Information TOI on the processing of personal data

(Privacy code – D.Lgs. 30.6.2003, No 196 and s. c. i. – EU Regulation 679/2016 on the processing of personal data – Art. 13)

TOI s.r.l. is a Limited Responsibility Company based in Pisa, Gate Centre, Largo Padre Renzo Spadoni 5616 (PI), carries out activities in the management of innovative technologies, with over 15 years of experience.

TOI is the holder and owner of the Zerynth project and mark by which it prepares, launches and manages its activities.

The dominion website “https://www.zerynth.com/” (hereinafter referred to as ‘the Portal’) and all its contents are owned by TOI s.r.l.

TOI s.r.l. is dedicated to the design and development of intelligent products and interconnected systems, to the simplification of the design and development of

applications for the industrial Internet of Things, Analytics and Software Services, system integration, with the partnership of Universities, leading companies in software, hardware and Cloud Data and management, distributors and value-added resellers, as best presented on the web portal https://www.zerynth.com/partners/.

TOI s.r.l. safeguards the privacy of its users and the security of the information and data that it processes through its stay on its web pages and has provided a detailed document that explains how to means of which the activity is in accordance with the Privacy rules.

This document describes, among other things, what personal data is collected, the purposes and methods of processing for which personal data are intended and the security measures taken to protect the themselves.

The Privacy TOI rules contain the necessary information pursuant to art. 13 EU Regulation no. 2016/679 (hereinafter referred to as “GDPR”), Directive 2002/58/EC, as amended by Directive 2009/136/EC, on protection of personal data in electronic communications, as well as in accordance with the provisions concerning the processing of particular categories of data, pursuant to art. 21, paragraph 1 of Legislative Decree no. 10 August 2018, n. 101 issued by the Guarantor for the Protection of Personal Data.

In particular, TOI informs that the “owner” of the processing pursuant to the Privacy Code is TOI s.r.l., based in Largo Padre Renzo Spadoni — 56126, Pisa (PI), Italy, in the person of its legal representative pro tempore, Dr. Gabriele Montelisciani.

The purpose of the treatment

The Portal “https://www.zerynth.com/” is a service designed to allow easy and clear use of information on products and services, research activities and TOI’s collaborations.

Personal data and all information collected are linked to access and stay on the Portal “https://www.zerynth.com/” and are:

a) as compulsory information which, pursuant to Article 6(b)(c) GDPR is necessary to use the Service and without which TOI cannot provide you with the requested access to the website and may concern:

– compulsory/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.

– log recording access to the site: IP address; date and time of access; state of access and state code http; volume of data transferred and content of the request; time difference in Greenwich (GMT) and language settings and browser versions, as well as versions of the operating system in use, navigation route within the site, any error;

– data on content placed by the user (e.g. requests for support in the Helpdesk dedicated Form, research query in the Articles section, revenue and/or functions of shared metatag within the chosen “head” form, which would configure Snippet within search engines) published by the user on the Portal;

– voice controls may be used for voice control of activities and services. Such functionality requires access to certain functions of your device to improve interactive experience. Your consent expressed through the controls of the device will enable the information to be collected for the specific purposes as indicated in the reference section.

In particular, in respect of mobile devices:

– Position: your explicit consent will allow the collection and use of sensor data necessary to access the information. This information will allow the specific position of your mobile device to be recorded (e.g. GPS or Bluetooth). In any event, registration of your IP address is essential for determining, for example, which country you are in order to comply with existing legislation and industrial property rights agreements.

– Voice: your explicit consent to access to the microphone will, if planned, increase the interactive experience with our services. You’ll always have the chance to disable access to the microphone.

Any refusal to communicate the data shall mean that it is impossible to complete the registration and to use the TOI services.

We will collect your contact information and, in case, authentication:

b) as information that can be rendered in an optional way, only with your specific and distinct consent (Art. 7 GDPR):

– for the following purposes of commercial information and marketing:

1) sending by e-mail, post and/or messaging, newsletters, commercial communications and/or advertising material on products or services offered by TOI and the satisfaction of the quality of services that require the processing of registration and authentication data: first name, last name, username, password, e-mail address, date of birth, gender, address, postal code and country. These types of data are optionally rendered by the user only by filling out the information request form and/or if the registration to the “newsletter” is required;

2) information and tools for collecting statistical data to measure the correspondence of products to the expectations of the users: Facebook pixel (https://www.facebook.com/business/help/7424786791253);

Cookies: the Portal “https://www.zerynth.com/” uses small textbooks that are stored in the memory of the terminal through the access browser, such as language and/or approaches preferred by the user, in order to make it more pleasant and more attractive to the user’s taste. TOI has provided an adequate information on the use and disablement of Cookies on its portal webpages, available at “https://www.zerynth.com/privacy/”

– for sharing purposes: information without identification and profiling elements will be shared with members and partners of TOI itself, to help trading partners provide us usefulness, services and promotional activities, and to improve the quality of services and products rendered, and to assess assumptions of business and work cooperation (“https://www.linkedin.com/psettings/privacy”) which you have submitted and therefore to your exclusive advantage.

