Informativa Privacy

Samsung Electronics Italia S.p.A. with registered office at via Mike Bongiorno 9 – 20124 Milan (“SEI”), is constantly committed to protecting the online privacy of users of the website (the “Site”) within the scope of the promotional operation “Samsung Crystal UHD TVs and Enel gift a fantastic Soundbar” (the “Operation”). This document (the “Information”) has been drafted to allow you to understand how your personal data will be processed for the Operation. This Information aims to provide you with the necessary information to express, if you deem it appropriate, explicit and informed consent to the processing carried out for the Operation.

In general, any information or personal data you provide to SEI within the scope of the Operation will be processed according to internationally recognized principles of lawfulness, fairness, transparency, purpose limitation and storage, data minimization, accuracy, integrity, and confidentiality.

If you register for the Operation by accessing through your Samsung Account, the processing of your Personal Data will also take place according to the relevant privacy policy. Any communication of Personal Data between SEI and Samsung Electronics Co. Ltd., the data controller for Samsung Accounts, will occur solely and exclusively in execution of your request to participate in the Operation, without prejudice to any further purpose pursued by Samsung Electronics Co. Ltd. and indicated in the relevant policy.

1. Data Controller and Data Protection Officer

SEI, as identified at the beginning of the Information, is the Data Controller for the Personal Data processed within the scope of the Operation.

You can contact the single Data Protection Officer (“DPO”) for all SEI affiliates established in the European Union at the following address:

Samsung Electronics (UK) Limited
Samsung House, 1000 Hillswood Drive, Chertsey, Surrey KT16 OPS

and by writing to: dataprotection.sei@samsung.com

2. Personal Data Subject to Processing

Within the scope of the Operation, we inform you that SEI will process information concerning you, which may consist – if you decide to register for the Operation – of an identifier such as your name, an identification number, an online identifier or one or more elements characteristic of your physical, physiological, psychological, economic, cultural, or social identity suitable for identifying or making you identifiable (hereinafter “Personal Data”).

Your Personal Data may be collected either because you voluntarily provide them (e.g., when you register for the Operation) or simply by analyzing your behavior on the Site.

The Personal Data processed are as follows:

a. Name, contact details, and other Personal Data

On the Site, specifically in the section through which you can participate in the Operation, you will be asked to fill out the appropriate form by entering various information such as, by way of example: name, surname, telephone number, email address, complete physical residence address, serial number of the Promotional Product you purchased, and the purchase date of the Promotional Product.

b. Special categories of personal data

When you fill out the forms to participate in the Operation (the “Forms”), you have the possibility to send SEI image files, such as a photo of the proof of purchase of the Promotional Product, the delivery note, the photo of the label containing the serial number, affixed to the back of the Promotional Product, which allow you to participate in the Operation (the “Submission”). However, you may also (voluntarily or not) provide SEI with some information that may contain Personal Data.

Through the Submission, you may also, more or less voluntarily, provide SEI with some information that could contain Personal Data or special categories of Personal Data, such as data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data intended to uniquely identify a natural person, data relating to health or sexual life or sexual orientation of the person (“Particular Personal Data”).

SEI will not process any information that may contain Particular Personal Data and therefore invites you not to communicate such Particular Personal Data.

c. Third-party data provided by the Data Subject

Through the Submission or the Form, you may send SEI, more or less voluntarily, information that may contain third-party Personal Data.

With respect to these hypotheses, you act as an independent data controller, assuming all legal obligations and responsibilities. In this sense, you provide the broadest indemnity in this regard with respect to any dispute, claim, request for damages from processing, etc., that may be received by SEI from third parties whose Personal Data have been processed through your use of the Site's functions in violation of the applicable data protection regulations.

In any case, if you provide or otherwise process third-party Personal Data when using the Site or for the Operation, you guarantee from now on – assuming all related responsibility – that this particular processing is based on the consent of such third party or on another suitable legal basis that legitimizes the processing of the information in question.

3. Purpose of Processing

SEI will use your Personal Data, collected as part of your registration and participation in the Operation, for the following purposes:

• to allow you to participate in the Operation, manage the activities related to the Operation, and provide you with any further assistance you may need (“Participation in the Operation”);
• to comply with legal obligations that require SEI to collect and/or further process certain types of Personal Data (“Compliance”);
• to protect the rights, property, or safety of SEI, our affiliates, our business partners, employees, or customers, for example, in the context of judicial proceedings, internal investigations, and investigations by competent authorities, as well as to prevent or detect any abuse in participation in the Operation or any fraudulent activity, for example by registering the Personal Data of those who have attempted to commit fraud against SEI within the scope of the Operation to protect SEI from further attempts, including possibly through random checks of participation requirements via video call. Video calls made for this purpose will not be recorded (“Abuse/Fraud”).

