ATASSpro Mobile App

PRIVACY POLICY TECHNOALPIN S.P.A.

Dear User,

as the Data Controller of the processing of personal data (hereinafter: “Data Controller”) pursuant to Italian Legislative Decree 196/2003 and subsequent amendments – Italian Personal Data Protection Code (hereinafter: “Privacy Code”) – TECHNOALPIN S.p.A. acknowledges the importance of protecting personal data and considers privacy and the safeguarding of personal data one of the key objectives of its business. We therefore invite you, before communicating any personal data to the Controller, to carefully read this Privacy Policy since it contains important information regarding your privacy, the protection of personal data and the security measures adopted to ensure confidentiality of the same in full compliance with the applicable regulations. In addition, this Privacy Policy:

is understood as given for the ATASSplus mobile application (herein: “Application”) managed by the Data Controller;
this Policy does not apply to processing performed by the Data Controller and consulted via external links or other functions and services provided by the Data Controller through its website; ● is an integral part of the Data Controller's Application;
is to also be understood as the Information required pursuant to art. 13 of the Privacy Code to those interacting with the Application;
complies with Recommendation no. 2/2001 regarding the minimum requirements for gathering data online in the European Union, adopted on 17 May 2001 by the Working Group “Article 29”

The Data Controller informs you that your personal data will be processed in keeping with the principles of correctness, legality, transparency and the protection of your confidentiality and your rights. Your personal data will therefore be processed in compliance with the legislative provisions of the Privacy Code and the confidentiality requirements provided for therein.

INDEX

The index of this Privacy Policy is provided below to help you find the information you are interested in relative to the processing of your personal data.

DATA CONTROLLER AND DATA PROCESSORS OF THE PERSONAL DATA
PERSONAL DATA SUBJECT TO PROCESSING
2.1 Navigation data
2.2 Data provided voluntarily by the user
2.3 Geopositioning
2.4 Cookies
PURPOSES OF PROCESSING AND OBLIGATORY OR OPTIONAL NATURE OF PROVIDING DATA
METHOD OF PROCESSING, SECURITY AND PLACE WHERE DATA IS PROCESSED
COMMUNICATION AND DISSEMINATION
YOUR RIGHTS
AMENDMENTS
CONTACTS

1. DATA CONTROLLER AND DATA PROCESSORS OF THE PERSONAL DATA

Following consultation and use of the Application, data relative to physically identified or identifiable persons may be processed. The identifying details of the Data Controller and Application operator are as follows:
TECHNOALPIN S.p.A., with registered office in Via Agostini no.2, 39100 Bolzano, VAT and Tax ID Code no. 02791150218.

Your personal data may be brought to the knowledge of employees or collaborators of the Data Controller, belonging to the categories of administrative, sales, legal, and accounting personnel or the administrators of computer systems depending on the processing, who acting under the direct authority of the latter, are appointed processors or persons in charge of processing pursuant to arts. 29 and 30 of the Privacy Code and who receive appropriate operating instructions in such regard. In compliance with art. 13.1.f of the Privacy Code, one of the data processors is Thomas Möltner. The updated list of data processors is available from the Data Controller and may be requested by writing to privacy@technoalpin.com.

2. PERSONAL DATA SUBJECT TO PROCESSING

2.1 Navigation data

During their standard operation, the computer systems and software procedures used for running the Application acquire some personal data, the transmission of which is implicit in the use of Internet communication protocols. This information is not gathered to be associated to identified parties but by its very nature could, through processing and association with data stored by third parties, allow identification of the users. This category of data includes the IP addresses or domain names of the devices used by users connecting to the application, the addresses in URI (Uniform Resource Identifier) form of the resources requested, the method used to submit the request to the server, the size of the file obtained in response, the code number indicating the status of the response given by the server (successful, error etc.) and other parameters relative to the operating system and IT environment of the user. This data is used to derive anonymous statistical information on the use of the Application and to check that it functions correctly, to enable – given the architecture of the systems used – the correct provision of the various functions requested by the user, for the functioning of the Application and the provision of the services offered, for security reasons and for ascertaining liability in the case of hypothetical computer crimes against the Application or third parties, and is generally deleted or rendered anonymous after seven days.

