ZERYNTH DATA PROTECTION POLICY

ZERYNTH DATA PROTECTION POLICY

zerynth.com

Last Modified: 04/05/2021

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Privacy Code (Legislative Decree 30.06.2003 no. 196). – General Data Protection Regulation (EU Reg. 679/2016, – art. 13).

PREMISES

  • A – Zerynth is a Limited Liability Company based in Pisa (56124), Galleria Giovanni Battista Gerace no.14, born in 2015 by the will and delight of experts in advanced robotics, Internet of Things and management of innovative technologies, with over 15 years of experience.
  • B – Zerynth, holder, and owner of the project and of the Zerynth brand, is active in the design, construction, and sale of IoT (Internet of Things) solutions, mobile software applications, web, stand alone and embedded, electronic, mechatronic, and intelligent devices. , analysis and measurement tools, uniquely identified in its reference market with the “Zerynth” brand.
  • B – The domain website “https://zerynth.com/” (hereinafter, “the Portal”) and all its contents are owned by Zerynth S.p.A
  • C – The Portal for which access was requested by accessing the URL https://zerynth.com/ complies with the General Data Protection Regulation (EU Reg. 679/2016, hereinafter “GDPR”) and already of Privacy Code (Legislative Decree 30.06.2003 no. 196) as well as the consumer decree and allows users in navigation to benefit from the features in compliance with the law.
  • D – Zerynth is attentive to the protection of the privacy of its users and the security of the information and data it processes by staying on its web pages and has provided a detailed document that illustrates the methods by which the activity complies with the Privacy Rules. This document describes, among other things, which personal data are collected, the purposes and methods of processing for which the personal data are intended and the security measures adopted for the protection of the same.
  • E – Zerynth informs that the “holderof the processing pursuant to the Privacy Code is Zerynth S.p.A, with registered office based in Pisa (56124), Galleria Giovanni Battista Gerace no.14, 56124, in the person of its pro tempore legal representative, Eng. Gabriele Montelisciani.

Purpose of the processing

The portal https://zerynth.com/ was created to allow easy and clear use of information relating:

  1.  know the skills, purposes, activities and brands of Zerynth, including their specific technological characteristics, fields of application and use in general;
  2.  know aspects, methods and sectors of commercial communication of brands and / or products and services referable to Zerynth;
  3. to the goods and services offered by Zerynth, also by downloading programming guides, information material, as well as by accessing the Zerynth Tutorials.
  4.  to keep in touch with Zerynth to receive information and commercial proposals.

Personal data and all information collected when accessing and staying on the Portal “https://zerynth.com/” and are configured:

  1. a) as mandatory information which, pursuant to art. 6 letter b), e) GDPR are are necessary in order to use the Service and without which Zerynth will not be able to provide you with the requested access to the website and may concern:
  • Obligatory / necessary information for technical reasons to make available and / or facilitate access to the Portal and will be collected and stored and used for a short time.
  • logs that record access to the site: IP address; date and time of access; access status and http status code; volume of data transferred and content of the request; time zone differences compared to Greenwich (GMT) and language settings and browser versions, as well as versions of the operating system in use, navigation path within the site, any errors
  • data relating to the contents entered by the user (eg. support requests in the dedicated Helpdesk form, search queries in the Articles section, check marks and / or sharing functions of “meta tags” within selected “heads”, such as to configure Snippets within search engines) published by the user on the Portal;
  • it will be possible to use voice commands for voice control of activities and services. These features require access to certain functions of your device in order to improve the interactive experience. Your consent expressed through the commands of the device will allow the collection of information for the specific purposes indicated in the reference section.
  • In particular, in relation to mobile devices:
  • Location: your explicit consent will allow us to collect and use data relating to the sensors necessary to access the information. This information will allow the recording of the specific location of your mobile device (using, for example, GPS or Bluetooth). In any case, the registration of your IP address is essential to determine, for example, which country you are in in order to comply with existing legislation and industrial property agreements.
  • Voice: Your explicit consent to access the microphone will allow, if applicable, to increase the interactivity of the experience lived with our Services. You will always have the option to disable microphone access.
  • Any refusal to communicate the data will make it impossible to complete the registration and use the Zerynth services. 
  • We will collect and encrypt your authentication password.
  1. b) as information that can be provided on an optional basis, only with specific and distinct consent (Article 7 of the GDPR):
  • for the following commercial and marketing information purposes:
    1. sending via e-mail, post and / or messaging, newsletters, commercial communications and / or advertising material on products or services offered by Zerynth and detection of the degree of satisfaction with the quality of services that require the processing of registration and authentication data: name, surname, username, password, email address, date of birth, gender, address, postcode and country. These types of data are optionally provided by the user only by filling out the information request form and / or where subscription to the “newsletter is required”;
    2. information and tools for collecting statistical data to measure the correspondence of products to the expectations of Users: Facebook pixel (https://www.facebook.com/business/help/742478679120153).
  1. c) Cookies: the “https://zerynth.com/” Portal uses small text files that are stored in the memory of the terminal via the access browser, such as the language and / or settings preferred by the User, in order to to make browsing more pleasant and consistent with the User’s tastes. Zerynth has provided adequate information on the use and disabling of cookies on the web pages of its portals, which can be found athttps://zerynth.com/privacy
  • for sharing purposes: information without identifying and profiling elements will be shared with the MEMBERS and Partners of Zerynth itself, to help business partners to provide us with utilities, services and promotional activities, as well as to improve the quality of services and products returns, as well as to evaluate hypotheses of commercial and working collaboration (“https://www.linkedin.com/psettings/privacy”) submitted by you and therefore to your exclusive advantage.