In particular, expressing consent to allow data collection for statistical purposes and to improve interaction between TOI and the users and receive “exclusive offers and promotions” and/ or receive updates on initiatives related to TOI products for possible applications or job offers and positions, the user agrees and authorizes the collection, use, sharing and other treatment of their information, including any advertising purposes.

The data may also be communicated and shared with:

  • staff and consultants of TOI and Partner Companies and/or in any case connected with

TOI;

  • State financial administration and P.A.;
  • judicial authorities and police forces, where TOI receives a formal request from the judicial authority in relation to criminal investigations, other investigations and findings in relation to alleged breach of rules and rights of third parties;
  • subjects for the purpose of studying and publishing de-identified or aggregated information relating to the use of the Service.

Exclusion from treatment

In case of mobile access, will not be collected data on the functionality of your Hardware

support such as photos and camera; location; geo-location specific (touch screen data; information from the accelerometer sensors and gyroscope of the device, concerning the specific position of your mobile device, nor it’s possible interfacing with the applications proximity (iBeacon); voice; contacts; access data and preferences expressed during stay.

The portal is designed and intended for use by adults and not for use by children under 18 years of age. The use of identity credentials not corresponding to the user who intends to register constitutes illegitimate replacement of person and as such constitutes a crime against public faith.

Data retention

The only data to be collected, and referred to a) point above, will be retained on the servers that are dedicated to us in Germany at Hetzner Online GmbH (https://www.hetzner.com/rechtliches/datneschutz), appointed for this purpose, where they are processed in order to enable the functionalities described in this Information.

Data shall not be transferred outside the European borders without express and reasoned authorization. TOI shall ensure the maximum confidentiality of personal data by applying the most suitable technologies, in compliance with the Italian and European standards on minimum security measures to avoid unauthorized access to its databases, possible loss and/or accidental destruction of data.

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 locations, where the interested parties are located: in particular subjects appointed as “Data Processor”, pursuant to art. 4 GDPR, as well as the security personnel of telematic networks and generally the subjects who have been designated as “Chargers” of the processing pursuant to Art. 2 quaterdecies of the

Privacy Code to offer support to users in relation to the services offered by TOI, answering to requests by the Judicial Authority, to verify non-compliant behavior and for any other need.

TOI guarantees a daily backup of the data treated; backup data is saved on an AWS server in Ireland.

Exercise of rights by the data subject

TOI assures data subjects the possibility to exercise the rights recognized by art. 15 EU Regulation 679/2016 (GDPR) and precisely to:

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

2) get the indication:

(a) the origin of the personal data collected or processed;

(b) the purpose and arrangements of the processing;

(c) the categories of personal data object of the treatment;

(d) the period of retention of personal data if identified, otherwise the criteria used to determine the period;

(e) the logic applied in the event of treatment performed with the aid of electronic tools;

(f) the identification numbers of the Controller, the Chargers and the designated representative pursuant to Article 3(1) of Regulation EU 679/2016;

(g) persons or categories of persons to whom personal data may be communicated or may be known as representative designated in the territory of the State, of persons responsible or in charge;

3) request:

(a) updating, correcting and, if so, integration of data;

(b) cancellation, processing anonymously or blocking data processed into law infringement, including those for which storage is not necessary in relation to the purposes for which data have been collected or processed;

(c) the certification that the operations referred to in points (a) and (b) have been brought to the attention, including in respect of their content, of those to whom the data have been communicated or disseminated, except where such compliance proves impossible or involves the use of means manifestly disproportionate to the protection law;

4) object in whole or in part to the processing of data concerning you: a) for legitimate reasons, even if pertinent to the purpose of the collection; for the purpose of sending advertising or direct sales material or for the performance of market or commercial research, through the use of automated systems and/or by e-mail and/or by means of traditional marketing arrangements by telephone and/or paper mail. It is noted that the right of opposition (Art. 21 GDPR) can only be exercised partly. Therefore, the data subject may decide to receive only communications through traditional modes or only automated communications or neither types of communication.

(5) exercise the rights referred to in Articles 16-21 GDPR (Right to rectification, right to erasure (“right to be forgotten”), right to restriction of processing, right to data portability, right of object), and the right to complain to the Guarantee Authority.

The above rights may be exercised by contacting the Data Processing Controller, TOI s.r.l., based in Largo Father Renzo Spadoni – 56126, Pisa (PI), in the person of his legal representative pro-tempore, Ing. Gabriele Montelisciani, either by registered a/r, or alternatively by contacting us at the e-mail address privacy@zerynth.com.

The holder has the responsibility to accept pursuant to Article 12, par.6 GDPR, the identity of the data subject which intends to exercise the rights referred to above.

The updated list of the Processors and Chargers shall be kept at the registered office of the Processing Controller.

TOI undertakes to review regularly and update, where necessary, technical and organizational measures relating to data processing security.

TOI s.r.l.

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