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PRIVACY POLICY FOR THE APPLICATION “TRACKTING”

PRIVACY POLICY FOR THE APPLICATION “TRACKTING”

1. General

EIKON s.r.l. has created the commercial App “Trackting” and undertakes to adopt all necessary precaution to preserve the privacy of those using the Service it offers. This page informs the User on the Privacy Policy underlying the use of the application named “Trackting”, namely, on the policy adopted for collecting, using and disseminating Personal Data of those who use the Service.

It is specified that the User’s Personal Data are collected and used to make the Service more functional and easy to use, in compliance with the modalities established by the GDPR Regulation (EU Regulation 2016/679 effective from 25.05.2018). The collected User information and data will be used to provide and improve the Service and will not be used for purposes that are external or different from those specified in this Privacy Policy.

We reserve the right to modify and/or update this Privacy Policy, informing the User in the way deemed most appropriate. The Use of the Service will result in the acceptance of this Privacy Policy as modified. We recommend consulting this Privacy Policy periodically. By using the Service, the User accepts the collection and use of his Personal Data as specified in this Privacy Policy which, in compliance to the relevant regulations, stipulates that the treatment of Personal Data will always be based on the principles of lawfulness, fairness, transparency, limited data use and retention, minimization, integrity, accuracy and confidentiality.

Unless otherwise specified by the Privacy Policy, the terms used in this Privacy Policy have the same meaning as our Terms and Conditions. Please read the General Contract Conditions carefully, available on the www.trackting.com website.

Index

1. Data Controller.
2. Personal Data Processing.
A. Data Concerning Your Device.
B. Data Concerning Your Position.
C. Personal Data Concerning You.
3. Purpose of Processing
4. Personal Data Transfers.
5. Personal Data Retention.
6. Rights of the User

1. Data Controller

The Data Controller is the subject who (possibly in collaboration with third parties) establishes the way in which the Personal Data will be collected and processed and for what purposes. For the scope of this Privacy Policy, the Data Controller, responsible for the Personal Data of Users enjoying the Service provided by the App “Trackting” is EIKON s.r.l.
To obtain any information concerning the processing of your Personal Data by “Trackting”, including the list of responsible persons and operators involved in the processing of your Personal Data you may:
– Send a registered letter with notification of receipt to the EIKON s.r.l. registered office (Via Borgognina 5, 61030 Cartoceto, PU);
– Send a certified email to: info@pec.eikonsite.it.

2. Personal Data Processing.
When you install the App “Trackting” on your Device, we inform you that this App will process all your Personal Data in order to operate the Service properly and optimally.
Collected and processed Personal Data may consist of:  Personal Data required for User Identification; Personal Data concerning your Device in order to operate the Service properly and optimally; Personal Data concerning your Position and Geolocation and serving the intention of the Service; any other Personal Data voluntarily supplied by the User in order to improve the Service or to access additional Services.

A. Data Concerning Your Device.
By giving consent to the installation of the “Trackting” application, you automatically allow for its installation on your mobile Device as well as for having “Tracting” access some Data on it, only for the purpose of ensuring the correct installation and proper operation of the application. By installing the App “Trackting”, you automatically grant consent access to any information relating to the Device, such as: Device model, IP address, telephone number, operating system version, browser information, system updates, screen resolution, all information related to network connection and battery level, language settings, interaction information between our Services and app, browsers and devices, reports on abnormal operations or interruptions, information on date and time and any other Device identifying data used for running the Service. It is understood that all this information is shared because intrinsic to the app’s installation; denial of consent would prevent its installation and the provision of the Service.

B. Data Concerning Your Position.
Trackting uses and stocks Personal Data concerning your vehicle’s position in order to operate the App and the Service. Specifically, Tracker sends, via SIM, the GPS coordinates of your vehicle which are memorized, encrypted and stocked on the EIKON s.r.l. infrastructural cloud. The User can use the App to consult these in order to use the Services provided.

Trackting via the GPS coordinates ensures
– Anti-theft Service
– Location of the last Parking Position
according to the provisions of the General Contract Conditions.

To operate this Service, Trackting accesses Personal Data concerning your vehicle’s location and GPS coordinates which are sent via SIM to EIKON s.r.l., and therefore, to the User, to be visualized on the App from his Device.
Consenting to having location data relative to your SIM and vehicle processed is essential for operating the system. However, our main goal is to protect the Privacy of our clients. This is why location data required for operating the Service will be stocked in such a way as to impede access without the use of decrypting systems, as further explained in the section concerning how we stock your data.

C. Personal Data Concerning You.
The use of our Service is based on Personal Data Processing and specifically on processing information used to contact or identify you such as registration (name and surname) data and your email address.
Any Personal Data voluntarily and optionally integrated in the App and not essential for operating the service and will be stocked exclusively in your personal Device and will not be communicated to EIKON s.r.l.

3. Purpose of Processing.
The App “Trackting” will process your Personal Data for the following purposes:
a) to enable the Services requested by you, namely:  monitor the position and track non-authorized travel direction followed by your vehicle via the combined use of the App installed on your Device, of a wireless remote control and of “Tracker” by EIKON s.r.l.
b) to respond to assistance or information requests, that we will receive via the App.
c) To perform profiling activities that are strictly related to the provision of the Services you have requested.

