NOTICE FOR VISITORS TO THE WEBSITES www.inim.biz, www.inimdns.biz and www.inimcloud.com

This Privacy Notice is for Visitors and Users of Websites www.inim.biz, www.inimdns.biz and www.inimcloud.com, property of INIM ELECTRONICS S.R.L. Sole Proprietor Company (henceforth “INIM”) and not for other websites consulted by the user through internal links. Pursuant to Articles 13 and 14 of EU Regulation 2016/679 ("General Data Protection Regulation" or "GDPR"), we wish to inform you that, by using the aforementioned websites, INIM, as Data Holder (henceforth "Holder") is necessarily aware of personal data relating to you. For this reason, it is necessary for us to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

1. WHO IS THE HOLDER OF YOUR PERSONAL DATA?

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.

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

Whenever INIM acquires and processes your personal data, it does so solely in compliance with the principles of lawfulness provided for by law and for the purposes illustrated below.

2.1. Purpose of processing data

The data will be processed for the purposes indicated below:

1. purposes related to the obligations established by laws and regulations (including accounting and tax purposes), as well as purposes related to instructions issued by the competent authorities/supervisory and control bodies;
2. purposes strictly connected to and/or necessary for the execution of the services requested by the User;
3. operational purposes and/or purposes complementary to the activity carried out by INIM which, by way of example but not limited to, and only after obtaining consent, the sending to the User, via e-mail, of newsletters and promotional material or, more in general, CD activity so-called "direct marketing" relating to the products and/or services provided by INIM itself, having, however, a nature similar to the subject of previous sales or supplies;
4. User profiling, after obtaining consent, in order to allow INIM to process the consumer choices, habits and propensities of the User and, consequently, to send to the User specific offers related to INIM products and services.

2.2. Categories of subjects to whom the data can be communicated To achieve the purposes described in paragraph 2.1 above, INIM may need to communicate the data provided by the User 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 companies, subsidiaries or associates; entities that perform acquisition services; subjects who perform data acquisition, processing and services necessary for the execution of the orders received from customers; subjects who provide services for the management of INIMìs 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 paragraph 2.1.

3. 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.

4. 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.

5. 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 paragraph 2.1 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 data acquired for the purposes of registration to the INIM CLOUD SERVICES portal is regulated by a specific detailed Notice on the registration form. The data will be 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 obligations required by law or regulations. As part of these purposes, data processing also relates to data regarding subscriptions/registrations to the portal required for the management of business relations with INIM, as well as to enable effective institutional communication and to comply with any legal, regulatory or contractual obligations. The data will be stored according to the conditions of the service offered or alternatively until the possible revocation of your consent. 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 emails 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 anonymised 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. Specific security measures will be observed at all times to prevent data loss, illicit or incorrect use and unauthorized access.

6. WHAT ARE YOUR RIGHTS?

In your capacity as the interested party, you can exercise, using the methods indicated in paragraph “11 EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY”, the rights referred to in article 15 to 22 of the Regulation and in particular:

1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered and communication of the same in an intelligible form;
2. obtain the indication: a) of the origin of personal data; b) of the purposes and methods of processing; c) of the logic applied in the event of processing carried out with the aid of electronic tools; d) of the identification details of the Holder, managers and the designated representative pursuant to art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who may become aware of such in their capacity as designated representative in the territory of the State, persons in charge or responsible;
3. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which it was collected or subsequently processed; c) the attestation that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data may have been communicated or disseminated, except in the case where such fulfillment reveals itself to be impossible or involves a use of means manifestly disproportionate to the protected right;
4. objecting, in whole or in part: a) for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without the intervention of an operator by e-mail and/or through traditional marketing methods (telephone and/or paper mail). It should be noted that the right of opposition of the interested party, for the purposes of direct marketing through automated methods extends also to traditional methods and that, however, the possibility remains for the interested party to exercise the right to object even if only partially. The interested party, however, can choose to receive only communications, that is, solely via traditional methods or automated communications or neither of the two types of communication.

Where applicable, it is also possible to exercise the rights referred to in Articles 15 to 22 of the GDPR (Right of rectification, right to be forgotten, right of limitation of treatment, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.

