INFORMATIVE NOTE ACCORDING TO ART. 13 OF THE EU GENERAL DATA PROTECTION REGULATIONS 2016/679 (GDPR)

This document (hereinafter, the “Policy”) was drawn up to explain how FERROLI ESPAÑA, S.L. will use your personal data during your use of the “FERROLI ELECTRIC” application (hereinafter, the “App”).

The information and data you provide or that are otherwise acquired in the use of the application shall be processed according to the provisions of the GDPR and the fundamental confidentiality obligations of the activity.

This Policy refers solely and exclusively to the app.

The app was created and developed by Third parties at the request of FERROLI ESPAÑA S.L.U., or through the parent company thereof, FERROLI Spa.

FERROLI ESPAÑA, S.L. is licensed the rights and anticipates that the application will be available.

FERROLI ESPAÑA, S.L. benefits from the app through a specific contractual arrangement with Third parties.

Data controller

The data controller responsible for the personal data collected through the app is FERROLI ESPAÑA, S.L., domiciled at C/ Alcalde Martín Cobos, nº4, Polígono Industrial de Villayuda, 09007, Burgos, SPAIN, Fiscal Code No. B09497264.

Purposes of the processing

The data are necessary for FERROLI ELECTRIC’s electric radiators (hereinafter, also the “equipment”) in order to manage the following operations using a remote system:

· Turning on/off the equipment;

· Selection of the operating mode;

· Regulation of the temperature selection in the deposit;

· Operating time schedule;

· Indication of alarm codes in the event the equipment malfunctions.

The application also indicates in real time the operating status of the apparatus.

Data voluntarily provided by the interested party:

• Time zone of the installation (required);
• E-mail address (required);
• Password (required);
• Device name (required);

· Name assigned at installation (required);

· Name assigned to the area (not required);

Data automatically collected by the application/server:

• Identification of the remote portable device (required);
• Virtual device identification, automatically assigned by the server (required);
• IP address (Internet Protocol) of the device (required);
• Device MAC (Media Access Control) address (required);

By installing this app, you authorise the collection of your personal data for the aforesaid processing.

Collection and transfer of personal data

The services provided by the app, as well as the characteristics and functions thereof, require the user perform a simplified registration process using some personal data: time zone of the installation, the e-mail address and a password defined by the user.

To guarantee access security, the app automatically identifies the remote device, the e-mail address and/or the telephone number of the user and the device’s installation location.

In order to function, the app needs all the aforesaid data, partially provided voluntarily by the user and partially collected automatically by the app/server.

Other data may be collected by the app distribution service provider, specifically Apple Store and Google Play.

To expand the information, the user can visit the websites of said service providers to consult their privacy policies.

QR code reader

The application includes a QR code reading function through the mobile phone camera. This function is exclusively used to register the user and the devices on the app.

Advertising

The app does not require you to accept ads in order to download same. You will only receive ads if you check the box “I want to receive electronic commercial communication, including those from third parties, according to the Privacy Policy”.

Target audience

FERROLI ESPAÑA, S.L. may grant access or transfer the personal data provided by the user to the necessary third party service providers with whom FERROLI ESPAÑA, S.L. or the parent company thereof, FERROLI S.p.A., has subscribed data processing agreements, where said third party must access said information to provide a service on behalf and in favour of the Data controller.

The app was created and developed by third parties at the request of FERROLI ESPAÑA S.L., or through the parent company thereof, FERROLI S.p.A.

FERROLI ESPAÑA, S.L. shall ensure that the entrusted third parties adopt the necessary security measures to ensure the security, confidentiality and integrity of the processed information.

The personal data collected shall not be transferred to other third parties, except when legally obligated to do so, for example any communications to Courts and Tribunals, or the State’s law enforcement bodies.

Data preservation

Personal data collected for registration in the app shall be preserved as long as the user uses the application.

Confidentiality and information security

FERROLI ESPAÑA, S.L. has adopted the technical and organisational measured necessary for minimising information loss and unauthorised access risks.

Maintaining the user’s information confidential is paramount to FERROLI ESPAÑA, S.L. We review our security policies on a regular basis in order to improve the system and find possible shortcomings.

We will not use your personal data for any other purpose than that expressed in this privacy policy.

If you are using the App with a user account for which you registered and chose a password, we would like to remind you that you must not share this password in order to avoid identity theft problems.

Minors

By virtue of the terms of Article 7.2 of Organic Law 3/2018, of 5 December on Personal Data Protection and the Guarantee of Digital Rights, the processing of the data of minors under fourteen years of age, based on consent, shall only be legal where the holder of parental authority or custody holder has also given their consent.

The APP is intended for users ages 14 and up. Therefore, children under 14 years old must have the consent of their parents, guardians or legal representatives to install and use the App. The owner of the App reserves the right to request any information that verifies the user’s age.

Rights of the data subject

Pursuant to Art. 15 et seq. of the GDPR, the data subject can exercise the rights envisaged by said Regulation at any time, namely:

· access their personal data;

· demand the rectification or omission of their data or oppose the processing thereof;

· request that the processing be limited in the cases envisaged in Art. 18 of the GDPR, in addition to receiving - in a structured format in common use that can be read with automatic devices - the data that pertain to them, in the cases established by Art. 20 of the GDPR.

Said rights may be exercised as follows:

All users have the right to receive information on the processing of their data, which is carried out by FERROLI ESPAÑA, S.L. You can exercise your rights to the rectification, omission and portability of your data and the limited processing thereof and the opposition thereto, as well as not be subject to decisions based solely on the automated processing of your data by contacting FERROLI ESPAÑA, S.L. at C/ Alcalde Martín Cobos, nº 4, Polígono Industrial de Villayuda, 09007, Burgos, SPAIN, or at the email address lopd@grupoferroli.es. In the event you are not satisfied with the exercise of your rights, you may file a claim before the control authority (the Spanish Agency for Data Protection or the AGPD as per its Spanish initials).