Privacy policy
Data Controller
Enel S.p.A. with headquarters in Viale Regina Margherita 137, 00198 Rome, VAT 00934961003 (hereinafter, "Enel" or the "Data Controller"), is the Data Controller of the personal data you provide by surfing through openinnovability.com website (“Wesbsite”) and by creating an account on the Open Innovability® platform.
This Privacy Policy is provided exclusively for the activities carried out through the Website, and for the registration to the Open Innovability® platform; not for other sites accessible via links available from openinnovability.com. We invite you to check the Privacy Policy of the sites you visit.
Data Protection Officer (DPO)
The Data Controller has appointed a DPO you may contact at the following e-mail address dpoenel@enel.com
Scope and tools of processing
The type of Personal Data we process from you depends on how you use our Website. Generally, when using our Website, we may process Personal Data collected in two ways:
(i) Personal Data you provide to us, or
(ii) Personal Data collected automatically.
Process Personal Data, means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Please note that your Personal Data will be processed manually and / or with the support of automated means. We use physical, procedural, technical and administrative security measures to protect your Personal Data against loss or theft as well as unauthorized access and disclosure to protect your privacy.
Purpose and legal basis of the processing
Enel will process the Personal Data you have uploaded or shared with us exclusively for purposes related to the services provided via Open Innovability’s Website and platform.
- We process any Personal Data you enter on our Website or give us in any other way. We will collect information that can identify you, such as your name, surname, address, telephone number, e-mail address, professional experience, field of expertise, educational background and curriculum vitae, and other similar information when it is voluntarily submitted to us when you:register as a User and submit to receive information about Challenges and related initiatives;
- update your profile information;
- request information from us.
We will use your information to respond to requests, to communicate with you about Challenges, to communicate with you about Open Innovability® services, which might be of interest to you, and from time to time, we may refer to your information to better understand your needs and how we can improve our websites and services.
To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from OpenInnovability.enel.com, if your device supports such capabilities.
When you accesses the Open Innovability® and submits a solution, ENEL S.p.A and other ENEL Group companies that consider the solution interesting or needs more investigation, become the independent Data Controller of the processing.
We receive and store certain types of automatic information whenever you interact with us. For example, like many websites, we use "cookies," and we obtain certain types of information when your web browser accesses openInnovability.enel.com or advertisements and other content served by or on behalf of openInnovability.enel.com on other websites. To have more information on how we process your Personal Data through cookies, please check our cookie policy .
We only collect the minimum amount of Personal Data about you that we consider necessary for achieving the aforementioned purposes.
The processing of your personal data is necessary for the stipulation and management of the contract, for the provision of the Services indicated in the general contractual conditions and for all the operations of interest to the user; different processing activities may be based on your consent or on Enel legitimate interest.
Recipients of Personal Data
We may share your Personal Data, for the aforementioned purposes: a) With our affiliates, subsidiaries, and branch offices’ employees and collaborators. ENEL Group companies mentioned above, are listed here below: ENEL S.p.A.; ENEL Green Power S.p.A.; ENEL Sole S.r.l.; EDESUR S.A.; ENEL Trading Argentina; Endesa Energia SAU; PJSC ENEL Russia; EMGESA; CODENSA; ENEL Produzione SpA; ENEL Energia SpA; ENEL DISTRIBUCIÓN PERÚ S.A.A.; Endesa Distribuzione; ENEL Foundation; ENEL Brasil S.A.; ENEL Energie S.A.; ENEL Enegie Muntenia S.A.; ENEL Distribucion Chile S.A.; 3SUN s.r.l; ENEL Italia S.r.l.; ENEL X S.r.l.; Enel Innovation hubs.
b) To third party companies who carry out outsourcing activities on our behalf, expressly appointed as Data Processor. This third parties usually provide services to help with our business activities such as providing email distribution services, customer service, or technical support. These companies are authorized to use your Personal Data only as necessary to provide these services to us. InnoCentive is one of the Data Processor who carries out processing activities on our behalf, such as: answering your questions, communicating with you about the use of our Challenges and services, responding to your inquiries, troubleshooting problems, working with our third-party providers to process your orders and for other customer service purposes and paying the challenge’s award in case a solver wins the Challenge.
c) We may share your Personal Data to allow you to participate to Challenge made available on other crowdsourcing platforms, as, for example, InnoCentive.
d) Moreover, only in case of victory, we may share your Personal Data with companies which have a partnership with Enel and are interested in the solution of the challenge.
e) Enel S.p.A. cooperates with law enforcement inquiries, as well as other third parties to enforce laws and intellectual property rights. Therefore, in response to a verified request by law enforcement, an applicable regulator, or other government officials relating to a criminal investigation or alleged illegal activity, we can disclose your name, city, state, telephone number, and email address. Without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Data to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure. Except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss; report suspected illegal activity; or in response to a regulator’s request for information regarding compliance with applicable law.
Storage and Transfer of your Personal Data
Your Personal Data will be processed within the European Union and stored on servers located within the European Union. The same data may be processed in countries outside the European Union, provided that an adequate level of protection is guaranteed, recognized by a specific adequacy decision of the European Commission.
Any transfers of Personal Data to non-EU countries, in the absence of a European Commission adequacy decision, will only be possible if Data Controllers and Data Processors involved provide adequate guarantees of contractual nature, including Binding Corporate Rules and Standard Contractual Clauses.
The transfer of your Personal Data to third countries outside the European Union, in the absence of an adequacy decision or other appropriate measures as described above, will be made only if you have explicitly consented to it or in the cases provided for by the GDPR and will be processed in your interest. In these cases, we inform you that, although the Enel Group adopts operating instructions common to all the countries in which it operates, the transfer of your Personal Data may be exposed to risks related to the peculiarities of local legislation regarding the processing of Personal Data.
We may retain your Personal Data for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances, we may be required by law to retain your Personal Data, or may need to retain your Personal Data in order to continue providing a service.
Generally, we will retain your Personal Data as long as you do not withdraw your consent by deleting your account.
Rights of the Data Subjects
Pursuant to articles 15 - 21 of the General Data Protection Regulation, as regards the Personal Data you have the right to:
a) access and request a copy;
b) right to rectification;
c) right to erasure;
d) right to restriction of processing;
e) right to object;
f) right to data portability;
To exercise your rights, you can write an email to OpenInnovability-support@enel.com.
Please note that it is your right to send a complaint to the Italian Data Protection Authority, Piazza di Monte Citorio, 121, 00186 Rome RM Phone: 06 696771 urp@gpdp.it, or to the Data Protection Authority of your country of residence within the European Union.
Changes to this Privacy Policy
Please note that this Privacy Policy may change from time to time. We will not retroactively reduce your rights under this Privacy Policy without your explicit consent, and we expect most such changes will be minor. For future changes, we will notify you of any material changes in the way we collect, use, or share your Personal Data by sending you an email at the last email address that you provided us, or by prominently posting notice of the changes on the Website. We will also post the new Privacy Policy to the Website, which you are advised to consult regularly for any changes.
