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Privacy Policy

Information pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ('Regulation' or 'GDPR')

Privacy - Inim Sites

Information for visitors and users of the sites:inim www.inimdns.biz and www.inimcloud.com

This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.

Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.

To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE DATA CONTROLLER

Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.

2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.

2.1. Purpose of processing

The Data are processed for the following purposes:

  1. purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
  2. Purposes strictly related and/or necessary for the performance of the services requested by the User;
  3. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
  4. User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.

2.2. Categories of individuals to whom the Data may be disclosed

In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM

With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.

At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.

3. WHERE WE PROCESS YOUR DATA

Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.

4. YOUR DATA IS TRANSFERRED ABROAD

INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.

5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG

Processing of Data:

  1. is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
  2. is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.

Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.

The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.

Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.

The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.

You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.

Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.

6. WHAT ARE YOUR RIGHTS

In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:

  1. Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
  2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
  3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which 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;
  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data

The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

7.2. Data voluntarily provided by the user

Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.

7.3. Cookies

For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.

8. INIM PROCESSES DATA RELATED TO MINORS

As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.

9. OPTIONALITY OF CONFERRING DAT

Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

9.1. Provision of Data and Consent

Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.

However, it should be pointed out that:

  • any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
  • any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
  • any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.

With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.

With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.

10. USE AND METHODS OF DATA PROCESSING

10.1. Network-collected data

As a result of consulting this site, data relating to identified or identifiable persons may be processed.

The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.

Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.

In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.

No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.

Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.

The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.

10.2. Data voluntarily provided by the user and collected for the performance of services

The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:

  1. registering for the personal area or joining the services offered by INIM through the Sites;
  2. Answer questions and provide information requested by the User;
  3. The handling of User requests of a technical, commercial, order status and general nature;
  4. The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
  5. legally required registrations and disclosures;
  6. The detection of the User's satisfaction and preferences;
  7. enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
  8. Payment processing, including anti-fraud control in the case of credit card payments;
  9. the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
  10. The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
  11. Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.

11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim

12. UPDATE OF THIS POLICY

This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.

Last updated June 1, 2020

Privacy - Inim Cloud Users

Information for registered users of the restricted area of the services portal "Inim Cloud"

This Privacy Policy regards Users who register on the INIM CLOUD SERVICES portal accessible from the Websitesinim www.inimdns.biz, www.inimcloud.com and my.inimcloud.com property of 'INIM ELECTRONICS S.R.L' SOLE PROPRIETOR COMPANY (henceforth INIM).

Pursuant to Articles 13 and 14 of EU Regulation 2016/679 ('General Data Protection Regulation' or 'GDPR'), we wish to inform you that, by registering with the portal, INIM, as Data Holder (henceforth 'Holder') will be made aware of your personal data.

For this reason, it is necessary for INIM to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

This Privacy Policy supplements the general Privacy Policy of INIM Websites and that of the 'INIM HOME,' 'INIM HOME P2P,' 'INIMTECH SECURITY' and 'INIM FIRE' Apps.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The Holder is 'INIM ELECTRONICS S.R.L.' SOLE PROPRIETOR COMPANY with registered office in Monteprandone (AP), District of Centobuchi, Via dei Lavoratori n. 10 Tax Code and VAT no. 01855460448. \ INIM has appointed a data protection officer (DPO) who can be contacted at the address: inim

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?

Your data is processed for the creation and management of your personal account in INIM CLOUD. Additionally, INIM might process the data as necessary both for the execution of a contract of which you are a party and for the execution of pre-contractual measures adopted at your request.

Every time INIM acquires and processes your personal data, it guarantees its availability, integrity and confidentiality.

INIM processes your data in compliance with the following principles of lawfulness provided for by law:

  1. pursuant to art. 6.1 (b) of the Regulations, in order to allow registration and;
    • allow the creation of a Personal Account on the INIM Cloud and the use of the related dedicated services;
    • allow INIM to respond to your contact requests and provide the necessary assistance;
    • allow INIM to provide the services activated by you;
  2. pursuant to art. 6.1 (a) of the Regulation, or subject to your specific and explicit consent, for the purpose of conducting marketing activities, both through automated tools (SMS, MMS, messaging platforms, e-mail, push notifications) and through traditional channels (paper mail, telephone call with operator);
  3. pursuant to art. 6.1 (a) of the Regulation, or subject to your specific and explicit consent, for profiling purposes, i.e. to identify your preferences, interests and consumption choices, in order to be able to provide you with services that are more suited to your expectations and needs;
  4. pursuant to art. 6.1 (c) of the Regulation, to fulfill legal obligations to which INIM is subject;
  5. pursuant to art. 6.1 (f) of the Regulation, for the pursuit, under the conditions and in compliance with legal constraints, of a legitimate interest of INIM or third parties, such as for example the prevention of fraud, the improvement of processes management, the exercise and defense of one's own rights, the organizational and strategic optimization of INIM.

2.1. Purpose of processing data

Your personal data will be processed by INIM for:

  1. creation of your own INIM CLOUD account;
  2. purposes functional to the management of your alarm control panels such as, by way of example and not limited to, sending notifications by e-mail, SMS or, if the INIM HOME APP is used, Push notifications regarding alarms, events and status information. Notifications can be deactivated and reactivated at any time via the INIM CLOUD account page of the User. Included in these purposes is the backup service offered in relation to the data of INIM control panels and P2P devices that can be integrated with them, for example the configuration of home-automation systems or video cameras;
  3. purposes functional to the management of your alarm control panels by your Installer. The above notifications can in turn be sent to the reference INSTALLER Account. For such data processing, see point 3.2 of this Privacy Policy;
  4. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example and not limited to, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, 'direct marketing' relating to the products and/or services marketed by INIM itself, having, however, a nature similar to those subject to previous sales or supplies;
  5. your profile in order to allow INIM to process your choices, habits and propensity to consume and, consequently, to send you specific offers related to INIM products and services;
  6. your enrollment in courses and events organized by INIM, both in presence and remote, as well as participation in promotions related to them, when consent for commercial activities has previously been acquired. For such data processing, see point 3.5 of this Privacy Policy.

The granting of consent for the purposes referred to in letter a) is necessary and eventual refusal will prevent you, the user, from completing the process of creating an account. \ The release of consent for the purposes referred to in letters b), c), d), e), f), is optional; your refusal does not prejudice in any way your existing relationship with INIM, nor the successful outcome of the process of creating a personal User account on the 'INIM' Website.

2.2. Further purposes of data processing

The data might be processed for purposes functional to the management of commercial relationships between the Data Controller and interested parties belonging to the Installer and Distributor categories or existing relationships between the latter.

2.3. Categories of subjects to whom the data can be communicated

To achieve the purposes described in paragraphs 2.1 and 2.2 above, INIM may need to communicate your Personal Data to third parties belonging to the following categories: agents and/or area dealers of products marketed by INIM; subjects who provide banking, financial and insurance services; authorities and supervisory and control bodies and, in general, subjects, public or private, in their role as Public Officials or subjects appointed to Public services; other companies in the group of which INIM is part or, however, parent, subsidiary or associated companies; entities that perform acquisition services, subjects who perform the services of data acquisition and processing necessary for the execution of the orders received from customers; subjects who provide services for the management of INIM's data and IT systems and telecommunication networks (including e-mail); subjects in charge of IT security and maintenance; subjects who carry out data transmission, enveloping, transport and the sorting of communications with users; subjects who carry out document filing and data entry activities; subjects who carry out customer assistance activities; subjects who carry out surveys and companies in the ambit of assistance and consultancy relations; subjects who carry out activities for the promotion and sale of products and services on behalf of INIM and of other companies belonging to the group of which INIM is part. \ With reference to the data communicated to them, the subjects belonging to the previously-mentioned categories will be able to operate, as the case may be, in complete autonomy as distinct Holders, or even, as managers or persons in charge of data processing. \ At the same time, the Data may also be communicated to other data processors appointed by INIM as well as to its employees operating as data processors, always for the purposes indicated in the previous paragraphs 2.1 and 2.2.

3. CATEGORIES OF INTERESTED PARTIES AND RELATED SPECIFICATIONS OF PERSONAL DATA PROCESSING

Detailed indications are provided to the various categories of interested parties, depending on their involvement and the related processing of Personal Data.

3.1 Private

The creation of a Private account in the Cloud means that the individual who registers can control and manage the associated control panel(s). The registration of the private account involves the entry of a series of data, including personal data, in the appropriate online form. The Private individual is made aware that, to manage the installation and management processes of their alarm system for the purposes referred to in point 2.1 c) of this Privacy Policy, they must necessarily communicate some data - User name and surname and serial number of the control panel - the reference Installer by means of a manual procedure (to be carried out by accessing the keypad of the control panel of the private individual) for the association of the control panel with the respective User account.

We wish to specify that this conferment is necessary in order to follow up the execution of the activation and management services of the control panels through INIM CLOUD.

Following this communication, the Installer will control and process the data of the Private individual as an independent Data Holder also through their own auxiliary installers (if any). Any personal data relating to 'Private' users, in addition to the User name and surname and serial number of the control panel, will be entered independently by the Installer, after the association of the control panels.

The association of one or more control panels by a 'Private' User, when the control panel is owned by the same, with the reference Installer, can be revoked at any time through the function present in the management panel of the Cloud.

3.2 Installer

The Installer account manages, on behalf of 'Private' accounts, the control panels associated with them and the related management and programming processes.

There are two types of 'Installer Account'.

Admin Installer Account

The 'Admin Installer' account is that linked to an individual who, in any capacity, is part of a company/sole proprietorship and is fully responsible for managing the same and the 'Auxiliary' accounts.

If there are not yet any accounts associated with the company (VAT-Country combination), the first individual who registers as the 'Installer' account automatically becomes the 'Admin Installer' account.

Those who have the 'Admin Installer' account also have the right to:

  • control and view all the control panels enrolled directly by the 'Admin' as well as those enrolled by 'Auxiliaries';
  • manage groups of 'Auxiliaries' and limit viewing and control by the same on the installed control panels;
  • Decide which group to assign the control panels to.

The registration of the 'Admin Installer account' involves the entry of a series of data, including Personal Data, in the appropriate online form.

The 'Admin installer' is made aware that, in order to manage all the processes relating to the activation of their account for the purposes referred to in point 2.1 c) of this Privacy Policy, they must complete the registration procedure.

Auxiliary installer account

An 'Auxiliary installer account' is subject to the control of the 'Admin Installer account' of the company/individual enterprise (VAT number/Company).

The registration of an 'Auxiliary Installer account' requires the entry of a series of data, including Personal Data, in the appropriate online form. The 'Auxiliary' installer is made aware that, in order to manage all the processes relating to the activation of their account for the purposes referred to in point 2.1 c) of this Privacy Policy, they must complete the registration procedure and contextually receive an e-mail containing details relating to the 'Admin' (name and surname); the 'Admin' is also made aware, in the same manner, of the Personal Data of the 'Auxiliary' (name and surname).

