INFORMATION NOTICE PRIVACY
Zucchetti Axess S.p.A., with registered offices in via Solferino, 1, 26900 Lodi (Italy) editor of the APP “ENTRO” (“APP”), pursuant to art. 13 of the Italian D. Lgs. N 196/2003 (“Privacy Code”, hereinafter “PDPA”) and in line with the recommendations expressed by the European Working Group in the “Opinion 02/2013 on apps on smart devices”, wishes to provide you with some information on the use of this APP, and in particular on the processing of your personal data.
The Company, in keeping with the principle of “necessity of data processing” ‐according to which IT programs must be set so as to minimize the use of personal and identifying data‐ informs you that the use of the APP does not imply the performance of any personal data processing operation.
This is due to the fact that, except as specified below, the Company neither requires nor collects your personal data or any other information regarding yourself –including personal data pertaining to your health, your identification or registration/log‐in, your behaviour, or your geo‐positioning detected by the APP.
Whenever the APP’s functions require the user to enter any personal or sensitive data (including videos and pictures), the Company informs that all personal data intentionally entered through the APP are only stored locally on the device, and will be accessible exclusively by the user. While entering the user’s personal data is optional, and is recommended to take full advantage of all the functions available through the APP, doing so is not required to make the use of the APP possible.
When the APP enables users to share their personal data with third parties, and users choose to do so ‐i.e. by publishing them on their social network’s profile, by sending them via email or SMS text message etc.‐, the use of the mentioned data shall be subject to the privacy conditions that the Company recommends to check before carrying out any such operation.
Except as per the above specifications, the user’s personal data are not communicated to third parties, be they physical or legal persons, and are not disseminated in any way.
We specify that the data originally gathered in anonymous form, or later anonymized, as well as aggregate anonymous data, are NOT considered personal data for the purposes of the applicable data protection legal provisions and/or the present Privacy Information notice. Specifically, the expression “aggregate anonymous data” refers to those information about users that are collected and grouped in a way that renders it impossible to identify them individually. Such anonymous data, e.g. those pertaining to the correct use and maintenance of the APP, the frequency of the APP’s use, updates, system crash reports etc., may automatically be collected by the Company through the APP for maintenance and analysis purposes. Furthermore, pursuant to art. 122 of the PDPA, and as exemplified in the pop‐up banner displayed when the APP is installed, the Company informs users that it may, with their consent, access their personal data and/or store limited information on their device; such information shall in no case exceed what is strictly necessary for
the provision of the service required by the user and/or for the correct functioning of the APP.
Data are processed in strictly anonymous form. The Company informs that, pursuant to Art. 7 of the PDPA, anyone may contact the Data Controller to exercise the right to receive confirmation that his/her personal data are being held by the company, verify the data’s content, origin and correctness, supplement, update, amend, delete, anonymize their personal data, block them in case of illegal processing, or oppose to their processing for any legitimate reason. For any request concerning the processing of personal data by the Company, as well as to exercise the mentioned rights, users may contact the Data Controller at the contacts above. Furthermore, we invite you to carefully read the Privacy Policies of the specific “Stores” from which the APP has been downloaded (Appstore, Google Play), as each Store may carry out independent processing operations with the user’s data (including, by way of example, their email address, the data pertaining to their smartphone/device, their geo‐positioning, their consumption habits, as well as health‐related or other sensitive data, etc.), and even share such data with third parties, in line with their respective Privacy Policies. If you are interested, you may become acquainted with each specific data processing regulation by visiting the relevant Store’s website. We emphasize that Stores act as autonomous Data Controllers for the purposes of the PDPA (art. 4, D. lgs. 196/03) and that, for this reason, the Company may not be held liable, for any reason whatsoever, for the processing operations performed by the Stores.
The user confirms to have read the information notice and to accept its content.