Privacy policy for Zucchetti Axess APPs
pursuant to Art. 13 European Data Protection Regulation 2016/679 (GDPR)
This Privacy Policy is provided solely and exclusively for the Entro and Entro2 application and not also for any websites through which you may access and/or use the application.
Data Controller
The data controller of personal data, pursuant to Article 4 point 7) of the GDPR, is ZucchettiAxess spa with registered office in Lodi, Via Solferino, no. 1, 26900 – e-mail ufficio.privacy@zucchetti.it
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Data Protection Officer
The person responsible for data protection is Dr. Mario Brocca, whom you can contact by sending an e-mail to dpo@zucchetti.it.
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Developer
The Developer of the application is ZucchettiAxess Spa, with registered office in Lodi, Via Solferino n. 1, 26900 – ufficio.privacy@zucchetti.it
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Personal data collected
The services provided by the App as well as its features and functions do not require any form of User registration. We would like to point out, however, that the IT systems and software procedures used to operate the App (such as the Apple Store, Google Play or App Gallery), acquire during their normal operation, some data in any case referable to the User, the transmission of which is implicit in the use of Internet communication protocols, smartphones and devices used. This category of data includes, but is not limited to, geographical location, telephone identity, the User’s contact details, e-mail, and credit card data. The User may consult the Privacy information available on the following sites:
-Apple   Store – http://www.apple.com/legal/privacy/en-ww/
-Google Play – https://www.google.it/intl/it/policies/privacy/
The Entro and Entro2 apps collect the following data:
- Geolocation*: the App does not use this functionality
- Camera*: the App does not use this functionality
- Access to files contained in the device*: the App does not use this functionality
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- It collects and manages the following personal data:
- App Within without registration to the Entry 365 cloud service
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- Unique code that is generated by the app within the installation;
- Entro app with Entry 365 cloud service registration
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- E-mail address, first and last name
- Unique code generated by the Entry365 service and sent to the smartphone (the APP stores it);
Compulsory or optional nature of providing data and consequences of refusal
The provision of data is optional; however, the provision of some data is necessary for the provision of the service. In this case, refusal to provide the data does not allow the provision of the service and the use of that particular App functionality.
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Treatment modalities
Processing takes place electronically and while using the app, personal data is redirected through secure connections to the Entry365 software product if the APP is used with registration to the Entry365 cloud service. If, on the other hand, the APP is used without registering with the aforementioned service, the unique code is transmitted in BLE to the terminals as if it were the badge code. In the first case, the unique code is stored by the APP and a special button is available to delete the data stored on the user’s smartphone and unregister from the Entry365 service.
Secure processing procedures for personal and sensitive user data
The developer has developed and implemented secure data processing procedures consisting of security measures at the technical organisational level and at the service level.
In particular, the security measures that can be configured at application level are:
The Entro app benefits from all the security measures that the user can choose to activate directly on his smartphone, e.g. facial recognition, fingerprint, passcode, etc.
With specific reference to the App, I will enter the security measures below:
The unique code (and possibly name, surname and email in the case of registration for the Entry365 service) is stored on the device in encrypted format;
The identification code is sent via Bluetooth (BLE) to the access control terminal, in encrypted format
With regard to service procedures, security of treatment is ensured for each mode of delivery as follows:
SUPPORT SERVICE METHODS
Support for Zucchetti Axess products and services is provided in the following ways:
- On Site Assistance
- Telephone Assistance
- Support via email/web tickets
- Assistance through the reception of customer databases
- Support through remote TeamViewer and/or Meeting Webex connection
- Support through remote connection via vpn
- Conversions and start-up projects
As defined in the contract, remote assistance involves access to the system, which must always be authorised and controlled by the Customer/Data Controller. Therefore, each access is recorded by the operator who performs it by saving the email exchange.
CONTRACTORS TO WHOM THE SERVICE IS PROVIDED
The service is provided to:
- Direct customers Zucchetti Axess
- Indirect Customers
Care management generally involves:
- for direct customers: telephone call or email to the service (backoffice/dedicated mailbox) which sends an email to the service. The call is opened on Ad Hoc;
- for indirect customers, the request is sent directly by the customer to a dedicated mailbox (support@axesstmc.com) and is used as an HDA ticket tool.