3.3 Distributor

The Distributor account (provided, together with the relevant password, directly by INIM) manages the relevant installers as assigned by the agreements with the Owner and might display some data relating to existing relationships between the parties, in order to best guarantee the carrying out of management and support activities.

INIM informs the Interested parties, Distributors and Installers that INIM may retain such data for statistical purposes.

3.4 Data processing specifications for the categories of interested parties 'Installer,' 'Private,' 'Designer' and 'Distributor'

The 'Admin' Installer processes the data of the 'Auxiliary' installer in the role of an independent Data Holder. It should be noted that this provision of Data from the 'Auxiliary' to the 'Admin' is necessary in order to follow up on the activation of the specific profile.

An 'Auxiliary' installer can control and view only the control panels associated with their group, in accordance with the permission granted by the 'Admin' Installer.

For all the Data processing that is carried out, the 'Auxiliary' installer operates under the responsibility of his 'Admin' Installer, in the role of the person authorized (in charge) of processing or responsible for processing.

For the processing of Data relating to 'Private' user typology, the 'Main User' operates as an independent Data Holder and it is their exclusive task to inform the 'secondary' (if any) via their own Privacy Policy and collect eventual consent.

For the 'Designer' profile, there are no further processing specifications with respect to what is indicated, generally, in this Privacy Policy.

For the 'Distributor' profile there are no further processing specifications than those indicated, in a general manner, in this Privacy Policy.

3.5 Data processing specifications for those enrolled in INIM courses and events

If you enroll in INIM courses and events, your Personal Data will be processed in order to fulfill all the administrative, logistical and organizational obligations related to the use of the same, including the sending of any certificates and the administration of satisfaction questionnaires to which you are free to answer or not. Your Personal Data, on registration, may be communicated, as provided for in point 2.1, to allow the correct fruition of the courses.

If participation in the courses is related to promotions and you have provided consent for commercial activities, your Personal Data may be communicated to one or more INIM distributors in your area in order to allow you to be contacted and thus allow you to benefit from the dedicated advantages. Personal Data will not be disclosed further than has been described, unless required by legal obligations or by regulations relating to the issue of certifications for the courses/events attended.

3.6 Specifications of data treatment for users of the voice assistant services named 'MARILYN' and 'MARILYN MORE'

In the event you wish to use, following your consent, the voice assistant services named 'MARILYN' and 'MARILYN MORE', INIM informs you that it processes the following types of data:

  • data collected automatically, such as server logs and data transmitted by Actions on Google/Dialogflow API during the user's interaction with Google Actions;
  • data collected automatically, such as server logs and data transmitted by the Skill to Amazon servers during the user's interaction with inim;
  • data obtained from the User, either directly or through the Authorization API;
  • pre-existing identification data (such as user ID of the user's My Inim Cloud profile).

The computer systems and software processes used for the functioning of voice commands, during their normal operation, acquire, from the respective servers of service providers that send the conversations collected by the Voice Assistant within the scope of the manageable functions, some personal data whose transmission is implicit in the operation of the voice instructions. This data is not collected for the purpose of association with the identity of the interested parties, but which, by their very nature allows users to be identified. This category of data includes the commands given, the Inim anti-intrusion systems involved and in general all the conversation data the voice assistants provide to the Inim servers for the operation of commands and instructions.

These data are stored for a limited period of time, for the sole purpose of having diagnostic information for the resolution of any problems relating to the functioning of the actions and to keep track of the activities carried out via voice commands for purposes provided for by law (for example, in the case of a request made by the police or the judiciary or other competent bodies). The data that Inim keeps for the aforementioned purpose of technical assistance, relating to the actions on voice assistants, are deleted twelve months after their collection.

The data of users is utilized for providing the services offered by the Inim Apps and is activatable through them or the Inim Cloud, for the management of the alarm systems they possess and the home-automation devices that can be connected to them, and include the possibility of their identification and recognition for subsequent uses of the App.

INIM does not use any collected data for the purposes of customer profiling, for offering products and services or for any other commercial purposes.

The personal data that INIM processes are collected for purposes strictly related to the activation and operation of the voice functions activated by the user.

However, we inform you that the computer systems and software processes of third parties in charge of functions, may acquire, in providing their services, some data referable to the user whose transmission is implicit in the use of the voice assistant functions on smartphones and on other compatible devices. Inim is not involved in such processing, carried out autonomously and exclusively by the respective Data Controllers, nor can Inim be held responsible for them.

Therefore, prior to the activation of the services, we invite you to consult the privacy policies of the Google and Amazon voice assistant services published on their respective websites.

3.7 Processing specifications for users of services dedicated to the management of Video surveillance via INIM Cloud and INIM App

In the event that you wish to use, following activation by you, the Services (offered via Cloud and INIM App) dedicated to the management of Video surveillance, INIM informs you that it processes the following types of data:

  • information such as images and short films (maximum duration of 15 seconds) which are acquired and stored exclusively following the automatic signalilng of presence or alarm by the installed systems;
  • information relating to the zone in alarm and the event that generated it.

The IT systems and software procedures responsible for the operation of the Video surveillance system, during their normal operation, acquire this information from the respective systems of users.

This data is recorded for a limited period of time, for the sole purpose of making information available on events that could be useful to users based on their legitimate interest in carrying out such collection of data and storage. The data that INIM keeps for the aforementioned purposes are deleted by choice of the user or in any case thirty days after their collection. INIM may have access to such data exclusively for technical purposes and following requests for assistance from the User, thus covering the role of Privacy Manager, pursuant to art. 28 of the GDPR. This nomination is present in the D.P.A. (Agreement for the processing of personal data).

The User data is utilized to provide the services offered by Inim Apps that can be activated via the same or in the Inim Cloud, for the management of the video surveillance system of the Users and includes the possibility of identifying them and recognizing them for subsequent use of the Apps.

The personal data that INIM processes are collected for purposes strictly connected to the functions activated by the User.

We inform you, however, that the IT systems and software procedures of third parties responsible for the functioning of the entire system may acquire, in providing their services, some data in any case referable to the User, the transmission of which is implicit in the use of the functions present on Smartphones and other compatible devices. INIM is not involved in such processing, carried out autonomously and exclusively by the respective Data Controllers, nor can INIM be held responsible for them.

Therefore, we invite you to consult, before activating the services, the privacy policies of your suppliers and managers of hardware, software and related services.

3.8 Specifications of treatment for users of the INIM DRIVE service dedicated to file management and sharing

In the event that the Installer User uses the Service dedicated to file management and sharing (via Cloud and INIM App), INIM may process the following types of data:

  • files uploaded to the general Drive environment, which can be shared with other company accounts (admin and auxiliary installer accounts) registered with the same VAT number;
  • files uploaded to the checklist and Storage areas relating to individual systems, which can be shared with other accounts in the company organization concerned and/or with private user accounts enrolled on a specific system.

The files located in the INIM DRIVE space are the exclusive property of the Installer User. The data that INIM stores for the aforementioned purposes are managed and shared exclusively at the choice of the Installer User. INIM may have access to such data exclusively for technical purposes and following requests for assistance from the Installer User, thus acting as Privacy Manager, pursuant to art. 28 of the GDPR. This appointment is present in the specific D.P.A. (Data Processing Agreement) of the service which can be consulted within the dedicated area of the INIM Cloud.

4. WHERE DO WE PROCESS YOUR DATA?

The processing operations connected to the Web services of this Website take place at the aforementioned headquarters of INIM and are handled solely by technical staff responsible for or in charge of data processing, or by other persons responsible for or in charge of occasional maintenance operations.

5. WILL YOUR DATA BE TRANSFERRED ABROAD?

INIM currently processes your personal data without transferring it to countries other than those belonging to the European Union or that do not ensure adequate levels of personal data protection. The privacy regulation allows the transfer of personal data abroad with the consent of the User, or where there is a legal justification and where an adequate level of data protection is guaranteed. INIM undertakes to ensure that if the data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate safety measures will be taken to protect personal data in such countries/territories.

6. HOW IS YOUR DATA PROCESSED AND FOR HOW LONG?

Data processing:

  1. is carried out by means of the operations or set of operations amongst which the collection, registration and organization, processing, including modification, comparison/interconnection, use, consultation, conservation, cancellation/destruction, security/protection, integrity and safeguarding;
  2. takes place using manual, computerized and telematic tools with logic strictly related to the purposes referred to previously in paragraphs 2.1 and 2.2 above and, however, in such a way as to guarantee the security and confidentiality of the data.

Your personal data will be stored by INIM only for the time strictly necessary to achieve the purposes for which collected and processed, unless subject to requirements for further conservation in the face of specific provisions of the Law.

The Personal Data processed for the creation of the personal account and for the use of the services dedicated to those with a personal account, will be stored and processed until your personal account is closed.

In relation to system logs, these are treated by INIM as follows:

  • system logs relating to user activities, collected for assistance and maintenance purposes as well as to improve the services offered, are kept by INIM for 12 months from their collection;
  • system logs, collected for statistical purposes, are deleted or anonymized by INIM within 12 months of their collection;
  • system logs, relating to the activities of users in the Cloud, are kept by INIM for 12 months from their collection except for the need to keep them in compliance with laws or regulations relating to the specific services used;
  • system logs, relating to the activities of users who make use the MARILYN and MARILYN MORE voice assistants are kept by INIM for 12 months from their collection for the purpose of assistance and maintenance as well as to improve the services offered;
  • system logs, relating to communication activities addressed to users for the management of the services offered are kept by INIM for 12 months from their collection except for the need to keep them in the legitimate interest of the data controller for legal protection purposes or on the basis of compliance with current regulatory requirements.

We inform you that any requests for extension of storage times, made for justified reasons, should be addressed to the contact details in point 10 of this informative notice.

The data processed for the purposes of marketing and profiling (always, of course, provided that your express consent has been given), will be stored in accordance with the applicable legislation and in any case until the revocation of your consent to the processing of your personal data.

The data processed following your eventual purchase of products, will be used exclusively for the sending of e-mails in accordance with the provisions of art. 130, paragraph 4, of the Data Protection Act.

In all cases, the User will have the right to revoke consent to the processing of personal data for marketing and profiling purposes at any time: in each commercial communication there is a section that will allow the User to easily revoke their given consent.

At the time of the revocation of consent, even if expressed before the expiry of the retention period of data collected for the aforementioned purposes, the same will be automatically deleted or permanently anonymized and our Company may ask the User to renew consent to its processing.

The data transmitted to any service providers will be processed by them for the time strictly necessary for the execution of the tasks entrusted to them.

In regard to data backup management, it is to be noted that:

  • the data is backed up on the Cloud;
  • backup is activated automatically at login;
  • the user can deactivate data backup before configuring their security system;
  • the user can disable data backup after configuring their security system via the appropriate option in the APP: 'Settings' > 'Data backup on Cloud' and deselect 'Backup active;
  • once the backup is disabled, the user can decide whether or not to cancel backup via the Cloud.

Specific security measures will be observed at all times to prevent data loss, illicit or incorrect use and unauthorized access.