In particular, by giving consent to allow the collection of data for statistical purposes and to improve the interaction between Zerynth and the User and to receive “exclusive offers and promotions” and / or to receive updates on initiatives related to Zerynth products for any applications or for offers and job positions, the user consents and authorizes the collection, use, sharing and other processing of their information, including any advertising purposes.

The data may also be communicated and shared with:

  • personnel and consultants of Zerynth and Member Companies and / or in any case Connected to Zerynth
  • State Financial Administration and Public Administration; o Judicial Authorities and police enforcement, if Zerynth receives a formal request from the judicial authority in relation to inquiries, investigations and verifications regarding the alleged violation of the rules and rights of third parties; 
  • subjects with the purpose of studying and publishing de-identified or aggregated information relating to the use of the Service.

In the event of access from mobile support, data relating to the functionality of your hardware support such as photos and cameras will not be collected or processed; position; specific geo-location (data from the “touch screen”; information from the accelerometer and gyroscope sensors of the device, relating to the specific position of your mobile device, it is possible to interface with proximity applications (i.e .: iBeacon); voice; contacts; data relating to accesses and preferences expressed during the stay.

The Portal is designed and intended for use by adults and not for use by children under the age of 18.

The use of identity credentials that do not correspond to the user who intends to register constitutes an illegitimate replacement of a person and as such constitutes a crime against public faith.

The use of identity credentials that do not correspond to the user who intends to register constitutes an illegitimate replacement of a person and as such constitutes a crime against public faith.

Data Retention

The only data that will be collected and referred to in point a) above, will be stored on servers dedicated to us located in Germany at Hetzner Online GmbH https://www.hetzner.com/rechtliches/datenschutz), appointed by Zerynth, where they will be processed in order to allow the functions described in this information.

The data will not be transferred outside the European borders without express and justified authorization

Zerynth guarantees the maximum confidentiality of personal data by adopting the most suitable technologies, in compliance with Italian and European standards in terms of minimum security measures aimed at averting and preventing unauthorized access to its databases, data breach, as well as any loss and / or accidental destruction of data.

The access to personal data will also be allowed to the staff of all the operational offices of the Data Controller and in all other processing places, where the interested parties are located: in particular to the subjects appointed “Data Processor Responsible”, pursuant to art. 4 GDPR, as well as to those in charge of the security of telematic networks and in general the subjects who have been designated as “Persons in charge” of the processing pursuant to Article 2 quaterdecies of the Privacy Code to offer support to users in relation to the services offered by Zerynth, to respond to requests from the Judicial Authority, to verify non-compliant behavior and for any other need.

Zerynth guarantees a daily backup of the data it processes; the backup data is saved in EU, on an AWS server in Ireland and on Hetzner servers in Germany and Finland.

Exercise of rights by the interested party

Zerynth assures the interested parties the possibility of exercising the rights recognized by art. 15 EU Regulation 679/2016 (GDPR) and precisely:

1) to obtain information about the existence or not of personal data concerning you and their communication in an intelligible form (right of Access – Art 15 GDPR).

2) to obtain the indication:

  1. a) the origin of the personal data collected or processed; 
  2. b) the purposes and methods of the processing; 
  3. c) the categories of personal data being processed; 
  4. d) the retention period of personal data if identified, otherwise the criteria used to determine the aforementioned period; 
  5. e) the logic applied in case of processing carried out with the aid of electronic tools; 
  6. f) the identity of the owner, manager and the representative appointed pursuant to art. 3, paragraph 1, EU Regulation 679/2016; 
  7. g) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, managers or agents.

3) request:

  1. a) the updating, rectification and, in hypothesis, the integration of data; 
  2. b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including data which need not be kept for the purposes for which the data were collected or subsequently processed; 
  3. c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment is proves impossible or involves the use of means that are manifestly disproportionate to the protected right.

4) to oppose, in whole or in part, to the processing of personal data concerning you: a) for legitimate reasons, even if pertinent to the purpose of the collection; b) for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated systems and / or by e-mail and / or by traditional marketing methods by phone and / or paper mail. Please note that the right to object (Article 21 GDPR) can also be exercised only in part. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or neither of the two types of communication.

5) to exercise the rights referred to in Articles 16-21 GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

The aforementioned rights may be exercised by contacting the Data Controller Responsible, Zerynth S.p.A, based in Galleria Giovanni Battista Gerace no. 14 – 56124, Pisa (PI), in the person of its pro-tempore legal representative, Eng. Gabriele Montelisciani, by registered letter with return receipt, or alternatively by contacting us at the e-mail address privacy@zerynth.com. The Data Controller Responsible has the duty to ascertain pursuant to Article 12 paragraph 6 GDPR, the identity of the interested party.

The updated list of data processors and persons in charge of processing is kept at the registered office of the Data Controller Responsible. 

Zerynth undertakes to periodically review and update, where necessary, the technical and organizational measures relating to the security of data processing.

Zerynth S.p.A.