This document describes the methods for processing personal data relating to the eTouch eTouch App.
The information is provided pursuant to art. 13 of Legislative Decree no. 196/2003 (“Privacy Code”) and Article 13 of EU Regulation 679/2016 (“General Data Protection Regulation”) to all those who interact with the eTouch App product.
All data are processed by adopting the necessary technical and physical protection measures required by law.
This privacy statement refers to the user data collected directly from Eelectron and therefore refers to the relationship that exists exclusively between Eelectron as owner and the interested party.
Every user of eTouch App, taking note of this information, agrees to use the product in full compliance with the rules on privacy and, where eTouch App is installed in a business context, labor law.
This information does not refer to the processing of data carried out by the owner of the sensor network connected to the eTouch App application (the “Network Manager”) in the case where the same uses the collected data, also thanks to particular modifications of the product or through the crossing of several databases, for workers remote control use or for other purposes not included in this statement. The Network Operator is in such cases to be considered as an independent data controller.
- Data controller
Via Claudio Monteverdi 6
Legnano, 20025, Italia
Contacts: email@example.com – Phone + 39 0331 500 802
- Type of processed datas
2.1 Installation datas
Upon installation of the product and registration on the connected mobile application, eTouch App will request all necessary informations for user authentication, customisation and improvement of the offered service. In particular, eTouch App will request the inclusion of (i) personal data (name, surname), and (ii) e-mail.
2.2 Datas of the devices associated to the product
This category includes the hardware model, the IMEI number and other unique device identification codes, the MAC address, the IP address, the version of the operating system used and the used device settings to utilise the service.
2.3 Environmental datas
eTouch App allows you to connect sensors that can detect the temperature and the brightness of the environments accessed by users, allowing them to modify manually or automatically the parameters according to personal needs and energy saving purposes.
2.4 Datas on how to use the device
eTouch App collects data on the use of the device, including direct adjustments to environmental parameters, the switching on and off of the device, the number of associated automated devices and remote control of the same.
2.5 Information Collection and Use
- Processing Methods
The owner processes the personal data of users by adopting appropriate security measures to prevent access, disclosure, modification or unauthorised destruction of personal data.
The processing is carried out using IT and non-IT and / or telematic tools with organisational methods and with logic strictly related to the purposes indicated, so that an adequate level of protection of personal data is guaranteed.
- Communication and dissemination of datas
In addition to the owner, categories of employees involved in the organisation of the owner (administrative, commercial, marketing, legal, system administrators) or external parties (such as affiliates, business partners and service providers) may have access to the data and, if necessary , may be appointed as responsible for the processing from the owner. The data may also be disclosed in the context of business operations concerning the owner, such as mergers or sales of business units. The data may always be disclosed to third parties in aggregate and / or anonymised form.
With the express consent, you can request access to networks organised and managed by different Managers, authorising the sharing with them of your personal data.
eTouch App, unless otherwise indicated, will share with your Network Manager exclusively your name, surname and e-mail address. You may at any time withdraw consent to the communication of data to third parties and exit the network organised and managed by each Manager. The updated list of managers and employees can always be requested to the data controller. The communication of data, where required by law, is kept as Eelectron’s right.
In order to generate statistical reports related to the use of the areas involved and to energy efficiency, the Data Controller will communicate data in an anonymised and / or aggregated form to third-party services that will reprocess them for statistical purposes.
- Place of treatment
The processing of data takes place at the headquarters of the owner and in any other place where the parties legitimately involved in the processing are located. The interested party can always request information concerning the place of treatment.
- Transfer of personal datas
Management and storage takes place on servers located within the European Union. The owner, if necessary, maintains the right to move the server location, adopting all the security and organizational measures necessary to guarantee its protection.
If the personal data being processed are transferred outside the European Union, the Data Controller will inform the data subject and identify an appropriate legal basis for the transfer, such as the adoption of standard clauses approved by the European Commission, the consent of the interested parties, the selection of subjects adhering to programs for free circulation of data and subject to an adequacy decision by the European Commission.
- Data retention times
The data are processed only for the time necessary to perform the service requested by the user, or required by the purposes described in this document, after which they will only be stored in compliance with current legal requirements. The Data Controller will evaluate the retention times of personal data on the basis of proportionality and minimization criteria, differentiating them according to the different company needs and to the type of personal data processed. The interested party can always ask the Owner to provide more details on the storage times, as well as request the interruption of the processing or the cancellation of the data as subsequently described.
- Purpose of the processing and legal basis of the processing
The data provided may be processed for the following purposes:
- a) Improve and customise the service offered to users by reprocessing the data on how to use eTouch App products
- b) Offer updates, news and promotions relating to our products and services and business parters
- c) Communicate data in an anonymised or aggregated form for statistical or industrial purposes.
The purposes referred to in points a) and b) are necessary for the execution of the service pursuant to article 6.1.b of the Regulations.
The purpose referred to in point b) is based on the consent of the interested party pursuant to article 6.1.a of the Rules. If the recipient of commercial communication is a user who has already purchased an eTouch App product or service, the promotion may be sent pursuant to Article 130.4 of the Privacy Code. You can always oppose further commercial communications.
- Mandatory or optional nature of the contribution
The provision of data is optional, but not consenting to certain options could result in the reduction or inability to provide the service. Failure to provide authentication data makes it impossible to connect to the eTouch App system and to use the manual personalisation and control options. Failure to provide data and geolocation will make it impossible to use the user detection services and automated changes while entering certain environments.
The user has the option of consenting separately to receiving offers to promote products and services.
- User rights
The subjects to whom the personal data refer have the right at any time to obtain confirmation of the existence or otherwise of the absence of the data with the data controller, to know its content and origin, to verify its accuracy or request its integration, cancellation, limitation, updating, rectification, transformation into anonymous form or blocking of personal data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their treatment. The user has the right to obtain the personal data supplied in a structured format, in common and automatically readable by automatic device, and to transmit them, directly or through the holder, to another data controller (so-called data portability) . In any case, the user has the right to withdraw the consent given. The withdrawal of consent does not affect the legitimacy of all previous treatments.
The rights of the user can be exercised by contacting the Data Controller directly to the following email address firstname.lastname@example.org or using the appropriate procedures provided by the site or in the App.
The interested party has in any case the right to lodge a complaint to the Privacy Guarantor, in writing, according to the procedures established by law and available on the website www.garanteprivacy.it
Personal Data (or Data)
It constitutes personal data any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.
Treatment (of data)
Any operation or set of operations concerning the collection, registration, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking , communication, dissemination, deletion and destruction of data, even if not registered in a database.
Data Controller (or Holder)
The legal entities to which compete, even together with another owner, the decisions regarding the purposes, the methods of processing personal data and the tools used, including the security profile, in relation to the operation and use of the site. The data controller, unless otherwise specified, is the owner of the site.
Data Processor (or Manager)
Person in Charge of the Treatment (or appointed)
The natural persons authorised to perform processing operations by the owner or manager.
The natural person to whom the personal data refers.