1. DATA CONTROLLER AND AUTHORIZED THIRD-PARTY DATA PROCESSORS
The Data Controller is GIACOMINI S.p.A. (Hereinafter also the “Controller”), with registered office in Via per Alzo, 39, (28017) - San Maurizio D’Opaglio (NO), phone number: 0322/923111, e-mail address: firstname.lastname@example.org. The updated list of data processors and authorized people in charge of the data processing is found in the data processing log in safekeeping at the registered office of the Data Controller.
2. DATA PROCESSED
Depending on the service provided, different types of personal data may be processed, as specified below.
- Data voluntarily provided by the user (registration and communications)
This app collects the following personal data: user's first name, last name, and e-mail address. This data is required for registration and account creation, for the use of the mobile application, and for accessing the services made available. Additionally, upon user's request, the data may be used to send e-mail responses to the e-mail addresses provided.
- Location data
This app collects location data for retrieving weather information in the area where the heating system is located.
By clicking on "set location", the application’s technology identifies the physical location of the user’s system, collecting longitude and latitude data regarding the location of the system. Furthermore, in the "set location" section, the user can manually enter the physical address of the system or redefine a previously configured location of the system by enabling the geolocation feature on the mobile device.
When the user, in the "set location" section, clicks on the "Replace with current location" button, the use provides consent to the identification of the physical location of the system.
The location data are processed, stored, and used by the Controller solely for the purposes and in the manner described in Article 3. The system does not allow remote real-time geolocation at any other time than that of the activation of the location feature by the user to redefine the previously configured location.
3. PURPOSES AND METHODS OF PROCESSING
Any personal data acquired shall be processed in compliance with applicable laws for purposes related and/or instrumental to accessing this mobile application and providing the services offered through said application, including any additional services requested by the user. In particular:
a) to sign-up for the app and provide a service (such as accessing the mobile application with all its features) and receive the requested information via e-mail
b) (regarding geolocation data) to provide weather information service for the location where the heating system is located
c) to fulfill all legal obligations
d) for operational and management needs at the Controller’s and related to the services offered
e) to protect a legitimate interest of the Controller (e.g., defending itself in a court of law).
The personal data will be processed lawfully and fairly and used only for the purposes mentioned above. The data processing may be performed using automated tools to store, manage, and transmit such data. In any case, it will be performed using appropriate tools to ensure the confidentiality, security, availability, and integrity of the information systems used for data collection, transmission, and storage, as well as the collected data.
4. LEGAL BASIS OF THE PROCESSING, REASONS FOR DATA PROVISION AND CONSEQUENCES FOR NOT PROVIDING THE DATA
The legal basis for the processing is the implementation of the contract or pre-contractual measures (purposes a, and c), compliance with legal obligations (purpose b), and pursuing the legitimate interests of the data controller (purpose d). The processing of the geolocation data is based on the consent given by selecting "set location".
Therefore, the processing is lawful (Art. 6 Paragraph 1 of EU Regulation 2016/679).
The provision of the personal data for the purposes outlined in section 3) is necessary for using the application. If the data is not provided, it will not be possible to access the services offered by the application.
5. DATA RECIPIENTS
If necessary to achieve the purposes set out in section 3), the personal data may be disclosed, in addition to employees specifically authorized according to their duties, to the following external third parties, appointed in writing and acting as data processors, provided that they meet the applicable requirements:
- the company that developed the Application
- Public authorities
- IT service providers - hosting - technology companies entrusted with specific Application management tasks.
The Data Controller shall keep an updated list of external data processors, which will be submitted to the data subject upon request.
6. TRANSFER OF DATA TO A NON-EU COUNTRY
The data will be processed exclusively in Italy and within the European Union. If, for reasons related to the implementation of the contract, the data need to be transferred outside the European Union, the data controller shall ensure that the transfer will be carried out in compliance with appropriate safeguards or in accordance with the conditions set forth in Article 49 of the GDPR.
7. DATA STORAGE PERIOD
The data controller stores the personal data until the user deletes the application. Following the deletion of the application, the data will be promptly erased.
8. RIGHTS OF DATA SUBJECTS
You shall have the rights provided for in Articles 15 and following of the EU Regulation 2016/679 and you may exercise these rights at any time:
a) The right to access personal data
b) The right to request the rectification or erasure of personal data, or the restriction of the processing
c) The right to object to the processing of personal data
d) The right to data portability
e) The right to withdraw consent, where applicable (the withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal)
f) The right to lodge a complaint with the supervisory authority (Garante Privacy).
These rights can be exercised by sending a notification via e-mail to the following address: email@example.com.