Mobile App Policy information Privacy

Privacy Notice drafted pursuant to Article 13 of Regulation (EU) 2016/679
(European regulation on the protection of personal data)

Through this document, Eurotec S.r.l. informs users of the E-TEC app about the methods and purposes governing the processing of the personal data of anyone who uses the application.
This notice applies exclusively to this app and does not extend to other apps and/or websites that the User may access via any links contained herein.

1. Preamble

For the sake of brevity, the following conventions apply throughout this document:

· The E-TEC app was developed by Micronova S.r.l., which holds exclusive ownership and the economic/commercial exploitation rights, including those pertaining to the related source code.

· The terms “User” or “Users” refer to all individuals who are about to use the E-TEC app.

2. Legislation and Reference Documents

This notice is provided pursuant to Article 13 of Regulation (EU) 2016/679 (the General Data Protection Regulation, hereinafter GDPR) and to the applicable Italian legislation on the protection of personal data (Legislative Decree 196/2003, as amended by Legislative Decree 101/2018). It applies to all persons who interact with the E-TEC app and not to other applications and/or external websites that may be reachable via links within the app.

“Processing of personal data” means any operation or set of operations performed on personal data, with or without automated means, even if the data are not contained in a database. Such operations include: collection, recording, organisation, structuring, storage, processing, selection, restriction, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or any other form of making available, alignment or combination, restriction, erasure or destruction.

If the User is under sixteen (16) years of age, consent to the processing of personal data must, pursuant to Article 8(1) of the GDPR, be given or authorised by the holder of parental responsibility.

3. Data Controller

The Data Controller is Micronova S.r.l., with its registered office at Via Antonio Niedda, 3 – 35010 Vigonza (PD), Italy, represented by its legal representative pro tempore, who can be contacted at:

• Telephone: +39 049 8931563
• E-mail: info@micronovasrl.com

4. Data Processed

The data processed can be grouped into the following categories:

• registration data
• contact details
• personal identification data
• browsing data
• data voluntarily provided by the User
• data made available by other applications installed on the smartphone
• data generated by this App

For the purposes of this notice, these items are further divided into two macro-types:

1. Personal data – any information that identifies or makes the User identifiable.
2. Usage data – information collected automatically by the App during its operation.

4.1 Usage Data

In the course of normal operations, the Data Controller—through its IT systems, system application services, network devices, and software procedures that operate the E-TEC app—collects certain personal data whose transmission is implicit in the use of Internet communication protocols.

This information is automatically recorded in dedicated system logs while the User interacts with the app and includes:

• the IP address;
• the requested action;
• the date and time of the request;
• the parameters associated with the request.

4.2 Voluntarily Provided Data

When registering with the E-TEC app, the User is asked to supply the following mandatory information:

• product serial number
• MAC address of the communication gateway
• product model
• product part number
• product description
• e-mail address and password

The User may also enter the following optional data:

• Country
• Province/Region
• Municipality/City

At registration the app additionally requests permission to:

• communicate with the product’s gateway via Bluetooth
• access the camera to scan the QR or bar code on the product label and retrieve the serial number and/or gateway MAC address
• obtain the device’s geographic location
• send push notifications (denial of this permission may prevent the app—and the connected cloud platform—from delivering the full service)

In certain versions of the app, the User is also asked whether to allow:

• collection of the product’s operating data for monitoring, diagnostics and analytics
• automatic generation of a service code for the product manufacturer

5. Legal Basis for Processing

The E-TEC app processes personal data on the basis of:

• the legitimate interest of the Data Controller, pursuant to Article 6(1)(f) GDPR;
• the User’s consent, pursuant to Article 6(1)(a) GDPR.

By using the app, the User confirms that they have read this privacy notice and expressly consents to the processing of their personal data in the manner and for the purposes described herein.

Providing personal data—and the corresponding consent to their collection and processing—is necessary in order to continue using the app; without it, the services cannot be supplied.

Data type

Data type

Data type

Data type

Data type

Usage data

Legitimate interest

(Art. 6 UE)

Until the user account is deleted

Mandatory

1. To verify the proper functioning of the mobile app and for security reasons.

2. To ensure the security of the company’s IT systems.

Usage data

Legitimate interest

(Art. 6 UE)

Until the user account is deleted

Mandatory

3. To fulfil the performance of a contract to which the customer is a party.

Data voluntarily provided during registration

Consent (Arts. 4 & 7 UE))

Until the user account is deleted

Mandatory

3. To enable the user’s registration for the service.

Data voluntarily provided during registration

Consent (Arts. 4 & 7 UE))

Until consent is withdrawn

Optional

4. To broaden the company’s product and/or service offering and to improve its quality.

6. Methods of Processing

With regard to the two data categories described above, processing is carried out using electronic tools—namely system application services, network devices and automated procedures—operating both on the cloud platform and within the app. Data are retained only for the time strictly necessary to achieve the purposes for which they were collected.

