Pursuant to Legislative Decree No. 196 adopted on 30th June 2003 (“Data protection Law”), and subsequent amendments, we hereby supply you all due information about the processing of your personal data that you have provided as well as in compliance with the Opinion 2/2013 on apps on smart devices, adopted on 27th February 2013 and Opinion 8/2014 on Recent Developments on the Internet of Things (IoT) both issued by the Working Party 29, the independent EU Advisory Body on Data Protection and Privacy that has been established by Directive 95/46/EC, Section 29.
1. DATA CONTROLLER, under Legislative Decree no. 196/2003, Section 28, is Laboratori Fabrici srl with its registered office in Pordenone (Italia) at Piazzetta Ado Furlan 4, 33170 duly represented by its authorized person.
DATA PROCESSOR, under Section 29 of the aforementioned law is Graffiti 2000 S.r.l. with its registered office in Riva del Garda (TN) at Loc. Pasina, 46 – 38066.
2. CATEGORIES OF PROCESSED DATA
Personal data. Data provided on a discretionary basis
Personal data means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, e-mail phone number.
Potential sensitive data which reveal information about his or her health status if you provide possible allergies and/or breathing problems in general.
We collect data concerning your device connected via Mobile or Wifi or home wireless network. We collect information regarding the “status” of the said device.
We inform you that anonymous and aggregated data related to the interaction between your device and the environment will be provided to institutes/research laboratories for statistics purposes.
Personal data of children
Children may not give their personal data. Data Controller may not be held liable in case of any false statements made by children.
If you supply us with personal data belonging to third parties (relatives and interested parties in general), please be sure that those third parties have been correctly informed and have consented to the processing of their personal data, if required in compliance with this policy statement.
PLACE OF DATA PROCESSING
Data Controller processes your data related to such website (hosted by third parties) at its operating office. Your data may be processed either by Data Controller’s persons in charge or even by outsourcing service providers in the event of the maintenance and updating operations.
3. PURPOSES OF DATA PROCESSING WITH SPECIFIC CONSENT WHEN NEEDED (pursuant to D.LGS. 196/03, Section 23)
Data Controller processes your voluntarily provided data for the following purposes:
A) personal data processing related to Laboratori Fabrici srl’s APP for account creation in order to connect with your device, to supply you several services such as maintenance of your account and device. The APP may use the following information: history of both App and device, location of the device; mobile; photos /media elements /files stored on the device, external storage device; camera; network connection information; device ID. Such device has implemented a natural air purifying system. Thanks to such app you may connect to Clairy in order to:
- test indoor air quality;
- monitor temperature and humidity;
- turn on/off the fan of the flowerpot;
- get valuable tips to improve your health;
- share information with other devices.
B) with prior consent: potential sensitive data processing concerning health to ensure the best use of both Laboratori Fabrici srl’s App and device (input, pop-up notification and tip) interaction with user’s respiratory problems, unless you object to such processing.
C) with prior consent: location data processing to ensure the best use of both Laboratori Fabrici srl’s App and device (input, pop-up notification and tip) interaction with user’s respiratory problems, unless you object to such data processing.
D) with prior consent the App may, through Flurry Analytics di Yahoo, assess the user experience in order to improve its performance, collect information about your device and how you use it, unless you object to such data processing. For any further information please click on the following link http://www.flurry.com/solutions/analytics
E) with prior consent to direct marketing unless you object to such processing: Laboratori Fabrici srl, as Data Controller, may send you any newsletters, advertising materials, direct sale materials, market surveys and commercial information related also to upcoming events and campaigns, through electronic means, such as e-mail, SMS (Short Message Service), pop-up notification and the like as well as through mails or phone-calls with operator.
4. MEANS OF DATA PROCESSING – DATA RETENTION
Personal data will be processed by electronic, automated and/or manual means that may ensure the utmost security and confidentiality by authorized persons in compliance with those requirements provided by D. Lgs. 196/03, Section 31 and subsequent. Your personal data will be kept for a period not exceeding the purposes for which the data have been collected and subsequently processed. Data Controller uses platforms to send newsletters and commercial advertisements with a related report. Through this report, Data Controller may access to any information such as: the emails effectively sent and received, the number of openings, clickers, and clicks on single link.