7. WHAT ARE YOUR RIGHTS?

The privacy legislation (articles 15-22 of the Regulation) guarantees you the right at all times to access data that concerns you, as well as to correct and/or integrate such data, if incorrect or incomplete, the cancellation or the limitation of processing, if the conditions are met, to oppose processing for reasons related to your particular situation, to the portability of the data you provided, where processed automatically for the services you requested, within the limits of the provisions of the Regulation (art. 20).

8. DOES INIM PROCESS DATA RELATING TO MINORS?

As a general rule, we do not intentionally collect Personal Data regarding minors. If it is discovered that inadvertently Personal Data from such individuals has been collected, INIM reserves the right to act in such a way as to delete the said data as soon as possible, except where the applicable law requires us to conserve it.

9. OPTIONALITY OF DATA SUPPLY

Apart from what is specified for the registration data necessary for the creation of your account and the management of the requested services, you are free to provide the personal data contained in the request forms or otherwise indicated in contacts to request, for example, the sending of material information or other communications. Failure to provide such data may make it impossible to obtain what has been requested. For completeness, it should be remembered that in some cases (not subject to the ordinary management of this Website) the Authorities may request information for the purpose of checking the processing of personal data. In such cases, a reply is mandatory under penalty of an administrative sanction.

In particular, it should be noted that, if you decide not to give consent to the processing of your personal data for marketing purposes, INIM will not be able to involve you in its promotional initiatives, including periodic updating via the newsletter service.

If you decide not to give consent to the processing of your personal data for profiling purposes, this would have no impact on your participation in the Inim promotional communications plan, but would simply make it impossible for INIM to send you personalized promotional communications.

10. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party can at any time exercise towards the Data Holder the rights provided for in articles 15 to 22 of the Regulation, by contacting 'INIM ELECTRONICS S.R.L.' Sole Proprietor Company at their registered office in Monteprandone (AP), District of Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, e-mail: inim

11. UPDATING OF THIS POLICY

This Privacy Policy regulates the processing of your Personal Data released when registering on the INIM CLOUD SERVICES portal and may be amended or simply updated, in whole or in part, also in consideration of changes in the laws or regulations governing the protection of Personal Data. Any changes and updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published on the Website. INIM, therefore, invites Users to access this page regularly and check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when it was last updated.

Last updated: 30th July 2025

Privacy - Quote Requests

Information for users requesting quotes from Inim installers and information about Inim products

This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.

Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.

To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE DATA CONTROLLER

Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.

2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.

2.1. Purpose of processing

The Data are processed for the following purposes:

  1. purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
  2. Purposes strictly related and/or necessary for the performance of the services requested by the User;
  3. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
  4. User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.

2.2. Categories of individuals to whom the Data may be disclosed

In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM

With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.

At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.

3. WHERE WE PROCESS YOUR DATA

Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.

4. YOUR DATA IS TRANSFERRED ABROAD

INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.

5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG

Processing of Data:

  1. is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
  2. is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.

Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.

The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.

Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.

The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.

You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.

Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.

6. WHAT ARE YOUR RIGHTS

In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:

  1. Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
  2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
  3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which 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;
  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data

The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

7.2. Data voluntarily provided by the user

Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.

7.3. Cookies

For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.

8. INIM PROCESSES DATA RELATED TO MINORS

As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.

9. OPTIONALITY OF CONFERRING DAT

Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

9.1. Provision of Data and Consent

Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.

However, it should be pointed out that:

  • any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
  • any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
  • any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.

With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.

With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.

10. USE AND METHODS OF DATA PROCESSING

10.1. Network-collected data

As a result of consulting this site, data relating to identified or identifiable persons may be processed.

The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.

Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.

In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.

No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.

Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.

The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.

10.2. Data voluntarily provided by the user and collected for the performance of services

The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:

  1. registering for the personal area or joining the services offered by INIM through the Sites;
  2. Answer questions and provide information requested by the User;
  3. The handling of User requests of a technical, commercial, order status and general nature;
  4. The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
  5. legally required registrations and disclosures;
  6. The detection of the User's satisfaction and preferences;
  7. enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
  8. Payment processing, including anti-fraud control in the case of credit card payments;
  9. the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
  10. The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
  11. Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.

11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim

12. UPDATE OF THIS POLICY

This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.

Last updated June 1, 2020

Privacy - Contact

Information for users requesting information using the form on the Inim website

This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.

Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.

To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE DATA CONTROLLER

Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.

2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.

2.1. Purpose of processing

The Data are processed for the following purposes:

  1. purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
  2. Purposes strictly related and/or necessary for the performance of the services requested by the User;
  3. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
  4. User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.

2.2. Categories of individuals to whom the Data may be disclosed

In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM

With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.

At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.

3. WHERE WE PROCESS YOUR DATA

Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.

4. YOUR DATA IS TRANSFERRED ABROAD

INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.

5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG

Processing of Data:

  1. is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
  2. is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.

Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.

The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.

Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.

The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.

You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.

Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.

6. WHAT ARE YOUR RIGHTS

In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:

  1. Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
  2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
  3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which 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;
  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data

The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

7.2. Data voluntarily provided by the user

Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.

7.3. Cookies

For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.

8. INIM PROCESSES DATA RELATED TO MINORS

As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.

9. OPTIONALITY OF CONFERRING DAT

Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

9.1. Provision of Data and Consent

Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.

However, it should be pointed out that:

  • any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
  • any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
  • any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.

With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.

With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.

10. USE AND METHODS OF DATA PROCESSING

10.1. Network-collected data

As a result of consulting this site, data relating to identified or identifiable persons may be processed.

The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.

Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.

In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.

No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.

Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.

The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.

10.2. Data voluntarily provided by the user and collected for the performance of services

The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:

  1. registering for the personal area or joining the services offered by INIM through the Sites;
  2. Answer questions and provide information requested by the User;
  3. The handling of User requests of a technical, commercial, order status and general nature;
  4. The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
  5. legally required registrations and disclosures;
  6. The detection of the User's satisfaction and preferences;
  7. enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
  8. Payment processing, including anti-fraud control in the case of credit card payments;
  9. the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
  10. The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
  11. Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.

11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim

12. UPDATE OF THIS POLICY

This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.

Last updated June 1, 2020

Privacy - Applications

Disclosure for submitting applications throughinim

This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.

Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.

To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE DATA CONTROLLER

Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.

2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.

2.1. Purpose of processing

The Data are processed for the following purposes:

  1. purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
  2. Purposes strictly related and/or necessary for the performance of the services requested by the User;
  3. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
  4. User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.

2.2. Categories of individuals to whom the Data may be disclosed

In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM

With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.

At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.

3. WHERE WE PROCESS YOUR DATA

Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.

4. YOUR DATA IS TRANSFERRED ABROAD

INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.

5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG

Processing of Data:

  1. is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
  2. is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.

Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.

The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.

Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.

The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.

You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.

Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.

6. WHAT ARE YOUR RIGHTS

In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:

  1. Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
  2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
  3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which 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;
  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data

The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

7.2. Data voluntarily provided by the user

Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.

7.3. Cookies

For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.

8. INIM PROCESSES DATA RELATED TO MINORS

As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.

9. OPTIONALITY OF CONFERRING DAT

Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

9.1. Provision of Data and Consent

Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.

However, it should be pointed out that:

  • any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
  • any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
  • any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.

With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.

With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.

10. USE AND METHODS OF DATA PROCESSING

10.1. Network-collected data

As a result of consulting this site, data relating to identified or identifiable persons may be processed.

The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.

Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.

In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.

No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.

Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.

The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.

10.2. Data voluntarily provided by the user and collected for the performance of services

The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:

  1. registering for the personal area or joining the services offered by INIM through the Sites;
  2. Answer questions and provide information requested by the User;
  3. The handling of User requests of a technical, commercial, order status and general nature;
  4. The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
  5. legally required registrations and disclosures;
  6. The detection of the User's satisfaction and preferences;
  7. enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
  8. Payment processing, including anti-fraud control in the case of credit card payments;
  9. the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
  10. The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
  11. Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.

11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim

12. UPDATE OF THIS POLICY

This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.

Last updated June 1, 2020

Privacy - Webinar

Information dedicated to participants of web courses and events organized by "Inim Electronics s.r.l." Unipersonale through the GoToWebinar platform

This information is provided for visitors and users of the websites:inim www.inimdns.biz and www.inimcloud.com, owned by INIM ELECTRONICS S.R.L. Unipersonale (henceforth INIM) and not for any additional websites that may be consulted by the user through internal links.

Pursuant to Articles 13 and 14 of the EU Regulation 2016/679 ("Regulation" or "GDPR"), we inform you that, by using the aforementioned sites, INIM, as the Data Controller (henceforth also simply "Data Controller") necessarily becomes aware of personal data relating to you.

To this end, it is necessary to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE DATA CONTROLLER

Whenever INIM acquires and processes your personal data, it does so exclusively in accordance with the principles of lawfulness set forth in the regulations and for the purposes outlined below.

2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA

Your data is processed based on your consent for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process data as it is necessary both for the performance of a contract to which you are a party and for the performance of pre-contractual measures taken at your request.

2.1. Purpose of processing

The Data are processed for the following purposes:

  1. purposes related to obligations under laws and regulations (including those of an accounting and tax nature) as well as provisions issued by the competent supervisory and control authorities/bodies;
  2. Purposes strictly related and/or necessary for the performance of the services requested by the User;
  3. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example but not limited to, and subject to obtaining consent, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, so-called "direct marketing" activities relating to products and/or services marketed by INIM itself, having, in any case, a nature similar to those covered by previous sales or supplies;
  4. User profiling, after obtaining consent, in order to allow INIM to process the User's choices, habits and propensities for consumption and, consequently, to send him specific offers related to its products and services.

2.2. Categories of individuals to whom the Data may be disclosed

In order to pursue the purposes described in paragraph 2 above.1, INIM may need to communicate the Data provided by the User, to third parties belonging to the following categories: agents and/or area concessionaires of the products marketed by INIM; subjects that perform banking, financial, insurance services; authorities and supervisory and control bodies and in general subjects, public or private, holding the position of Public Officials or persons in charge of a public service; other companies of the group of which INIM is part or, in any case, parent, subsidiary or associated companies; subjects that perform data acquisition, processing and processing services necessary for the execution of the instructions received from customers; parties that provide services for the management of INIM 's computer and information systems and telecommunications networks (including electronic mail); IT security and maintenance officers; parties that carry out transmission, enveloping, transport and sorting activities for communications with Users; parties that carry out documentation archiving and data entry activities; parties that carry out customer service activities; firms and companies within the scope of assistance and consulting relationships; parties that carry out promotion and sales activities for products and services of INIM and other companies of the group of which INIM is part INIM

With regard to the Data communicated to them, the individuals in the above categories may operate, as the case may be, either completely independently as separate data controllers, or, as data processors or data processors.

At the same time, the Data may, moreover, be communicated to any additional data processors appointed by INIM as well as to its own employees in their capacity as data processors, again for the purposes indicated in section 2.1 above.

3. WHERE WE PROCESS YOUR DATA

Processing related to the web services of this site takes place at the aforementioned headquarters of INIM and is handled only by technical personnel responsible for or in charge of processing, or by those responsible for or in charge of occasional maintenance operations.