Support is provided both on the Xatlas software and on the hardware (firmware) as well as on video surveillance systems (whether integrated in Xatlas or not).
Zucchetti Axess operators access the customer’s structure in order to carry out training or technical maintenance/support and installation activities.
In this case, they work as if they were part of the Customer’s/Data controller’s structure and they adopt all the procedures required by the Customer. The Customers/Data Controllers can generate individual user names for accessing their systems or they will provide access under supervision to Zucchetti Axess appointees in order to train their staff.
If, during the assistance activity, the Zucchetti Axess representatives need to retrieve archives or databases in order to solve the problems highlighted, they must inform the Customer/Data Controller and formalise, even by simply sending an email, the information that they have retrieved the DB’s with the customer’s authorisation. At the end of the activity at the Zucchetti AX offices, the person in charge who handled the intervention shall delete the data; should it be necessary to keep the data for a further period of time, a specific email must be sent to the Customer/Data Controller with the following minimum content:
“Dear Customer, I would like to inform you that the problem you have reported for the solution of which there was a need to retrieve your archives has been resolved. I inform you that we will keep the archives from our information systems for the next X days (to be defined from time to time according to need). At the end of the agreed period, the archives will be deleted from the Zucchetti Axess information systems and can no longer be restored’.
It presents no problems from a personal data processing point of view. No data or files are transmitted and communication remains verbal. Generally, the first contact after the customer’s request for assistance always takes place in this manner, to define the reported problem in detail.
ASSISTANCE VIA EMAIL/WEB TICKETS
When assisting by e-mail always include the disclaimer in the message text:
“The contents of this email and any attachments are strictly confidential, non-producible in court and intended for the person(s) to whom it is addressed. The content of the reply to this email could also be known by other employees belonging to the same homogenous group as the writer or to different homogenous groups but specular to the solution of the problem you have reported. Should you include attachments containing personal data in your reply to this message, these will be saved in the ticketing tool and/or in the email attachments stored for 3 years. If you have received this email in error, please notify us immediately and delete it from your computer. Copying and dissemination of the content of this email is prohibited. Any misuse of the information contained herein by third parties or persons not named in this email may result in prosecution under the law. Please note that in order to exercise your rights under Articles 15 et seq. of the EU Regulation 2016/679 (GDPR), you may contact the following address: ufficio.privacy@zucchetti.it.
Zucchetti Axess representatives must never have the customer’s access credentials sent to them by email (only those used and in the customer’s possession, not those generated specifically for technicians who need to log in), nor must they save them on the ticketing tool and/or in emails.
If a customer/partner sends access credentials to their environment without a request from Zucchetti Axess appointees, it is necessary to reply that we are not authorised to access the systems with credentials of other users as this mode violates EU Regulation 2016/679 (GDPR). Therefore Zucchetti AX appointees will have to request individual credentials or connection with Teamviewer (or equivalent tool).
Each e-mail must be signed with the first and last name of the operator who handled the customer’s problem and the information must be saved in the ticketing and/or e-mail.
Clarification:
The disclaimer can also be inserted in web tickets.
Personal e-mails should not be used, as they cannot be checked.
SUPPORT VIA CUSTOMERS’ DATABASE IMPORT
If, in order to solve the problem reported by the Customer/Data Controller, it is necessary to have the database or other files or queries containing personal data transmitted, it is necessary to inform the customer of this necessity. If the customer is not in a position to make the copy himself and requests the Zucchetti Axess representatives to do so, it is necessary to receive his authorisation also for the VPN connection (to be saved in the ticketing tool and/or in the e-mail).
To carry out this activity, it is necessary to send the Customer/Data Controller an email of the following tenor:
“Esteemed Customer,
In order to solve the problem you reported, it is necessary to carry out checks on your archives.
We ask you to authorise us to connect via VPN to take copies and to process them for the resolution of what has been reported’.
The archives will be kept for as long as is strictly necessary to resolve the reported problem and must be deleted by Zucchetti Axess representatives at the end of the intervention.
Data must be saved in non-backed-up directories’.
