Privacy policy

PERSONAL DATA PROCESSING POLICY

The 679/2016 GDPR (“General Data Protection Regulation”) provides for the protection of individuals and other subjects with regards to personal data treatment. In compliance with the regulation in force, such treatment will be based on the principles of correctness, lawfulness, transparency and protection of your privacy and rights. Pursuant to Article 13 of the GDPR, the following information is therefore given.

1)    DATA CONTROLLER
The Data Controller is GIACOMINI S.p.A., via Per Alzo 39, 28017, San Maurizio d’Opaglio (NO), phone +39(0)322/923111, email: info@giacomini.com.

2)    TYPE OF DATA PROCESSED
The treatment will involve the following data:

Data provided by the user
Personal data (name and family name / business name); contact data (email, phone; registered seat address).

Browsing data
The IT systems and software procedures implemented for regular operation of this website acquire data the transmission of which is required for the use of Internet communication protocols. Such information is not collected for association to identified individuals, but, based on its nature, it may enable the identification of users through processing and association with data held by third parties. This data category includes IP addresses or IT domain names of the computers used by those connecting to the website, URI (Uniform Resource Identifier) notation addresses of the resources requested, time of the request, method used to send the request to the server, size of the file obtained in response, numeric code indicating the server response status (successful, error, etc.) and other parameters linked to the operating system and the user’s IT environment. 

3)    PURPOSES, NATURE  AND JURIDICAL BASE OF THE DATA PROCESSING
The data processing aims at:
A.    Enabling the user to browse the website
B.    Providing the services offered by the website (feedback on information and contact requests  / customer care / after-sales support), also when accessing reserved areas of the website;
C.    Processing anonymous statistics on how the services and the website are used;
D.    Monitoring proper operation of the website;
E.    Verifying IT crimes against the website;
F.    Sending information, promotional material of technical and/or marketing nature or other communications about Giacomini S.p.A.’s activity both in digital and paper format;
G.    Evaluating the client’s satisfaction degree, as provided by the UNI EN ISO 9001 standard, according to in-house procedures duly drawn up by GIACOMINI S.p.A.
The purposes described at points A-B are legally based on the implementation of the contract or pre-contractual measures, and any denial to provide the data will prevent the execution of the service; points C, D, E, G are legally based on the Controller’s legitimate interest, and any denial to provide the data will not prevent the navigation and/or possibility to receive a feedback to your requests. The purposes of which at point F are legally based on the consent lawfully expressed by the interested party, and denial to provide the data will not prevent the navigation but only the possibility to receive newsletters. 

4)    DATA RETENTION PERIOD
We will hold your data for a limited period of time which is strictly connected to the purposes for which they are collected, and in compliance with the obligations provided by Law or by applicable regulations. At the end of such period, the data is deleted or made irreversibly anonymous.
However, we will hold the data provided by the user for:
-    Refer to the cookie policy for the purposes set forth by letter A) of article 3) above;
-    A period not exceeding 10 years after the request of information/contact for the purposes set forth by letter B) of article 3) above; a period not exceeding 2 years when the request regards customer care assistance;
-    The time required to solve the issues connected to use of the website for the purposes of which at letter D) of article 3) above;
-    A period not exceeding 10 years for the purposes of which at letter E) of article3) above;
-    A period not exceeding 10 years for the purposes of which at letter F) of article 3) above, holding firm the possibility to withdraw your consent at any time by unsubscribing from the newsletter service.

5)    DATA RECIPIENTS
Your data will be processed by the Controller and the employees expressly authorized to do so based on their responsibilities (e.g. marketing department; IT department). Your data may also be disclosed to third parties, such as: third party companies administering the website and the newsletter service; the company providing CRM services (customer relationship management); the company managing IT support; the judicial authority.

