Dear Customer,

We would like to inform you that respecting our customers’ privacy is very important to us, which is why we aim to offer services that consistently meet the highest privacy standards. Officinae Verdi is one of Italy’s leading companies operating in the liberalized natural gas and electricity markets. In parallel with its wholesale market activities, the group supplies gas and electricity to its end customers, ranging from industrial groups to small and medium-sized enterprises and households.

In recent years, Officinae Verdi has launched specific initiatives that have enabled it to expand its offering by developing the energy efficiency sector in an innovative way.

Our Privacy Policy explains what information we collect and how this affects the customer. We also explain the steps we take to protect customer privacy, such as the fact that Officinae Verdi provides users with the ability to manage the data they provide to use our services online.

Identity of the Data Controller

The terms “OV,” “our,” “we,” or “us” refer to Officinae Verdi Srl, with registered office in Via Tirso 14 – 00198 Rome (RM), VAT number 11446471002. The Data Protection Officer can be contacted by sending an email to privacy@ovaerdi.com or by calling the toll-free number 800 688 828.

This Privacy Policy (“Privacy Policy”) also applies to our applications, services, features, software, and website (the ‘Services’). Please read the General Terms and Conditions of Supply (“GTC”), which set out the terms and conditions applicable to our sales service.

Purpose and legal basis of processing: the data acquired may be processed for the execution of pre-contractual measures adopted at the request of the Customer, such as requests for quotes or in order to receive economic offers relating to the products and services sold by the Data Controller, to perform the services deriving from the conclusion of contracts for the supply of natural gas and electricity, proposed by OV (which may also concern energy efficiency products, assistance and maintenance services, services and systems for measuring energy consumption, etc.). Furthermore, within the scope of the purposes described above, the data communicated by Customers may also be processed to manage any administrative activities related to the supply of natural gas or electricity, with the processing of payment data, including identification details, in accordance with current legislation. The data may be processed to fulfill a legal obligation to which the data controller is subject or, if necessary, for the performance of a task carried out in the public interest or for the exercise of public powers.

The performance of contractual services by OV involves the implementation of measures aimed at protecting against credit risk, such as possible operations aimed at identifying the economic reliability/solvency of the Customer, both before and during the contractual relationship. To this end, OV may use the information systems of authorized companies, as well as credit information as provided for by Legislative Decree 124/2017, to acquire information processed, where necessary, solely for the purpose of verifying the reliability and timeliness of payments. Payment of invoices may also be made by direct debit from a bank or post office account. OV may contact the Bank/Poste Italiane by telephone or through the digital channels made available for this purpose to verify that the Bank indicated by the Customer/Poste Italiane does not reject this request.

Please also note that, pursuant to Article 1, paragraphs 154 and 156 of Law No. 208/2015, personal data provided when entering into a contract for the supply of electricity may be used for billing purposes, to charge the RAI license fee or to refund any license fees not due. Specifically, for the purposes described above, the communication of personal data is a necessary requirement for the conclusion and subsequent effectiveness of a contract for the purchase of goods and services provided by the Company. The withdrawal of consent to the processing of personal data may prevent, in whole or in part, the provision of the services provided for in the contract concluded between the parties. 

Legitimate interests pursued by the Data Controller or by third parties: Customers who have given their consent may be contacted for activities aimed at improving the services provided, connected to the contractual relationship (e.g., surveys to assess customer satisfaction), for the performance of activities aimed at processing market studies and research, direct sales activities, including by telephone, or the placement of products/services and the forwarding of commercial information, including interactive information, as well as the sending of advertising/informational material, carried out using “traditional” methods (for example, paper mail and/or operator calls) or through “automated” contact systems. These activities may be carried out by OV as well as by third parties, commercial partners of OV, operating mainly in the sectors of gas and electricity supply and sales and, more generally, in the generation of energy from renewable sources and/or the provision of energy efficiency solutions. OV informs the Customer that the email address provided by the data subject in the context of the existing contractual relationship may be used to send commercial offers relating to products and/or services similar to those previously purchased. The data subject may object to the processing at any time by sending a request to OV. 

