Privacy Policy

Pursuant to Legislative Decree no. 196 of 30 June 2003 and subsequent amendments and additions (“Privacy Code”) and of the European Regulation no. 679 of 2016 (the “Privacy Regulation”), Vemer S.p.A. wishes to inform you and all the users of the “Clima Vemer” app (respectively, the “Users” and the “App”), concerning the use of personal information collected through the App itself.

1. Data Controller and Data Processors

The Data Controller of the personal information is Vemer S.p.A., with registered office in 32032 Villapaiera Feltre (BL), Via Camp Lonc, 16, VAT no. 01041410257, e-mail info@vemer.it (hereinafter the “Data Controller”).

The updated list of the designated Data Processors can be provided upon Users’ request to the e-mail info@vemer.it.

2. Personal Data Processed

2.1 Information collected automatically by the App

Our App makes use of log files, in which are stored information collected in an automatic way during your visits. The computer systems and software procedures used to operate this App, indeed, automatically acquire, in the course of the use of some information, some personal information whose transmission is implicit in the use of Internet communication protocols. To access the App and carry out the relative navigation, the information collected is as follows:

• Internet Protocol (IP) address or the domain name of the device you are using;
• the addresses in the Uniform Resource Identifier (URI) notation of the requested resources or the method used to submit the request to the server;
• name of the Internet Service Provider (ISP);
• the numerical code indicating the status of the response given by the server (success, error, etc.);
• other parameters relating to the operating system and the IT environment of your device;

This information is processed in automated form and collected exclusively in aggregate form in order to verify the correct functioning of the App.

2.2 Information you provide to use the App

The information necessary to use the App and access the services offered and requested therein are the common identification data, contact data and data relating to the last thermostat setting.

3. Purposes of the processing

We need your data to allow you to register and access the App to take advantage of its features.

Your personal information will be processed for the following purposes:

(i) to comply with legal obligations;

(ii) to carry out the technical management of the App;

(iii) to register with the App for the activation of the control and command of the air ducting system and/or heating and/or air conditioning and depending on the model of thermostat installed;

The information you provide will be processed mainly with IT tools under the authority of the Data Controller, by subjects specifically designated, authorised and instructed to the processing, pursuant to art. 29 of the Privacy Regulation and 2-quaterdecies of the Privacy Code. We inform you that appropriate security measures are also observed pursuant to art. 5 and 32 of the Privacy Regulation to prevent data loss, unlawful or incorrect use and unauthorised access.

4. Nature of the provision of data and legal basis for the processing

For the purposes referred to in the points of art. 3 above, the provision of your personal data is necessary as you will not be able to use the services offered by the App without it. Consequently, for the purposes referred to in point (i), the legal basis of the processing is the fulfilment of legal obligations, pursuant to art. 6 para. 1, letter c) of the Privacy Regulation: for the purposes referred to in points (ii) and (iii) the legal basis of the processing is the execution of the services provided through the App and requested by you, pursuant to art. 6, para. 1, letter b) of the Privacy Regulation.

5. To whom and to what extent may we disclose your personal information

Your personal information may be communicated, within the EU, to external structures, subjects and companies (including consultants and service providers) that the Data Controller uses for the management of the App and for the performance of activities connected, instrumental or consequent to the execution of the services offered through the App.

6. Your rights

Arts. 15 et seq. of the Privacy Regulation give the interested party the right to obtain, in the manner and within the limits established by art. 2-undecies of the Privacy Code and art. 12 of the Privacy Regulation:

• the confirmation as to whether or not personal information concerning you are being processed, and, where that is the case, access to the personal information in a readable form;
• the indication of the origin of the personal information, of the purposes and procedures of the data processing, of the logic applied in the case of processing carried out with the aid of electronic instruments, of the identification details of the Data Controller;
• the updating, rectification, integration, erasure of the personal information, the anonymisation or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed -, the certification to the effect that the operations have been notified, as also related to their contents, to the parties to whom the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.

The concerned party also has the right:

• to withdraw at any time the consent (if given) to the processing of personal information (without prejudice to the lawfulness of the processing based on the consent given before the withdrawal);
• to oppose, in whole or in part, the processing of their personal information for legitimate reasons of their concern, even if pertinent to the purpose of its collection;
• to oppose, in whole or in part, the processing of their personal information for the purpose of sending advertising materials, for direct sales or for carrying out market research or commercial communications;
• to lodge a complaint with the Guarantor for the protection of personal information in the cases provided for by the Privacy Regulation, by contacting the Guarantor for the protection of personal information directly: App web www.garanteprivacy.it   E-mail:  protocollo@gpdp.it  Telephone switchboard: (+39) 06.69677.1;
• to the portability of the personal information within the limits of art. 20 of the Privacy Regulation.

For the exercise of the rights, it is necessary to send an e-mail to the address info@vemer.it.

7. Duration of the Data processing

Without prejudice to legal and judicial protection obligations, personal information will be stored for a fixed period, based on criteria based on the nature of the services provided. In particular, the data referred to in art. 2.1 will be processed for a period not exceeding 7 days, while the personal information processed for registration and access to the services provided through the App pursuant to art. 2.2 will be processed until the User’s account is deactivated and stored for a period not exceeding 6 months.

8. Security measures

Through the App, your data are processed in compliance with the applicable law and using appropriate security measures in compliance with the regulations in force, also pursuant to articles 5 and 32 of the Privacy Regulation.

In this regard, we confirm, among other things, the adoption of appropriate security measures aimed at preventing unauthorised access, theft, disclosure, modification or unauthorised destruction of your personal information.

9. Changes to the Privacy Policy

The Data Controller reserves the right to make changes to this Privacy Policy. In that case, you shall be informed of it in a timely way, in the moment that you once again use the App.