4. YOUR DATA IS TRANSFERRED ABROAD

INIM currently processes your data without transferring it to foreign countries other than those belonging to the European Union or which do not ensure adequate levels of protection of individuals. Privacy legislation allows the transfer of personal data abroad with your consent, or where there is another legal justification and an adequate level of data protection is ensured. INIM is committed to ensuring that if data is transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are taken to protect personal data in those countries/territories.

5. HOW YOUR DATA IS PROCESSED AND FOR HOW LONG

Processing of Data:

  1. is achieved by means of the operations or complex of operations including collection, recording and organization, processing, including modification, comparison/interconnection, use, consultation, storage, erasure/destruction, security/protection, integrity, protection;
  2. is carried out by means of manual, computerized and telematic tools with logics strictly related to the purposes set out in paragraph 2.1 above and, in any case, in such a way as to guarantee the security and confidentiality of the Data.

Your personal data are kept by INIM only for as long as is strictly necessary to achieve the purposes for which they were collected and processed, without prejudice to the need for further storage in the face of specific provisions of Law.

The data acquired for the purpose of registration to the portal INIM CLOUD SERVICES are governed by special detailed information in the registration form. These are processed in relation to the services offered by INIM through its portal, exclusively for the purposes that fall within the institutional tasks of the company or for the fulfillments required by law or regulations. Within the scope of these purposes, processing also concerns data related to registrations/registrations to the portal necessary for the management of relations with INIM, as well as to enable effective institutional communication and to fulfill any legal, regulatory or contractual obligations. These data are retained in accordance with the terms and conditions of the service offered or alternatively until any revocation of your consent.

Data processed for marketing and profiling purposes (always, of course, provided that your express consent has been acquired), are retained in accordance with the provisions of current legislation and in any case until your consent to the processing of personal data is revoked.

The data processed as a result of your possible purchase of products, are used for the exclusive sending of e mails according to the provisions of Article 130, paragraph 4, Privacy Code.

You have in any case the possibility of revoking your consent to the processing of data for marketing and profiling purposes at any time: there is a section in each commercial communication that allows you to easily revoke the consent you have given. When you revoke your consent, even if expressed prior to the expiration of the retention period of the data collected for these purposes, the same will be automatically deleted or permanently anonymized and INIM may ask you to renew your consent to the processing. Data transmitted to any service providers are processed by them for the time strictly necessary to carry out the tasks entrusted to them.

Specific security measures are observed at all times to prevent data loss, illegal or incorrect use, and unauthorized access.

6. WHAT ARE YOUR RIGHTS

In your capacity as a data subject, you may exercise, using the methods indicated in paragraph "11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY", the rights set forth in Articles 15 to 22 of the Regulations and in particular:

  1. Obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet registered, and their communication in intelligible form;
  2. obtain indication of: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in case of processing carried out with the aid of electronic instruments; d) the identification details of the owner, managers and designated representative under 'art. 3, paragraph 1, GDPR; e) the subjects or categories of persons to whom the personal data may be communicated or who may become aware of them as appointed representative in the State territory, managers or agents;
  3. obtain: a) the updating, rectification or, when interested, the integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which 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;
  4. oppose, in whole or in part: a) for legitimate reasons, the processing of personal data concerning you, even if pertinent to the purpose of collection; b) the processing of personal data concerning you, for the purpose of sending advertising materials or direct sales or for carrying out market research or commercial communication, through the use of automated calling systems without the intervention of an operator, by e-mail and / or traditional marketing methods (telephone and / or paper mail). It should be noted that the data subject's right to object, for direct marketing purposes by automated means, extends to traditional ones and in any case the possibility remains for the data subject, to exercise the right to object even in part. The data subject may, therefore, decide to receive only communications by traditional means or only automated communications or neither type of communication.

Where applicable, you may also exercise your rights under Articles 15 to 22 of the GDPR (Right to rectification, Right to be forgotten, Right to restrict processing, Right to data portability, Right to object), as well as the right to complain to the Data Protection Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data

The computer systems and software procedures used to operate these websites acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This is information that is not collected to be associated with identified interested parties but which, by its very nature, could, through processing and association with data held by third parties, allow users to be identified. This category of data includes the IP addresses or domain names of the computers used by users who connect to the site, the URI (Uniform Resource Identifier) notation addresses of the resources requested, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct operation and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the site.

7.2. Data voluntarily provided by the user

Following optional, explicit and voluntary consent expressed in advance by the interested party by filling in the forms on the site or by using the addresses indicated in the same, INIM collects and retains the data received, including the e-mail address, for the time necessary to respond to requests, for the purpose of exchanging information or contacts. Specific summary information will be progressively reported or displayed on the pages of the site prepared for particular services on request or for particular categories of data.

7.3. Cookies

For information regarding the Cookie Policy adopted you can consult the Cookie Policy in the dedicated section of the site.

8. INIM PROCESSES DATA RELATED TO MINORS

As a general rule, INIM does not intentionally collect personal data concerning minors. If INIM learns that it has inadvertently collected personal data from such individuals, INIM will act to delete it as soon as possible, except where applicable law requires retention.

9. OPTIONALITY OF CONFERRING DAT

Apart from what has been specified for navigation data, the user is free to provide the personal data indicated in the request forms or in any case indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide them may make it impossible to obtain what has been requested. For the sake of completeness, it should be remembered that in some cases (not subject to the ordinary management of this site) the Authority may request news and information for the purpose of monitoring the processing of personal data. In these cases, the response is mandatory under penalty of administrative sanction.

9.1. Provision of Data and Consent

Without prejudice to the personal autonomy of the User, the provision of Data for the purposes mentioned in paragraph 2.1 above is optional.

However, it should be pointed out that:

  • any refusal of the User to confer the Data for the purposes set out in paragraph 2.1, letters (a), (b) above, or the deletion of the same, following the User's request, entails the impossibility for INIM to guarantee access to the reserved area of the Site and, consequently, to benefit from the services requested;
  • any refusal by the User to confer the Data for the purpose referred to in paragraph 2.1, letter (c) above, or the cancellation of the same, following its request, entails the impossibility for INIM to carry out the other functional/complementary activities of a promotional and advertising nature for the benefit of the User, without prejudice, however, to the possibility for the latter to access the reserved area of the Site and to benefit from the services requested;
  • any refusal by the User to provide Data for the purpose referred to in paragraph 2.1, letter (d) above, or the cancellation of the same, entails for INIM the impossibility of profiling the User according to the choices, habits and propensities to consumption shown and prevents it from rendering, to the same User, information and communications structured on the basis of the preferences shown. Failure to provide the Data referred to in paragraph 2, letter (d) above, however, does not affect the possibility for the User to access the reserved area of the Site and benefit from the services requested.

With regard to the purposes under paragraph 2.1, letters (a) and (b), we inform you that the processing of the Data by INIM, including its communication to the entities referred to in paragraph 2.2 below, does not require your consent as the processing is necessary to perform services requested by you as well as to comply with legal obligations.

With regard to the purpose indicated in paragraph 2.1, letter (c), we point out that the consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Privacy Code (so-called "direct marketing") implies consent to receive such communications by both automated (e-mail) and traditional (paper mail and telephone calls through an operator). The User is, however, left the option to express his or her consent to the receipt of the aforementioned communications through the contact methods provided. This is without prejudice, on the other hand, to the provisions of art. 130, paragraph 4, Privacy Code, which authorizes INIM to use, for the direct sale of its products or services, the electronic mail details provided by the User in this context, without his prior consent, provided that the services in question are similar to those being sold and the User, adequately informed, does not refuse such use initially or on the occasion of subsequent communications. The User may object to such processing at any time.

10. USE AND METHODS OF DATA PROCESSING

10.1. Network-collected data

As a result of consulting this site, data relating to identified or identifiable persons may be processed.

The provision of data is optional, however, the same may in some cases be indispensable for the performance of specific activities and therefore, failure to provide them would result in INIM being prevented from providing services and information.

Failure to provide all data except those that do not relate to legal, tax, and contractual obligations is evaluated by INIM on a case-by-case basis and determines the resulting decisions, related to the importance to INIM of the data requested and not provided.

In particular, for the purposes defined in the following point "10.2. Data provided voluntarily by the user and collected for the performance of services ", will be required to express, free and informed consent to the processing of data, through specific signing of appropriate documentation drawn up for processing where required.

No data is disclosed or disseminated unless expressly specified in the notices drafted for specific processing for which explicit and separate consent will be required from the data subject.

Likewise, if it turns out to be necessary to acquire sensitive data, it will be required to provide explicit and separate consent to the data subject.

The technical data related to your accesses to the Site, as well as those collected from any e-mails you send, are not, in any case, disclosed to third parties, nor are they subject to dissemination.

10.2. Data voluntarily provided by the user and collected for the performance of services

The collection and processing of the User's personal data is carried out in accordance with the general principles of necessity, correctness, relevance and non-excessiveness, and in particular, the processing of data is carried out for:

  1. registering for the personal area or joining the services offered by INIM through the Sites;
  2. Answer questions and provide information requested by the User;
  3. The handling of User requests of a technical, commercial, order status and general nature;
  4. The performance of activities related, instrumental or necessary to the provision of INIM's services, including the communication of data to third party companies that, by way of example only, perform activities necessary or instrumental to the provision of INIM 's services or may handle payments on the Site;
  5. legally required registrations and disclosures;
  6. The detection of the User's satisfaction and preferences;
  7. enable the User to access, following registration and creation of their User profile in the INIM CLOUD SERVICES portal, the restricted area for the provision of services, products and any other kind of request and the subsequent and autonomous management of their User profile from the control panel;
  8. Payment processing, including anti-fraud control in the case of credit card payments;
  9. the sending, subject to obtaining consent, of advertising, informative and commercial information material, as well as the transfer to third parties of data processed for commercial purposes, including for sale or attempted sale, or for all those purposes of a commercial and/or statistical nature that are lawful under current legislation. Consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called "direct marketing") implies consent to receive such communications by automated and traditional means (paper mail and telephone calls through an operator). In such circumstances, the User is nevertheless left with the option of expressing consent to receive the aforementioned communications exclusively through traditional modes of contact;
  10. The profiling of the User, after obtaining consent, in order to allow INIM to process his choices, habits and propensities for consumption and, consequently, send him specific offers related to its products and services;
  11. Subscription to the "NEWSLETTER" service. The User can subscribe to it when registering to the restricted area. Such data will not be disclosed to third parties. Specifically, it is possible to consult the dedicated information.

11. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party at any time may exercise against the Data Controller the rights provided for in Articles 15 to 22 of the Regulation, by contacting INIM ELECTRONICS S.R.L. Unipersonale with registered office in Monteprandone (AP), locality Centobuchi, at Via dei Lavoratori 10, c.f. and p. i.v.a. 01855460448, by e-mail: inim

12. UPDATE OF THIS POLICY

This Privacy Policy governs the processing of personal data released by the User while browsing any of the INIM Sites and may be amended or simply updated, in whole or in part, by INIM , including in consideration of changes in laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy are made known to Users as soon as they are adopted and become binding once posted on the Site. INIM therefore invites Users to regularly access this page to check the publication of the most recent and updated Privacy Policy. For this purpose, the document highlights the date it was updated.

