Privacy Policy
PRIVACY POLICY REGARDING THE PROCESSING OF PERSONAL DATA
ART. 13 REG. EU 2016/679
This document informs you, as provided for by Art. 13 of EU Reg. 2016/679 (hereinafter referred to as GDPR), about which personal data we will collect and process through the user’s use of the 4Box mobile application (hereinafter, the “App”). This information does not concern other sites, pages, or online services accessible via hyperlinks or widgets that may be published in the App but refer to external resources.
WHO WILL PROCESS YOUR DATA
Data Controller: FINDER S.p.A. con unico socio
Tax Code/VAT No.: IT05732610018
Address: 10040 Almese (TO) Via Drubiaglio 14
CONTACTS
To receive information and to exercise your rights regarding the protection of personal data, you may use the online contact form found at the link https://www.findernet.com/it/italia/tutela-dati-personali/ (or select “Support” > “Personal Data Protection” on the website https://www.findernet.com ).
WHICH DATA WE WILL PROCESS AND FOR WHAT REASON
Below you will find all the indications to understand which data of the App users we collect and for what reason. After installation, the App requests permission from the user’s device to access user data. Following the granting of permission, it can be revoked by the user at any time through the device settings. The refusal or revocation of the requested permissions, where indicated as necessary, results in the impossibility of using all or part of the App’s services.
Purposes for which we collect data:
USER REGISTRATION
Creation of the user account in order to benefit from the services provided by the apps and to store the settings of the 4Box S-series devices connected to the App.
What data we collect
- First name, last name
- E-mail address
Communication of data to other organizations
- Professionals and companies appointed by the Controller
- Companies providing IT services to the Controller
- Finder Group companies
Data type: Personal; Legal basis: Performance of a contract; Necessary data: YES; Retention period: Until the request for deletion of the user account.
APP FUNCTIONALITY
To allow the user to use the features and services of the App and the 4Box S-series devices connected to the App.
What data we collect
- User’s smartphone device ID
- App access logs and device disconnection logs
- Session error logs
- Device ID linkage with the User
- GPS Location (optional)
- ID of 4Box S-series devices connected to the App
- Status of 4Box S-series devices connected to the App: data relating to consumption and power (kWh, Ampere, Volt, number of Wi-Fi disconnections, device ON/OFF actuation)
Communication of data to other organizations
- Professionals and companies appointed by the Controller
- Companies providing IT services to the Controller
- Finder Group companies
Data type: Personal; Legal basis: Performance of a contract; Necessary data: YES; Retention period: RAW kWh consumption data: 2 days – Other User Log data: 2 months or until account deletion.
TECHNICAL ASSISTANCE
To provide technical assistance upon user request.
What data we collect
- E-mail, city, province/State
- User data necessary to respond to the request and provide assistance
- Any further information provided by the data subject
Communication of data to other organizations
- Professionals and companies appointed by the Controller
- Companies providing IT services to the Controller
- Finder Group companies
Data type: Personal; Legal basis: Performance of a contract; Necessary data: YES; Retention period: For the time necessary to respond to the user’s request.
PERMISSION TO USE SMART ASSISTANT
To allow the user to control the devices connected to the App through Smart Assistant systems.
What data we collect
- First name, last name, e-mail
- Unique identifiers of the devices to be monitored
- Name assigned by the user to the devices to be controlled
Communication of data to other organizations
- Service provider of the Smart Assistant device (e.g., Google Assistant ®, Amazon Alexa ®)
Data type: Personal; Legal basis: Performance of a contract; Necessary data: NO; Retention period: 2 months or until account deletion.
PROTECTION OF PERSONAL DATA
To respond to requests from the data subject to exercise their rights for the protection of personal data.
What data we collect
- First Name, Last Name, Email
- Any further information provided by the data subject
Communication of data to other organizations
- Public and judicial Entities and/or Authorities
- Professionals and companies appointed by the Controller
- Finder Group companies
Data type: Personal; Legal basis: Legal obligation; Necessary data: YES; Retention period: Until the expiration of the legal statute of limitations.
COMPLIANCE WITH LEGAL OBLIGATIONS
To comply with the obligations provided for by current legislation and/or orders issued by Public Authorities.