5. COMMUNICATION AND DATA DISCLOSURE
Your processed data will be kept confidential and will not be communicated or disclosed to any other person or legal entity except those companies contractually bound to Laboratori Fabrici srl based in EU countries, in compliance with and within the limits set forth by L. Decree n. 196/2003, Section 42. Such data may be transferred to extra-EU countries in accordance with D.Lgs. n. 196/2003, Sections 43 e 44 lett. b). Your data will be disclosed to third parties belonging to the following categories:
– any third-party companies providing IT and network services to Laboratori Fabrici srl, including APP development; – any third-party consultants related to the APP management; – any competent authorities as prescribed by the applicable law, as recognized/enforced by any decisions or upon request. Such third parties are appointed Data Processor themselves otherwise they may operate as independent Data Controller. Data Processor are enlisted in a document that is constantly updated and available at Laboratori Fabrici srl’s operating office based in Pordenone (Italia) at Piazzetta Ado Furlan 4, 33170.
6. NATURE OF THE CONSENT- REFUSAL
You may provide your personal data on an optional and discretionary basis although it may be necessary to avail of the offered services with respect to those purposes stated at paragraph A) as well as use the app. However, failure to provide such data may affect your ability to obtain such services and/or to use the app.
You may provide your personal data on an optional and discretionary basis with respect to paragraph letter B); C); D); E). The refusal to submit your personal data for those purposes mentioned in letter B) and C) hereinabove may limit the use of the device. The refusal to submit your personal data for those purposes mentioned in letter D) and E) hereinabove will not affect data processing for the purposes stated in paragraph letter A).
At any time, you may uninstall the APP, for any further information please send an e-mail to email@example.com.
7. DATA SUBJECT RIGHTS
You may freely exercise your rights at any time under Legislative Decree no. 196/2003, Sections 7, 8, 9 and 10 by contacting the Data Controller Laboratori Fabrici srl, or by sending an e-mail to the following address firstname.lastname@example.org. You have the right, at any time, to obtain from the Data Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to personal data, verify their accuracy or request their rectification or erasure (please refer to D. Lgs. 196/2003, Section 7). For the purposes of such applicable law, you may demand the restriction of processing of personal data concerning the data subject, their pseudonymization or to object on legitimate grounds to such processing.
You may modify/update your personal data, demand to not receive any more communications or notification from your device, stop transmitting any further data, disable your account by sending an e-mail to email@example.com.
If you do not wish to receive anymore advertising and commercial direct marketing communications through e-mail, SMS, you may unsubscribe, at anytime, by sending an e-mail to firstname.lastname@example.org with sub. “unsubscribe from automated direct marketing communications” or by clicking the link unsubscribe form newsletter, so that you will not be bothered anymore.
If you do not wish to receive anymore marketing mails you may send an e-mail to email@example.com with sub. “unsubscribe from manual direct marketing communication” so that you will not be bothered anymore. If you do not wish to receive anymore communications at all you may send an e-mail to firstname.lastname@example.org with sub. “unsubscribe from marketing” at any time so that so that you will not receive any kind of advertising materials, direct sale materials, market surveys and commercial information.
Data Controller reserves the right to amend, update, add or remove any part of the current privacy statement at his own discretion and at any time. Please refer to this privacy statement regularly to review the updated version. In order to make this review easier for you, our privacy statement will outline the last update. Your use of the website signifies and constitutes your assent to and acceptance of the revised privacy statement.
9. SOCIAL LOGIN
Social Login is a form of single sign-on using existing information from a social networking service to sign into a third party website by sharing basic social account information. For example, User may use social login to rapidly sign into a third-party website or to take part in a competition or to buy on-line. In short, with prior user’s consent, the social network will share user’s personal data needed to login into a third-party website, without filling the registration form.
For any further information according to L. Decree 196/2003, Section 13, please refer to Third-Party policies hereinbelow mentioned where you can find a link to the policies and, if provided, give you the option to either provide or refuse your consent:
Facebook social login: https://developers.facebook.com/docs/plugins
Twitter social login: https://support.twitter.com/articles/20170519#
Google account login: https://www.google.com/policies/privacy/
Last update: 22.05.2017