PRIVACY DISCLAIMER

This Privacy Policy ("Notice") describes the treatment performed by UDINO S.R.L.(hereinafter "Company") of personal data ("Data") provided by Users of the mobile application named "SCLAK" (hereinafter, "Application"), available on the iTunes Store and Google Play, in accordance with as described in the license agreement concerning the use of the Application. Terms of Use
Personal data provided by Users will be processed in accordance with the provisions of Legislative Decree 30 June 2003, n. 196 ("Privacy Code") and Regulation (EU) 2016/679 (hereafter "GDPR").
SCLAK S.p.A. intends to guarantee the privacy and security of the personal data of each visitor in accordance with the provisions of this Notice and, in particular, in compliance with the principles of necessity, transparency, lawfulness, correctness and proportionality of the processing of personal data.

1. HOLDER OF THE TREATMENT

Name: UDINO S.R.L.
Registered office: via Amedeo Avogadro, 24 10121 Torino
VAT number: 11989000010
E-mail: info@sclak.com

2. TYPOLOGY OF DATA PROCESSED

The Company collects only personal data provided specifically and voluntarily by the User when registering or downloading the Application. The provision of personal data is mandatory, and failure to provide data will make it impossible to use the service.

When the user accesses the Application, the Company will process the following data:

Identifying information (name and surname, email address and telephone number);
User codes and passwords;
Geolocation data;

3. TYPE OF DATA COLLECTED - NAVIGATION DATA

The computer systems used to operate the services acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols (for example, IP addresses of the devices used by the User, the timetable of the request and other parameters related to the User's operating system).
This information is not collected to be associated with identified subjects, but by their very nature could, through processing and association with data held by third parties, allow to identify the User.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Application and to check its correct functioning and are deleted immediately after processing.
These data could be used to ascertain responsibility in case of any computer crimes against the Company or its assignees.

3.1 TYPES OF DATA COLLECTED - BANK DATA AND SENSITIVE DATA

The application also provides for the possibility of access to gates or entrances subject to payment.
In this case, the bank transaction will be handled exclusively by the operator of the aforementioned passages or entrances, and the data relating to the credit card used by the User for the payment of the entry price to the gate or entrance will be handled exclusively by the gate operator or entrance.
The Company will collect, in addition to the identification data of the Users, also the data related to the registration of entry and exit times from the gates and / or entrances and billing data. The Company will decide which data, in any case limited to those strictly related to the provision of the service, provide the operator with the driveway and / or pedestrian entrance.

The Company will not process sensitive data, understood as personal data capable of revealing the User's racial and ethnic origin, its religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing the User's state of health and sexual life.

The User is invited not to transmit sensitive data to the Company.

4. METHOD AND PURPOSE OF THE TREATMENT

SCLAK will process the personal data of the Users exclusively for the purposes related to the provision of the service. The Company will not use the data for marketing purposes or sending commercial communications to Users.

Personal data are processed with automated electronic tools for the time strictly necessary to achieve the purposes for which they were collected.

Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

The technology used by the Company is based on high safety standards, such as, for example:

128 bit AES cryptographic system, through which every message is encrypted;
128-bit private key is never transmitted in the clear;

communication between client and server is protected;

Data transmission and connection between the "SCLAK" hardware device and the application via a Bluetooth 4.0 Low Energy interface;

the Bluetooth connection is without pairing;

The encrypted transmission phase is preceded by an authentication phase where it is verified that both the "SCLAK" device and the smartphone are able to encrypt a secret code in the same way, both having the same private key;
All messages are coded in Xor with CODx codes generated from time to time for each individual message sent.

5. LEGITIMATION

The processing of personal data provided by the User will be exclusively for the following purposes:

fulfilment of contractual obligations;
management of the services and functionality of the Application.

6. DATA COMMUNICATION AND CIRCULATION

The User's personal data will be accessible to internal and external personnel in charge of processing in relation to the purposes specified above.
Personal data provided by Users may be communicated to suppliers of the company or other intermediaries that support the company itself for the purposes of operation and provision of services (for example, distributors, wholesalers, installers, or other service providers or partners of the Company) , exclusively for the specific purposes related to the provision of the aforementioned services.
The data will not be disclosed to other third parties and will be disclosed only in the presence of an order of the competent judicial or administrative authority. With regard to data processing carried out by Apple, Inc. and Google, Inc. as managers of the iTunes and Google Play platforms, we recommend that you review the related data processing policies.

7. RIGHTS OF THE INTERESTED

The subjects referred to in the aforementioned personal data (so-called "interested parties") have the right to exercise their rights according to the methods and within the limits established by the current privacy legislation.
To exercise these rights, report problems or request clarification on the processing of their personal data, you can send an email to info@sclak.com, obligatorily attaching a photocopy of the identity card, passport or similar document.
In particular, Users, with reference to their personal data, have the right to ask SCLAK:

access (Article 15 of the GDPR): may request confirmation of the existence or not of personal data concerning them and their communication in an intelligible form, within the limits of reasonableness, as well as more clarifications about the information referred to in this informative. They can ask to: know the origin of the data, the purposes and the modalities of the treatment; the indication of the identification details of the owner, the managers and the subjects or the categories of subjects to whom the personal data can be communicated.
The rectification (Article 16 of the GDPR): they can ask to verify the accuracy of the data, correct them if inaccurate, integrate them if incomplete or update them.
The cancellation (right to be forgotten - Article 17 GDPR): may request that their data acquired or processed by SCLAK be deleted - (I) if they are no longer necessary for the purposes for which they were provided; (II) in case of revocation of consent or opposition to treatment; (III) in case of unlawful processing; (IV) if there is a legal obligation to cancel.
The limitation (Article 18 of the GDPR): when one of the conditions referred to in art. 18 of the GDPR. In this case, their data will not be processed, except for storage, without their consent, except for what is specified in the same article in paragraph 2.
Portability (Article 20 of the GDPR): may request to receive their data, or send them to another owner indicated by them, in a structured format, commonly used and readable by automatic device.
The opposition (Article 21 of the GDPR): may for legitimate reasons oppose the processing of their data at any time, unless SCLAK has reason to proceed with the processing (eg for the defense in court).
The revocation: may, pursuant to art. 7, par. 3, at any time revoke the consent, without prejudice to the lawfulness of the treatment based on consent previously granted.

Finally, each interested party has the right to lodge a complaint with the Supervisory Authority, which in Italy is the Guarantor for the Protection of Personal Data (www.garanteprivacy.it).

8. CHANGES TO THE INFORMATION

The eventual entry into force of new sector regulations, as well as the constant examination and updating of the services to the User, could entail the need to modify the methods and terms described in this Notice. It is therefore possible that this document undergoes changes over time. We therefore invite you to periodically consult this page.
We will publish any changes to this Statement on this page, notifying Users if the changes were relevant.