Master Enel

This privacy policy refers to the Master Enel website ("Master Enel"), which is an online platform offered by Politecnico di Milano ("Polimi") in partnership with Enel Green Power S.p.A. and Enel Thermal Generation, Italy.

This page describes how the Master Enel website is managed under the provisions of Article 13 and Article 14 of European Union GDPR - General Data protection Regulation (679/2016/EU) in relation to the processing of the personal data of its users.

This privacy policy provides information to those who interact with the Master Enel service, which can be accessed electronically and pertains to the domain: masterenel-oem.polimi.it/ and its subdomains. This privacy policy is issued solely in relation to the Master Enel website.

Purpose of the personal data processing

Personal data is processed according to all purposes related to design and delivery of Master Enel, that include:

• purposes related to monitoring, analyzing and assessing the use of the service;
• purposes related to teaching and learning.

Data processing procedure

In relation to the stated purposes, the data processing is carried out with digital tools. In any case the protection is ensured by password.

Data Controller: Politecnico di Milano - Directorate General upon authorisation of the pro-tempore Rector dirgen@polimi.it
Piazza Leonardo da Vinci 32 - 20133 Milan Italy
Phone +39 0223992243
PEC: pecateneo@cert.polimi.it

Data Protection Officer: privacy@polimi.it - phone: +39 0223999378

This privacy policy is organized as follows:

1. Information that Master Enel collects from you (including Personal Information)
2. Cookies and tracking technologies on Master Enel website
3. Third Party Cookies
4. How your information is used
5. How your information is shared
6. How to manage your personal information
7. Storage & security
8. Privacy policy updates
9. Contact information

Master Enel directly collects information when you:

• login and participate in the online platform;
• send email messages to technical support (including messages to learner support);
• participate in forums, webinars, and other interactive experiences on the Master Enel site.

Master Enel also indirectly collects usage information about your visit to the Master Enel Site, as explained in the section below titled Cookies and tracking technologies.

Master Enel encourages you to use discretion before voluntarily sharing additional Personal Information on the Master Enel Website (if you later choose to delete your Master Enel account, deletion of your Personal Information will be subject to the process and limits outlined below).

Master Enel uses cookies and other common tracking technologies on the Master Enel website and in email communications to help Master Enel better understand your use and needs of the Master Enel website, and how Master Enel can improve. For example:

• based on your cookie settings, Master Enel tracks information indicating, among other things, which pages of the Master Enel were visited, the order in which they were visited, when they were visited, and which hyperlinks and other user interface controls were used;
• Master Enel may log the IP address, operating system, and browser software (including mobile use and device type when you use Master Enel native mobile apps) you used when accessing the Master Enel website, and Master Enel may be able to determine from an IP address your Internet Service Provider and the geographic location of your point of connectivity;
• Tracking is performed via Google Analytics based upon anonimyzation of IP addresses;
• Master Enel may track and collect information from emails that Master Enel sends to you, for example whether you opened the email or clicked on any links from the email.

Master Enel uses cookies and other tracking technologies for the following purposes:

• when necessary for system administration, security, and integrity to ensure the Master Enel website works properly for you. Without these technologies, the Master Enel website may not function correctly;
• to enable analytics, performance and functionality, to help Master Enel gather information about how visitors use the Master Enel website and monitor Master Enel website performance, and to enhance your experience by recognizing and remembering whether you have visited the Master Enel website before and may have any personal preferences.

You have some options for managing cookies and other tracking technologies. These include modifying your browser settings: you should be able to control how and whether your web browser accepts cookies by adjusting its privacy and security settings. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, and how to disable existing cookies. If you reject Master Enel's cookies, many functions and conveniences of the Master Enel website may not work properly.

This website uses Google Analytics, a web analytics service provided by Google Inc. of 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ("Google"). Google Analytics uses 'cookies', which are text files placed on your computer, to help the web team analyse how Users use the website. The information generated by the cookie about your use of the website will generally be transmitted to and stored by Google on servers in the United States. In case of activation of a IP-anonymisation, Google will reduce your IP address within the member states of the European Union and other member States to the Treaty on the European Economic Area. Only in exceptional cases, the full IP-address will be transmitted to a server of Google in the United States and be reduced there. In assignment of the operator of this website Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf.

Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this website. You may also deactivate Google Analytics by installing a so called browser-input-group-addon, which is provided by Google under the following address: http://tools.google.com/dlpage/gaoptout?hl=en.
Please note that this website extended Google Analytics for the code "gat._anonymezlp();" to ensure an anonymised recording of IP-addresses (IP masking).

