Hiltron Srl VAT number 06947340631 with registered office in Naples via Strada Provinciale di Caserta, 218, in the capacity of Data Controller (hereinafter, also “Data Controller”), wishes to provide information regarding the processing of personal data , pursuant to current legislation on the protection of personal data (GDPR).
1) Categories of data being processed
The personal data provided by the Customer belong to the category of common data, consist mainly of identification data, and do not include sensitive, health, genetic, biometric, judicial data, or data referred to in the articles. 9 and 10 of EU Regulation no. 2016/679, as the processing of the latter categories of data is not necessary for the purposes pursued by the Data Controller.
The data may include the Customer's bank details, including the IBAN code, if this is necessary for the provision of the requested service.
Both at the time of signing the contract and/or in the pre-contractual phase and during the execution of the contract, only those personal data necessary for the pursuit of legitimate purposes will be requested and processed, with respect to which the processing will always be relevant and never excessive.
2) Source from which the personal data originates
The personal data being processed are mainly collected at the Customer's premises by employees and collaborators of the Data Controller appointed as Data Processors.
Personal data can also be collected at the offices of the Data Controller, from third parties specifically authorized by the Customer, or can be sent electronically by the Customer to the Data Controller.
3) Purpose of the processing
The Customer's personal data may be processed:
a) For the provision of the services covered by the contract to the Customer and the fulfillment of the related obligations as well as for the execution of specific pre-contractual measures requested by the Customer;
b) For the fulfillment of obligations established by law and community regulations;
c) For commercial, promotional, advertising and marketing purposes in the broad sense, which involve processing;
4) Consequences of failure to provide personal data and related consent for the purposes referred to in art. 3) letters a) and b)
The provision by the Customer of the personal data requested at the time of signing the contract or during the execution of the relationship, as well as the consent to the related processing, although they are left to the exclusive and autonomous will of the Customer, they are mandatory to allow the Data Controller to pursue the purposes referred to in article 3 letter a) of the information.
Therefore, in the absence of the provision of the aforementioned data and consent to the related processing, or even in the event of an express refusal to process the same, the Data Controller will not be able to carry out pre-contractual activities possibly desired by the Customer, will not be able to stipulate the contract with the Customer or fulfill to the obligations arising from the contract already stipulated and, furthermore, the Customer could incur contractual responsibilities towards the Owner.
The provision of this data is required also to allow the Data Controller to fulfill specific obligations established by law and community regulations, which may involve the processing of the user's personal data.
5) Consequences of failure to provide personal data and related consent for the purposes referred to in art.3) letter c)
Consent to the processing of personal data for the purposes referred to in letter c) it is purely optional.
By giving consent to the processing of personal data for commercial, advertising, promotional and marketing purposes in a broad sense, the user authorizes the processing of their data:
The user has the right to request at any time the Data Controller to limit the processing of personal data for the purposes referred to in the aforementioned art.3 letter c) to only some of the methods explained above (for example only through "traditional" means), or to only some of the marketing purposes specified above (for example, only to send newsletters).
6) Legal basis of the processing
The legal basis of the data processing for the purposes referred to in letter a) of article 3 consists in the fulfillment of the contractual obligations arising from the signing of the contract, or in the execution of pre-contractual measures adopted at the request of the Customer, as well as in the consent of the Customer.
The legal basis of the processing of personal data relating to the purposes referred to in article 3 letter b) consists in the fulfillment of obligations imposed by law or community regulations.
The legal basis of the processing of personal data relating to the purposes referred to in art. 3 letters c) consists exclusively in the prior, free, specific, optional and informed consent to the processing for the aforementioned purposes.
7) Treatment methods
The personal data provided by the Customer will be processed at the Data Controller's offices, or in other places where the parties involved in the processing operate, with electronic and/or mechanical and analogue methods for the time strictly necessary to achieve the purposes for which they were collected and in any case not exceeding the limits indicated in article 12, in full compliance with the purposes indicated in article 3, and, in any case, in compliance with current legislation on privacy.
Specific security measures are observed to prevent data loss, illicit or incorrect use of the same as well as unauthorized access.
8) Communications of personal data for the fulfillment of contractual or pre-contractual obligations or legal obligations
In compliance with current privacy legislation, the user's personal data may be communicated to third parties to whom communication is necessary for the pursuit of the purposes referred to in article 3 letters a) and b), without the need to acquire separate consent.
Pursuant to art. 13 letter e) of EU Regulation no. 2016/679, it is specified that the following categories of subjects may become aware of such personal data of the Customer:
9) Communications of personal data for the pursuit of promotional and marketing purposes
The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User's behavior.
10) Further communications of personal data
For the sole purpose of satisfying the legitimate interest of the Data Controller in the protection of his rights, the user's personal data may be communicated, without the latter's consent, to individuals and companies that carry out legal, tax and administrative consultancy activities. , tax or defense and technical assistance, both judicial and extrajudicial, who will act in the capacity of independent data controllers. Outside of these hypotheses, the Customer's personal data will not be subject to publication or further dissemination.
11) Dissemination and transfers of personal data to non-EU countries or to international organisations
The Data Controller will not disseminate the Customer's personal data and will not transfer them outside the EU or to international organizations.
12) Period of retention of personal data
Taking into account that the guarantee provided for by civil law, with reference to the contracting of works and, consequently, to the continuous and periodic provision of services, is 2 years from the delivery of the work or the provision of the service, the personal data provided by the interested party for the purposes referred to in art. 3 letter a) will be kept by the Data Controller for a period not exceeding 2 years starting from the termination of the contractual relationship, unless a previous request for cancellation is made by the interested party.
With reference to the purposes referred to in art. 3 letter c) for which the interested party has possibly given his consent, the storage and processing of personal data will last for a period not exceeding 12 months from collection, unless previously requested cancellation by the interested party.
In any case, the terms of five or ten years of conservation of only the documents and related data will be respected for the purposes of fulfilling the civil, accounting and tax obligations prescribed by current legislation, as well as for the legal protection of the Data Controller's rights.
13) Rights of the interested party
Pursuant to the articles. 13, co.2, letters b) and d), 15,18,19,21 of EU Regulation no. 2016/679, the interested party is informed that he may at any time exercise, by contacting the Data Controller directly, the rights referred to in the articles. From 15 to 23 of the aforementioned EU Regulation.
In particular, the interested party will be able to exercise:
14) Use of automated decision-making processes
The Data Controller will not subject the user's personal data to automated decision-making processes.
15) Data Controller - Data Controller - Data Protection Officer
For the exercise of the rights referred to in the articles. from 15 to 23 of EU Regulation n.2016/679, the Customer can contact the Data Controller at any time, whose identification details are indicated: Hiltron Srl – Strada Provinciale di Caserta,218, 80144 Naples – tel. 0817050912, e-mail info@hiltron.it.
The updated list of appointed data processors can be found at the indicated office of the Data Controller.
For myHiltron cloud services (XM Live) Hiltron Srl does not store passwords or device access codes in any way on its servers or in its databases.
Passwords saved in the Android / iOS apps are in no way shared with Hiltron Srl; However, the automatic cache copy of the package with all the settings (including passwords) on the cloud servers of the operating system producers may fall within the policies of the operating systems used; to remove such copies it is necessary to delve into the policies expressed by the operating system producers.
Hiltron Srl uses secure connections (SSL) to protect the information you share with us. SSL technology offers reliable protection of data from interception by third parties. We are constantly improving our security technologies to prevent system intrusions.
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