4. Legal Basis and Mandatory or Optional Nature of Processing

The legal bases used by SEI to process your Personal Data, according to the purposes indicated in the preceding Paragraph 3, are as follows:

• Participation in the Operation: the processing for this purpose is necessary to allow you to participate in the Operation and, therefore, to follow up on your request and as necessary for the execution of the contract or pre-contractual measures in place with you. Providing your Personal Data to SEI for this purpose is not mandatory, but in its absence, it will not be possible to participate in the Operation.
• Compliance: the processing for this purpose is necessary for SEI to comply with any legal obligations. When you provide Personal Data to SEI, they will be processed in accordance with applicable regulations, which may include their retention and communication to Authorities for accounting, tax, or other obligations.
• Abuse/Fraud: the information collected for this purpose will be used exclusively to prevent and/or detect any fraudulent activities or abuses within the scope of participation in the Operation (with criminal relevance).

5. Recipients of Personal Data

Your Personal Data may be shared with the subjects indicated below (the “Recipients”):

• Subjects who typically act as data processors, such as, for example, individuals, companies, or professional firms that provide assistance and consultancy services to SEI in accounting, administrative, legal, tax, financial, and debt collection matters relating to the management of the Operation, including those delegated to carry out certain activities related to it;
• Subjects with whom it is necessary to interact for the management of SEI's activities (e.g., hosting providers or email sending platform providers);
• Subjects delegated to carry out technical maintenance activities (including maintenance of network equipment and electronic communication networks);
• Individuals authorized by SEI to process Personal Data necessary to carry out activities strictly related to its business, also in relation to the Operation, who have undertaken to maintain confidentiality or have an adequate legal obligation of confidentiality (e.g., SEI employees);
• Samsung Group companies for internal administrative purposes;
• Subjects, entities, or authorities to whom your Personal Data must be communicated for Compliance, Abuse, or Fraud purposes, or by order of the authorities.

6. Transfer of Personal Data

Given SEI's international presence, some of your Personal Data are shared with Recipients who may be located outside the European Economic Area. SEI assures that the processing of your Personal Data by these Recipients complies with applicable regulations. Indeed, transfers are carried out through adequate guarantees, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other considered adequate guarantees. More information is available from SEI by writing to the following address: dataprotection.sei@samsung.com.

7. Retention of Personal Data

Personal Data processed for the purpose of Participation in the Operation will be retained by SEI for the time strictly necessary to pursue the aforementioned purpose. In any case, since such Personal Data are processed to allow you to participate in the Operation, SEI may retain them for a longer period, particularly as necessary to protect SEI's interests from possible liabilities related to the Operation.

Personal Data processed for Compliance purposes will be retained by SEI for the period provided for by specific legal obligations or applicable regulations.

Personal Data processed to prevent Abuse/Fraud will be retained by SEI for the time strictly necessary for the aforementioned purpose and therefore until SEI is required to retain them to protect itself in legal proceedings or to communicate said data to the competent Authorities.

At the end of the retention period, we delete Personal Data in a way that ensures they cannot be reconstructed or read.

8. Rights of the Data Subject

You have the right to ask SEI, at any time:

• For access to your Personal Data (and/or a copy of such Personal Data), as well as further information on the processing operations underway on them;
• For the rectification or updating of your Personal Data processed by SEI, where they are incomplete or not updated;
• For the erasure of your Personal Data from SEI's databases, where you believe the processing is not necessary or is unlawful;
• For the restriction of the processing of your Personal Data by SEI, where you believe that your Personal Data are not correct, are not necessary, or are unlawfully processed, or where you have objected to their processing;
• To exercise your right to data portability, i.e., to obtain in a structured, commonly used, and machine-readable format a copy of the Personal Data provided to SEI concerning you, or to request their transmission to another Controller;
• To object to the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent SEI from processing your Personal Data.

You can exercise your rights by writing to the following address: dataprotection.sei@samsung.com or through our GDPRS portal at the address www.samsung.com/request-desk.

In any case, you always have the right to lodge a complaint with the Supervisory Authority or to bring legal action before the competent Judicial Authority, should you believe that the processing of your Personal Data is contrary to the regulations in force. The contact details of all EU Supervisory Authorities are available here: (http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).