INFORMATION PURSUANT TO ART. 13 OF EU REGULATION N. 2016/679
The content of relevant joint-controlling’s agreement can be viewed by making a request through the contact details in art. 7.
B810 GROUP processes (but does not retain), in order to execute the specific processing purposes described in art. 2., your personal data pursuant to art. 4 n. 1) of GDPR, consisting of following specific your personal information (hereinafter only “personal data”) or, in the case, non-personal information pursuant to art. 3 n. 1) of EU Regulation n. 2018/1807: (i) telephone number associated with the SIM card in use on the device described in art. 2.1. letter a); (ii) personal information (or, in the case, information of a merely technical/configuration/setting nature), contained within one or more SMS received by you, and concerning (or in any case, related to) exclusively the pursuit of the processing purposes set out in the following art. 2; (iii) data relating to your location, processed, in accordance with the settings predefined by app store’s manager, in order to execute, in a complete manner, the processing purposes described in art. 2 (in particular, the one indicated in letter a) of art. 2.1.).
Your personal data are processed, by B810 GROUP, for the performance of following processing purposes, which are to be considered interdependent and interconnected:
Send and/or receive configuration commands, via SMS and/or bluetooth, from/to DIGICOM’s gateway or router, enabled to this functionality (e.g. “2G LIFT DIALER” and “4G LIFT DIALER” product) even after the publication of the mobile software application in question named “Look@LIFT” (hereafter “App”);
Possibility to send one or more SMS for the purpose of configuring the selected device, and possibility to access one or more SMS received from you and concerning (or in any case, connected to) exclusively the execution of the processing purposes set forth in art. 2, in order to obtain a response to the configuration commands set and selected and to view the response within App.
In compliance with article 13 paragraph 2) letter e) of GDPR, B810 GROUP informs you that any failure to communicate your personal data (specifically, represented by points (i) and (iii) of art. 1.1.) determines the impossibility, by B810 GROUP, to perform, correctly and completely, the processing purposes referred to in art. 2.
In this regard, B810 GROUP points out to you that the legal basis of the processing purposes referred in article 2 is found in article 6 paragraph 1) letter b) of GDPR.
In compliance with art. 13 paragraph 2) letter a) of GDPR, B810 GROUP hereby specifies that, as mentioned in art. 1.1 above, it will not store, either through App or any other means (automated, partially automated, non-automated), your personal data for execution of processing purposes referred in art. 2.: in this regard, B810 GROUP further specifies that your personal data referred in point (i) of art. 1.1 are processed only during the configuration phase and are therefore not stored in any way since, once App is closed, such information is automatically deleted (as is your personal data referred in point (ii) of art. 1.1); B810 GROUP points out, moreover, that your personal data (and/or your non-personal data) referred in point (ii) of art. 1.1. are subject, by B810 GROUP, only to a viewing activity and are not, therefore, stored in any way, given that, once App is closed, this information is automatically deleted; B810 GROUP adds, finally, that your personal data referred in point (iii) of art. 1.1. are processed (but not stored, in any way), in accordance with the settings made by app store’s manager, in order to execution the processing purposes described in art. 2 (in particular, the one indicated in letter a) of art. 2.1.).
In compliance with art. 13 paragraph 1) letter e) of GDPR, B810 GROUP specifies that your personal data referred in point (i) of art. 1.1. may be communicated, if appropriate and necessary, to one or more recipients pursuant to art. 4 n. 9) of GDPR identified by category as follows: (i) for the performance of the processing purposes referred in art. 2: IT companies.
Finally, B810 GROUP informs you that your personal data will not be disseminated in any way.
In compliance with article 13 paragraph 1) letter f) of GDPR, B810 GROUP informs you that there will be no transfer of your personal data to a country outside the European Economic Area (EEA) or to an international organisation.
In relation to your personal data, B810 GROUP informs you of your right to exercise the following rights, which may be subject to the limitations set out in articles 2 undecies and 2 duodecies of amended Legislative Decree n. 196/2003 (Privacy Code): right of access under article 15 of GDPR: right to obtain confirmation as to whether or not personal data is being processed, as well as the information referred in article 15 of GDPR (e.g. purpose of processing, storage period); right to rectification under article 16 of GDPR: right to correct, update or supplement personal data; right to erasure under article 17 of GDPR: right to obtain the erasure or destruction or anonymization of personal data, where, however, the conditions listed in the same article apply; right to restriction of processing ex art. 18 of GDPR: a right with a markedly precautionary connotation, aimed at obtaining the restriction of processing where the assumptions governed by the same art. 18; right to data portability ex art. 20 of GDPR: right to obtain personal data, provided to B810 GROUP, in a structured, commonly used and machine-readable format (and, if required, to transmit them directly to another Controller), where the specific conditions indicated in the same article exist (e.g. legal basis of consent and/or performance of a contract; personal data provided by the data subject); right to object ex art. 21 of GDPR: right to obtain the cessation, on a permanent basis, of a specific processing of personal data; right to lodge a complaint with Supervisory Authority (i.e. Italian Privacy Guarantor) ex art. 77 of GDPR: right to lodge a complaint where it is believed that the processing under analysis violates national and EU legislation on the protection of personal data.
In addition to the rights described in art. 6.1. above, B810 GROUP specifies that, in relation to your personal data, there is, if possible and conferring, the right to exercise, on the one hand, the (sub) right provided for by art. 19 of GDPR (“The controller shall communicate to each of the recipients to whom the personal data have been transmitted any rectification or erasure or restriction of processing carried out pursuant to article 16, article 17, paragraph 1), and article 18, unless this proves impossible or involves a disproportionate effort. The data controller shall inform the data subject of such recipients if the data subject so requests"), to be considered connected and related to the exercise of one or more of the rights regulated in articles 16, 17 and 18 of GDPR; on the other hand, B810 GROUP informs you that, in relation to your personal data, there is, if possible and conferring, the right to exercise the right provided in art. 22 paragraph 1) of GDPR (“The data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar way”), subject to the exceptions provided for in paragraph 2) below.
In accordance with article 12 paragraph 1) of GDPR, B810 GROUP undertakes to provide the communications referred in articles from 15 to 22 and 34 of GDPR in a concise, transparent, intelligible, easily accessible form and in simple and clear language: such information will be provided in writing or by other means that may be electronic or, at the request of data subject, will be provided orally provided that the identity of the latter is proven by other means.
In accordance with article 12 paragraph 3) of GDPR, B810 GROUP informs you that it undertakes to provide information relating to the action taken in respect of a request pursuant to articles from 15 to 22 of GDPR without undue delay and, in any event, at the latest within one month of receipt of such request; such period may be extended by n. 2 months if necessary, taking into account the complexity and number of requests (in this case, B810 GROUP undertakes to inform you of such extension and the reasons for the delay, within one month of receipt of the request).
The rights described above (with the exception of the right pursuant to article 77 of GDPR) may be exercised using the contact details set out in article 7 below.
GROUP B810 may be contacted at the following alternative addresses: info@b810group.it; privacy@digicom.it; mcregem@legalmail.it.
The Data Protection Officer (DPO), appointed by GROUP B810 pursuant to article 37 paragraph 2) of GDPR, can be contacted at the following alternative addresses: privacydpo810@baldiandpartners.it; privacydpodigicom@baldiandpartners.it; dpomcregem@baldiandpartners.it
Reggio Emilia/Legnano, 5.10.2021 (date of last update)
(in the person of their respective pro tempore legal representatives)