PERSONAL DATA PROCESSING INFORMATION – ART. 13 REG. UE 2016/679
In accordance with European Union Regulation N. 2016/679 (hereinafter “GDPR”) and Article 13 in particular, please find below the information relating to personal data we will collect and process through the use of Finder YOU Mobile Application (hereinafter, “App”). This information does not concern other websites, webpages or online services that can be reached through hyperlinks or widgets that may be published on the App but refer to external resources
WHO PROCESSES YOUR PERSONAL DATA
Data controller: FINDER S.p.A. con unico socio
Cod.Fisc./P.IVA:IT05732610018
Address: 10040 Almese (TO) Via Drubiaglio 14
CONTACT DETAILS
Data Subjects contact form at: https://www.findernet.com/en/worldwide/data-protection/ or at https://www.findernet.com select “Support” “Data Protection
HOW AND FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA
Please find below all the information to understand which personal data of the App’s Users we need to process. After installation, the App asks the User’s device for permission to access the User’s device data. Once the permission has been given, it can be revoked by the User at any time through the device settings. Please note that the denial or revocation of the requested permissions, where indicated as necessary, might impact the proper functioning of the App’s services
Data Processing Purposes
USER’S REGISTRATION
Registration of User’s account in order to provide the App’s services and to store the device settings connected to the App
Processed data:
• Name, Surname
• Email
APP FUNCTIONALITY
To provide the services of the App and of the devices connected to the App
Processed data:
• Device ID
• Wi-Fi network connection/disconnection
• Bluetooth settings
• Paired Bluetooth devices
• IP address
• Location data (BLE)
• Event log: User ID
• Event log: “Autoaway”
• User location for geofencing functions
• Status of the controlled devices
• Thermostat temperature history
• Settings history
• Unique ID of connected devices
• Type of device to control (lights, shutters, thermostat, etc.)
• Device-specif configuration parameters
• User assigned device name
• User assigned system/house/room name
• Names of personalised scenarios
• Names and Email addresses of people with whom you share your devices
TECHNICAL SUPPORT
To allow the User to control the devices connected to the App through Smart Assistant devices
Processed data:
• Email, City/Province
• User’s data necessary to process the request and provide assistance
• Any additional information provided by the Data Subject
SMART ASSISTANT PERMISSION
To allow the User to control the devices connected to the App through Smart Assistant devices
Processed data:
• Name, Surname, Email
• Unique ID of connected devices
• Type of device to control (lights, shutters, thermostat, etc.)
• User assigned device name
DATA PROTECTION SUPPORT
To provide information on action taken on a request of a Data Subject to exercise rightsunder GDPR
Processed data:
• First name, Surname, Email
• Any additional information provided by the Data Subject
LEGAL OBLIGATION COMPLIANCE
Provided by current legislation and/or order given by Public Authorities
Processed data:
• Personal data required by law or by order of a Public Authority
PROTECTION OF RIGHTS
For the establishment,exercise or defence of legal claims in courts
Processed data:
• Personal data required to exercise rights
INFORMATION SECURITY MANAGEMENT
Management, maintenance and protection of IT infrastructure
Processed data:
• Data collected for User account registration purposes
• Data collected by the App
HOW LONG WE KEEP YOUR PERSONAL DATA
We will retain your personal data for as long as necessary to achieve the purposes as set out above.
The data collected for the purposes of App functionality will be retained for 30 days following the User’s request for erasure of data.
Please note that simply uninstalling the App from the User’s device is not enough to fully erase the collected data. To this end, the User can request the Data Controller to erase the data by using the contact form indicated above or, where available, the appropriate functionality within the App.
We may also be obliged to keep your personal data for a longer period in the case of legal obligation or by order of an Authority, or in case their use is necessary to the Data Controller for the establishment, exercise or defense of legal claims. At the end of the retention period your personal data will be deleted. Therefore, after this period, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.
TO WHOM WE DISCLOSE YOUR PERSONAL DATA
Your data will not be disclosed to third parties, unless where a law or a Public Authority requires us to do so, or in the event it is necessary for the establishment, exercise or defense of legal claims.
In addition, your data may be disclose to data processors, which are organizations external to ours that have been previously authorized to process your data on our behalf.
You will find in the table above the categories of recipients towhom we may disclose data.
In the case of use of Smart Assistant devices (e.g. Google Assistant ®, Amazon Alexa ®): after the User’s authorization, the App communicates the User’s identification data and the data relating to the connected devices to the third party providing the
service. Please refer to the personal data processing information provided, as independent data controller, by the Smart Assistant service provider
HOW WE PROCESS YOUR PERSONAL DATA
Your data will be processed by persons specifically authorized for this activity and/or by data processors, who are also authorized. The Data Controller verifies andchecks their work. The processing will be carried out with the aid of electronic tools (including automated means) in addition to manual means, always respecting the provisions of the Privacy Code and the GDPR, to guarantee the security and confidentiality of your personal data.
PUBLIC DISCLOSURE OF PERSONAL DATA
We do not use systems that make automated decisions based on personal data
AUTOMATED DECISION-MAKING
No personal data provided will be disseminated
TRANSFER OF PERSONAL DATA OUTSIDE THE EEA
Personal data are managed within countries belonging to the European Economic Area (EEA).
The Data Controller may need to transfer some data to suppliers and/or Finder Company subsidiaries based in countries outside the EEA, for reasons of personal data’s organization or to achieve the purposes indicated above.
In these case, the Data Controller will ensure that the information is properly protected, in accordance with the principles set out in articles 45 and 46 of GDPR, if necessary by entering into legal agreements governing the transfer of information by providing adequate guarantees.
DATA SUBJECT’S RIGHTS
As a Data Subject, you can exercise your Rights, as required by articles 13, 15-23 of the GDPR.
To do this, you can contact us through the contact form indicated above.
We will reply to you within one month. In cases of particular complexity of the request, we may reply to you within three months, but in this case we will notify you.
In summary, the Data Subject, with reference to personal data concerning him/her, has the possibility:
• To request access to personal data, rectification or erasure of personal data or restriction of processing;
• To object to processing;
• To data portability;
• To withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
• To lodge a complaint with a supervisory authority, which in Italy is constituted by the “Garante per la Protezione dei Dati Personali”, which can be contacted through the references found on the website http://www.garanteprivacy.it.
THE COMPLETE PRIVACY POLICY FOR FINDER YOU: https://cdn.findernet.com/app/uploads/FINDER_IN19E.EN_.0_privacy-policy-app-YOU.pdf