7. WHAT DATA DO WE PROCESS?

7.1. Navigation data The computer systems and software procedures used to operate the 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 IP addresses or domain names of the computers utilized by Users connecting to the Website, the addresses in URI (Uniform Resource Identifier) notation of the requested resources, the time of the request, the method used to submit 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 operating system and the computer environment of the User. This data will be used for the sole purpose of obtaining anonymous statistical information regarding the use of the Website and to check its correct functioning and will be deleted immediately after processing. Such data may be used to ascertain responsibility in the event of hypothetical computer crimes against the Website. 7.2. Data provided voluntarily by the User Following the optional, explicit and voluntary consent expressed in advance by the interested party by means of the forms present on the Website or by using the addresses indicated therein, INIM collects and stores 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 Website prepared for specific services on request or for specific categories of data. 7.3. Cookies For information regarding the Cookies Policy, please refer to the Cookie Policy in the dedicated section of the Website.

8. DOES INIM PROCESS DATA RELATING TO MINORS?

As a general rule, we do not intentionally collect personal data regarding minors. If we discover that we have inadvertently collected personal data from such individuals, INIM acts to eliminate such data as soon as possible, except where the applicable law requires us to conserve it.

9. OPTIONALITY OF DATA SUPPLY

Besides that specified for navigation, the User is free to provide the personal data contained in the request forms or indicated in contacts to request, for example, the sending of informative material 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. 9.1. Provision of Data and consent Without prejudice to the personal autonomy of the User, the provision of data for the purposes referred to in paragraph 2.1 is optional. However, it should be noted that:

• the eventual refusal of the User to provide data for the purposes referred to in paragraph 2.1, points (a) and (b) or the cancellation thereof, as a result of a request by the User will make it impossible for INIM to guarantee access to the reserved area of the Website and, consequently, for the User to benefit from the services requested;
• the eventual refusal by the User to provide data for the purposes referred to in paragraph 2.1, point (c) [or cancellation of the same, as a result of  request by the User will make it impossible for INIM to offer other functional/complementary promotional and advertising activities that benefit the User, without prejudice to the possibility for the User to access the reserved area of the Website and benefit from the services requested;
• the eventual refusal of the User to provide data for the purposes referred to in paragraph 2.1, point (d) or the cancellation of the same will make it impossible for INIM to profile the User in accordance with their consumer choices, habits and propensities indicated, thus preventing INIM from providing the User with information and communications structured on the basis of preferences shown. Refusal to provide the Data referred to in paragraph 2, point (d) does not, however, prejudice the possibility for the User to access the reserved area of the Website and benefit from the services requested.

Concerning the purposes in sub-paragraph 2.1, points (a) and (b), we inform the User that the processing of data by INIM, including the communication of the same to the parties referred to in paragraph 2.2, does not require the consent of the User as processing is required in order to provide the services requested by the User and to comply with legal obligations. For that which concerns the purpose indicated in paragraph 2, point (c), we specify that the consent given for the sending of commercial and promotional communications pursuant to art. 130, paragraphs 1 and 2, of the Data Protection Act (so-called “Direct Marketing”) implies the consent to receive the aforementioned communications not only through automated methods (e-mails), but also through traditional methods (paper mail and telephone calls via operator). However, the User has the right to express consent to the receipt of the aforementioned communications exclusively through the traditional methods of contact. Although, without prejudice to the provisions of art. 130, paragraph 4, of the Data protection Act, which authorizes INIM to use the electronic mail coordinates provided by the User for the direct sale of its products or services, without the prior consent of the User, provided that these are similar services to those subject of the sale and that the User, adequately informed, does not refuse such use initially or during subsequent communications. The User has the right to object to this at any time.