OV may use “traditional” systems (for example, paper mail and/or operator calls) or “automated” contact systems to carry out market studies and research or other activities aimed at selling products or services or advertising them by sending advertising communications, including by transferring the data acquired to its commercial partners. Commercial offers may be customized based on the end customer’s consumption profile, obtained in part by examining the use of products and services offered by OV, carried out using systems that measure overall energy consumption and its hourly distribution or consumption related to specific user devices. 

Consequences of refusing to provide personal data: the data subject has the right to decide whether to provide the requested personal data; however, failure to provide such data, or providing partial or inaccurate data, could make it impossible to provide the services requested. Consent to the processing of personal data is necessary for all the above-mentioned processing operations, as well as for the performance of services resulting from the conclusion of a contract between the data subject and OV, or to satisfy specific requests of the data subject prior to the conclusion of the contract. The personal data of the data subject may be disclosed in order to comply with an obligation imposed by law or by any other public, national, or European regulatory act. 

Methods of processing: processing is carried out by means of operations that may involve the use of automated applications and/or processes, including computerised ones, applied to personal data or sets of personal data, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, communication by transmission, dissemination or any other form of making available, comparison or interconnection, restriction, erasure or destruction. However, automated decisions that produce significant legal or similar effects on Data Subjects are excluded. The supervision of processes by natural persons authorized to process data is guaranteed, including for the possible performance of operations requested in order to ensure the exercise of the rights provided for in Articles 16, 17, 18, and 20 of Regulation (EU) 2016/679. 

Recipients: OV will process the personal data of the data subject exclusively in Italy and may disclose it only to third parties, service providers with whom it has a relationship, transferring to them only the information strictly necessary to perform the requested services. The personal data of the data subject may be disclosed to OV’s subsidiaries and/or parent companies, as well as to OV’s qualified Business Partners, for the purpose of carrying out marketing activities or developing further commercial initiatives. Each of OV’s Commercial Partners represents and acts as a separate Data Controller or as a Data Processor and/or Person in Charge appointed by OV. OV employees, collaborators, and consultants may access personal data where specifically authorized by the Data Controller or Data Processor. Finally, the data may be disclosed to the Public Authorities if requested. 

Rights of the Data Subject: OV informs the data subject that it is possible, at any time, to obtain confirmation of the existence or otherwise of the data and to know its content and origin, verify its accuracy or request its integration or updating, or correction, migration to another operator (portability). Furthermore, the data subject has the right to request, even partially, the deletion, transformation into anonymous form, or blocking of data processed in violation of the law, as well as to oppose, in any case, for legitimate reasons, their processing. The unavailability of the data subject’s personal data, whether original or subsequent, could make it impossible for OV to perform the services arising from the conclusion of a contract for the supply of electricity and/or natural gas or the services and/or products requested. In order to exercise the above rights, a request must be sent to the dedicated email address privacy@gaspowernetwork.it. 

Duration of storage: personal data will be stored after the end of the supply until the expiry of the limitation period for all legal actions and all rights arising from the conclusion of a contract between the Parties or from the communication of data through this policy. 

The Data Protection Officer is available at the Data Controller’s headquarters, whom you may contact in order to exercise, within the time limits and in the manner provided for by law, the rights provided for by law and by European Regulation 679/2016. If the data subject has reason to believe that their rights regarding the protection of personal data have been infringed, they may:

• contact the Data Protection Officer, who can be reached at the Data Controller’s headquarters, or by writing to privacy@gaspowernetwork.it;
• lodge a complaint with the Italian Data Protection Authority, Piazza di Monte Citorio n. 121 00186 ROME Fax: (+39) 06.69677.3785 Switchboard: (+39) 06.696771, 
• Email: garante@gpdp.it, protocollo@pec.gpdp.it.

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