6)    DATA TREATMENT METHODS
All information voluntary transmitted to this website by the user will be processed by Giacomini S.p.A. in compliance with the methods set forth by GDPR 679/2016. The databases hosting your personal data comply with the safety standards set forth by article 32 of the GDPR. Data processing carried out with electronic and/or manual means will include, according to the terms and restrictions set forth by article 5 of the GDPR, all operations or bundle of operations set forth by article 4 par. 1 letter 2 of the GDPR, which is essential for the processing.

7)    USER’S RIGHTS
At any time, the user may enforce the rights set forth by article 15 and subsequent amendments of the EU 2016/679 Regulation:
a)    Right to access personal data;
b)    Right to modify or delete the data or limit the treatment;
c)    Right to deny the treatment;
d)    Right to data portability;
e)    Right to revoke consent, if applicable (revocation of your consent will not compromise the lawfulness of the treatment based on the consent conferred prior to revocation);
The user is entitled to submit a claim before an independent authority should the data treatment infringe the present regulation. More information on www.garanteprivacy.it.
Enforcement of the rights listed above may be requested via email to the following address: privacy@giacomini.com, i.e. By writing to Giacomini S.p.A., Via per Alzo 39 (28017), San Maurizio d’Opaglio (NO).

(version 30.10.2023)                            Giacomini S.p.A.

PRIVACY POLICY
This information document (or "privacy policy") is provided in accordance with Article 13 of the EU Regulation 679/2016 and describes the personal data processing methods applied by the K-Domo mobile application (hereinafter referred to as the "application" or the "app") related to the use of heating systems produced by Giacomini S.p.A.
This privacy policy applies only to this mobile application and not for third-party websites or other mobile applications that may be accessed by the user through links.

1. DATA CONTROLLER AND AUTHORIZED THIRD-PARTY DATA PROCESSORS
The Data Controller is GIACOMINI S.p.A. (Hereinafter also the “Controller”), with registered office in Via per Alzo, 39, (28017) - San Maurizio D’Opaglio (NO), phone number: 0322/923111, e-mail address: info@giacomini.com. The updated list of data processors and authorized people in charge of the data processing is found in the data processing log in safekeeping at the registered office of the Data Controller.

2. DATA PROCESSED
Depending on the service provided, different types of personal data may be processed, as specified below.
-    Data voluntarily provided by the user (registration and communications)
This app collects the following personal data: user's first name, last name, and e-mail address. This data is required for registration and account creation, for the use of the mobile application, and for accessing the services made available. Additionally, upon user's request, the data may be used to send e-mail responses to the e-mail addresses provided.
-    Location data
This app collects data about the system and user’s location.
By clicking on "locate", the application’s technology identifies the physical location of the system, collecting longitude and latitude data of the location of the system. Furthermore, in the "geofencing" section, the user allows the app to identify if their location is within or outside a specific radius (as identified through the app) from the installation location of the thermostat, without ever mapping their movements, for any reason.
The location data are processed, stored, and used by the Controller solely for the purposes and in the manner described in Article 3. The system does not allow remote real-time geolocation at any other time than that of the activation of the location feature by the user to redefine the previously configured location.

3. PURPOSES AND METHODS OF PROCESSING
Any personal data acquired shall be processed in compliance with applicable laws for purposes related and/or instrumental to accessing this mobile application and providing the services offered through said application, including any additional services requested by the user. In particular:
a)    to sign-up for the app and provide a service (such as accessing the mobile application with all its features) and receive the requested information via e-mail
b)    (regarding geolocation data) to provide weather information service for the location where the heating system is located
c)    to fulfill all legal obligations
d)    for operational and management needs at the Controller’s and related to the services offered
e)    to protect a legitimate interest of the Controller (e.g., defending itself in a court of law).
The personal data will be processed lawfully and fairly and used only for the purposes mentioned above.  The data processing may be performed using automated tools to store, manage, and transmit such data. In any case, it will be performed using appropriate tools to ensure the confidentiality, security, availability, and integrity of the information systems used for data collection, transmission, and storage, as well as the collected data.