2.2 Data provided voluntarily by the user. Registration procedure

By registering on the Application the following information may be gathered: e-mail address, Sim Card ID, Android ID or Global Unique Identifier, Google Cloud Messaging Key, Firebase Notification Key, registration code supplied by the Data Controller to activate the ATASSplus software and registration. The user is responsible for the accuracy of the personal data provided.

2.3 Geopositioning

Among the services offered by the Application, the user can visualize his/her geographical position on a map showing the geographically closest snowmaking devices. This positioning data is not transmitted or made accessible outside the user's mobile device; the Data Controller does not therefore perform any processing of such data. In any case the user may refuse to share such data with the Application right from the start using the settings menu on his/her mobile device.

2.4 Cookies

- Definitions, features and application of regulations

Cookies are small text files which sites and/or apps used by the user send and store on the computer or mobile device to then be retransmitted to them the next time such app/site is visited. It's precisely thanks to the cookies that a site remembers the user's actions and preferences (such as, for example the login data, chosen language, font size and other display features etc.) so that they do not need to be indicated again when the user returns to visit said site and/or application or navigates from one page to another. Cookies are therefore used to carry out computer authentication, to monitor sessions and to store information relative to the activities of users accessing a site and/or application and may contain a unique identification code which makes it possible to trace the navigation of the user within the site or application for statistical and/or advertising purposes. While navigating a site or using an application, the user may receive on his/her computer or mobile device cookies from web server sites or applications other than those being visited (“third party” cookies). Some operations cannot be performed without the use of cookies which, in certain cases, are therefore technically necessary for the functioning of the site or application.

There are various types of cookies with different features and functions and these may remain on the user's computer or mobile device for varying periods of time: session cookies, which are automatically deleted when the browser is closed; persistent cookies which remain in the user's device until a given expiry date.

According to current regulations in Italy, specific user consent is not always required for the use of cookies. Specifically, "technical cookies" i.e. those used solely for the purposes of performing the transmission of a communication on an electronic communication network, or to the extent strictly necessary to provide a service explicitly requested by the user, do not require such consent. In other words these are cookies which are essential for the functioning of the Application or needed to perform activities requested by the user.

Among the technical cookies not requiring specific consent for their use, the Italian Authority for the protection of personal data (see the Ruling of 08 May 2014, Identification of simplified procedures for information and consent to the use of cookies are:

"analytical cookies", where used directly by the Application operator, gather information in aggregate form on the number of users and how they visit the site;
"navigation" or "session cookies" (for authentication);
"operating cookies", which allow the user to navigate depending on a series of selected criteria (e.g. language, the products selected for purchase) so as to improve the service provided.

Instead, "profiling cookies", namely those aimed at creating user profiles and used to send on-line advertising in line with the preferences shown by the user while navigating on the net, require prior consent of the user.

- Types of cookies used by the Application

The Application uses the following types of cookies:
Third party cookies, namely cookies from web server sites or applications other than those of the Data Controller, used for purely technical purposes, such as:

Crashlytics Crash Reporting and Firebase Crash Reporting, used to send crash reports and utilization data of the Application. With reference to such technologies the Data Controller communicates the following data: email address, IMEI and registration code used at the moment of registering for the Application;
Crashlytics Answers and Firebase Analytics, used to send utilization data of the Application. These technologies are set in anonymous mode by the Data Controller as made possible by the third party supplier of such technologies.

The settings within the Application can be used to authorize or block the sending of information.

A list is provided below of the links to the information on privacy relative to the use of cookies by such third parties including their policies for processing personal data (as required by the Ruling Identification of simplified procedures for information and consent to the use of cookies – 08 May 2014):

3. PURPOSES OF PROCESSING AND OBLIGATORY OR OPTIONAL NATURE OF PROVIDING DATA

The data you provide through the Application will be processed by the Data Controller for the following purposes:

a) purposes relative to the provision of the services requested (e.g. contact request, registration, solution of problems relative to use of the Application, etc).