If there is a need to maintain archives, there is a need to send an email to the customer, as follows:
“Esteemed Customer,
Having solved the problems with the archives you sent us, we request your authorisation to store your archives in our infrastructure for a further _____ days. The purpose of this storage is to check any problems that you may report to us while using the restored archives. At the end of the period mentioned above, we will permanently delete the archives. If we need your archives after this period, we will request them from you.
We request your express confirmation to this effect by replying to this message. Should your reply be negative, we will immediately delete your records.
Customer files may never be passed on to working groups other than those aimed at solving the problem reported by the customer.
The only possibility we have to keep archives without the client’s prior authorisation is to anonymise them.
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ASSISTANCE THROUGH REMOTE TEAMVIEWER CONNECTION
This mode of connection on the clients’ instruments guarantees privacy because:
- The connection is always requested by the customer
- Access credentials are always individual
- The customer gives us access to an environment with an authorisation profile chosen by him to perform the service tasks
- The customer may disconnect us whenever he/she wishes.
Through TeamViewer, it is also possible to have 2-level assistance access the same session we opened. In this case the customer has the evidence because it is provided by the tool and therefore implicitly accepts this mode.
If there is a need not to show the customer codes, passwords, licences that we have to enter for the tool to work properly, it is essential to use the TeamViewer function: Show black screen
It is essential to use our TeamViewer as it is licensed and customised with all the documentation that must be produced by the Data Protection Act.
Only in exceptional cases and after careful evaluation by the manager and the privacy office is it possible to use other connection tools that behave in the same way.
If support is to be carried out via VPN or private access, Zucchetti Axess employees are required to enter customer systems:
- Subject to customer authorisation
- That they have active credentials for the time required to perform the requested activities
- That at the end of the activity the Client/Processor deactivate
The creation of the user name must only be requested from the customer, who must generate it individually for each Zucchetti AX appointee.
An email must be sent to the customer:
“In order to perform the service activities you have requested, it is necessary to create individual access profiles for the operators who will perform this activity. Therefore it is necessary for you to generate such credentials in the system’.
When the customer makes the request, once the individual user has been created:
“In order to carry out the service activities you have requested, it is necessary to activate the user associated with me.”
At the end:
“We remind you to deactivate your credentials in order to protect your personal data.
OTHER TYPES OF SUPPORT
Assistance is also provided on video surveillance systems. When the camera does not work, if the system is integrated in Xatlas, intervention is carried out directly on Xatlas; in these cases access is to the configuration settings or images but only in real time and no one ever accesses the recordings. If the recordings do not work, the assistance is carried out by the video surveillance system maintainers.
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Categories of recipients to whom the data may be disclosed
The personal data collected may be communicated to the companies of the Zucchetti group and their subcontractors, in order to perform all support and maintenance activities.
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Personal data retention period
Again, a distinction is made between the two scenarios, i.e. whether the Entro app is used in conjunction with the Entry365 service or not.
– Use without registering for the Entry365 cloud service
In this scenario the only data stored on the smartphone is the unique code generated by Entro on installation. This data is deleted when you uninstall the Entro app.
- Use by registering for the Entry365 cloud service.
If the user has subscribed to the Entry365 service, then inside the ENTRO app, in addition to the user identification code received from Entry365, the user’s email, first name and last name are also stored.
The data is stored in ENTRO until the user presses the “disassociate device” button from Entry365. In this case, the data is deleted from the phone and the identification code received from Entry365 is replaced with a unique code generated by the app itself.
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Purposes of the processing for which personal data are intended
The app is used for clocking in and out and access control. A further purpose of the processing is to provide support and maintenance services to the Controller.
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Scope of knowledge of your data
Processed data from the app is transmitted to the Entry365 software product if the app is used with registration to the relevant cloud.
Territorial scope of treatment
The data provided will be processed in Italy.
Rights of data subjects
You may exercise your rights by sending an email to ufficio.privacy@zucchetti.it. In particular, you may request access to your personal data, rectification or deletion, or you may request restriction of processing and you may object to processing. In addition, you shall have the right to data portability and, should you wish to lodge a complaint, you may also lodge it with the Data Protection Authority.
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