indirectly. For example, AGSM Lighting collects your personal data when:
  • request the'authentication through the'application "Verona SmartAPP"
  • use the Services, l'Application and the Website, and when
  • contact AGSM Lighting.

AGSM Lighting collects your personal data for the following purposesto.
2.1 GManagement of account registration requests and management of credentials and browsing access authorization
AGSM Lighting processes your personal data to manage your authentication request through the'application "Verona SmartAPP"

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Legal basis for processing
The processing of personal data is necessary so thatis AGSM Lighting may perform its obligations to you in accordance with the terms of the Services.
Retention period: Personal data are kept for the time required to process the request
2.2 Provision of the service
AGSM Lighting processes your personal data for the purpose of providing the Services.
If you have allowed the'Application to access location services, AGSM Lighting will collectto information on the geographic location of your mobile phone for the same purpose.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Technical data, eg. which device is used el'Unique ID of the mobile phone
Location data, e.g. where you are at any given time based on the position of the mobile phone, the starting position, the chosen destination and l'itinerary
Legal basis for processing
The processing of personal data is necessary so thatis AGSM Lighting may perform its obligations to you in accordance with the terms of the Services.

The Location data processing is based (if not is necessary for the purposes of the Service in question) on the consent given to us by activating the position data in the'Application on your mobile phone. IS It is possible to withdraw consent to AGSM Lighting's collection, use and sharing of such position data by disabling the function "authorizes the'access to location data" on the mobile phone
Retention period: Personal data are kept for the time necessary for the'service delivery.
2.3 Communications
AGSM Lighting processes your personal data in order to communicate with you about the Services provided.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Legal basis for processing
Legitimate interest. The processing of personal data is necessary to meet the'legitimate interest of AGSM Lighting to communicate with you about the Services and to inform you about offers
Retention period: Personal data are kept for the duration of the relationship with the customer and for the following 12 months for the same purposes.to
2.4 Conducting Surveys
AGSM Lighting processes your personal data for the purpose of conducting surveys regarding Verona SmartAPP and the Services, for example by asking for comments and reviews through the Application and by email.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Communications, eg. data concerning your questions and our answers
Legal basis for processing
Legitimate interest. The processing of personal data is necessary to meet the'legitimate interest of AGSM Lighting to communicate with you about the Services and to inform you about offers
Retention period: Personal data are kept for the time required to process the request
2.5 Feedback and evaluation
AGSM Lighting processes your personal data for the purpose of preparing reports and statistics aimed at checking and evaluating the Services.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Technical data, eg. which device is used el'Unique ID of the mobile phone
Legal basis for processing
Legitimate interest. The processing of personal data is necessary to meet the'legitimate interest of AGSM Lighting to communicate with you about the Services and to inform you about offers
Retention period: Personal data are kept for the time necessary to carry out the purpose.
2.6 Management of requests
AGSM Lighting processes your personal data for the purpose of handling your inquiries.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Technical data, eg. which device is used el'Unique ID of the mobile phone
Legal basis for processing
Legitimate interest. The processing of personal data is necessary to meet the'legitimate interest of AGSM Lighting to communicate with you about the Services and to inform you about offers
2.7 Fulfillment of legal obligations
AGSM Lighting processes your personal data in order to comply with the legal obligations that fall on AGSM Lighting.

Personal Data
Identification data, e.g. name,, mobile number,.
Contact details, e.g. address, e-mail, telephone number.
Technical data, eg. which device is used el'Unique ID of the mobile phone
Legal basis for processing
Legitimate interest. The processing of personal data is necessary to meet the'legitimate interest of AGSM Lighting to communicate with you about the Services and to inform you about offers
Retention period: Personal data are kept for the time necessary to carry out the purpose.
3. Your rights
Based on the provisions of the applicable data protection legislation, you are recognized a series of rights relating to the processing of your personal data.
The Data Controller processes your personal data to the extent necessary to protect your rights.
You can exercise your rights by contacting the Data Protection Officer (DPO) at the address: dpo@agsm.it
3.1 Right of access
You have the right to ask us to confirm whether we process personal data concerning you and to request access to the same personal data we process. A copy of your data can be requested through our DPO.
3.2 Right of modification
If you believe that the personal data stored by the Data Controller are incorrect or adequate, you have the right to request modification by AGSM Lighting.
3.3 Right to object to direct marketing
You have the right, at any time, to object to the processing of your personal data for direct marketing purposes by AGSM Lighting and to request removal from any mailing lists for receiving future marketing communications, by contacting customer service.
3.4 Opposition to processing carried out on the basis of our legitimate interest
You have the right to object to the processing carried out on the basis of our legitimate interest for reasons related to your particular situation. Even if you object to the processing, we may continue to process your personal data if there are overriding and legitimate reasons for the processing that override your interest in data confidentiality.
3.5 Right to erasure ("right to be forgotten")
In some circumstances, you have the right to have your personal data deleted, for example if you have objected to the processing and AGSM Lighting does not have overriding and legitimate grounds for the processing that allow it to continue processing the data. This is of no value if, for example, we have to keep data to comply with legal obligations.
3.6 Request for restriction of processing
In certain circumstances, you have the right to request the restriction of the processing of your personal data. If you have made a request for restriction, AGSM Lighting may not be able to fulfill its obligations towards you during the period in which the processing of your personal data is restricted.
3.7 Data portability
Finally, you have the right to receive a copy of the personal data concerning you in a structured form and, if technically possible, to transfer the data to third parties (data portability). Unlike the right of access, the right to data portability only includes data that you have provided yourself and that we process under certain legal bases such as, for example, under the contract with you.
4 Security and modalitiesto of treatment
AGSM Lighting takes the problem of the security of your personal data very seriously.
The Data Controller applies appropriate technical and organizational measures to protect your personal data from unauthorized access, modification or destruction.
Access to information is restricted in various ways (e.g. with the necessary authorization of the user and through the use of mandatory passwords assigned exclusively to employees who must access the data in order to carry out their work duties).

Personal data will be processed and stored on electronic media according to logic strictly related to the aforementioned purposes and, in any case, in such a way as to guarantee the security and confidentiality of the data for the period strictly necessary to achieve the purposes for which they were collected; in any case, the criterion used to determine this period is based on compliance with the terms permitted by applicable laws and the principles of minimization of processing.

The data will be processed by the internal staff of AGSM Lighting as authorized subjects for the processing. Some data processing may also be carried out by companies of the AGSM Group or other companies appointed to perform services in favor of the Company, as Data Processors.
5 Changes to the AGSM Lighting Privacy Policy
The Data Controller may change the Privacy Policy over time.
In the event of changes made to this Privacy Policy that involve changes to the way in which AGSM Lighting processes your personal data, for example due to the collection of additional personal data for the purposes specified above or to the processing of the same data for new purposes, AGSM Lighting will inform you about such changes eg. via the Website, Application or email messages.
AGSM Lighting recommends periodic reading of this Privacy Policy.