The granting of access to data for the purposes listed above (a) is optional but failure to provide such data may make it impossible to provide the functions requested.

Pursuant to art. 24, paragraph 1, letter b) of the Privacy Code permission to process your personal data for the performance of obligations resulting from a contract to which you are party and/or to comply with specific requests made by the data subject prior to entering into the contract is not necessary;

b) research/statistical analysis purposes on aggregated or anonymous data and therefore without the possibility of identifying the user, aimed at estimating the operation of the Application, measuring traffic and assessing its utility and interest.

The processing of aggregate or anonymous data does not require application of the Privacy Code;

c) purposes relative to complying with an obligation imposed by a law, regulation or European Community legislation.

The granting of data for the above listed purposes (c) is obligatory. Failure to provide such data would prevent the Data Controller from complying with the requirements of a law, regulation or European Community legislation.

Pursuant to art. 24, paragraph 1, letter a) of the Privacy Code consent to the processing of personal data for such purposes is not required.

4. METHOD OF PROCESSING, SECURITY AND PLACE WHERE DATA IS PROCESSED

Your personal data will be processed by the Data Controller – or by third parties carefully selected for their reliability and competence as well as duly appointed as data processors – solely to the extent of achieving the purposes specified above, mainly with automated instruments but also on paper, for the time strictly necessary to achieve the purposes for which such data were collected.

Specific security measures are taken to prevent the loss of data, illicit or improper use and unauthorized access in full compliance with the provisions of arts. 31 et seq. of the Privacy Code and of the Technical Specifications – Annex B to the Privacy Code – as regards minimum security measures. Processing relative to the functions offered by the Application takes place mainly at the aforementioned registered office of the Data Controller. The Data Controller's data centers are located in Italy.

5. COMMUNICATION AND DISSEMINATION

Your personal data may be communicated to parties external to the Data Controller whose activities are required for providing the services. Your personal data may be communicated to third parties such as:

a. persons, companies or professional firms providing assistance and consultancy services to the Data Controller, duly appointed as data processors;
b. subjects, bodies or authorities to whom your personal data must be communicated pursuant to legal provisions or orders of the competent authorities;
c. parties delegated and/or appointed by the Data Controller to perform activities strictly related to achieving the purposes indicated above (including technical maintenance operations on systems), duly appointed as data processors;
d. commercial partners, suppliers of services required to develop the software, to provide the services related to the Application. Where necessary the Data Controller reserves the right to ask for your specific consent.

As regards the scope of disclosure of your personal data, the personal data required to activate subscription to the Application will not be disseminated. As a general rule, your personal data will not be disclosed by the Data Controller. The Data Controller reserves the right to perform processing every so often which involves dissemination, after obtaining your specific consent.

6. YOUR RIGHTS

The parties to whom the personal data refer have the right at any moment to obtain confirmation as to whether or not such personal data exist, to find out the content and source thereof or request that they be updated, integrated or rectified (art. 7 Privacy Code).

Pursuant to the same article, you also have the right to request the erasure, anonymization or blocking of data processed unlawfully, as well as to object in any case on legitimate grounds, to their processing.

Such requests may be sent by email to privacy@technoalpin.com

7. AMENDMENTS

The Data Controller may amend or merely update this Application Privacy Policy, in whole or in part, including on account of changes to legislative and regulatory provisions on the matter and protect its rights. Such variations or amendments of the Privacy Policy will be notified to users on the home page as soon as they are introduced and will become binding as soon as they are published in the Application. We therefore suggest you visit this Privacy Policy regularly to keep up to date with its most recent, updated version and the information we collect, as well as the use we make of it.

8. CONTACTS

If you wish to receive any information on the processing of your personal data performed by the Data Controller, please send an e-mail to the following address: privacy@technoalpin.com.