10. PURPOSES AND METHODS OF PROCESSING

10.1. Data collected from the Internet Following consultation of this Website, data relating to identified or identifiable persons may be processed. The conferment of data is optional, however, the same could in some cases be indispensable for the performance of specific activities and therefore, failure to provide it would create an impediment for INIM regarding the provision of services and information. Failure to provide all data except that which is not attributable to legal, tax and contractual obligations will be assessed by INIM from time to time and will determine the consequent decisions, related to the importance for INIM of the data requested and not conferred. In particular, for the purposes defined in point “10.2. Data provided voluntarily by the User and collected for the execution of services”, the User will be asked to express their free and informed consent to the processing of their data by signing appropriate documentation prepared, where necessary, for such processing. No data will be communicated or disseminated unless expressly specified in the informative notes drawn up for the specific processing for which the User will be requested to express explicit and separate consent to the interested party. Likewise, if the acquisition of sensitive data is necessary, the User will be requested to provide explicit and separate consent to the interested party. The technical data related to User access to the Website, as well as data collected from any e-mails sent by the User, will not, in any case, be communicated to third parties, or disseminated. 10.2. Data provided voluntarily by the User and collected for the execution of the services The collection and processing of the personal data of the User is in compliance with the general principles of necessity, correctness, relevance and non-excess and in particular the processing of data will be used for:

1. registration to the personal area or adhesion to the services offered by INIM through the Websites;
2. response to questions and provision of information requested by the User;
3. management of User requests, of a technical and commercial nature, relating to the progress of orders and also of a general nature;
4. execution of activities, related to or necessary for the supply of services provided by INIM, including the communication of data to third-party companies which, by way of example, carry out activities related to or necessary for the supply of INIM services or the management of payments on the Website;
5. registrations and communications required by law;
6. detection of the degree of satisfaction and preferences of the User;
7. consent for User access, following the registration and creation of the User profile on the INIM CLOUD SERVICES portal, to the reserved area for the provision of services, products and any other kind of request and the subsequent and autonomous management of the User’s own profile via the control panel;
8. management of payments, including anti-fraud control in the case of payment by credit card;
9. sending, after obtaining consent, of advertising material, information and commercial information, as well as the transfer to third parties of the data processed for commercial purposes also for sale or possible sale purposes, or for all commercial and/or statistical purposes lawful according to current legislation. The consent given for sending commercial and promotional communications pursuant to art. 130, paragraphs 1 and 2, of the Code (so-called “Direct Marketing”) implies consent to the receipt of communications not only via automated methods, but also through traditional methods (paper mail and telephone calls via operator). In these circumstances, the User is also given the right to express consent to the receipt of the aforementioned communications exclusively through traditional methods of contact;
10. the profiling of the User, after obtaining consent, in order to allow INIM to process their consumer choices, habits and propensities and, consequently, to send to the User specific offers related to INIM products and services;
11. subscription to the “NEWSLETTER”. The User can register when registering in the reserved area. Such data will not be disclosed to third parties. For further details, it is possible to consult the specific information notice.

11. 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 S.R.L. Sole Proprietor Company ) at their registered office in Monteprandone (AP), Locality Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, e-mail: privacy@inim.biz

12. UPDATING OF THIS POLICY

This Privacy Policy regulates the processing of personal data released by the User when browsing INIM Websites and may be amended by INIM 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 1st June 2020

NOTICE FOR USERS REGISTERED IN THE RESERVED AREA OF THE “INIM CLOUD” SERVICE PORTAL

This Privacy Policy regards Users who register on the INIM CLOUD SERVICES portal accessible from the Websites www.inim.biz, 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. WHO IS THE DATA HOLDER?

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.

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:

a) 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;

b) 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);

c) 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;

d) pursuant to art. 6.1 (c) of the Regulation, to fulfill legal obligations to which INIM is subject;

e) 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 relating 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.

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-skill;
• data obtained from the User, 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 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.

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 PERSONAL 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 PERSONAL 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 anonymised 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 anonymised 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 eliminate 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: privacy@inim.it

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: 13th June 2024

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 safe guarding;
2. takes place using manual, computerized and telematic tools with logic strictly related to the purposes referred to previously in paragraph 2.1 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 anonymised 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 MORE voice assistant 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, you 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 allows 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 anonymised and INIM may ask you 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 to access, at any time, your Personal Data, as well correct and/or integrate the same if inaccurate or incomplete, cancel or limit 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, INIM does 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 eliminate the said data as soon as possible, except where the applicable law requires us to conserve it.

