Privacy Policy - APP

The Data Controller is: Mottura Serrature di Sicurezza S.p.A.

Strada Antica di Francia, 34, 10057 Sant'Ambrogio di Torino (TO),

hereinafter “Mottura”.

Mottura, pursuant to EU Regulation 2016/679 on the protection of individuals with regard to the processing of personal data, wishes to inform you on how it processes information relating to its services and in the context of the use of our Apps.

This policy applies to the processing of personal data relating both to the users of our App (hereinafter “Users”) and to all the subjects who may initiate enquiries, including for advertising purposes, in the context of all our services (present and future).

What data do we process?

By "personal data" we mean all information useful for identifying a natural person, either already held by Mottura or which the latter could come into possession of.

A user can use the Apps for the use and management of Mottura locks and devices.

During the registration procedure and use of the App, the following personal data can be collected, stored and subsequently processed:

• Identification data: name and surname
• Contact information: address, telephone number, e-mail address
• Geo-location data
• Navigation data (e.g. access date and time)
• password

 How is personal data collected by Mottura?

 Data collected by Mottura, within the services provided through the App, come from:

• information obtained during the download phase of the App and the registration necessary to access the services, as well as during the following use of the APP ;
• information communicated by telephone, by e-mail in relation to request of assistance by the Users;

We also inform you that Mottura does not use automated decision-making processes pursuant to art. 22 of the GDPR for decisions regarding the establishment and execution of business relationships.

Why does Mottura process personal data?

Mottura processes User data for the following purposes:

• provide the service of opening and managing locks as per users’ requests, and therefore to fulfill the obligations assumed under the agreement for the provision of services (including the geo-location of the device);
• improve the services and App functionalities and carry out statistical and trend analysis on the basis of Mottura’s legitimate commercial interest and with no significant impact on the User. In this case, User data will be aggregated and/or anonymized so to prevent the data subjects’ identification. Such anonymized or aggregated information may be shared with any commercial partners of Mottura, current or potential Merchants or other third parties on the basis of a legitimate commercial interest of Mottura;
• follow up on Users' requests for information, including marketing communications.

On what legal basis is personal data processed?

The processing of Users’ data is necessary to perform the agreement for the supply of services, and deliver the services related to lock opening and management. Furthermore, in case of Users’ refusal to provide their personal data, it won’t be possible for Mottura to deliver its afore-mentioned services.

In case of consent given for personal data processing with regard to specific purposes, the processing will be carried out on the basis of such consent and in accordance with the purposes declared in the consent form. It is possible to withdraw the given consent, at any moment, either through a request in written form or e-mail. The consent withdrawal does not prevent the lawfulness of the data processing activities performed before the withdrawal and in accordance with the consent.

The processing of the User's data for marketing purposes takes place on the basis of the User's consent, in compliance with Mottura's general Privacy Policy which can be consulted at the link: www.mottura.it/en/contacts/privacy

For how long does Mottura store personal data?

Mottura shall store personal data for a period of 5 years following the termination of the service delivery, and only with the purposes of anti-money-laundering and anti-terrorism provided by the applicable regulation. The request of erasure of personal data provided during the download phase will be fulfilled with regards to all the data processing purposes different from the ones defined by the aforementioned regulation.

With whom is personal data shared?

Nell’ambito delle attività di trattamento previste, Mottura potrebbe dover condividere i dati personali raccolti con soggetti che agiscono in qualità di Titolari autonomi oppure di Responsabili del trattamento (ex art. 28 GDPR), ove operino per suo conto.

A titolo esemplificativo e non esaustivo:

With reference to the planned data processing activities, Mottura may need to share the gathered personal data with subjects that act in its behalf in the role of Data Controller or of Data Processor pursuant to art. 28 GDPR; by way of example and not limited to, the following:

• IT service providers
• Employees, agents, partners
• Service providers for customer due diligence
• Any commercial partners of Mottura in the context of providing the services requested by the User
• Relatives, legal guardians and collaborators of the interested party
• Authorities responsible for issuing licenses
• Where required, the competent judicial authorities
• Where required, the police (by way of example, the Police)
• Where required, public administrations and supervisory and control authorities

Personal data shall not be diffused.

How does Mottura guarantee the security of personal data?

Mottura pays extreme attention to the security of the personal data of the data subjects. To this end, it has prepared special procedures for data security as well as an information security policy allowing to protect data from accidental loss or improper use. Mottura allows access to information only in the presence of a legitimate reason.

What rights can data subjects exercise in relation to the information processed by Mottura?

Any interested party (i.e. the User as well as those who are not yet Users but have requested information and given their personal data to Mottura) can exercise specific rights, including those to ask the data controller:

• The confirmation as to whether or not the personal data is being processed and, in this case, to obtain access to it (right of access);
• The correction of inaccurate personal data, or the integration of incomplete personal data (right to rectification);
• The deletion of the data, in the presence of one of the reasons provided for by art. 17 of the Regulation (right to erasure);
• To limit the processing of personal data, in the presence of one of the reasons provided for by art. 18 of the Regulation (right to restriction of processing);
• To receive the personal data provided in a structured format, commonly used and readable by an automatic device, and to transmit them to another data controller (right to data portability)

To exercise his rights, any interested party can write to the e-mail address privacy@mottura.it .

Pursuant to the Regulations, Mottura is not authorized to charge costs to fulfill one of the requests set out in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive. In cases where the data subject requests more than one copy of his personal data or in cases of excessive or unfounded requests, Mottura may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to comply with the request. In these cases, Mottura will inform the interested party of the costs before processing the request.