This information is provide by IRSAP Spa (Data Controller) for the processing of personal data belonging to the User/s of the Irsap Now app (Data Subjects) and is not to be considered as extended to other products and/or services provided by the Data Controller.

The app is available to the User/s due to the contractual relationship in being with the Data Controller.

1. DATA CONTROLLER 

The Data Controller is IRSAP SPA (Tax ID and VAT reg. no. 00040070294), with registered offices at Via delle Industrie 211, 45031 Arquà Polesine (RO). Tel. +39 0425 466611, fax +39 0425 466662, e-mail: support.smart@irsap.com.

2. DATA PROCESSED 

2.1 To use the app, the following personal data of the data subject will be processed:
- name,
- family name,
- email,
- telephone;
- account details 

2.2 The following data will also be processed in anonymous form: 

- approx. position of the system: Country/ZIP code
- exact position of the systems (if required by the User): Street, Town, Post code, Nation
- current status of system
- operating statistics of the systems
- data on terminal use

3. DATA COLLECTION METHOD 

The personal data as per point 2.1 will be provided directly by the Data Subject-User at the time of registration. 

The data as per point 2.2 will be stored by the IRSAP NOW devices and processed in anonymous form, while other data will be processed in aggregate form. 

4. PURPOSE OF PROCESSING - USE OF DATA 

4.1 Personal data processing, as in point 2.1 is carried out to: 

a) activate the application on mobile device and use the product with consultation and changes to current status of systems, management and recovery of credentials, development of new features, maintenance and use of the product (backup, prevention of attacks, security, system upgrades); 

b) promotional activities on the subject of the Data Controller’s products (marketing);
c) customer satisfaction surveys;

d) profiling (analysis and forecasting of personal and behavioural preferences linked to the use of the app). 

4.2 Personal data processing, as in point 2.2 is carried out to: 

a) use the product with consultation and changes to the current status of systems

a) warranty provision

c) provision of customer services

d) diagnostics for problems linked to product use

e) development of new features
f) continued operation of products (backup, prevention of attacks, security, system upgrades)

5. LEGAL BASIS FOR PROCESSING 

5.1 The legal basis for processing for the aims as in point 4.1 consists of:
- performance of a contract in which the Data Subject-User is party, or the performance of pre-contractual measures implemented at the request of same (art. 6 point 1, lett. b, Reg. EU 2016/679);
- The data subject’s consent to processing for promotional activities concerning the Data Controller’s products - marketing (art. 6 point 1, lett. a, Reg. EU 2016/679) and profiling;

5.2 The legal basis for processing for the aims as in point 4.2 consists of:

- performance of a contract in which the Data Subject-User is party, or the performance of pre-contractual measures implemented at the request of same (art. 6 point 1, lett. b, Reg. EU 2016/679);

6. RECIPIENTS OR CATEGORIES OF RECIPIENTS OF PERSONAL DATA

6.1 The data of the Data Subject-User will be processed by persons employed by the Data Controller (references and persons appointed/authorised for data processing), authorised for this purpose.

6.2 Data may also be processed by other, independent Data Controllers for reasons related to the service offered or closely linked to same.

On this point, please see the privacy policies of the platforms from which the app can be downloaded:

- Google play store https://policies.google.com/privacy 

- App Store https://www.apple.com/legal/privacy 

- store huawei https://consumer.huawei.com/it/campaign/appgallery/ 

6.3 Data can also be made known to external Managers, duly appointed by the Data Controller. An updated list of external Managers involved in data processing may be requested from the Data Controller at any time, at the following email: support.smart@irsap.com.

7. TRANSFER TO THIRD COUNTRIES 

Irsap Spa will not transfer data to third countries or international organisations. Nonetheless, data communicated to independent Data Controllers may be transferred to third countries.

With regard to the data protection guarantees offered by Google, Apple and huawei, please refer to their privacy policies, which can be consulted at the links provided in point 6.2.

8. RETENTION PERIOD   

The retention period for data as per points 2.1 and 2.2 is linked to the term of cancellation of the account, or to the longer terms set down in applicable regulations.

9. DATA SUBJECT’S RIGHTS 

The Data Subject-User has the right to request the following from the Data Controller:

- access to their own personal data (art. 15 Reg. EU 2016/679) 

- data portability (art. 20 Reg. EU 2016/679)

- correction (art. 16 Reg. EU 2016/679) 

- deletion (art. 17 Reg. EU 2016/679)  

- limits to processing (art. 18 Reg. EU 2016/679)

- opposition (art. 21 Reg. EU 2016/679) 

The Data Subject may enforce the above rights by sending notification by email to: support.smart@irsap.com
The Data Subject also has the right to submit complaint to the Data Protection Authority (art. 77 Reg. EU 2016/679).

10. PROVISION OF DATA 

The provision of personal data is a necessary requirement for using the service and Irsap Now app; therefore, failure of the Data Subject-User to provide said data will make it impossible to use the app.

11. PROFILING

Personal data may be subject to profiling (analysis and forecasting of personal and behavioural preferences linked to the use of the app).

12. DATA IN THIS POLICY 

12.1 This policy statement is valid as from 01/04/21 and the conditions therein may be updated in case of new versions of the app.

12.2 The data subject will be informed of any changes or updates by email/sms at the address/telephone number provided at the rime of registration.