More information on Google Inc. and Google Analytics can be found here: http://www.google.com/intl/en/policies/terms/.
This website also use YouTube, another service by Google, to provide you video lectures and YouTube can collect additional cookies. Google's privacy policy can be found here: http://www.google.com/intl/en/privacy/privacy-policy.html.

Your data is processed in accordance with Polimi policies; Master Enel uses information, including Personal Information, to carry out the following purposes:

• create and administer your account;
• provide and teach the online courses;
• improve Master Enel service - this includes enabling you to navigate the online courses and to learn effectively in such online courses;
• communicate with you - this includes answering your course and platform questions;
• track Master Enel website usage against goals and mission - this includes performing analytics to evaluate learners' access to the platform and performance in the online courses and, in some specific cases, to report personal usage information to Enel Green Power S.p.A. and Enel Thermal Generation.

Polimi may also seek your consent for additional uses of information, including Personal Information, and will use it only for the purpose described to you. All use of Personal Information is subject to applicable law.

Polimi may share information, including Personal Information, only as needed to fulfill the relevant purpose(s), with the following third parties:

• staff authorised to process personal data;
• Enel Green Power S.p.A. and Enel Thermal Generation;
• subjects that provide outsourcing services or acting as technicians operating the Master Enel equipment and service programs;
• entities / authorities for issuing public key certificates.

Delete account and Personal Information

To request deletion of your Master Enel account and Personal Information, you should send a request to privacy@polimi.it. Because deletion on the Master Enel system is a permanent action and cannot be reversed, Polimi may ask you to complete a process that aims to confirm your authority to manage the Master Enel account affected by your request.

With respect to your Master Enel account, Polimi will permanently:

• deactivate your Master Enel account,
• remove the active profile,
• retire your username, and
• remove you from Master Enel email lists.

With respect to your Personal Information, Polimi will permanently delete your Master Enel account profile Personal Information from the Master Enel website. By erasing the Personal Information in your Master Enel account profile, the remaining information about your activity on the Master Enel website will no longer be associated with you, except as noted below. These changes will be applied to data stores that are used for operation of the Master Enel website.

Exceptions:

• deletion will not apply to historical activity logs or archives unless and until these logs and data naturally "age-off" the Master Enel system;
• Polimi will archive course data (in a manner and to the extent permitted under applicable law) to enhance the service offered. These archives may be used to produce encrypted research data packages;
• Polimi will retain and use Personal Information as necessary to comply with its legal obligations, enforce its agreements, and as otherwise permitted by applicable law.

Data retention

Polimi will retain your Personal Information for as long as your account is active or as needed to provide you with services. Your Personal Information may be retained for a maximum of 3 years.

Polimi stores information, including Personal Information, on its own servers located at Polimi. Polimi controls its own copy of information collected through the Master Enel website and has an information security program designed to protect information in its possession or control. This is done through a variety of privacy and security policies, processes, and procedures. Polimi uses administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the information that it collects, receives, stores, or transmits. Nonetheless, no method of transmission over the Internet, or method of electronic storage, is 100% secure; and therefore, Polimi cannot guarantee its absolute security. While Polimi works hard to ensure the integrity and security of its network and systems, Polimi cannot guarantee that its security measures will prevent "hackers" or other unauthorized persons from illegally accessing or obtaining information.

If Polimi learns of a security breach involving its copy of your Personal Information, Polimi may attempt to notify you electronically so that you may take appropriate protective steps. By using the Master Enel website or providing Personal Information to Master Enel, you agree that Polimi can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Master Enel website. If a security systems breach occurs, Polimi may post a notice on the Master Enel homepage or elsewhere on the Master Enel website and may send an email to you at the email address associated with your Master Enel account.

This privacy policy will be reviewed and updated from time to time. When changes are made, the privacy policy will be labeled as "Revised (date)," indicating that you should review the new terms, which will be effective immediately upon posting on this page, with an updated effective date. By accessing the Master Enel website after any changes have been made, you accept the modified privacy policy and any changes contained therein. In case you miss the notification referenced above, be sure to return to this page periodically to ensure familiarity with the most current version of this privacy policy.

If you have privacy concerns, have disclosed data you would prefer to keep private, or would like to access the Personal Information that Polimi maintains about you, please contact the Data Protection Officer at privacy@polimi.it or phone +39 0223999378.

If you consider the answer provided to be unsatisfactory, you may lodge, free of charge, a complaint with the Italian Authority for Data Protection - Garante per la protezione dei dati personali (www.garanteprivacy.it)

Effective date: December 20, 2018