SPACEYE APP PRIVACY POLICY

 

Pursuant to and for the purposes of art. 13 of EU Regulation 2016/679 (“General Regulation on the protection of personal data”, hereinafter “Regulation”), the following information is provided to the interested party (hereinafter the “USER”) by the Data Controller, who purchased the Spaceye service from Vem Sistemi S.p.A. (from now “VEM”), who acts as Data Processor and who uses Mydev S.r.l., as a futher Data Processor for the development of the Spaceye application (hereinafter also “APP”).

Vem Sistemi S.p.A. considers fundamental the respect of the user’s privacy and for this reason all personal data (hereinafter “Personal Data” and/or “Data”) that you will provide or that will be collected in the context of the use of the application, will be processed in compliance with the principles recognised by the current legislation on the protection of personal data, such as the principles of transparency, correctness, lawfulness, data minimization, purpose limitation and storage, accuracy, integrity and confidentiality.

Purpose and legal basis of the processing and type of data collected

The APP aims to provide a booking service useful for the sharing of the Data Controller corporate assets.

The computer systems and software procedures used to operate the APP acquire, during their normal operation, data relating to their e-mail, username and company.

The processing of data for the aforementioned purposes will therefore be carried out on the basis of the execution of the contract between VEM and the Data Controller.

Type of data collected: location data

SpacEye collects location data to enable the following app’s core feature: 

• proximity check-in of the previously booked desk/meeting room

even when the app is closed and not in use.

Check-in is a necessary operation that the user must perform in order to confirm the booking.

How does the proximity check-in work?

If the User enables the proximity Check-in option and agrees to the app’s permissions requests, the app will be able to monitor the user’s proximity to booked desk/meeting room. In this way, if the user is near a previously booked desk/meeting room, the booking is automatically confirmed even when the app is closed and not in use.

SpacEye, with the user’s consent, can therefore collects location data to locate the user’s position in order to confirm the reservation of the desk or meeting room previously booked.

Even if the user gives his consent, he can disable the option even temporarily, from the settings of the operating system and device used and also directly from the app.

Mode of treatment

The data will be processed through computer or automated tools and supports.

The storage of databases is carried out in protected environments, whose access is controlled and managed in compliance with the provisions of the current legislation on the processing of personal data.

Nature of the provision of data

The provision of the data described above is optional but implicit in the use of the APP and necessary for its operation. Therefore, the interested party who does not want to provide the data may express such intention avoiding to access and/or use the APP. The provision of the data relating to your position for the proximity Check-in service is subject to the request of a specific consent to the User, the provision of this consent is optional and not indispensable for the use of the APP. In particular, consent to the survey of the User’s position in the proximity of the asset is also provided by activating the bluetooth service.

Time limits for data retention

The data will be stored for no longer than necessary for the purposes for which they are collected and subsequently processed. The data will be processed by VEM until the end of the contract with the Data Controller. In addition, the Data Controller will have the possibility to automatically set the cancellation of the same starting from a minimum retention of 6 months.

Cookie

What are the cookies. A “cookie” is a small text file installed on the user’s terminal when the user accesses a specific site or application. The purpose is to store and transport information. Cookies are sent from a web server (which is the terminal on which the visited site is running or on which the application is supported) to the user’s browser (Internet Explorer, Mozilla Firefox, Google Chrome, etc.) and stored on the latter’s device. For more information on what cookies are, please refer to the following web page: www.allaboutcookies.org

In general, cookies can be used for several reasons, for example to monitor the use of the service by visitors, improve the navigation of pages, allow you to set personal preferences of the services you are using, protect the security of the user. In general, and according to common terminology cookies may have different characteristics that allow you to classify them according to:

• the duration of the stay on the user’s device: in this case we speak of session/temporary cookies or persistent cookies;
• to the source: in this case we speak of first-party cookies (sent to the browser directly from the application you are visiting) or third-party cookies (sent to the browser by other web servers and not by what you are visiting);
• the purpose: in this case, also in line with what is regulated in this regard by the Authority for the Protection of Personal Data, we speak of technical cookies or analytical cookies identifying and profiling.

Following this classification, a same cookie may also have all these characteristics together so, for example, be a persistent cookie, coming from a third party and with profiling purposes.

Which cookies are used.

The APP uses temporary cookies, deleted from the user’s device once the APP is closed, and permanent, that is, stored on the device until they are deleted by the user or until they reach their expiry date if set.