What data we collect
- Personal data whose communication is required by law or by order of the Public Authority
Communication of data to other organizations
- Public and judicial Entities and/or Authorities
- Professionals and companies appointed by the Controller
- Finder Group companies
Data type: Personal; Legal basis: Legal obligation; Necessary data: YES; Retention period: Until the expiration of the legal statute of limitations.
PROTECTION OF RIGHTS
To ascertain, exercise, or defend a right in the appropriate forums.
What data we collect
- Personal data necessary for the exercise of rights
Communication of data to other organizations
- Public and judicial Entities and/or Authorities
- Professionals and companies appointed by the Controller
- Finder Group companies
Data type: Personal; Legal basis: Legal obligation; Necessary data: YES; Retention period: Until the expiration of the legal statute of limitations.
INFORMATION SECURITY MANAGEMENT
Management, maintenance, and protection of IT infrastructures.
What data we collect
- Data collected for user registration
- Data collected by the App during use
Communication of data to other organizations
- Public and judicial Entities and/or Authorities
- Professionals and companies appointed by the Controller
- Companies providing IT services to the Controller
- Finder Group companies
Data type: Personal; Legal basis: Legitimate interest; Necessary data: YES; Retention period: 2 months.
FOR HOW LONG WE WILL STORE YOUR DATA
We will store your personal data for the time necessary to achieve the purposes as indicated above.
The mere uninstallation of the App from the user’s device does not result in the deletion of data.
To obtain deletion, the user must request the Controller to delete the data using the contact form indicated at the top of this notice, or the specific functionality within the App. Data deletion is irreversible and makes it impossible to restore the data.
Furthermore, we may be obliged to retain your personal data for a longer period in the event of a legal obligation or by order of an Authority, or in the event that the Data Controller must assert or defend a right in court. At the end of the retention period, personal data will be deleted and application data will be anonymized. Therefore, after this term, the right to access, deletion, rectification, and the right to data portability can no longer be exercised.
TO WHOM WE WILL COMMUNICATE YOUR DATA
Your data will be communicated to third parties in cases where a legal provision obliges us to do so, such as in the case of administrative, accounting, and tax compliance. In addition to these cases, your data may also be communicated to other subjects who might be involved in the processing activities. You will find in the table the categories of recipients to whom we may communicate your data. In the cases provided for, we have entered into appropriate contracts with external organizations to authorize them to process your data on our behalf.
In the event of the user using Smart Assistant devices (e.g., Google Assistant ®, Amazon Alexa ®), the user’s identification data and data relating to connected devices are communicated through the App, subject to the user’s consent, to the third party providing the service.
Please refer to the information on the processing of data provided, as an independent data controller, by the Smart Assistant service provider.
WHO WILL PROCESS YOUR DATA AND IN WHAT WAY
Your data will be processed by persons who have been specifically authorized for this activity and/or by data processors, who are also authorized. The Controller verifies and monitors their work. The processing will be carried out both with electronic tools and in paper mode, always complying with the provisions of the Privacy Code and the GDPR, to guarantee the security and confidentiality of your personal data.
DISSEMINATION OF YOUR DATA
Under no circumstances will we disseminate your personal data.
AUTOMATED DECISIONS
We do not use systems that make decisions in an automated way based on personal data.
TRANSFER OF YOUR DATA OUTSIDE THE EEA AREA
Personal data processed by the Controller are managed within countries belonging to the European Economic Area (EEA).
WHAT ARE THE RIGHTS OF THE DATA SUBJECT
As a data subject, you have the possibility to exercise your rights, as provided for by Articles 13, 15-22 of the GDPR.
To do so, you may contact us through the contact channels indicated in this notice. We will respond within one month. In cases of particular complexity of the request, we may respond within three months, but in such cases, we will notify you.
In summary, the data subject, with reference to the personal data concerning them, has the possibility to:
• obtain access to personal data, their rectification or deletion, or the restriction of processing;
• object to the processing;
• obtain data portability;
• withdraw consent to the processing at any time, where provided;
• lodge a complaint with the supervisory authority, which in Italy is the Garante per la Protezione dei Dati Personali, contactable through the references found on the website http://www.garanteprivacy.it .