4. LEGAL BASIS OF THE PROCESSING, REASONS FOR DATA PROVISION AND CONSEQUENCES FOR NOT PROVIDING THE DATA
The legal basis for the processing is based on the implementation of the contract or pre-contractual measures (purposes a, d), compliance with legal obligations (purpose c), and pursuing the legitimate interests of the data controller (purpose e). The processing of the geolocation data for purpose b) is based on consent provided by selecting "locate" and "geofencing".
Therefore, the processing is lawful (Art. 6 Paragraph 1 of EU Regulation 2016/679). 
The provision of the personal data for the purposes outlined in section 3) is necessary for using the application. If the data is not provided, it will not be possible to access the services offered by the application.

5. DATA RECIPIENTS
If necessary to achieve the purposes set out in section 3), the personal data may be disclosed, in addition to employees specifically authorized according to their duties, to the following external third parties, appointed in writing and acting as data processors, provided that they meet the applicable requirements:
-    the company that developed the Application 
-    Public authorities
-    IT service providers - hosting - technology companies entrusted with specific Application management tasks.
The Data Controller shall keep an updated list of external data processors, which will be submitted to the data subject upon request.

6. TRANSFER OF DATA TO A NON-EU COUNTRY
The data will be processed exclusively in Italy and within the European Union.  If, for reasons related to the implementation of the contract, the data need to be transferred outside the European Union, the data controller shall ensure that the transfer will be carried out in compliance with appropriate safeguards or in accordance with the conditions set forth in Article 49 of the GDPR.

7. DATA STORAGE PERIOD 
The data controller stores the personal data until the user deletes the application.  Following the deletion of the application, the data will be promptly erased.

8. RIGHTS OF DATA SUBJECTS
You shall have the rights provided for in Articles 15 and following of the EU Regulation 2016/679 and you may exercise these rights at any time:
a)    The right to access personal data
b)    The right to request the rectification or erasure of personal data, or the restriction of the processing
c)    The right to object to the processing of personal data
d)    The right to data portability
e)    The right to withdraw consent, where applicable (the withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal)
f)    The right to lodge a complaint with the supervisory authority (Garante Privacy).
You can exercise these rights by sending a notification via e-mail to the following address:privacy@giacomini.com.

9. CHANGES TO THE PRIVACY POLICY
This Privacy Policy may be amended, including as a result of legislative or regulatory changes, technological developments and the provision of new services or modifications to existing ones. Therefore, all users are encouraged to periodically review this Privacy Policy.

PRIVACY POLICY
This information document (or "privacy policy") is provided in accordance with Article 13 of the EU Regulation 679/2016 and describes the personal data processing methods applied by the Giacomini Connect mobile App (hereinafter referred to as the "application" or the "app") related to the use of heating systems produced by Giacomini S.p.A.
This privacy policy applies only to this mobile application and not for third-party websites or other mobile applications that may be accessed by the user through links.

1. DATA CONTROLLER AND AUTHORIZED THIRD-PARTY DATA PROCESSORS
The Data Controller is GIACOMINI S.p.A. (Hereinafter also the “Controller”), with registered office in Via per Alzo, 39, (28017) - San Maurizio D’Opaglio (NO), phone number: 0322/923111, e-mail address: info@giacomini.com. The updated list of data processors and authorized people in charge of the data processing is found in the data processing log in safekeeping at the registered office of the Data Controller.

2. DATA PROCESSED
Depending on the service provided, different types of personal data may be processed, as specified below.
-    Data voluntarily provided by the user (registration and communications)
This app collects the following personal data: user's first name, last name, and e-mail address. This data is required for registration and account creation, for the use of the mobile application, and for accessing the services made available. Additionally, upon user's request, the data may be used to send e-mail responses to the e-mail addresses provided.
-    Location data
This app collects location data for retrieving weather information in the area where the heating system is located.
By clicking on "set location", the application’s technology identifies the physical location of the user’s system, collecting longitude and latitude data regarding the location of the system. Furthermore, in the "set location" section, the user can manually enter the physical address of the system or redefine a previously configured location of the system by enabling the geolocation feature on the mobile device.
When the user, in the "set location" section, clicks on the "Replace with current location" button, the use provides consent to the identification of the physical location of the system.
The location data are processed, stored, and used by the Controller solely for the purposes and in the manner described in Article 3. The system does not allow remote real-time geolocation at any other time than that of the activation of the location feature by the user to redefine the previously configured location.