Among the cookies used by the APP and that the legislation includes among the technical c.d. cookies there are:

• cookies essential to the operation of the APP itself and to the correct use of its contents (cd. navigation cookies, essential and strictly necessary); without them some of the contents of the APP could not be provided as they guarantee normal navigation and use of the APP. If these cookies are blocked, the APP may no longer work properly. In this APP these cookies are first-party and temporary.

• third-party statistical/analytics cookies without identification power (with IP masking and no cross-referencing with other data held by the third party): the APP uses the Google Analytics service provided by Google Inc. for the management of the web server supported by the APP. Google Analytics in turn releases cookies, which generate information on the use of the website by the user. These cookies can be assimilated in line with the current legislation to technical cookies, as their use in this APP has been configured in compliance with the following conditions: adoption of measures that reduce the identification power of cookies by masking significant portions of the IP (described at the following link: https://support.google.com/analytics/answer/2763052?hl=i); the third party refers to the commitment to use these cookies exclusively for the provision of the service, to store them separately and not to “enrich” them or not to “cross-reference” them with other information available to it. On this point, please note that VEM for the use of the APP has not connected Google Analytics to additional services of Google Inc. and that advertising or data sharing options have not been activated with Google Inc. same.

The cookies used by the APP do not allow VEM to collect personal information of Users, which therefore cannot be identified, tracked or become targeted or “targeted” advertising recipients based on habits and/ or behavior in the navigation of the APP. In the light of the measures adopted, for the use of these cookies and for the processing of personal data connected to them, it is not necessary, in accordance with the provisions of the current law, to request consent to the processing.

How to manage or delete cookies. Most Internet browsers are initially set to accept cookies automatically. You can change these settings in order to block cookies or to be warned every time cookies are sent to the navigation device. In addition, at the end of each browsing session you can delete collected cookies from your device. There are several ways to manage cookies. Please refer to the specific instructions of the browser used. If the User uses different devices to view and access the APP (for example, smartphones, tablets, etc.), it will be the User’s responsibility to ensure that each browser on each device is adjusted to reflect the preferences expressed about cookies.

Selecting the links below instead you can access the specific instructions for the management of cookies through some of the main browsers for navigation:

Microsoft Windows Explorer: http://windows.microsoft.com/en-us/windows-vista/block-or-allow-cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en&p=cpn_cookies

Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences

Apple Safari: http://www.apple.com/legal/privacy/it/cookies/

Opera: http://www.opera.com/help/tutorials/security/cookies/

If none of the browsers listed above is used, in any case the item “cookies” can be selected in the relative guide to the use of the User’s browser and find out where the folder for their management is located.

Communication and dissemination of data

The data may be known and processed by the personnel expressly authorized by VEM and/or by the designated persons responsible for the processing, according to the respective assigned authorization profiles, which may carry out the consultation operations, use, processing, comparison and any other appropriate operations, including automated ones, only where expressly authorized to do so.

In particular, the data may be made available to companies that provide specific supply services to VEM, such as IT service providers, data processing companies for the provision and management of IT services, which VEM uses for the administration and management of the JPA and its IT infrastructure.

These companies will have knowledge of the data (even if not covered by the definition of personal data) within the limits strictly necessary for the administration and management of the JPA.

Furthermore, among the security measures adopted, VEM shall ensure that, within the limits and for the purposes of the current legislation, its service providers have access to information as a result of the activity carried out are appointed as data controller. The data will not be transferred in any way and for any reason, neither free nor onerous, to third parties.

In case of express request and in the circumstances authorized by law, the data may be communicated to the Public Security Authorities and the police.

The data collected through the APP will not be disseminated in any way but, if necessary, may be transferred abroad, in particular to any data controllers having their headquarters or their archives there, only in the presence of one of the guarantees provided by Chapter V of the European Regulation 2016/679.

Rights granted to the data subject

The data subject, in addition to revoking consent and accessing data and the treatment, may at any time, in the cases provided for, request the rectification, deletion and portability of data with another data controller. The data subject may also object to the processing, request its limitation, and lodge a complaint with the Guarantor for the protection of personal data (for the relevant instructions he can access the website www.garanteprivacy.it ). For the exercise of their rights, the interested party may contact the Data Controller.

Data Protection Officer

Vem Sistemi S.p.A., based in Via Don Sebastiano Calderoni, 12 Forlì (FC), has appointed the Data Protection Officer, who can be contacted at the email address dpoprivacy@vem.com.