How can I use the contacts in Atoka?
The activities of commercial contact via e-mail may be carried out by requesting the prior consent of the possible recipient (legal or physical person), to which the e-mail box refers, in compliance with the opt-in regime in force in Italy.
Data related to email addresses provided by Atoka, as a rule, are data coming from public sources and not acquired from the subjects concerned with their prior consent. Consequently, following a Permission Marketing approach, they can be used for commercial contact campaigns in cases where:
- they are your customers and your company has already provided the recipients with appropriate information and acquired the prior consent to send commercial communications via email;
- they are potential customers (s.c. prospects) and your company intends to send a first communication to give the information on the processing of personal data: in this case to request consent to send promotional communications you must take care that this first message is not commercial or advertising.
It is recommended that you always give the contacted user the opportunity to request deletion from your list, i.e. to object to your company sending further commercial email communications.
The telephone numbers in Atoka are to be considered data from public directories, which can be used after verifying that these numbers are not registered in the Public Opposition Register (available at www.registrodelleopposizioni.it).
These checks can be carried out if you are registered as an Operator with the Opposition Register. If you are not, you can register by accessing the site of the Opposition Register: http://www.registrodelleopposizioni.it/it/operatori/home-operatori. Once registered, you can check the list of telephone numbers you intend to contact electronically. After entering your list of numbers, the system will combine it with the numbers entered in the Register. At the end you will get a “clean” list that can be considered updated and therefore usable for telephone contacts.
The list will be considered updated for 15 days from the verification, after which a new verification will have to be carried out (to check that no other numbers have been registered in the meantime).
If the telephone numbers concern subjects who have already opposed the reception of commercial contacts by your company, these numbers cannot be used for these purposes, regardless of whether or not they are present in the Opposition Register.
The current legislation provides that the call must be made with an unencrypted number, providing the called party with a brief informative report, also oral, in which it must be indicated where to find an informative report including all the elements foreseen by the GDPR and giving specific information regarding the possibility of registering the number with the Opposition Register.
In accordance with the provisions of Presidential Decree no. 178, published in Gazetta Ufficiale no. 256 of November 2, 2010, and the provisions of Law no. 5 of January 11, 201, Telemarketers wishing to contact subscribers included in public telephone directories for commercial or promotional purposes, or to carry out market research using the telephone, are required to register with the system managed by Fondazione Ugo Bordoni – the service provider – and to communicate the list of numbers they intend to contact. By comparing the information contained in the Registry of Objections with the list of numbers provided by the Operator, the Manager will delete from the latter all the numbers of Subscribers who have requested not to be contacted.