Privacy Policy – Websites

(last revision 05.06.2020)

Sky Italia Srl ("Sky"), as Data Controller, informs you under the applicable national legislation and the European Privacy Regulation no. 679/2016 ("GDPR") that your data will be processed as follows.
Your Privacy is very important to us and we want you to always feel protected. For this reason, we invite you to read the following information carefully.
By using our services, you transmit or share the information that enables us in some cases to provide a service, in other cases to meet your needs and improve our service. In this document we would like to explain to you the following concepts:

1. who is Data Controller of your data and who is Data Protection Officer?
2. what data do we use?
3. why and on what legal basis do we collect your data?
4. how is your data used?
5. which data are mandatory, and which are optional?
6. how long are your data kept?
7. who can have access to your data?
8. who can your data be disclosed to?
9. can your data be transferred?
10. what are your rights?

1. Who is the Data Controller of your data and who is the Data Protection Officer?
The Data Controller of your personal data is Sky Italia Srl based in via Monte Penice 7, 20138 Milan.
The Data Controller appointed a Data Protection Officer (DPO), who can be contacted via dpo@sky.it.
The list of our data processors, system administrators, and measures adopted as well as the non-European countries where the data may be transferred is available at the offices of Sky Italia and the DPO.

2. What data do we use?
In Sky we use a range of personal data (hereinafter referred to as "personal data" or "data"), namely:
- browsing data such as IP addresses - internet protocol (IP) address; type of browser used, parameters of the device used to connect to the web site, internet service provider (ISP), date and time of your visit, referring page (referral), and links you click on. These data are collected using cookies and metadata described in the Cookie Policy of the Sky websites, please see below for more information (hereinafter referred to as "usage data").

3. Why and on what legal basis do we collect your data?
The data you provide, on the one hand, let us carry out all administrative activities relating to the registration and use of Sky websites, on the other hand, they help us track statistics to optimize and improve your browsing experience without having to identify the user. In particular:

3.1. Why and on what basis do we process the identification data?

Usage data are processed without your prior consent for the service purposes and the following purposes and on this legal basis:

• contract or pre-contract commitments:
– to let you use Sky's websites;
– to manage and maintain our websites;

• legitimate interest of the Data Controller:
– to manage complaints and disputes, to claim debts, to prevent fraud and illegal activities, as well as to exercise the rights and protect the legitimate interests of the Data Controller, i.e. of Sky or third parties, for example, the right to defense in court, a constitutionally guaranteed right of action (Article 24 of the Constitution) and, as such, is socially recognized as prevailing over the interests of a concerned individual;

• fulfillment of legal obligations:
– to respect and fulfill the obligations, regulations, community regulations, orders, and prescriptions of competent authorities.

3.2. Why and on what basis do we process the usage data?

Usage data are processed with your prior consent and are used to optimize and improve your browsing experience, namely:
• to track statistics using third-party analytical cookies described in the Cookie Policy of the Sky Media website, please see below for more information to optimize and improve our web site browsability.

4. How are your data used?
Personal data are used for collection, registration, organization, storage, review, analysis, matching, processing, modification, selection, extraction, comparison of databases, use, interconnection, crossing, blocking, communication, cancellation, and destruction of data. Your personal data are subject to electronic and automated processing and are stored in a database.
Personal data are protected to minimize the risk of destruction, loss (including accidental loss), unauthorized access/usage, or usage for any unauthorized purposes. This is achieved through technical and organizational security measures implemented by Sky.

5. Which data are mandatory, and which are optional?
Among the data we collect, some are essential for browsing our website, while other data help us provide a better service, day after day. In particular:

• the provision of usage data for service purposes, is required to use the services of Sky Media website;
• the provision of usage data for optimization and improvement of browsability is optional. Failure to provide them does not prevent you from using the Sky website, however Sky will not be able to carry out statistical analyzes aimed at optimization and improvement of browsability.

6. How long are your data kept?
Sky retains the usage data for service purposes for up to 30 days starting from the end of the browsing session.
Sky retains the optimization usage data for up to 14 months.

7. Who can have access to your data?
We care about your privacy and do everything to protect you. Therefore, we share your data only when strictly necessary and only with those who help us offer you a better service every day. Your data is accessible to:
• employees and/or collaborators of Sky or of the Sky Group companies, who contributes to create, maintain, and improve all Sky services, acting as authorized person in charge and/or internal manager of data processing and / or system administrators;
• Sky Group companies and service providers that carry out outsourced activities on behalf of Sky, acting in their capacity as external data processors and carrying out activities connected with, instrumental or supportive to those of Sky, for example, management and maintenance of the contents of websites and Sky Apps, customer support, management of Information Technology systems, editorial services, etc.

