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Privacy Policy

Privacy Policy

Pursuant to Articles 13 and 14 of the European Regulation (EU) 2016/679 (hereinafter “GDPR”), and in relation to the personal data that will come into the possession of the Data Controller, we communicate the following:

Data Controller

Solution Tech S.r.l, Via Vittorio Veneto 1/C - 38086 Rovereto (TN) - E-mail: info@solutiontech.tech

Data Protection Officer (DPO)

To be specified.

Data Holder

Solution Tech S.r.l, Via Vittorio Veneto 1/C - 38086 Rovereto (TN) - E-mail: info@solutiontech.tech

1. Type of Data, Purpose, and Legal Basis of the Processing

The personal data processed through the use of the “Demo App” application (hereinafter also referred to as the “APP”) are the user’s name and last name, email address and the password entered during the registration phase. Furthermore, device location data, time zone settings, IP address, operating system details, names assigned to devices and homes, presets (i.e. comfort preferences), calendars, device product information (product codes, firmware versions), cloud connection details such as errors or software updates, wifi signal strength, requests and other product or device technologies used to access the service provided by the APP are collected.

The purposes of the processing consist of:

  1. home or remote management and control of the equipment purchased by the User, through their smartphone, tablet, or PC;
  2. providing remote technical assistance to the User.

The legal basis for the processing is the performance of a contract.

In the event that registration is carried out through a Google or Apple account, reference is made to their respective privacy policies:

2. How We Process the User’s Data

The Data Controller has adopted adequate security measures to preserve the confidentiality, integrity, and availability of the User’s personal data and imposes similar security measures on third-party suppliers and Data Processors. There is no automated decision-making process based on your data, including profiling. Data processing is carried out using information technology tools, with logic strictly related to the purposes of the processing itself.

Should the Data Controller intend to further process the User’s personal data for a purpose other than that for which they were collected, prior to such further processing, they will provide information regarding this different purpose and any further relevant information, asking, if necessary, for consent to the new processing.

The provision of personal data is optional. However, in order to benefit from the features of the APP for the purposes indicated above, a refusal to provide personal data makes it impossible to access and use the APP.

3. Recipients of Personal Data

Personal data are not subject to dissemination and may be processed exclusively by authorized persons or external data processors expressly appointed by the Data Controller for the purposes indicated in section 1 above.

4. Data Transfer Abroad

In the event that the User requests assistance by opening a ticket, the “Atlassian Jira Service Desk” software is used, which involves the transfer of data to third countries outside the EU in compliance with the provisions of the adequacy decision on the transfer of data to the United States (EU-US Data Privacy Framework) of 10.07.2023. The sub-processor Atlassian Inc. and its subsidiaries have obtained the self-certification of adequacy through the “Data Privacy Framework” (DPF) managed by the United States Department of Commerce (verifiable at the link https://www.dataprivacyframework.gov/list). The privacy policy of the sub-processor can be consulted at the link https://www.atlassian.com/legal/privacy-policy#how-we-transfer-information-we-collect-internationally.

Such transfer of data outside the EU is also permitted under Art. 49(b) of the GDPR, as it is necessary for the performance of a contract (the help desk assistance) at the request of the User.

5. Retention Period

The data are stored for up to 5 years from the last use of the APP, after which they will be permanently deleted.

6. User Rights

Pursuant to EU Regulation 2016/679 Articles 15 et seq. and the national legislation in force, the User may, in accordance with the procedures and within the limits provided by current legislation, exercise the following rights:

  • Right of access (Art. 15): to obtain confirmation as to whether or not personal data concerning them are being processed;
  • Right to rectification (Art. 16): to obtain the rectification of inaccurate personal data or the integration of incomplete data;
  • Right to erasure / “right to be forgotten” (Art. 17): to obtain the erasure of personal data under specific conditions;
  • Right to restriction of processing (Art. 18): to restrict processing under specific circumstances;
  • Right to data portability (Art. 20): to receive personal data in a structured, commonly used, and machine-readable format;
  • Right to object (Art. 21): to object at any time, on grounds relating to their particular situation, to the processing of personal data concerning them.

In general, to exercise their rights, the User may contact the Data Controller or the Data Protection Officer by writing to the contact details provided above.

Before providing a response, the Data Controller may need to identify the User by requesting a copy of their identity document.

A written feedback will be provided without unjustified delay and, in any case, no later than one month from receipt of the request itself. This period may be extended by two months, if necessary, taking into account the complexity and number of requests, as prescribed by Art. 12(3) of the GDPR.

7. EU Data Act

Documentation relative to the EU Data Act (Regulation (EU) 2023/2854), which grants consumers and businesses the right to access, use, and share the data generated by their connected smart devices, machines, and vehicles are publicly available here.