Last updated June 1, 2020

Privacy - Inim App

Information for users of the "Inim Home" app.

"INIM ELECTRONICS S.R.L Sole Proprietor Company (henceforth also "INIM" or "Supplier") thanks you for your interest in this App. Protecting your privacy as an App User is an important concern for "INIM".

Hereinafter "INIM" informs you about the processing of personal data carried out in relation to the App. "Personal data" is information that refers to an identified or identifiable natural person.

This Policy supplements that of the INIM CLOUD to which reference should be made for everything not mentioned in detail herein.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The Holder is INIM ELECTRONICS S.R.L. Sole Proprietor Company with registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori n. 10 Tax Code and VAT no. 01855460448. \ INIM has appointed a data protection officer (DPO) who can be contacted at the address: inim

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA

2.1 Categories of data

"INIM" processes the personal data that the User provides when registering on the INIM CLOUD with a Private User profile and when installing and using the App. Consent to the transmission of such data is not mandatory by law, nor necessary for the purposes of entering into a contractual agreement, however, any refusal or withdrawal of consent, may compromise the proper functioning of the App or limit its use. The User can deactivate or activate data transmission at any time via their profile settings in the INIM CLOUD.

2.2 Purpose of processing data

"INIM" processes the previously described personal data in compliance with the principles of the data protection regulations currently in force. Processing is carried out for the purposes described below.

(a) Management of the services offered by the APP.

'INIM' processes personal data for the purpose of executing the request of registration of the User for the use of the App (preparation of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing of the same ceases. Any further storage or processing of data will be allowed only under the conditions referred to in point 5.

In regard to data backup management, it is to be noted that:

  • the data is backed up on the Cloud;
  • backup is activated automatically at login;
  • the User can deactivate data backup before configuring their security system;
  • the User can disable data backup after configuring their security system via the appropriate option in the App: 'Settings' > 'Data backup on Cloud' and deselect 'Backup active;
  • once the backup is disabled, the User can decide whether or not to cancel backup via the Cloud.

In regard to video surveillance, it is to be noted that:

  • the relevant service is activated by the User in the Cloud and in the App
  • the information collected is exclusively images and short videos (saved in the Cloud with a maximum duration of 15 seconds) relating to the event that generated the alarm and the area involved and which remain available in the App for a limited period configured by the Main private User in the 'Cloud space and privacy' section of the App

(b) Consent to the processing of personal data

Where the User has given consent to the Supplier for the processing of their personal data for further purposes (see point 4), such data processing will take place on the basis of this consent. The declarations of consent are always optional and can be revoked freely at any time also by e-mail in writing to inim\ The withdrawal of consent does not affect the legitimacy of any data processing carried out up to that moment on the basis of the consent previously issued, nor the right to further processing of the aforementioned data by virtue of another legal basis, for example for the fulfillment of legal obligations (see point d).

(c) Pursuit of legitimate interests

Where necessary, 'INIM' processes the personal data of the User to protect the legitimate interests of themselves or third parties. The maintaining of functionality and security of the 'INIM' IT systems falls within the sphere of these legitimate interests. Generally, personal data will be deleted when further processing or storage of the same is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be allowed solely under the conditions referred to in point 5.

(d) Fulfillment of legal obligations or related to purchases made by the user

"INIM" is subject to compliance with legal obligations and provisions, such as obligations related to data retention in accordance with the regulations of the Commercial and Tax law. Therefore "INIM" processes the personal data of the User also to the extent necessary for the fulfillment of legal obligations, it being understood however that the personal data of a single User will be disclosed only in the presence of a legal obligation towards public order and judicial authorities.

3. PUSH NOTIFICATIONS

The User can consent to the receipt of push notifications on their devices, at the time of registration or subsequently, by activating the appropriate features on the control panel of the INIM CLOUD. The push notifications the App sends to the user may concern:

  1. Technical information arising from events:

    • arising from events that are recorded on the control panels connected to the account (e.g. faults, anomalies)
    • relating to alarms from the control panel or from a video surveillance device (N.V.R. - network video recorder)
    • related to the management of the Cloud account of the User (e.g. out of Cloud space, expiry of services)
    • related to the more general operational management of the Cloud (e.g. the Cloud will not be operational date... hour...)
    • relating to new product features, firmware and software updates, etc.

    These notifications can be enabled by the User in their personal area of the CLOUD or in the App.

  2. Data of a commercial nature. \ These notifications make provision for the consent, given by the interested party, when registering on the CLOUD, for the receipt of such information. Push notifications can be managed, deactivated and reactivated at any time directly via the pages of the INIM CLOUD account belonging to the User.

4. RECIPIENTS OF PERSONAL DATA

4.1 Transfer to third parties

If within the App the User takes advantage of services from service providers and other third parties, "INIM" may transfer the personal data of the User to such third parties but only to the extent necessary for the preparation and use of the App and its respective functions (see point 2.2 a), for the purpose of pursuing legitimate interests of their own or third parties (see point 2.2 c), or where the User has previously consented to such transfer (see point 2.2 b). Service providers, carefully selected by "INIM", are regularly checked by the same, in particular from the point of view of the accuracy of the processing and protection of personal data made accessible from time to time. All service providers are bound by "INIM" to the obligation of secrecy and to compliance with current laws in force.

4.2 Recipients of data in third countries

The personal data of the User will not be transmitted by the Supplier to recipients based in States outside the EU/EEA.

4.3 State institutions or authorities

The transmission of personal data to state institutions or authorities takes place only within the limits of binding laws (see point 2.2 d).

5. TERMS OF STORAGE AND CANCELLATION

"INIM" stores and processes the personal data of the User solely for the period strictly necessary for the respective purpose (see point 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms allowed for further purposes pursuant to point 2.2, such as for the fulfillment of legal obligations (e.g. retention obligations according to Tax and Commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis of the further processing.

6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION

In addition to the aforementioned rules, in accordance with the provisions of the European Union Data Protection Regulation (GDPR) and within the limits of the respective field of application, the following provisions apply.

6.1 Legal basis

The processing of personal data described in point 2.2 is based on the legal bases listed below.

  • Data processing for the execution of the contract: art. 6 c. 1 b) GDPR
  • Data processing on the basis of the consent of the interested party: art. 6 c. 1 a) GDPR
  • Data processing for the purpose of pursuing legitimate interests: art. 6 c. 1 f) GDPR
  • Data processing for the purpose of fulfilling legal obligations: art. 6 c. 1 c) GDPR

6.2 Protection in the case of suppliers in third countries

Where, in the opinion of the European Union, an "adequate level of protection" for the processing of personal data compliant with EU standards cannot be guaranteed, as suitable guarantee pursuant to art. 46 GDPR in the event of use of service providers (see point 4), the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules or approved codes of conduct apply. An electronic copy of the relevant extracts can be provided on a specific request to be presented to the Data Protection Officer.

6.3 Rights of the interested party

As the interested party in the processing of personal data, the User has the right of access to information (art.15 GDPR), correction (art.16 GDPR) and deletion of personal data (art.17 GDPR), limitation of processing (art 18 GDPR) and data portability (art.20 GDPR).

6.4 Right to object

For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of art. 6 c. 1 e) GDPR (data processing necessary in public interest) or art. 6 c. 1 f) GDPR (data processing based on a balancing of interests). In the event of opposition by the User, the related personal data will be processed by the Supplier where it is possible to demonstrate binding and justified reasons that prevail over the interests, rights and freedoms of the user, or where processing is necessary for the purposes of the claim, the exercise or defense of legal rights.

6.5 Complaints

If the User believes that the processing of their personal data may represent a violation of the law, they have the right to lodge a complaint with a competent data protection authority (art. 77 GDPR).

7. EXERCISE OF RIGHTS

The User can exercise the rights referred to in point 6 by e-mail in writing to inim

8. UPDATING OF THIS PRIVACY POLICY RELATED TO THE PROTECTION OF PERSONAL DATA

The Supplier reserves the right to amend or simply update, in whole or in part, this privacy policy, also in consideration of changes in the laws or regulations governing the protection of personal data. Such amendments/updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published on the Website. "INIM", therefore, invites Users to access this page regularly and check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when last updated.

Last updated: January 30, 2025

'INIM ELECTRONICS S.R.L' Sole Proprietor Company (henceforth also 'INIM' or 'Supplier') thanks you for your interest in this App. Protecting your privacy as a User of the Installer App (henceforth 'User' or 'Users' or 'Installer(s)') is an important concern for 'INIM'. \ Hereinafter 'INIM' informs you about the processing of personal data carried out in relation to the App. "Personal data" is information that refers to an identified or identifiable natural person. \ This Policy supplements that of the INIM CLOUD to which reference should be made for everything not mentioned in detail herein.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The Holder is "INIM Electronics S.R.L." Sole Proprietor Company with registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori n.10. Tax Code and VAT no. 01855460448. \ INIM has appointed a data protection officer (DPO) who can be contacted at the address: inim

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA

2.1 Categories of data

"INIM" processes the personal data the User provides when registering on the INIM CLOUD with an Installer User profile and the installation and use of the App. Consent to the transmission of such data is not mandatory by law, nor necessary for the purposes of entering into a contractual agreement, however, any refusal or withdrawal of consent, may compromise the proper functioning of the App or limit its use. The User can deactivate or activate data transmission at any time via their profile settings in the INIM CLOUD.

2.2 Purpose of processing data

"INIM" processes the previously described personal data in compliance with the principles of the data protection regulations currently in force. Processing is carried out for the purposes described below.

(a) Management of the services offered by the APP.

'INIM' processes personal data for the purpose of executing the request of registration of the User for the use of the App (preparation of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing of the same ceases. Any further storage or processing of data will be allowed only under the conditions referred to in point 5. Please remember that, as provided for in the INIM CLOUD, the data of Private Users with control panels connected to the Installer profile are processed by the Installer as an independent Data Holder. \ In regard to the video surveillance, it is to be noted that:

  • the relevant service is activated by the Installer in the Cloud and in the App
  • the information collected is exclusively images and short videos (saved in the Cloud with a maximum duration of 15 seconds) relating to the event that generated the alarm and the area involved which only the Installer can view if his/her supervision is active and solely to verify the correct functioning of the system. Such images and videos remain available in the App for a limited period and configured by the Main private User in the 'Cloud space and privacy' section of the INIM HOME App.

(b) Consent to the processing of personal data

Where the User has given consent to the Supplier for the processing of their personal data for further purposes (see point 4), such data processing will take place on the basis of this consent. The declarations of consent are always optional and can be revoked freely at any time also by e-mail in writing to inim\ The withdrawal of consent does not affect the legitimacy of any data processing carried out up to that moment on the basis of the consent previously issued, nor the right to further processing of the aforementioned data by virtue of another legal basis, for example for the fulfillment of legal obligations (see point d).