9. OPTIONALITY OF DATA SUPPLY

Besides the Personal Data required for registration and for the creation of your account, you are free to provide the Personal Data in the request forms or indicated in contacts to request, for example, the sending of informative material or other communications. Failure to provide such data may make it impossible to obtain the requested service. 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.

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 S.R.L. Sole Proprietor Company) at their registered office in Monteprandone (AP), Locality Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, e-mail: privacy@inim.biz

11. UPDATING OF THIS PRIVACY 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 17th March 2022

NOTICE FOR USERS WHO REQUEST INFORMATION USING THE FORM PRESENT ON THE INIM WEBSITE

“INIM ELECTRONICS S.R.L.” Sole Proprietor Company (henceforth “INIM” or “Holder”) wishes to inform you that your personal data will be processed in compliance with the provisions of EU Regulation 679/2016 (“GENERAL DATA PROTECTION REGULATION” OR “GDPR”) and any specific local regulations applicable to the protection of personal data. Below you will find all the necessary information relating to the data processing that “INIM” will carry out on the personal data you communicate to us by filling in the Contact form. This Privacy Policy supplements the general Privacy Policy of the Website, to which reference is made for everything not detailed herein

1. WHO IS THE HOLDER OF YOUR PERSONAL DATA?

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.

2. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

Your personal data will be processed in order to follow up your contact request, due to the necessary nature of data processing. Such data can also be processed to fulfill any legal obligations or in the pursuit of a legitimate interest of INIM or third parties, in compliance with the conditions and constraints envisaged by current legislation.

3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSE?

3.1. Data provided directly by the User This is personal data (for example, name, surname, address, landline and mobile telephone numbers and e-mail address), necessary to respond to the information requested. The communicated personal data may be used, after your expressed consent, to provide via electronic means (e-mail, sms, mms) and/or paper mail or by direct contact with an INIM operator, sector information and commercial offers related to products and services dispensed by the Holder. 3.2. Cookies For information on the adopted Cookie Policy, you should consult the Cookie Policy in the dedicated section of the Website.

4. TO WHOM WILL YOUR DATA BE COMMUNICATED?

In order to follow up on your requests, your personal data will be processed by INIM, availing itself of persons in charge and responsible in the context of their respective duties and in accordance with the instructions received, using appropriate methods and procedures, including IT tools.

5. WILL YOUR DATA BE TRANSFERRED ABROAD?

INIM currently processes your 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 to 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 those countries/territories.

6. HOW DO WE PROCESS AND STORE YOUR DATA?

Your personal data will be processed by means of appropriate methods and procedures, including IT and telematic methods, and stored using adequate organizational, technical and security measures. The processing of your personal data will be strictly limited to the time necessary to follow up on your contact request and for the execution of any activity or operations deriving from the subject of your request. If data processing is carried out on the basis of legal provisions or in the face of a legitimate interest of INIM or of third parties, the processing of your personal data will be strictly limited to the time necessary to achieve the purposes for which the data is processed. The data processed for marketing purposes (if your express consent has been acquired), will be stored according to the provisions of current legislation and in any case until your consent for the processing of personal data is revoked

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 the 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. 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 with registered office in Monteprandone (AP), locality Centobuchi, Via dei Lavoratori, n. 10. Tax Code and VAT no. 01855460448 or by e-mail: privacy@inim.biz.

9. UPDATING OF THIS POLICY

This Privacy Policy regulates the processing of personal data issued by the User for the service requested and can be modified or simply updated, in whole or in part, also in consideration of any changes in the laws or regulations governing the protection of personal data. Any changes to and updates of this Privacy Policy will be made known to Users as soon as they are adopted and will become binding as soon as they are published on the Website. Therefore, INIM 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 1st June 2020

NOTICE FOR SENDING APPLICATIONS THROUGH THE WEBSITE www.inim.biz

“INIM ELECTRONICS S.R.L.” Sole Proprietor Company (henceforth “INIM” or “Holder”) wishes to inform you that your personal data will be processed in compliance with the provisions of  EU Regulation 679/2016 (“GENERAL DATA PROTECTION  REGULATION” OR “GDPR”) and any specific local regulations applicable to the protection of personal data. Below you will find all the necessary information relating to the data processing that “INIM” will carry out on the personal data you communicate to us by filling in and sending your application form for any job vacancy present in the dedicated pages of the Contacts section of the Website www. inim.biz. This Privacy Policy sup​plements the general Privacy Policy of the Website, to which reference is made for everything not detailed herein.

