For the purposes of this document, which has been produced pursuant to article 13 of EU regulation 2016/679 (hereinafter the “GDPR”), the following meanings will be used:
“Snap”: an air aspiration system equipped with sensors produced by Elica and named as such;
“Site”: the website reached by the URL www.snap.elica.com.
“App”: the software application known as Snap that allows remote control of Snap, as defined in the terms and conditions of use in the information section;
“Elica”: the company, Elica S.p.A., based in Via Ermanno Casoli no. 2, 60044 Fabriano (AN), Italy;
“User”: the person who access Snap functionality through the Site and the App.
1. Data Controllers and Data Processors
The Data Controller is Elica S.p.A., based in Via Ermanno Casoli no. 2, Fabriano (AN), Italy, postcode 60044.
The Data Protection Officer (pursuant to article 37 of the Privacy Regulation) is reachable at the following e-mail address: email@example.com (hereinafter the "RPD")
For an updated list of the Data Processors, send a request to the following email address firstname.lastname@example.org
2. Purposes for processing data
The operations carried out involve processing the User’s personal data for the following purposes:
a) to fulfil contractual obligations and, specifically, to allow the full use of Snap functionality through the services offered by the Site and the App;
b) to send promotional and commercial information via email, SMS, traditional postal services, or through the App itself, regarding Elica products or services or to carry out market research and customer satisfaction surveys;
3. Processing means
Processing User data will be done automatically using electronic and telematic tools, with data being organised and processed logically, and related to the purposes indicated above and, in any case, in such a way as to guarantee the security and confidentiality of data and communications. Data may also be processed in hardcopy (paper) format.
Personal data obtained through the interested party giving his/her consent, as well as environmental data, may be put into an anonymous form, also for the purposes of obtaining aggregated statistical data.
Snap and the App
The App, as per the Site, may store personal data entered by the User on the device on which the App is running and will transfer this data directly to Elica’s servers. Elica’s servers will communicate with Snap, even potentially transferring to it, in whole or in part, the data collected.
Snap may communicate personal data, as well as other environmental data (pressure, humidity, temperature, etc.) directly to Elica’s servers. This data may be transferred to the App or to the Site in order to allow the User to view it.
The information systems used to operate the Site and the App may acquire, as part of their operation, some data the processing of which is a characteristic element of Internet communication protocols. This data, where collected, may only be used for the purposes of controlling the Site’s and the App’s operating parameters and to obtain statistical information.
This category of data includes, purely by way of example, the IP address(es) of the device(s) used by the User, the number of accesses made, the pages viewed and the date they were viewed, the URL of the page viewed immediately before the page served by Elica’s servers, the type of browser used and the User’s operating system.
Browsing data, cookies and environmental variables
The information systems and the procedures used to operate the Site and the App automatically acquire, in the course of their normal operation, some personal data related to the User’s browsing habits, including environmental variables.
Cookies are small text files that many websites save on the User’s device in order to process certain information relative to the browsing activity when online; if cookies are not disabled or deleted, they are communicated to the website that initially created them every time the User returns to that site, or to third parties. The Site only uses technical cookies (known as session cookies), to manage and to maintain the User’s authentication during a browsing session, and persistent cookies, to keep the authentication active between one browsing session and another. If cookies are not disabled or deleted, they are communicated to the website that initially created them every time the User returns to that site, or to third parties.
Deleting or disabling cookies
In any case, a User may configure his/her browser to prevent cookies from being set or used. The settings are specific to each browser and can be identified in each browser’s privacy settings.
4. The obligatory or optional nature of providing data and the legitimacy of processing
Granting consent to process personal data supplied for the purpose referred to in point 2a, above, being optional, is not requested as necessary to fulfil the obligations deriving from a contract to which the interested party is a party; in the event that consent is not given, it will not be possible to fulfil the contract and provide Snap’s full functionality through the services offered by the Site and the App.
Granting consent to process personal data supplied for the purpose referred to in point 2b, above, is optional; in the event that consent is not given, no commercial communications will be sent.
With reference to the purpose referred to in point 2a, above, the legal basis for processing is to fulfil the obligations deriving from the contract to which the interested party is a party (pursuant to article 6(1)(b) of the Privacy Regulations); although, with reference to the purposes referred to in points 2b, above, the legal basis for processing is the User’s freely expressed consent, where granted (pursuant to article 6(1)(a) of the Privacy Regulations).
5. Scope of communication and data retention
For the purposes detailed above, the User’s personal data may become known to Elica employees working in the Marketing, Information Technology and R&D departments, appointed as people in charge of the processing.
Personal data may be communicated to qualified parties, appointed as external Data Processors pursuant to article 28 of the GDPR, who supply Elica with services, or even supplemental services to the purposes indicated above, as Data Processors. These companies may:
- manage and/or maintain the Site and the App;
- send informational and/or promotional communications, even communications of a commercial nature, or that including advertising material and/or offers of goods and/or services;
- perform profiling activities, including recording habits, tastes, preferences and consumer choices, as well as the relative processing.
Personal data subjected to processing by the App may be processed until the User requests the data’s deletion or until the User uninstalls the App from his/her device.
6. The interested party’s rights
The interested party may exercise his/her rights to access his/her personal data as provided for by article 15 of the GDPR, as well as the rights provided for by articles 16, 17, 18 and 21 of the same Regulation regarding correcting, deleting, limiting and opposing processing, in the manner established by article 12 of the GDPR.
The interested party also has the right to object, in whole or in part:
for legitimate reasons, to the processing of personal data concerning him/her, even if pertinent to the purpose of the collection;
to the processing of personal data concerning him/her for the purpose of sending advertising material.
The request to exercise a right may be made directly by using the specific FORM found on the website www.snap.elica.com, or by contacting the Data Protection Officer at the e-mail address as indicated above by point 1). Alternatively, rights may be exercised by sending an appropriate communication by registered letter with return receipt to Elica S.p.A., via E. Casoli n. 2, 60044 Fabriano (AN), Italy.
This document may be modified without notice.
User are therefore invited to consult this page from time to time.