The legal basis for Processing Personal Data relating to your Device and Geolocation for the purposes of points 3a, 3b and 3c is set out in Art. 6 c. 1 letter b) of the EU Regulation no. 679/2016, inasmuch as such processing is inherent to the Service provided and therefore “the processing of Personal Data is necessary to the execution of the contract stipulated with the interested party or for the execution of pre-contractual measures adopted at the request of the same”.  The provision of Personal Data for these purposes is optional but it is to be understood that failure to provide these data would make it impossible to activate and enjoy the Services supplied by the system.
d) complying to any legal, accounting and tax obligations;
e) to promote security and protection within and outside the Services, for example by analyzing suspect activities or violations of the Terms, to ensure use in accordance with the Law on Services; to identify, analyze, prevent and manage frauds and other illicit activities or technical and security problems; all in order to protect the rights, property and security of the Users and/or third parties.

The legal basis for Processing Personal Data for the purposes set out in 3d and 3e is Art. 6 c.1 lett. c) of the EU Regulation no. 679/2016 because, given the consent to the processing of Personal Data, the processing is necessary to fulfill legal obligations to which the Data Controller is subjected.

f) To elaborate studies, researches, market statistics, to send you information and advertizing material, commercial information or surveys to improve the App (“customer satisfaction”) via email or informative/advertizing banners within the App.

The legal basis for this processing is Art. 6 c. lett. a) of EU Regulation no. 679/2016, the processing of Personal Data for these purposes not being essential to the Service provided, the processing is therefore optional and the lack of consent does not affect the use of the Services.

Should the user wish to object to the processing of his Personal Data for marketing purposes, he may at any time do so by sending a request:
–  by registered letter with a receipt notification to the registered office of EIKON s.r.l. (Via Borgognina 5, 61030 Cartoceto, PU);
– by certified e-mail to: info@pec.eikonsite.it

or, in the case of push notifications, revoke your consent through the settings of the Device.

4. Personal Data Transfers

Your Personal Data are processed and stocked within the European Union but, in order to improve the Service, they could be shared with third parties that could be located outside of the European Economic Zone.  For more information, write to the following address:  support@trackting.com.
EIKON s.r.l. will take all the necessary measures to make sure that your data will be processed in a secure way, in compliance with this Privacy Policy and that no Personal Data transfer to an organization or country will occur unless your Personal Data and other Personal Information will be subject are properly handled and monitored.

5. Personal Data Retention.

Your Personal Data can be shared for the above mentioned purposes, with:
a. The persons that are responsible for the processing, namely: Personal subjects, companies or professional firms that act as consultants for EIKON s.r.l. in accounting, in accounting, administrative, legal, tax and financial matters; ii) subjects with whom it is necessary to interact for the provision of the Services (ex. hosting providers or platform providers for sending e-mails) iii) subjects delegated to perform technical maintenance activities (including maintenance of network and electronic communications networks); iv) subjects authorized by EIKON s.r.l. to process data with the necessary guarantees of confidentiality or according to the legal obligations of confidentiality (such as the employees of EIKON s.r.l.);

b. subjects, bodies or authorities to whom it is mandatory to communicate your Personal Data as requested by Law or by the AuthoritiesPersonal Data processed for the purposes set out in section 3a, 3b and 3c will be kept for the time strictly necessary to achieve these purposes. In any case, being these processes inherent to the Service, pursuant to Art. 6 c.1 lett. b),EIKON s.r.l. we will process your Personal Data no longer than the period foreseen by Italian law, to protect its own interests (Art. 2946 c.c. and ss.).
Personal Data processed for the purposes set out in section 3d and 3e will be kept for the time necessary to fulfill any specific obligation or applicable law.

For the purposes set out in section 3 f), your Personal Data will be processed until revocation of your consent and / or until you oppose to their use. In any case, EIKON s.r.l. reserves the right to keep your Personal Data for up to the period allowed by Italian law to protect its own interests (Art. 2947c.c.).

Your privacy is important for EIKON s.r.l., therefore we want to ensure maximum clarity regarding the processing of your data related to location and geolocation, as this data may be source of sensitive information.

Therefore, data will be stocked using cryptographic systems (AES) in order to prevent third parties from accessing your sensitive data. Further information about data retention period and methods as well as on the criteria used to determine the period may be required:
– By sending a registered letter with receipt notification to the registered office of EIKON s.r.l. (Via Borgognina 5, 61030 Cartoceto, PU);
– By sending a certified email to: info@pec.eikonsite.i

6. Rights of the User
According to the Applicable Regulations, the Data Controller informs the Users of their right to obtain indication on (i) Personal Data provenience; (ii) processing purposes and methods; (iii) logic used for eventual processing carried out by electronic instruments; (iv) identification details of Data Controller and operators; (v) subjects or categories of subjects to whom the Personal Data may be communicated or on responsible persons or operators that may be exposed to them.

Furthermore, Users have the right to obtain:
1. access, updating, rectification or, when interested, integration of their data;
2. cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
3.  attestation that the operations referred to in letters 1) and 2) have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or divulgated, except in the case where such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right.

Furthermore, Users have:
1. the right to withdraw consent at any time, if the processing is based on their consent;
2. the right to data portability (right to retrieve all Personal Data in a structured format, commonly used and readable by automatic devices), the right to limit their Personal Data processing and the right to cancellation (“Right to be forgotten”);
3. the right to oppose:

a- in whole or in part, for legitimate reasons, to the processing of their Personal Data, even if consistent with the purpose of collection.

b- Users who consider that their Personal Data have been processed in violation with the Regulation, have the right to lodge a complaint with a supervisory authority (in the Member State in which they normally reside, in the one in which they work or in the one of the alleged violation). The Guarantor for the protection of Personal Data is the Italian Supervisory Authority, located in Piazza di Monte Citorio n. 121, 00186 – Rome (http://www.garanteprivacy.it/).

LAST DATE CHANGE: NOVEMBER 21st 2018