Privacy notice - App

Mottura Serrature di Sicurezza S.p.a., with registered office in Sant’Ambrogio di Torino (TO), Strada antica di Francia n° 34, (hereinafter "MOTTURA", the "Company", "we"), e-mail: privacy@mottura.it as data controller collects and processes personal data in accordance with Regulation (EU) 2016/679, the General Data Protection Regulation ("GDPR"), the Legislative Decree . June 30, 2003, n. 196 ("Privacy Code"), Legislative Decree 10 August 2018, n. 101 of adaptation of the Privacy Code to the GDPR (the "Adjustment Decree"), in compliance with the privacy principles and the rights of the interested party.

This policy applies to the processing of personal data relating both to the users (hereinafter “Users”) of the Mottura App (hereinafter “App”) and to all the subjects who may initiate enquiries, including for advertising purposes, in the context of all our services (present and future).

1. What data do we process?

By "personal data" we mean all information useful for identifying a natural person, either already held by MOTTURA or which the latter could come into possession of.

A user can use the Apps for the use and management of MOTTURA locks and devices.

During the registration procedure and the subsequent use of the App, the following personal data can be collected, stored and subsequently processed:

Identification data: first name and last name
Contact information: address, telephone number, e-mail address
Geo-location data
Usage data (e.g. access date and time, information on devices, etc)
Password

When the Users install the Mottura App, in order to create an account useful for remotely managing the locks, they must enter his name, email and password; any other data is optional. This data is saved in the Cloud in order to allow the management of MOTTURA locks and devices remotely. The use of the App (and the related Cloud service) is optional. If a buyer of Mottura locks does not want to use the Cloud, he can do so and in this case all the lock usage data is saved exclusively on the locks themselves and/or on the buyer's smartphones.

In case of Xtech series products and related App, there is no possibility of use via the internet and the data is saved exclusively on the locks themselves and/or on the users' smartphone.

2. How is personal data collected by MOTTURA?

Data collected by MOTTURA, within the services provided through the App, come from:

information communicated by the User during the download phase of the App and the registration/account creation necessary to access the services of remote lock management;
• information obtained automatically in relation to the activities of using the App, such as door opening, closing data, etc. (“Activity Log”) including geolocation and information relating to the device and operating system of the device on which the App is downloaded (by the User and the Invitees); the Activity Log information is also displayed by the User in the App itself;
information communicated by telephone, by e-mail in relation to request of assistance or information by the Users or the interested party;

We also inform you that MOTTURA does not use automated decision-making processes pursuant to art. 22 of the GDPR for decisions regarding the establishment and execution of business relationships.

3. Purpose and legal basis of data processing

MOTTURA processes User data for the following purposes:

provide the service of opening and managing locks remotely as per users’ requests, and therefore to fulfill the obligations to fulfill the contractual obligations for the provision of services (including the geo-location of the device) and the processing necessary to protect the security of the services themselves; the processing of the User's data in this case is necessary to execute the agreement for the provision of services useful to allow the management of the lock remotely, upon request of the User. Therefore, in the event of refusal by the User to provide his personal data, it will not be possible to proceed with the planned services;
improve the services and App functionalities and carry out statistical and trend analysis on the basis of MOTTURA's commercial legitimate interest and with no significant impact on the User. In this case, User data will be aggregated and/or anonymized so to prevent the data subjects’ identification. Such anonymized or aggregated information may be shared with any commercial partners of MOTTURA, current or potential Merchants or other third parties on the basis of a legitimate commercial interest of MOTTURA;
• follow up on Users' requests for information or of the interested party, even of a commercial/promotional nature. The processing of personal data is necessary to be able to follow up on the request of the User or interested party. The processing of the User's data for marketing purposes takes place, where necessary on the basis of the User's consent, in compliance with MOTTURA's general Privacy Policy, including marketing communications.

4. Invitees

As part of the lock management services through the APP, the User may grant third parties ("Invitees") authorization to use/access their locks. In this case, some of the User's personal data, as well as other product usage information, may be shared with Invitees, such as the User's name and product status (e.g. locked/unlocked). Invitees, who are in turn considered also Users, must necessarily download the App and read this Privacy Policy in order to access the service. Mottura will collect the name of the Invitees and the data of their use including geolocation, according to this Privacy Policy.

5. For how long does MOTTURA store personal data?

Mottura retains personal data for the time necessary to fulfill the purpose for which the data was collected with particular regard to the needs of providing the service and protecting its security and integrity. In any case, Mottura will delete the User's personal data if such data is no longer necessary to process a request or to manage the User's or interested party's account.

Activity Log data is automatically deleted after 30 days. Aggregated and anonymous data can be stored for longer periods.

6. With whom is personal data shared?

With reference to the planned data processing activities, MOTTURA may need to share the gathered personal data with subjects that act in its behalf in the role of Data Processor and according to his instructions pursuant to art. 28 GDPR; by way of example and not limited to, the following:

To other ASSA ABLOY Group organizations to the extent necessary to support the operation of the products and services;
Providers of Cloud services, IT and/or other support services, to the extent necessary to support the necessary data saving, operation and/or security of the products and services, including related technical assistance activities, and usage analysis;
Authorized internal employees
Any commercial partners of MOTTURA in the context of providing the services requested by the User
Parents or legal guardians of the interested party
Bodies or institutions that need to receive your personal data on the basis of legal provisions and/or regulations, such as administrative, judicial and law enforcement authorities in the exercise of their duties and functions.

7. How does MOTTURA guarantee the security of personal data?

MOTTURA pays extreme attention to the security of the personal data of the data subjects. To this end, it has prepared special procedures for data security as well as an information security policy allowing to protect data from accidental loss or improper use. Mottura allows access to information only in the presence of a legitimate reason.

8. What rights can data subjects exercise in relation to the information processed by MOTTURA?

Each interested party (i.e. the User as well as those who are not yet users but have requested information and provided their personal data to MOTTURA) can exercise specific rights, including those to ask the Data Controller: You can contact the Company at any time at the addresses indicated at the beginning of this Privacy Notice and at the email address privacy@mottura.it to request the updated list of our data processors and exercise your privacy rights pursuant to articles. 15 ss. GDPR:

confirmation of whether or not your personal data is being processed and, if so, to obtain access (right of access);
the rectification of inaccurate personal data, or the integration of incomplete personal data (right of rectification);
the deletion of the data itself, in the presence of one of the reasons provided for by the art. 17 of the Regulations (right of cancellation);
to limit the processing of your personal data, in the presence of one of the reasons provided for by the art. 18 of the Regulation (right of limitation);
to receive the personal data provided in a structured format, commonly used and readable by an automatic device, and to transmit them to another data controller (right to portability).

To exercise their rights, any interested party may write to the e-mail address privacy@mottura.it.

Furthermore, you have the right to lodge a complaint with the competent supervisory authority which in which in Italy is the Garante per la Protezione dei Dati Personali (hereinafter the "Garante”).

Pursuant to the Regulation, MOTTURA is not authorized to charge costs to comply with one of the requests reported in this paragraph, unless they are manifestly unfounded or excessive, and in particular are repetitive in nature. In the latter case, MOTTURA may (i) charge a reasonable fee, taking into account the administrative costs incurred to process the request or (ii) refuse to satisfy the request. In these eventualities MOTTURA will inform the interested party of the costs before processing the request