1. WHO IS THE HOLDER OF YOUR PERSONAL DATA?

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.

2. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?

The legal basis of the processing is the legitimate interest of INIM in the selection of personnel in accordance with needs. The consent of the interested party is in any case expressed once the form has been completed and sent. Such data may also be processed to fulfill any regulatory and/or legal obligations, for example in the case you wish to establish employment and/or a relationship of business collaboration with the interested party, or for the pursuit of a legitimate interest of INIM, in compliance with the conditions and constraints envisaged by current legislation.

3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSE?

3.1. Data provided directly by the User Your personal data will be processed for the purpose of following up your application and the respective sending of your Curriculum Vitae (henceforth “CV”), due to the necessary nature of such processing. In this context, INIM generally processes general personal data, including any photographs accompanying the CV. In the event that your CV contains any particular or sensitive data, INIM will process only the data relevant for the assessment of the professional figure, within the limits in which the acquisition of such information is strictly indispensable. Also for this reason INIM kindly recommends that candidates always indicate their consent to the processing of the data in their CVs in accordance with the provisions of the Regulations. Without prejudice to the freedom in the provision of personal data by the interested party, it should be noted that the lack of communication of the same implies the impossibility, for INIM, to consider candidacy in the context of the evaluation and selection of personnel. 3.2. Cookies For information on the adopted Cookie Policy, you should consult the Cookie Policy in the dedicated section of the Website.

4. WHO WILL YOUR DATA BE COMMUNICATED TO?

Your personal data will be processed in appropriate ways and using pertinent procedures, involving IT, operated by INIM employees and collaborators who deal with the selection of personnel within their respective functions and in accordance with the instructions received. Such data may also be communicated:

• to third parties, appointed as data processors, who provide ancillary services which are instrumental to INIM’s business activities;
• to the companies of the group of which INIM is a part or, in any case, parent companies, subsidiaries or associates, in order to evaluate the possibility of collaboration or hiring, in regard to the legitimate interest of the Holder.

Your personal data will not be published, displayed or communicated, unless required by a law or regulation or by EU legislation.

5. WILL YOUR DATA BE TRANSFERRED ABROAD?

INIM currently processes your 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 to 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 those countries/territories.

6. HOW DO WE PROCESS YOUR DATA AND FOR HOW LONG

Your personal data will be processed by means of appropriate methods and procedures, including IT and telematic methods, and stored using adequate organizational, technical and security measures. Your personal data will be stored for a maximum period of 36 months from the date of receipt of your CV, or from the last update of your CV that you communicate to us. If the processing is carried out on the basis of legal provisions or in the face of a legitimate interest of INIM or of third parties, the processing of your personal data will be exclusively limited to the time strictly necessary to achieve the purposes for which the processing of the data is required.

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. 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 with registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori, n. 10. Tax Code and VAT no. 01855460448 or by e-mail: privacy@inim.biz.

9. UPDATES TO THIS POLICY

This Privacy Policy regulates the processing of personal data issued by the User when sending job applications through the pages of the Contacts section of the Website www.inim.biz and can be modified or simply updated, in whole or in part, also in consideration of any changes in the laws or regulations governing the protection of personal data. Any changes to and updates of this Privacy Policy will be made known to Users as soon as they are adopted and will become binding as soon as 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 1st June 2020

Privacy Policy pursuant dedicated to participants in Web courses and events organized through the GoToWebinar platform by “INIM ELECTRONICS S.R.L.” Sole Proprietor Company.