(c) Pursuit of legitimate interests

Where necessary, 'INIM' processes the personal data of the User to protect the legitimate interests of themselves or third parties. The maintaining of functionality and security of the 'INIM' IT systems falls within the sphere of these legitimate interests. The maintaining of functionality and security of the 'INIM' IT systems falls within the sphere of these legitimate interests. \ Generally, personal data will be deleted when further processing or storage of the same is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be allowed solely under the conditions referred to in point 5.

(d) Fulfillment of legal obligations or related to purchases made by the user

"INIM" is subject to compliance with legal obligations and provisions, such as obligations related to data retention in accordance with the regulations of the Commercial and Tax law. Therefore "INIM" processes the personal data of the User also to the extent necessary for the fulfillment of legal obligations, it being understood however that the personal data of a single User will be disclosed only in the presence of a legal obligation towards public order and judicial authorities.

3. PUSH NOTIFICATIONS

The User can consent to the receipt of push notifications on their devices, at the time of registration or subsequently, by activating the appropriate features on the control panel of the INIM CLOUD or in the App.

The push notifications the App sends to the Installer may concern:

  1. Technical information:

    • arising from events that are recorded on the control panels connected to the account (e.g. faults, anomalies);
    • relating to alarms from the control panel and, if inspection is active, from a video surveillance device (N.V.R. - network video recorder);
    • related to the management of the Cloud account of the User (e.g. out of Cloud space, expiry of services);
    • related to the more general operational management of the Cloud (e.g. the Cloud will not be operational date... hour...)
    • relating to new product features, firmware and software updates, etc.

    These notifications can be enabled by the User in their personal area of the CLOUD.

  2. Data of a commercial nature. \ These notifications make provision for the consent, given by the interested party, when registering on the CLOUD, for the receipt of such information.

Push notifications can be managed, deactivated and reactivated at any time directly via the pages of the INIM CLOUD account belonging to the User.

4. RECIPIENTS OF PERSONAL DATA

4.1 Transfer to third parties

If within the App the User takes advantage of services from service providers and other third parties, "INIM" may transfer the personal data of the User to such third parties but only to the extent necessary for the preparation and use of the App and its respective functions (see point 2.2 a), for the purpose of pursuing legitimate interests of their own or third parties (see point 2.2 c), or where the User has previously consented to such transfer (see point 2.2 b). Service providers, carefully selected by "INIM", are regularly checked by the same, in particular from the point of view of the accuracy of the processing and protection of personal data made accessible from time to time. All service providers are bound by "INIM" to the obligation of secrecy and to compliance with current laws in force.

4.2 Recipients of data in third countries

The personal data of the User will not be transmitted by the Supplier to recipients based in States outside the EU/EEA.

4.3 State institutions or authorities

The transmission of personal data to state institutions or authorities takes place only within the limits of binding laws (see point 2.2 d).

5. TERMS OF STORAGE AND CANCELLATION

"INIM" stores and processes the personal data of the User solely for the period strictly necessary for the respective purpose (see point 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms allowed for further purposes pursuant to point 2.2, such as for the fulfillment of legal obligations (e.g. retention obligations according to Tax and Commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis of the further processing.

6. SUPPLEMENTARY REGULATIONS FOR THE EUROPEAN UNION

In addition to the aforementioned regulations, in accordance with the provisions of the European Union Data Protection Regulation (GDPR) and within the limits of the respective field of application, the following provisions apply.

6.1 Legal basis

The processing of personal data described in point 2.2 is based on the legal bases listed below.

  • Data processing for the execution of the contract: art. 6 c. 1 b) GDPR
  • Data processing on the basis of the consent of the interested party: art. 6 c. 1 a) GDPR
  • Data processing for the purpose of pursuing legitimate interests: art. 6 c. 1 f) GDPR
  • Data processing for the purpose of fulfilling legal obligations: art. 6 c. 1 c) GDPR

6.2 Protection in the case of suppliers in third countries

Where, in the opinion of the European Union, an "adequate level of protection" for the processing of personal data compliant with EU standards cannot be guaranteed, as suitable guarantee pursuant to art. 46 GDPR in the event of use of service providers (see point 4), the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules or approved codes of conduct apply. An electronic copy of the relevant extracts can be provided on a specific request to be presented to the Data Protection Officer.

6.3 Rights of the interested party

As the interested party in the processing of personal data, the User has the right of access to information (art.15 GDPR), correction (art.16 GDPR) and deletion of personal data (art.17 GDPR), limitation of processing (art 18 GDPR) and data portability (art.20 GDPR).

6.4 Right to object

For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of art. 6 c. 1 e) GDPR (data processing necessary in public interest) or art. 6 c. 1 f) GDPR (data processing based on a balancing of interests). In the event of opposition by the User, the related personal data will be processed by the Supplier where it is possible to demonstrate binding and justified reasons that prevail over the interests, rights and freedoms of the User, or where processing is necessary for the purposes of the claim, the exercise or defense of legal rights.

6.5 Complaints

If the User believes that the processing of their personal data may represent a violation of the law, they have the right to lodge a complaint with a competent data protection authority (art. 77 GDPR).

7. EXERCISE OF RIGHTS

The User can exercise the rights referred to in point 6 by e-mail in writing to inim

8. UPDATING OF THIS PRIVACY POLICY RELATED TO THE PROTECTION OF PERSONAL DATA

The Supplier reserves the right to amend or simply update, in whole or in part, this privacy policy, also in consideration of changes in the laws or regulations governing the protection of personal data. Such amendments/updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published on the Website. "INIM", therefore, invites Users to access this page regularly and check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when last updated.

Last updated: January 30, 2025

"INIM ELECTRONICS S.R.L Sole Proprietor Company (henceforth also "INIM" or "Supplier") thanks you for your interest in this App. Protecting your privacy as an App User is an important concern for "INIM".

Hereinafter "INIM" informs you about the processing of personal data carried out in relation to the App. "Personal data" is information that refers to an identified or identifiable natural person.

This Privacy Policy supplements that of the INIM CLOUD to which should be referred to for everything not mentioned in detail herein.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The Holder is "INIM Electronics S.R.L." Sole Proprietor Company with registered office in Monteprandone (AP), District of Centobuchi, Via dei Lavoratori n.10. Tax Code and VAT no. 01855460448. \ INIM has appointed a data protection officer (DPO) who can be contacted at the address: inim

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR PERSONAL DATA?

2.1 Categories of data

"INIM" processes the personal data that the User provides when registering on the INIM CLOUD (either with an Installer profile or Private User profile) and when installing and using the App. Consent to the transmission of such data is not mandatory by law, nor necessary for the purposes of entering into a contractual agreement, however, any refusal or withdrawal of consent, may compromise the proper functioning of the App or limit its use. The User can deactivate or activate the transmission of personal data at any time via their INIM CLOUD profile settings.

2.2 Purpose of processing personal data

"INIM" processes the previously described data in compliance with the principles of the data protection regulations currently in force. Processing is carried out for the purposes described below.

  1. Management of the services offered by the APP \ "INIM" processes personal data for the purpose of executing the request for registration made by the User for the use of the App (preparation of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing of the same ceases. Any further storage or processing of data will be allowed only under the conditions referred to in point 5. It should be noted that, as provided for in the INIM CLOUD, the data of the fire detection control panels of Private users connected to an Installer profile, are processed by the Installer who operates as an independent data holder.
  2. Consent to the processing of personal data \ Where the User has given consent to the Supplier for the processing of their personal data for further purposes (see point 4), such data processing will take place on the basis of this consent. The declarations of consent are always optional and can be revoked freely at any time also by e-mail in writing to inim The withdrawal of consent does not affect the legitimacy of any data processing carried out up to that moment on the basis of the consent previously issued, nor the right to further processing of the aforementioned data by virtue of another legal basis, for example for the fulfillment of legal obligations (see point d).
  3. Pursuit of legitimate interests \ Where necessary, "INIM" processes the personal data of the User to protect the legitimate interests of themselves and/or third parties. The maintaining of functionality and security of the "INIM" IT systems falls within the sphere of these legitimate interests. Generally, personal data will be deleted when further processing or storage of the same is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be allowed solely under the conditions referred to in point 5.
  4. Fulfillment of legal obligations or related to purchases made by the User \ "INIM" is subject to compliance with legal obligations and provisions, such as obligations related to data retention in accordance with the regulations of the Commercial and Tax law. Therefore "INIM" processes the personal data of the User also to the extent necessary for the fulfillment of legal obligations, it being understood however that the personal data of an individual User will be disclosed only in the presence of a legal obligation towards public order and judicial authorities.

3. PUSH NOTIFICATIONS

The User can consent to the receipt of push notifications on their devices, at the time of registration or subsequently, by activating the appropriate features on the control panel of the INIM CLOUD.

The push notifications the App sends to the user may concern:

  1. Technical information arising from events:

    • recorded on "INIM" fire detection control panels connected to their account (e.g. faults, anomalies, Installations Register compiling);
    • related to the management of the Cloud account of the User (e.g. out of Cloud storage, Expiry of services);
    • related to the general operational management of the Cloud account (e.g. out of Cloud storage, Expiry of services);
    • related to the more general operational management of the Cloud (e.g. the Cloud will not be operational date ... hour ...);
    • for information purposes (e.g. new product features, firmware and software updates).

    These notifications can be enabled by the User in their personal area of the CLOUD.

  2. Data of a commercial nature. \ These notifications make provision for the consent, given by the interested party, when registering on the CLOUD, for the receipt of such information.

Push notifications can be managed, deactivated and reactivated at any time directly via the pages of the INIM CLOUD account of the User.

4. RECIPIENTS OF PERSONAL DATA

4.1 Transfer to third parties

If within the App the User takes advantage of services from service providers and other third parties, "INIM" may transfer the personal data of the User to such third parties but only to the extent necessary for the preparation and use of the App and its respective functions (see point 2.2 a), for the purpose of pursuing legitimate interests of their own and/or third parties (see point 2.2 c), or where the User has previously consented to such transfer (see point 2.2 b). Service providers, carefully selected by "INIM", are regularly checked by the same, in particular from the point of view of the accuracy of the processing and protection of personal data made accessible from time to time. All service providers are bound by "INIM" to the obligation of secrecy and to compliance with current laws in force.

4.2 Recipients of data in third countries

The personal data of the User will not be transmitted by the Supplier to recipients based in States outside the EU/EEA.

4.3 State institutions or authorities

The transmission of personal data to state institutions or authorities takes place only within the limits of the binding laws (see point 2.2 d).

5. TERMS OF STORAGE AND CANCELLATION

"INIM" stores and processes the personal data of the User solely for the period strictly necessary for the respective purpose (see point 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms allowed for further purposes pursuant to point 2.2, such as for the fulfillment of legal obligations (e.g. retention obligations according to Tax and Commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis of the further processing.

6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION

In addition to the aforementioned rules, in accordance with the provisions of the European Union Data Protection Regulation (GDPR) and within the limits of the respective field of application, the following provisions apply.

6.1 Legal basis

The processing of personal data described in point 2.2 is based on the legal bases listed below.

