- This section contains information regarding how Mat is operating with reference to the processing of Mat users’ data.
- This policy also applies to the purposes of Article 13 of Regulation (EU) No 2016/679, relating to the protection of individuals with regard to the processing of personal data as well as the free movement of such data, for subjects interacting with Mat and can be reached from the instructions page within Mat’s app.
- The information is made only for Mat and not also for other websites consulted by the user through links that may be contained in it.
- The purpose of this document is to provide information about the methods, timing and nature of the information that data controllers must provide to users at the time of use of Mat, regardless of the purposes of the use itself, according to Italian and European legislation.
- The information may be subject to change due to the introduction of new rules in this regard, therefore the user is invited to periodically check this page.
- If the user is under 14 years of age, pursuant to art.8, c.1 Regulation (EU) 2016/679, and Art. 2 – Quinquies of D.Lgs 196/2003, as amended by Legislative Decree 181/18, must legitimize its consent through the authorization of parents or those who take its place.
II – DATA PROCESSING
1 – Data Controller
- The data controller shall be the natural or legal person, public authority, service, or other body which, individually or together with others, determines the purposes and means of processing personal data. It also deals with security profiles.
- With regard to this product, the data controller (owner) is: Elisium s.r.l., and for any clarification or exercise of the user’s rights can be contacted at the following email address: firstname.lastname@example.org.
2 – Data processing location
- The data processing generated by the use of Mat takes place on the user’s device and at the servers of Elisium s.r.l.
III – DATA PROCESSED
1 – Data processing mode
- Like all apps, this app also makes use of log files in which information collected in an automated manner during use by users is stored anonymously. The information collected can be as follows:
– used device (make and model);
– parameters of the device used;
– Android or iOS version used;
– date and time of use;
– used in-app services (e.g., Italian LTZ).
- The aforementioned information shall be processed in an automated form and collected in an exclusively aggregated form in order to verify the proper functioning of the app, and for security reasons. This information will be processed according to the legitimate interests of the owner.
- For security purposes (spam filters, firewalls, virus detection), the automatically recorded data may also include personal data such as the Ip address, which could be used, in accordance with the relevant laws, in order to block attempts to damage the owner or to harm other users, or in any case harmful activities or constituting a crime. Such data is never used for the identification or profiling of the user, but only for the purpose of protecting Mat and its users, such information will be processed according to the legitimate interests of the owner.
- The information that Mat users will consider making public through the services and tools made available to them, is provided by the user knowingly and voluntarily, exempting this product from any responsibility for any violations of the laws. It is up to the user to verify that he has permission to enter personal data of third parties or content protected by national and international rules.
2 – Purpose of data processing
- The data collected by Mat during its operation are used for the purposes indicated above and for the following purposes:
- Location, to provide the user with Italian LTZ, vehicle location and real-time location services even if the app is in the background (i.e., not visible on the phone display)
1. Audio Recording, to allow the user to use voice assistant
2. Call management, so you can make calls on user’s command
3. Access to call logs, to inform the user about who is calling him without the need to watch phone’s display
4. Access to contacts, to make calls on the user’s command to contacts in address book
5. Access to notifications, so you can read them for the user
- Data retention will be carried out for the period strictly necessary to achieve the above purpose and in any case not exceeding 5 years from the moment the user finish using the device if present, removing it from the car, and the application, removing it from all smartphones/tablets in use to the user.
- Data in aggregate form, i.e., completely anonymous, may be processed and shared with third-party companies based on the legitimate interests of the owner.
- The data collected directly by Mat may be used by the owner for marketing purposes aimed at improving the services offered (e.g., predictive navigation) and processed according to the legitimate interests of the owner.
- In any case, the data collected directly by Mat will never be provided to third parties, for any reason, unless it is a legitimate request by the judicial authority and in the cases provided for only by law.
- The data used for security purposes (blocking attempts of damage) shall be kept for as long as is strictly necessary to achieve the previously indicated end.
3 – User-provided data
- As indicated above, the optional, explicit, and voluntary sending of e-mail to the addresses indicated on this app involves the subsequent acquisition of the sender’s address, necessary to respond to requests, as well as any other personal data entered in the letter.
- 2. For all other data the sending is always explicit and voluntary but mandatory for the correct provision of the requested services. The user who wishes to withdraw his consent can do so at any time simply by removing the Mat device from the car, if present, the Mat app from all phone/tablet(s) and informing the data controller as per Chapter II of this policy.
- Summary information specifications will be progressively reported or displayed on the app pages prepared for services on request.
IV – USER RIGHTS
- Art. 13, c. 2 of Regulation (EU) 2016/679 lists your rights.
- The Mat app therefore intends to inform you about the existence of your rights, based on the following articles of Regulation (EU) 2016/679:
(a) According to Art. 15, of the right of the data subject to ask the data controller for access to personal data, according to art. 16 the possibility of rectifying the data provided, based on Article 18, the possibility of supplementing or limiting the processing concerning him, or of opposing, for legitimate reasons, their processing based on art. 21, in addition to the right to data portability under art. 20 Regulation (EU).
- b) the right to request deletion based on Art.17, the transformation into anonymous form or the blocking of data processed in violation of the law, including those whose storage is not necessary in relation to the purposes for which the data was collected or subsequently processed.
- c) the right to obtain proof that the operations of updating, rectifying, integrating data, erasing, blocking data, processing have been brought to the attention, including with regard to their content, of those to whom the data have been communicated or disseminated, except where such fulfillment proves impossible or involves the use of means manifestly disproportionate to the protected right.
- Requests may be addressed to the data controller, without formalities or, alternatively, using the model provided by the Guarantor for the Protection of Personal Data, or by sending an email to: email@example.com
- If the processing is based on art. 6(1)(a) – consent expressed to use – or art. 9(2)(a) – express consent to the use of genetic, biometric, health-related data that reveals religious, philosophical or trade union beliefs, which reveal racial or ethnic origin, political opinions – you have the right to withdraw your consent at any time without prejudice to the lawfulness of the consent-based processing provided prior to revocation.
- Similarly, in case of violation of the legislation, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for the control of processing in the Italian State.
- For a more in-depth examination of your rights, see Articles 15-22 of Regulation (EU) 2016/679.
V – DATA TRANSFER TO NON-EU COUNTRIES
- This product may share some of the data collected with services located outside the European Union area. With Google, Facebook and Microsoft (LinkedIn) through social plugins and the Google Analytics service. The transfer is authorized and strictly regulated by Article 45, paragraph 1 of Regulation (EU) 2016/679, so no further consent is required. The companies mentioned above guarantee their adherence to the Privacy Shield.
- Data will never be transferred to third countries that do not comply with the conditions laid down in Article 45 and ss, of the Regulation (EU).
VI – SECURITY OF DATA PROVIDED
- This product treats user data in a lawful and correct manner, taking appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of data. The processing is carried out through IT and /or telematic tools, with organizational methods and with logics closely related to the indicated purposes.
- In addition to the owner, in some cases, categories of persons involved in the organization of the product (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have temporary and limited access to the data.
VII – AMENDMENTS TO THIS DOCUMENT
of Mat’s app.
- It may be subject to changes or updates. In the case of relevant changes and updates, these will be reported with specific notifications to users.
- The document was updated on 31/10/2018 to comply with the relevant regulatory provisions, and in particular in accordance with Regulation (EU) 2016/679.