3. PURPOSES AND METHODS OF PROCESSING
Any personal data acquired shall be processed in compliance with applicable laws for purposes related and/or instrumental to accessing this mobile application and providing the services offered through said application, including any additional services requested by the user. In particular:
a)    to sign-up for the app and provide a service (such as accessing the mobile application with all its features) and receive the requested information via e-mail
b)    (regarding geolocation data) to provide weather information service for the location where the heating system is located
c)    to fulfill all legal obligations
d)    for operational and management needs at the Controller’s and related to the services offered
e)    to protect a legitimate interest of the Controller (e.g., defending itself in a court of law).
The personal data will be processed lawfully and fairly and used only for the purposes mentioned above. The data processing may be performed using automated tools to store, manage, and transmit such data. In any case, it will be performed using appropriate tools to ensure the confidentiality, security, availability, and integrity of the information systems used for data collection, transmission, and storage, as well as the collected data.

4. LEGAL BASIS OF THE PROCESSING, REASONS FOR DATA PROVISION AND CONSEQUENCES FOR NOT PROVIDING THE DATA
The legal basis for the processing is the implementation of the contract or pre-contractual measures (purposes a, and c), compliance with legal obligations (purpose b), and pursuing the legitimate interests of the data controller (purpose d). The processing of the geolocation data is based on the consent given by selecting "set location".
Therefore, the processing is lawful (Art. 6 Paragraph 1 of EU Regulation 2016/679). 
The provision of the personal data for the purposes outlined in section 3) is necessary for using the application. If the data is not provided, it will not be possible to access the services offered by the application.

5. DATA RECIPIENTS
If necessary to achieve the purposes set out in section 3), the personal data may be disclosed, in addition to employees specifically authorized according to their duties, to the following external third parties, appointed in writing and acting as data processors, provided that they meet the applicable requirements:
-    the company that developed the Application 
-    Public authorities
-    IT service providers - hosting - technology companies entrusted with specific Application management tasks.
The Data Controller shall keep an updated list of external data processors, which will be submitted to the data subject upon request.

6. TRANSFER OF DATA TO A NON-EU COUNTRY
The data will be processed exclusively in Italy and within the European Union. If, for reasons related to the implementation of the contract, the data need to be transferred outside the European Union, the data controller shall ensure that the transfer will be carried out in compliance with appropriate safeguards or in accordance with the conditions set forth in Article 49 of the GDPR.

7. DATA STORAGE PERIOD 
The data controller stores the personal data until the user deletes the application. Following the deletion of the application, the data will be promptly erased.

8. RIGHTS OF DATA SUBJECTS
You shall have the rights provided for in Articles 15 and following of the EU Regulation 2016/679 and you may exercise these rights at any time:
a)    The right to access personal data
b)    The right to request the rectification or erasure of personal data, or the restriction of the processing
c)    The right to object to the processing of personal data
d)    The right to data portability
e)    The right to withdraw consent, where applicable (the withdrawal of consent does not affect the lawfulness of the processing based on consent before its withdrawal)
f)    The right to lodge a complaint with the supervisory authority (Garante Privacy).
These rights can be exercised by sending a notification via e-mail to the following address: privacy@giacomini.com.

9. CHANGES TO THE PRIVACY POLICY
This Privacy Policy may be amended, including as a result of legislative or regulatory changes, technological developments and the provision of new services or modifications to existing ones. Therefore, all users are encouraged to periodically review this Privacy Policy.