  • Data processing for the execution of the contract: art. 6 c. 1 b) GDPR.
  • Data processing on the basis of the consent of the interested party: art. 6 c. 1 a) GDPR.
  • Data processing for the purpose of pursuing legitimate interests: art. 6 c. 1 f) GDPR.
  • Data processing for the purpose of fulfilling legal obligations: art. 6 c. 1 c) GDPR.

6.2 Protection in the case of suppliers in third countries

Where, in the opinion of the European Union, an "adequate level of protection" for the processing of personal data compliant with EU standards is not guaranteed, as suitable guarantees pursuant to art. 46 GDPR in the case of use of service providers (see point 4), the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules or approved codes of conduct apply. An electronic copy of the relevant extracts can be provided on a specific request to be presented to the Data Protection Officer.

6.3 Rights of the interested party

As the interested party in the processing of their personal data, the User has the right of personal data access (art.15 GDPR), correction (art.16 GDPR), deletion (art.17 GDPR), limitation of processing (art 18 GDPR) and portability (art.20 GDPR).

6.4 Right to object

For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of art. 6 c. 1 e) GDPR (data processing necessary in public interest) or art. 6 c. 1 f) GDPR (data processing based on a balance of interests). In the event of opposition by the User, the relevant personal data will be processed by the Supplier where it is possible to demonstrate binding and justified reasons that prevail over the interests, rights and freedoms of the User, or where processing is necessary for the purposes of the claim, the exercise or defense of legal rights.

6.5 Complaints

If the User believes that the processing of their personal data may represent a violation of the law, the User has the right to lodge a complaint with a competent data protection authority (art. 77 GDPR).

7. EXERCISE OF RIGHTS

The User can exercise the rights referred to in point 6 via e-mail, by writing to inim

8. UPDATING OF THIS PRIVACY POLICY RELATED TO THE PROTECTION OF PERSONAL DATA

The Supplier reserves the right to amend or simply update, in whole or in part, this Privacy Policy, also in consideration of changes in the laws or regulations governing the protection of personal data. Such amendments/updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published.

"INIM", therefore, invites Users to access this page regularly in order to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when last updated.

Last updated: January 30, 2025

"INIM ELECTRONICS S.R.L Sole Proprietor Company (henceforth also "INIM" or "Supplier") thanks you for your interest in this App. Protecting your privacy as an App User is an important concern for "INIM". Hereinafter "INIM" informs you about the processing of personal data carried out in relation to the App. "Personal data" is information that refers to an identified or identifiable natural person.

This Policy supplements that of the INIM CLOUD to which reference should be made for everything not mentioned in detail herein.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The Holder is "INIM Electronics S.R.L." Sole Proprietor Company with registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori n.10. Tax Code and VAT no. 01855460448. \ INIM has appointed a data protection officer (DPO) who can be contacted at the address: inim

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?

2.1 Categories of data

"INIM" processes the personal data that the User provides when registering on the INIM CLOUD with a Private User profile and when installing and using the App. Consent to the transmission of such data is not mandatory by law, nor necessary for the purposes of entering into a contractual agreement, however, any refusal or withdrawal of consent, may compromise the proper functioning of the App or limit its use.

The User can deactivate or activate data transmission at any time through their profile settings via the options presented in the INIM HOME P2P APP and in the INIM CLOUD.

2.2 Purpose of processing data

"INIM" processes the previously described personal data in compliance with the principles of the data protection regulations currently in force. Processing is carried out for the purposes described below.

(a) Management of the services offered by the APP.

"INIM" processes personal data for the purpose of executing the request of registration of the User for the use of the App (preparation of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing of the same ceases. Any further storage or processing of data will be allowed only under the conditions referred to in point 5.

In regard to data backup management, it is to be noted that:

  • the data is backed up on the Cloud;
  • backup is activated automatically at login;
  • the user can deactivate data backup before configuring their security system;
  • the user can disable data backup after configuring their security system via the appropriate option in the APP: 'Settings' > 'Data backup on Cloud' and deselect 'Backup active';
  • once the backup is disabled, the user can decide whether or not to cancel backup via the Cloud.

(b) Consent to the processing of personal data

Where the User has given consent to the Supplier for the processing of their personal data for further purposes (see point 4), such data processing will take place on the basis of this consent. The declarations of consent are always optional and can be revoked freely at any time also by e-mail in writing to inim
The withdrawal of consent does not affect the legitimacy of any data processing carried out up to that moment on the basis of the consent previously issued, nor the right to further processing of the aforementioned data by virtue of another legal basis, for example for the fulfillment of legal obligations (see point d).

(c) Pursuit of legitimate interests

Where necessary, "INIM" processes the personal data of the User to protect the legitimate interests of themselves or third parties. The maintaining of functionality and security of the "INIM" IT systems falls within the sphere of these legitimate interests. Generally, personal data will be deleted when further processing or storage of the same is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be allowed solely under the conditions referred to in point 5.

(d) Fulfillment of legal obligations or related to purchases made by the user

"INIM" is subject to compliance with legal obligations and provisions, such as obligations related to data retention in accordance with the regulations of the Commercial and Tax law. Therefore "INIM" processes the personal data of the User also to the extent necessary for the fulfillment of legal obligations, it being understood however that the personal data of a single User will be disclosed only in the presence of a legal obligation towards public order and judicial authorities.

3. PUSH NOTIFICATIONS

The User can consent to the receipt of push notifications on their devices, at the time of registration or subsequently, by activating the appropriate features on the control panel of the INIM CLOUD.

The push notifications the App sends to the user may concern:

  1. Technical information arising from events:

    • recorded on the control panels connected to the account of the User (e.g. faults, anomalies);
    • related to the management of the Cloud account of the User (e.g. out of Cloud space, expiry of services);
    • related to the more general operational management of the Cloud (e.g. the Cloud will not be operational date ... hour ...);
    • for information purposes (e.g. new product features, firmware and software updates).

    These notifications can be enabled by the User in their personal area of the CLOUD.

  2. Data of a commercial nature \ These notifications make provision for the consent, given by the interested party, when registering on the CLOUD, for the receipt of such information.

Push notifications can be managed, deactivated and reactivated at any time directly via the pages of the INIM CLOUD account belonging to the User.

4. RECIPIENTS OF PERSONAL DATA

4.1 Transfer to third parties

If within the App the User takes advantage of services from service providers and other third parties, "INIM" may transfer the personal data of the User to such third parties but only to the extent necessary for the preparation and use of the App and its respective functions (see point 2.2 a), for the purpose of pursuing legitimate interests of their own or third parties (see point 2.2 c), or where the User has previously consented to such transfer (see point 2.2 b). Service providers, carefully selected by "INIM", are regularly checked by the same, in particular from the point of view of the accuracy of the processing and protection of personal data made accessible from time to time. All service providers are bound by "INIM" to the obligation of secrecy and to compliance with current laws in force.

4.2 Recipients of data in third countries

The personal data of the User will not be transmitted by the Supplier to recipients based in States outside the EU/EEA.

4.3 State institutions or authorities

The transmission of personal data to state institutions or authorities takes place only within the limits of binding laws (see point 2.2 d).

5. TERMS OF STORAGE AND CANCELLATION

"INIM" stores and processes the personal data of the User solely for the period strictly necessary for the respective purpose (see point 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms allowed for further purposes pursuant to point 2.2, such as for the fulfillment of legal obligations (e.g. retention obligations according to Tax and Commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis of the further processing.

6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION

In addition to the aforementioned rules, in accordance with the provisions of the European Union Data Protection Regulation (GDPR) and within the limits of the respective field of application, the following provisions apply.

6.1 Legal basis

The processing of personal data described in point 2.2 is based on the legal bases listed below.

  • Data processing for the execution of the contract: art. 6 c. 1 b) GDPR
  • Data processing on the basis of the consent of the interested party: art. 6 c. 1 a) GDPR
  • Data processing for the purpose of pursuing legitimate interests: art. 6 c. 1 f) GDPR
  • Data processing for the purpose of fulfilling legal obligations: art. 6 c. 1 c) GDPR

6.2 Protection in the case of suppliers in third countries

Where, in the opinion of the European Union, an "adequate level of protection" for the processing of personal data compliant with EU standards cannot be guaranteed, as suitable guarantee pursuant to art. 46 GDPR in the event of use of service providers (see point 4), the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules or approved codes of conduct apply. An electronic copy of the relevant extracts can be provided on a specific request to be presented to the Data Protection Officer.

6.3 Rights of the interested party

As the interested party in the processing of personal data, the User has the right of access to information (art.15 GDPR), correction (art.16 GDPR) and deletion of personal data (art.17 GDPR), limitation of processing (art 18 GDPR) and data portability (art.20 GDPR).

6.4 Right to object

For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of art. 6 c. 1 e) GDPR (data processing necessary in public interest) or art. 6 c. 1 f) GDPR (data processing based on a balancing of interests). In the event of opposition by the User, the related personal data will be processed by the Supplier where it is possible to demonstrate binding and justified reasons that prevail over the interests, rights and freedoms of the user, or where processing is necessary for the purposes of the claim, the exercise or defense of legal rights.

6.5 Complaints

If the User believes that the processing of their personal data may represent a violation of the law, they have the right to lodge a complaint with a competent data protection authority (art. 77 GDPR).

7. EXERCISE OF RIGHTS

The User can exercise the rights referred to in point 6 by e-mail in writing to inim

8. UPDATING OF THIS PRIVACY POLICY RELATED TO THE PROTECTION OF PERSONAL DATA

The Supplier reserves the right to amend or simply update, in whole or in part, this privacy policy, also in consideration of changes in the laws or regulations governing the protection of personal data. Such amendments/updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published on the Website.

"INIM", therefore, invites Users to access this page regularly and check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when last updated.

Last updated: January 30, 2025

Privacy - P.D.A.

1. PREMISE

1.1 This DPA (Data Processing Agreement) regulates the processing of Personal Data carried out by 'INIM ELECTRONICS S.R.L.' Sole Proprietor Company (hereinafter also: the 'Privacy Manager' or 'Manager' or 'Supplier' or 'INIM'), necessary to be able to provide the 'INIM DRIVE' service (the 'Service') to the Installer User (hereinafter the 'User'). \ The User is the Data Controller (hereinafter also the 'Owner').

1.2 If the User must carry out processing operations on behalf of another Data Controller, he/she may act as Privacy Manager. In this case, the User guarantees that the instructions given and the activities undertaken in relation to the processing of Personal Data, including the appointment, on his/her part, of the Supplier as further Privacy Manager resulting from the stipulation of this DPA, have been authorized by the relevant Data Controller and undertakes to show the Supplier, upon simple written request, the documentation certifying the above.

2. NORMATIVE REFERENCES

2.1 This DPA guarantees that the processing of Data carried out by the Supplier complies with EU Regulation 679/2016 ('GDPR') and more generally with Italian and European legislation on Privacy and Protection of personal data (the 'Applicable Law').