8. Who can your data be disclosed to?
Sky can communicate your data without your express consent for service purposes:
• to the judicial authorities, upon their request;
• to the companies of the Sky Group and to all other subjects that are required to process your data by law or by contract for the purposes as described above (such as, for example, credit institutions, professional firms).
Sky can communicate your data with your prior consent to the analytical cookie providers, as better described in the cookie policy described below. These subjects will process your data as independent data controllers. Anyways, we want to reassure you that your data will not be revealed.

9. Can your data be transferred?
Your data may be transferred outside the European Union to the subjects specified in paragraphs 7 and 8 (including, subjects based in the USA). To protect your data during these transfers Sky will adopt appropriate safety measures, including adequacy evaluation and standard contractual clauses approved by the European Commission.

10. What are your rights?
So far we have talked about how we process your data and how we behave; now let us show you what your rights are, to always have control over your privacy and information. Unless there are limitations established by law you have the right to:

• have a confirmation regarding whether or not your personal data has been collected, even if not yet registered, and to request that such data be made available to you clearly and understandably;
• request information and, if necessary, a copy of:
a) the origin and category of your personal data;
b) the usage criteria if your data is processed electronically;
c) the purposes and methods of the processing; d) the identity of the Controller and the Processors;
e) the subjects or categories of subjects to whom your personal data may be disclosed or who can become aware of them;
f) the period of storage or the criteria that are used to determine this period, when possible;
g) the existence of an automated decision-making process, including the profiling process. In this case, you can request the criteria used, the significance, and the consequences that may impact to you;
h) the existence of adequate guarantees in case of transfer of your data to a non-EU country or an international organization;
• obtain, without a justifiable delay update, modify, correct your incorrect data or complete your incomplete data, if you wish to do so;
• cancel, block your data or, where possible, anonymize it:
a) if unlawfully processed;
b) if no longer necessary for the purposes they were initially collected or subsequently processed for;
c) in the event of revocation of the processing consent and should there be no other legal basis;
d) if you oppose the processing and there are no further legitimate reasons to continue using your data;
e) if required by law;
f) if they belong to minors.
The Data Controller, i.e. Sky, may refuse to delete your data only if:
a) it exercises the right to freedom of expression and information;
b) it fulfills a legal obligation, performs a commitment in the public interest, or exercises public authority;
c) it is a matter of public health;
d) it keeps records in the public interest, for scientific or historical research or statistical purposes;
e) needs the data to assess, exercise, or defend its right in court;
• obtain the restriction of the processing in the event of:
a) a dispute regarding the accuracy of your personal data;
b) unlawful processing by the Data Controller, i.e. Sky aimed to prevent data cancellation;
c) exercise of your right in court;
d) verification of potential prevalence of the Data Controller’s legitimate reasons over those of the data subject; • receive, if the processing is carried out electronically, without obstacles and in a structured commonly used and legible format, your personal data obtained with prior consent or based on contract, authorizing their transfer to another Data Controller or - if technically feasible - to directly transfer them the Data Controller to another Data Controller;
• oppose at any time in whole or in part:
a) for legitimate and prevailing reasons connected to your particular situation the processing of your personal data;
b) the processing of your personal data for marketing and / or profiling purposes, if applicable (e.g. you can oppose advertising or direct sales material, market research or commercial communications using automated call systems, emails and traditional marketing tools, telephone and postal service);
c) not to be subject to a decision based solely on automated processing, including profiling, which has legal effects on you or which similarly affects you. This does not apply when the decision:
d) is required to sign a contract between you and the Controller, i.e. Sky;
e) is a result of a legal obligation of the Data Controller which specifies appropriate measures to protect your rights, freedoms, and legitimate interests;
f) is based on your explicit consent.

In all these cases mentioned above, if necessary, Sky will inform the third parties, to whom your personal data are communicated, that you may exercise your rights, except for specific cases (e.g. when this is impossible or involves disproportionate measures compared to the protected right).

You can exercise your rights at any time in different ways: by sending a request to Sky Italia srl - Legal Affairs Department - Data Protection Officer, Via Monte Penice 7, 20138 Milan, or by sending an email to the following address privacy@sky.it.

Finally, concerning this document, you have the right to lodge a complaint with the Guarantor for the Protection of Personal Data (www.garanteprivacy.it).
This information may be subject to changes. For any updates visit our websites and other channels made available by Sky.