Privacy Notice for MS Teams Meeting Recordings and Microsoft 365 Copilot Usage

Deltatre S.p.A. (hereinafter also the “Company” or “Deltatre”), P. IVA 09489350018, with its registered office in Italy, Turin, via F. Millio, 41, as the Data Controller, informs you that MS Teams meetings may be recorded, and Microsoft 365 Copilot may be used for transcription, summarization, and note-taking of the meetings. This includes the recording of images and voices of the participants and the processing of such data by Microsoft 365 Copilot.

1. Personal Data Collected and Processed

Your image and voice.

2. Purpose of the Processing

The recordings and subsequent processing by Microsoft 365 Copilot are intended for internal business use, including but not limited to minute taking, training, quality assurance, and creating meeting summaries and action items.

3. Legal Basis

Deltatre S.p.A.'s legitimate interest in conducting its business effectively and efficiently, keeping track of what discussed/shared during the meeting for internal use.
Additionally, your explicit consent is required for the recording of your image and voice, and the use of Microsoft 365 Copilot during the meeting.

4. Opt-Out Option

If you wish to join the meeting without having your voice and/or image recorded or processed, you may:

  • Join the meeting with your camera turned off and microphone muted.
  • Use the chat feature to communicate without being audibly recorded or processed by Microsoft 365 Copilot.
  • Contact the meeting organizer to discuss alternative arrangements or express your preference to opt out of the recording and processing.

5. International Transfer

As a globally active company, Deltatre may have to transfer the Data to countries that do not belong to the European Union (EU) or the European Economic Area (EEA) (hereinafter the "Third Countries") in which the Company or other companies of the Group have their headquarters or operate.

In this case, the Company will provide appropriate safeguards for such cross-border transfers, in accordance with the provisions of the law; these include the use of standard contractual clauses approved by the European Commission. These clauses impose similar obligations in the protection of Data directly for the recipient unless we are allowed by the applicable Data protection law to
transfer Data without such formalities. Some third countries, such as Canada and Switzerland, have been authorized by the European Commission as they provide protection similar to that of EEA Data protection legislation and therefore no additional legal protections are required.

Copy of this documentation and of the list of the countries where the Company may transfer the Data can be requested by contacting privacy@deltatre.com

6. Data Retention

The recordings and any processed data will be retained for as long as necessary to fulfill the purpose for which they were collected and in accordance with Deltatre S.p.A.'s data retention policy.

7. Data Subjects' Rights

You have the right to access, to request the correction, the deletion, the restriction of the processing, or to request the transfer of your personal data.

Also, you have the right to object to the processing on the ground of your particular situation, contacting privacy@deltatre.com

Consent. By joining the MS Teams meeting, you acknowledge and provide your explicit consent to
the recording of your image and voice, as well as the processing of the meeting data by Microsoft 365
Copilot. If you do not wish to be recorded or have your data processed by Microsoft 365 Copilot,
please follow the opt-out procedures outlined in the paragraph num. 4“Opt-Out Option”.

Also, you can revoke your consent, at any time, by contacting privacy@deltatre.com The withdrawal of your consent will not affect the lawfulness of xthe processing carried out prior to the time of your withdrawal.

Should you wish to exercise any of the above rights, you can write to privacy@deltatre.com We will check if you are entitled to do so and will respond you within, as a rule, one month.

Nevertheless, should You wish, you may forward your complaints to the data protection authority using the following contact details: Garante per la protezione dei dati personali - Piazza Venezia n.11- 00187 ROMA – Phone number: (+39) 06.696771 - E-mail: protocollo@gpdp.it – Certified email: protocollo@pec.gpdp.it

8. Contacts

The contact details of Deltatre as Data Controller and of the Data Protection Officer (DPO) are the following: privacy@deltatre.com and dpo.italy@deltatre.com

Last update: August 2024