3. PROCESSING OF PERSONAL DATA

3.1 Purpose of Data Processing: is the provision of the Services by INIM, as specified in the 'General Conditions of Navigation of the Website and Use of the Cloud'.

3.2 To provide the Services to the User, the Privacy Manager processes, on behalf of the Data Controller, certain categories of Personal Data collected by the Data Controller and entered by the latter into the IT structures responsible for managing the Services.

3.3 'Personal data' means any information relating to an identified or identifiable natural person ('interested party') as defined by the art. 4 of the GDPR. \ The Privacy Manager processes the following types of Personal Data necessary to provide the 'Service': files uploaded by authorized users in the general Drive environment, which can be shared with users in their organization, or files uploaded in the checklist and Storage areas relating to individual systems, which can be shared with users in their organization or with users enrolled on the specific system. \ The Privacy Manager carries out exclusively the processing activities necessary and relevant to ensure the execution of the Services to the Data Controller.

3.4 The Privacy Manager adopts a register of processing activities in accordance with the art. 30, par. 2 of the GDPR.

4. INSTRUCTIONS

4.1 The Privacy Manager may process Personal Data only in accordance with instructions from the Data Controller (the 'Instructions'), unless Applicable Law provides otherwise. With this DPA, the Data Controller provides instruction that the Privacy Manager may process the Personal Data only for the purpose of providing the Services. Subject to the terms of this DPA and with the mutual agreement of the parties, the Data Controller may provide the Manager with further written instructions consistent with the terms of this Agreement.

4.2 The Data Controller guarantees to process the Personal Data in compliance with current legislation on Privacy and Protection of personal data. The instructions provided by the Data Controller must comply with Applicable Law. The Data Controller is solely responsible for the accuracy, quality and limitation of storage of the Personal Data collected and processed. The Data Controller must also ensure that the Data is collected and processed in a lawful, correct and transparent manner. 4.3 The Privacy Manager shall inform the Data Controller if he/she believes that the Instructions violate Applicable Law and does not execute such Instructions until they are recognized as legitimate.

5. OBLIGATIONS OF THE PRIVACY MANAGER

5.1 Confidentiality

5.1.1 The Privacy Manager shall treat all Personal Data as strictly confidential information. Personal Data cannot be copied, transferred or processed in conflict with the Instructions, unless authorized following further agreements with the Data Controller. \ 5.1.2 The subjects authorized for processing by the Manager are also obliged to maintain confidentiality and must have signed a specific nomination authorizing them to process the Data in a manner compliant with the Applicable Law and the provisions contained in this DPA. \ 5.1.3 Personal Data shall be processed only by the personnel necessary to provide the Services. \ 5.1.4. The Privacy Manager shall also ensure that the authorized parties, who carry out processing operations on Personal Data, process only the categories of Personal Data provided for by this DPA and in accordance with the Instructions.

5.2 Security

5.2.1 The Privacy Manager must implement the appropriate technical and organizational measures as established in this DPA and pursuant to Article 32 of the GDPR. The Privacy Manager may update or modify the security measures from time to time provided that such updates and modifications do not lead to a worsening of the overall security levels. The security measures are available and consultable upon request.

5.3 Data protection impact assessments and prior consultation

5.3.1 If the assistance of the Privacy Manager is necessary and relevant, the Manager may assist the Data Controller in preparing the data protection impact assessments in accordance with art. 35 of the GDPR, together with any prior consultation pursuant to art. 36 of the GDPR. \ Any personalized assistance requests may be subject to the payment of a fee by the User. It is understood that it is the exclusive responsibility and burden of the User, as Data Controller, to proceed with the impact assessment based on the characteristics of the processing of Personal Data carried out by the same in the context of the Services.

5.4 Rights of interested parties

5.4.1 If the Data Controller receives a request from an interested party (data subject) to exercise their rights under the Applicable Law and the correct and legitimate response to such request requires the assistance of the Privacy Manager, the Manager will undertake to assist the Data Controller by providing him/her, within a reasonable time, with the necessary information and documentation requested by the same. The Privacy Manager will undertake to assist the Data Controller in managing such requests in accordance with Applicable Law. \ 5.4.2 If the Privacy Manager receives a request from an interested party (data subject) to exercise his or her rights under Applicable Law and such request is connected to Personal Data collected by the Data Controller, the Privacy Manager must immediately forward the request to the Data Controller and refrain from responding directly to the interested party.

5.5 Violation of Personal data

5.5.1 In the event of a breach of Personal Data ('Data Breach') which may result in the destruction, loss, alteration, disclosure or unauthorized or accidental access to Personal Data processed on behalf of the Data Controller, the Manager must notify the Data Controller within forty-eight (48) hours from the moment the Data Breach is detected by the Manager. \ 5.5.2 The Privacy Manager must make every reasonable effort to identify the cause of such a breach and take such measures as deemed necessary to determine the cause and to prevent such breach from recurring.

5.6 Compliance documentation and audit rights

5.6.1 Upon request of the Data Controller, the Privacy Manager must make available to the Data Controller all relevant information necessary to demonstrate compliance with this DPA. \ 5.6.2 The Manager recognizes the right of the Data Controller, in the manner and within the limits indicated below, to carry out audits to verify the compliance of the Manager with the obligations set out in this DPA and the legislation. The Data Controller may make use of their own specialized personnel or external auditors for these activities, provided that these subjects are previously bound by suitable confidentiality agreements. \ In the case of a request for audit activities, the User must first send a written request to the Manager, via e-mail. Following the request for an audit or inspection, the Manager and the User shall agree, before starting the activities, the details of such checks (start date and duration), the types of checks and the object of the checks, the confidentiality constraints to which the User and those who carry out the checks must be subjected and the costs that the Privacy Manager may charge for such checks and which will be determined in relation to the extension and duration of the verification activities. \ 5.6.3 The Manager may object in writing to the appointment by the Data Controller of any external auditors who are, at the sole discretion of the Manager, not adequately qualified or independent, are competitors of the Manager or who are obviously inadequate. In such circumstances, the Owner is required to appoint other auditors or conduct the audits himself/herself. \ 5.6.4 The Manager undertakes to respond to requests for additional documentation or audit planning forwarded by the Owner within thirty (30) days from the date of receipt of the request.

5.7 Transfer of Data

5.7.1 Under normal circumstances, the Privacy Manager does not transfer the Data to countries not belonging to the European Economic Area (EEA). Where the transfer outside the European Economic Area (EEA) is necessary to carry out certain types of processing (for example: backup, hosting, etc.), the Data will be transferred only to Sub-Privacy Managers who have adopted the appropriate guarantees provided in articles 44-50 of the GDPR (by way of example: Adequacy decisions of the European Commission, Standard Contractual Clauses, or similar).

6. GENERAL AUTHORIZATION FOR THE APPOINTMENT OF SUB-PRIVACY MANAGERS (SUB-DATA PROCESSORS)

6.1 The Privacy Manager is granted the general authorization to appoint third parties ('Sub-Privacy Managers') for the processing of Personal Data without the need for further written and specific authorizations from the Data Controller. \ The User expressly agrees that some Personal Data processing operations are entrusted by the Supplier to other companies of the INIM group and/or to third parties possibly identified in the DPA. \ 6.1.1. The User also agrees to the entrusting of Personal Data Processing operations to additional third parties in accordance with the methods set out in the following article 6.1.3. \ 6.1.2. It is understood that the signing of the Standard Contractual Clauses (provided for in point 5.7.1 in the event of transfer of Personal Data abroad), by the User with an Additional Privacy Manager, must be understood as consent to the assignment to the third party of the processing operations. \ 6.1.3. In cases where the Supplier has to resort to Additional Privacy Managers for the execution of specific Personal Data processing activities, the Supplier: \ 6.1.3.1. undertakes to make use of Additional Privacy Managers who guarantee adequate technical and organizational measures and ensure that access to Personal Data, and the related processing, will be carried out exclusively within the limits of what is necessary for the provision of the requested services. \ 6.1.3.2. At least 15 (fifteen) days before the start date of the Personal Data processing operations by the Additional Privacy Manager, INIM shall inform the User of the assignment to the third party (as well as the identification data of the third party, its location - and possibly, the location of the servers on which the data will be stored, if applicable - and the activities entrusted) by sending a notification e-mail or other means deemed suitable by the same. \ 6.1.4. Any additional information on the list of Additional Privacy Managers (Sub-Data Processors), the processing entrusted to them and their location, is available upon request from the Data Controller. \ 6.1.5. The absence of any objections on the part of the Data Controller is to be understood as consent for the appointment of a new Sub-Privacy Manager.

6.2 The Privacy Manager must sign a specific DPA with each new Sub-Privacy Manager. Such agreement must provide at least the same data protection obligations applicable to the Privacy Manager, including the obligations set out in this DPA. The Privacy Manager Data undertakes to monitor and periodically verify the compliance of its Sub-Privacy Managers (Sub-Data Processors) with the Applicable Law. Documentation of such monitoring must be provided to the Data Controller if requested in writing.

6.3 The Privacy Manager, at the time of the introduction of this DPA, employs Sub-Privacy Managers (Sub-Data Processors). If the Privacy Manager signs a contract with a new Sub-Privacy Manager, this new Sub-Privacy Manager must be added to the appropriate list, with the list available, upon request, at the head office.

7. LIMITED WARRANTY

7.1 The responsibility towards the User, on the part of the Privacy Manager, for any losses caused by or in any way connected to the provisions contained in this DPA, is subject to the clauses established in the 'General Conditions of Navigation of the Website and Use of the Cloud.'

8. DURATION

8.1 This DPA shall remain in force until the contract for the provision of the specific service is terminated.

9. DATA PROTECTION OFFICER (DPO)

9.1 The Privacy Manager shall appoint a Data Protection Officer (DPO) where such appointment is required by the GDPR.

10. DELETION OF DATA

10.1 After the expiration or termination of the service supply contract, the Privacy Manager will delete or return to the Owner all Personal Data in their possession within the terms set out in the supply contract itself, except in the case where it is required by the Law Applicable to the Privacy Manager to retain some or all of the Personal Data (in which case the Manager will store the data and implement reasonable measures to prevent the Personal Data from being further processed). The terms of this DPA will continue to apply to such Personal Data. \ 10.1.1. The Manager shall keep the Personal Data available to the User for the extraction request for the period envisaged in the Service Supply Contract. Where this Contract does not provide for a specific term, the Supplier shall keep the Personal Data available to the User for this purpose for the period of 30 (thirty) days following the termination of the Contract or subscription to the Service. \ 10.1.2. The User acknowledges that he/she can extract Personal Data, upon termination of the Service, in the ways agreed in the Contract and agrees that it is his/her responsibility to provide for the total or partial request of only the Personal Data that he/she deems useful to keep and that such extraction must be carried out before the expiry of the deadline referred to in point 10.1.

11. CONTACT DATA.

11.1 The contact details of the Data Privacy Manager are as follows: 'INIM ELECTRONICS S.R.L.' Sole Proprietor Company with registered office in Monteprandone (AP), District of Centobuchi, Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448. \ E-mail: inim

Last updated: 30th July 2025