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Privacy APP



Privacy Policy Apps – Mottura Serrature di Sicurezza S.p.A.

 

The data controller of the data provided  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.

 

Mottura aims to collect data and information in an accurate, relevant and appropriate manner for the purpose for which such collection is necessary, without requiring unnecessary information.

 

This policy applies to the processing of personal data of the Users of our Apps in the context of all Services (present and future).

 

Furthermore, this policy also governs the processing of personal data of Users and of all persons not yet Users who have asked Mottura to receive information, including promotional information, on our Apps, the sector in which it operates and its Services, therein. including information on initiatives undertaken through information and social channels.

 

 

What is meant by "personal data"?

 

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

 

By way of example, the following are considered personal data:

- name and surname

- address

- telephone number

- email address

- localization

 

What is a data privacy policy?

 

To ensure that personal data are handled correctly and lawfully, Mottura is required to inform the User and any interested party:

- on the reasons why you need such data

- on how such data will be used

- on the subject (s) with whom the data will be shared

 

Use of the App

 

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, saved and subsequently processed:

 

  1. name
  2. telephone number
  3. e-mail address
  4. password
  5. data relating to the product, service and contract
  6. date and time of access
  7. operating systems used by the terminals
  8. languages, country of origin
  9. data for the fulfillment of legal and regulatory provisions

 

The aforementioned data is stored and processed for the exclusive purpose of responding to your request or for contacting and related administration.

 

For what purposes and on what legal basis are personal data processed?

 

The processing of your data serves to initiate and implement our business relations or to process the respective assignment. If you do not provide us with your data, we are usually forced to refuse to enter into a contract or to carry out an assignment or we cannot continue to perform an existing contract and must therefore terminate it.

 

If your consent is required for processing, we will collect it. The authorizations are in any case given on a voluntary basis. If you have given us your consent for the processing of personal data for certain purposes, the processing takes place on the basis of this consent in accordance with the purposes set out in the declaration of consent and to the extent agreed therein. A consent given with effect for the future can be revoked at any time in writing or by e-mail. The withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.

 

We also inform you that we do not use automated decision-making processes pursuant to art. 22 of the GDPR for decisions made regarding the establishment and execution of a business relationship.

 

What are your rights regarding data processing?

 

Under the applicable law, you have the following rights:

 

- check if and which personal data concerning you are processed and receive a copy of the same

- request the rectification, integration or cancellation of personal data that are incorrect or processed in violation of the law

- ask us to limit the processing of personal data

- object to the processing of personal data

- ask for data portability

- know the identity of the third parties to whom the personal data are transmitted

 

Without prejudice to the processing of your personal data on the basis of your consent, you have the right to withdraw this consent at any time by email or post. The withdrawal of consent does not affect the lawfulness of the processing based on consent before the withdrawal.

 

How is personal data collected by Mottura?

 

The personal data that the User communicates to Mottura come from:

 

- information communicated during the download phase of the App and registration necessary to access the Services

- information communicated by telephone, by email or through social media, and  the checks carried out to verify their accuracy and

- information communicated in relation to the request to receive newsletters and / or other information from Mottura

 

Mottura may also collect data relating to people not yet Users in relation to the request to receive information, including promotional information, on Mottura, the sector in which it operates and its Services, including information on initiatives undertaken through information channels and social networks.

 

Why does Mottura process personal data?

 

Mottura processes User data for various purposes:

 

- provide the service of opening your lock and managing it requested by the User and therefore to fulfill the obligations assumed under the agreement for the provision of Services (including the geolocation of the device)

- improve the Services and App functionalities and carry out statistical and trend analysis, and this on the basis of a legitimate commercial interest of Mottura that has no significant impact on the User. In addition, for the same purposes and to carry out campaigns relating to the Services, User data may be aggregated and / or anonymized so as to no longer allow the identification of individuals. 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 and in consideration of the impossibility of reconnecting said information to specific individuals

- follow up on Users' requests for information

 

 

With reference to data relating to persons not yet Users, they are processed to respond to the request to receive information, including promotional information, on Mottura, the sector in which it operates and its Services, including information on initiatives undertaken through information channels. and social.

 

Who are the subjects whose personal data are processed by Mottura?

 

Mottura processes personal data of multiple subjects including the following:

 

- Users

- personnel, including volunteers, agents, casual workers, partners, self-employed workers and people who work under contract in the name of Mottura

- providers

- subjects presenting complaints

- subjects whose personal data are provided by Users as part of the provision of the Services

- natural persons not yet Users who request information, including of a promotional nature, from Mottura, including information on initiatives undertaken through information channels and social networks

 

With whom is personal data shared?

 

Mottura obtains and shares personal data from and with various subjects including, by way of example and not limited to, the following:

 

- other Mottura Users

- IT service providers

- personnel, including volunteers, agents, casual workers, partners, self-employed workers and people who work under contract in the name of Mottura

- subjects presenting complaints

- commercial information providers

- 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

- those responsible for the processing of personal data who work on behalf of Mottura

- 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

 

All these subjects act as independent owners or have been authorized by Mottura, if they act on its behalf, as data processors.

 

The information in Mottura's possession will be shared only with those who actually need to know it.

 

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.

 

Mottura is also required to comply with strict confidentiality obligations, as well as professional secrecy.

 

What happens if the data held by Mottura is found to be inaccurate?

 

It is important that the data held by Mottura are accurate and up-to-date. If the data provided to Mottura undergoes changes and / or variations, the latter must be promptly communicated to the e-mail address privacy@mottura.it  or through social media, so as to allow Mottura to update its personal data.

 

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:

 

- 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 of rectification)

- the deletion of the data itself, in the presence of one of the reasons provided for by art. 17 of the Regulation (right of cancellation)

- to limit the processing of  personal data, in the presence of one of the reasons provided for by art. 18 of the Regulation (right of limitation)

- 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 portability)

 

Each interested party has the right to withdraw consent to the processing of his personal data (where this has been given), at any time, without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal.

 

Any personal data provided by the User starting from the download phase of the App (for example, name, surname, e-mail, telephone number) will be kept by Mottura to the extent that such storage is necessary to comply with the obligations established by the law. anti-money laundering and prevention of terrorism. The request for deletion of personal data provided starting from the download phase, therefore, will be fulfilled with reference to all those purposes of data processing other than those relating to the aforementioned legislation. When not possible to proceed with the cancellation request, it is specified that Mottura will be responsible for the following actions:

 

-  keep personal data for a period of 5 years starting from the moment in which the provision of the Services is terminated and exclusively for the purposes of anti-money laundering and prevention of terrorism provided for by the applicable legislation;

-  allow access to the personal data provided by the User, for as long as it is required to keep them, only to its competent anti-money laundering, legal and compliance functions and to fulfill any requests from the competent authority

- after 5 years from the moment in which the provision of the Services has ended, it will proceed with the User's request for cancellation in compliance with the applicable legislation.

 

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

 

Mottura will do its best to follow up the requests of Users and any interested party.

 

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.

 

Mottura may request additional information before processing requests, should it need to verify the identity of the individual who submitted them.

 

Links relating to external websites

 

Mottura may provide links to other content such as websites, web applications and downloadable applications. Unless otherwise indicated, such contents are not under the control of Mottura which therefore does not assume or accept any responsibility for the contents of third parties. The provision of a link is indicative only and does not imply any approval of the linked content or of whoever has control over it.

PRIVACY DISCLAIMER

- Customer APP