EU Regulation 2016/679 (hereinafter, “General Data Protection Regulation” or “GDPR”) contemplates both the regulations relating to the protection of individuals with regard to the processing of personal data and those relating to the free circulation of personal data. The Regulation protects the fundamental rights and freedoms of individuals and in particular their right to the protection of personal data. This Privacy Policy is provided pursuant to art. 13 and 14 of the General Data Protection Regulation, in compliance with the principles contained therein. Any personal data will be collected only to an extent compatible with the purposes described in the following Privacy Policy and processing will be based on principles of correctness, lawfulness and transparency.

1. HOLDER AND PROCESSOR OF PERSONAL DATA

“INIM ELECTRONICS S.R.L.” Sole Proprietor Company (hereinafter also “INIM” or “Holder”), with registered office in Monteprandone (AP), District of Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, is the Holder of your personal data, in relation to use.

2. PURPOSE OF PROCESSING, RELATED LEGAL BASES AND STORAGE TIMES OF PERSONAL DATA

Your communicated personal data will be used, based on the consent given upon registration, by “INIM ELECTRONICS S.r.l.” Sole Proprietor Company (Data Holder), for:

1. the management of your participation in the course and/or web event including all administrative, logistical and organizational requirements such as and by way of example:
   • communication by INIM of the results of the course, where required;
   • the issue of the Certificate of Participation in the course and/or certification, where applicable;
   • the sending of questionnaires regarding satisfaction with the training course attended to which you are free to respond or not.
   The collected data will be kept for a period of time not exceeding the achievement of the purposes for which processed (“Conservation limitation principle”, Article 5, GDPR) and/or for the time necessary for the fulfillment of legal obligations.
2. the sending, by e-mail, of invitations to future events and courses organized by INIM: for such processing the envisaged retention period will last until the data subject has unsubscribed;
3. the sending of communications of a commercial nature: for such processing, the expected retention period is 24 months.

3. COMMUNICATION AND/OR DISCLOSURE OF PERSONAL DATA

Upon registration, your personal data will be communicated to LogMeIn, Inc., owner of the GoToWebinar platform, to allow use of the courses. GoToWebinar's privacy policy is available on the registration form. Personal data will not be disclosed further than what is illustrated, unless required by law or regulations relating to the issue of certifications for the courses attended.

4. COMPULSORY CONSENT

The provision of your personal data for the purposes referred to in point 2 letter a) is mandatory. Failure to provide the data will prevent you from registering and/or participating in the course. For the additional purposes referred to in point 2 letters b) and c), consent is optional and does not preclude the possibility of participating in INIM courses and events.

5. METHOD OF PROCESSING

Your personal data will be processed both in paper form and through computer and data transmission methods, with organizational methods and logic strictly related to the aforementioned purpose in compliance with the security measures prescribed by the GDPR. The collected data will not be subject to transfer abroad. Privacy legislation 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. Any transfer of data to countries located outside the European Union will take place, in all cases, in compliance with the provisions of European legislation regarding the transfer of personal data to third countries or international organizations, in particular pursuant to articles 44, 45, 46, 47 and 49 of the General Data Protection Regulation.

6. AUTOMATED DECISION-MAKING PROCESSES

“INIM” does not carry out processing that consists of automated decision-making processes on your personal data.

7. RIGHTS OF THE INTERESTED PARTY

You, as the interested party, have the right to ask “INIM ELECTRONICS S.r.l.” Sole Proprietor Company (Data Holder), at any time by means of a specific request, for the revocation of the processing of the data subject of this privacy policy, as well as for access to your personal data, the correction or deletion of the same or the limitation of any processing that concerns your personal data or to oppose their processing, as well as their portability, pursuant to art. from 15 to 22 of the GDPR and the right to lodge a complaint with the supervisory authority (Guarantor for the protection of personal data).

8. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

You, as the interested party, may at any time exercise the rights provided for in articles 15 to 22 of the GDPR, towards the Data Holder “INIM ELECTRONICS S.R.L.” Sole Proprietor Company with registered office in Monteprandone (AP), District of Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, e-mail: privacy@inim.biz

9. UPDATING OF THIS PRIVACY POLICY

This Privacy Policy regulates the processing of your Personal Data released when registering for courses and events organized by INIM through the GoToWebinar platform 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. For this purpose, the document indicates the date when it was last updated.

Last updated 1st June 2020

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