INFORMATION REGARDING THE PROCESSING OF YOUR PERSONAL DATA
(as per Art. 14 of EU Regulation 2016/679)
In relation to the SkyVote service, Multicast Srl is required to collect and process Your personal
data, classified as “special categories of data” under EU Regulation 2016/679, which specifies that
those who process personal data are required to inform the data subject about the nature of the data
being processed and about certain aspects of the data processing procedure, which must, regardless,
always be carried out properly, legally, and transparently in order to safeguard Your rights. Thus,
in compliance with EU Regulation 2016/679, Multicast Srl provides the following information:
Nature of the Data Being Processed
These privacy regulations outline the specific categories of personal data pertaining to residents of
the Municipality of Livorno who have turned 18 years old as of 9 June 2024 and are eligible to vote
and participate. The data is to be used by Multicast Srl for the on-line election of Deputy
Councillor of the Municipality of Livorno through the “SkyVote” intermediary service and the
websites voting.skyvote.it and candidature.skyvote.it.
Personal data refers to information about an individual from which it is possible to infer his or
her identity. As such, data that cannot be traced back to the identity of the Subscriber (anonymous
and/or encrypted data) is not considered personal data and therefore its processing is not governed
by the GDPR. We process personal data relating to the participants and voters who use the SkyVote
Cloud platform. This personal data falls into the following categories.
Identifying information: includes name, surname, and fiscal code.
Contact information: e-mail and telephone number provided by the individual upon accessing the
platform.
Connection data: IP address and browser user agent.
Additionally, we collect, use, and share aggregate data such as statistical and demographic
information. However, aggregate data may be derived from the Subscriber’s personal data even though
it is not classified as personal data according to regulations as it does not directly or indirectly
disclose the Subscriber’s identity. For example, we may aggregate data to calculate the
percentage of voters casting a vote. Even though when aggregate data is combined or linked with
personal data it can in NO WAY, directly or indirectly, identify the preference expressed by the
voter, the combined data will nevertheless be treated as personal data in accordance with this
privacy policy.
The SkyVote Cloud system for cloud and online voting ensures the separation between voters’
identities and the vote they are casting in the event of anonymous voting. As a result, the casting
of one’s vote, which is encrypted and dissociated from the user, remains anonymous and outside of
the scope of the GDPR, as well as unavailable to both Multicast Srl and the Municipality of Livorno
(anonymous vote). It must be noted that, in processing such data, we strictly adhere to the limits
and conditions set by the Privacy Guarantor.
Furthermore, we do not collect any judicial data concerning the Subscriber.
The processing of personal data by Multicast Srl, as mentioned above, is essential for participation
in elections. Therefore, failure to process this data prevents use of the services and hinders the
ability to cast a vote.
Purposes of Processing
Your personal data is processed solely for the purpose of participating in the voting process and
providing support in the event of issues related to Your user account or device during the voting
process.
Legal Basis of Processing
The processing is necessary for the pursuit of public interest entrusted by law to the Municipality
of Livorno as the data controller (Art.6(e) of the GDPR) and for the pursuit of the legitimate
interests of Multicast Srl as the data processor (Art.6(f) and Recital 47 of the GDPR).
Without the need for explicit consent under Art.9(2)(d) of the GDPR, the processing is carried out,
within the scope of its legitimate activities and with appropriate safeguards, by a foundation,
association, or other non-profit organisation pursuing political, philosophical, religious, or trade
union objectives, provided that the processing relate solely to members, former members, or
individuals who have had regular contact with the Municipality of Livorno in relation to these
objectives and that the personal data not be disclosed with third parties without the subject’s
consent.
Methods of Processing
The processing of Your personal data is carried out through the operations specified in Art. 4(2) of
the GDPR, namely for its collection, recording, storage, consultation, availability, deletion,
destruction, or communication. Your personal data may be subjected to electronic and/or automated
processing. Multicast Srl does not use the processed data of its users for promotional purposes, nor
does it share it with third parties for the creation of databases. For this reason no consent is
required for processing. Please note that, given the purposes of processing as specified above,
providing one’s data is mandatory. Failure to provide data, or providing incomplete or inaccurate
data, may make it impossible to perform the intended activities. For the technical management of the
voting process via the SkyVote Cloud service, Multicast Srl emphasises that the identifying and
contact information held by us (such as Your personal data and the date on which you registered as a
resident of the Municipality of Livorno) is transmitted to Multicast Srl directly by the
Municipality of Livorno, which remains the sole and exclusive controller of the aforementioned data,
and is processed by Multicast Srl as the data processor. Connection data is processed by Multicast
as the independent data controller.
Communication and Disclosure of Data
Your data may also be disclosed for the aforementioned purposes, namely to judicial authorities, as
well as to any entities to which communication is required by law for the fulfilment of said
purposes, or for legal action or defence in legal proceedings related to electoral operations. These
entities will process the data as independent data controllers. Your data will not be shared or
transferred in any way to non-EU countries or international organisations.
Retention Periods for Data and Other Information
Regarding the personal data processed for the aforementioned purposes, this same data will be stored
in accordance with the principle of proportionality and regardless until the purposes of the
processing have been fulfilled, for a period not exceeding 6 months. Data related to registration
and to voting documentation is passed on to the Municipality of Livorno and deleted within 24 hours.
Your Rights
You may exercise the following rights outlined in Article 15 and following of EU Regulation 2016/679
at any time:
- obtain confirmation of whether or not personal data concerning You exists;
- access Your personal data and obtain the information referred to in Art. 15 of EU Regulation
2016/679;
- update, integrate, rectify, or delete Your data within the limits provided by law;
- restrict the processing of Your data (in cases provided for in Art.18 or EU Regulation
2016/679);
- object to processing for reasons associated with Your specific situation (within the limits
provided for in Art. 21 of EU Regulation 2016/679);
- the right to data portability (in cases provided for in Art.20 or EU Regulation 2016/679);
- You also have the right to lodge a complaint with the Data Protection Authority (Art. 77 EU
Regulation 2016/679).
How to Exercise Your Rights
The methods by which data subjects may exercise all of their rights are, in general, specified in
Articles 11 and 12 of the Regulation. The address for exercising one’s rights, pursuant to Art. 14
of the GDPR (including requests addressed to third parties with whom data has been shared with the
specific consent of the data subject) is: Municipality of Livorno. The Municipality of Livorno is
the data controller of your personal information (identifying and contact information).
Multicast Srl, with headquarters at Via Caulonia 13, 00183 – Rome, represented by its DPO who can be
reached via e-mail at dpo@multicastsrl.it, is the data processor of your personal information and
the data controller of your connection data.