Specific security measures are adopted to prevent data loss, unlawful or improper use and unauthorised access.

The processing of personal data encompasses all the operations listed in Article 4 of the Italian Privacy Code and Article 4(2) of the GDPR: collection, recording, organisation, storage, consultation, processing, alteration, selection, extraction, comparison, use, interconnection, restriction, communication, erasure and destruction.

6.1 Purpose of Processing

While using the E-TEC app, certain information is collected in order to:

• ensure the proper functioning of the application and its related services;
• protect the security of the system and of its Users, on the basis of the Controller’s legitimate interest.

For security reasons the system logs automatically store personal data such as the IP address, which—always in compliance with applicable law—may be used to:

• block attempts to damage the system;
• prevent or stop conduct that could harm other Users;
• counteract malicious or criminal activities.

These data are never used to identify or profile the User, but solely to safeguard the integrity of the system.

The voluntarily provided data are processed to understand Users’ needs and to improve the offering of products and services. Within the dedicated app screens, the User can grant or withdraw consent for any optional processing.

6.2 Retention Period

Voluntarily provided personal data are retained only for the time strictly necessary to fulfil the purposes outlined above. In accordance with Article 5(1)(e) GDPR, they are stored in a form that permits identification of the data subject for no longer than is required for those purposes.

The User may withdraw at any time any optional consents previously given and may delete their account, which will result in the removal of the related data unless retention is required by law.

6.3 Access to Information

The Data Controller guarantees that it will not sell or transfer Users’ personal data to third parties. All information collected is processed and protected in accordance with this privacy notice.

Service providers, duly authorised by the Controller, may be engaged to perform specific tasks—such as collecting or processing non-sensitive, anonymised data—on the Controller’s behalf, solely within the purposes described and under appropriate security and confidentiality measures.

6.4 Data Storage Location

The data are stored on the servers of the Data Processor.

7. Transfer to Third Parties

In line with the above, the data collected are processed exclusively within the European Economic Area.

8. Data Recipients

Access to the collected data is granted only to the Controller’s employees and collaborators who have been expressly authorised and who process the data under the Controller’s direct instructions, each according to their assigned duties.

9. Data Subject Rights

Pursuant to Articles 15 et seq. of the GDPR, the data subject (the natural person to whom the data refer) may, at any time, exercise the following rights:

· access to their personal data;

· rectification or updating of data that are inaccurate or incomplete;

· restriction of processing;

· erasure of data (“right to be forgotten”) when the data have been processed unlawfully;

· objection to processing.

These rights may be exercised provided that:

· they do not conflict with the Controller’s legitimate interests or with legal obligations;

· they are technically feasible;

· the data are still stored on the Controller’s servers and have not already been deleted.

To exercise these rights, the data subject may contact the Data Controller as follows:

· E-mail: info@micronovasrl.com

· Mail: Micronova S.r.l., Via Antonio Niedda 3, 35010 Vigonza (PD), Italy

· Telephone: +39 049 8931563

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali) by following the procedures set out on the Authority’s official website: www.garanteprivacy.it.

10. Methods for Exercising Rights

The exercise of these rights is free of charge and not subject to any formal requirements.
To request access, rectification, restriction or erasure of personal data, or to withdraw consent previously given, the data subject may:

· send a written notice to Micronova S.r.l., Via Antonio Niedda 3, 35010 Vigonza (PD), Italy;

· e-mail info@micronovasrl.com;

· call +39 049 8931563.

To make it easier for users to exercise the rights provided by the GDPR, the company has placed the following templates in the “Privacy” section of its website:

· Report to the Controller (Segnalazione_al_Titolare.pdf)

· Complaint to the Supervisory Authority (Reclamo_al_Garante.pdf)

11. Amendments to this Notice

This Privacy Notice may be updated or supplemented—also in light of legislative changes or measures issued by the Italian Data Protection Authority. Any changes will be promptly published in the “Privacy” section of the website and, where necessary, communicated to data subjects.

Last update: Verona, 2 May 2025