Privacy Policy
Effective Date: 01/06/2024
Updated: 26/07/2024
INFORMATION ON PERSONAL DATA PROCESSING
This page sets out the policy statement in accordance with articles 13and 14 of EU Regulation 2016/679 (“GDPR”) relating to the processing of yourpersonal data that we collect when you use this application and interact withthe services.
Identity and contact details of the Data controller
RADIATORS S.p.A., with registeredoffice in Moimacco (UD) Strada Statale 54, Nr. 21, telephone number +39 0432 705511, hereinafter also referred to as “Radiators” or “Data Controller”.
Datacategories and sources
Datacollected from the Application
The Applicationmay collect and send information on the functioning of its device to the DataController (such as time on, estimated consumption usage performance, poweruse, etc.) to provide the service you requested.
Datayou provide on a voluntary basis
The Data Controller processes the personal data thatyou communicate to us when you register or interact with the application andthe related services such as personal and identifying details, contact details,data relating to the products and services acquired and any other datacommunicated by telephone when assistance is being provided.
Legal purpose and basis
A. Management ofuser registration: personal data areprocessed to enable you to create an account and subsequently access thereserved area.
B. Management ofthe services requested: personal dataare processed for all the requirements related to managing all stages of thecontractual relationship (for example to provide the services, manage customersupport and comply with the regulatory obligations governing the DataController).
C. Defensivepurpose: the Data Controller may need toprocess personal data to manage complaints and out-of-court or court-baseddisputes.
Purpose | Legal basis (common data) |
|---|---|
A. | Performance of pre-contractual and contractual measures. |
B. | Performance of pre-contractual and contractual measures. |
C. | Legitimate interest of the Data Controller to ascertain, exercise or defend a right. |
Period of retention
Purpose | Period of retention |
|---|---|
A. | Deactivation of your use within 730 days of thelast time you accessed the app and erasure of the subsequent data. |
B. | 10 years after contract termination. |
C. | 10 years after the definitive finalisation ofthe dispute. |
Provision of data and consequences of refusal
The data in thefields marked with asterisks (*) for the purposes described under letters A),B) and C) above must be provided to register with the application and use theservices; if you do not provide said data, you will not be able to obtain theservices requested. On the other hand, even though the data in the fields notmarked with an asterisk could facilitate relations with the Data Controller,you have the option to provide them and if you do not, you will still be ableto obtain the services requested.
Purpose | Nature | Consequences |
|---|---|---|
A. | Necessary | You will not be able to create or use a useraccount. |
B. | Necessary | You will not be able to initiate or pursue abusiness relationship. |
C. | Necessary | It will not be possible to manage the dispute.Categories of external recipients |
Scope of communication
The data are processed by internal staff authorised tocarry out specific duties and are communicated externally on the basis of thefollowing rules.
Purpose | Categories of external recipients |
|---|---|
A. | External consultants, companies that offer technological platform hosting/management services. |
B. | Companies that belong to the same businessgroup, Distributors, retailers, technical assistance centres and localpartners, payment service providers, companies that offer technologicalplatform hosting/management services. |
C. | Law firms; debt collection or assignment of debtcompanies; Legal authorities. |
Since data are also processedwith IT instruments, they may be visible to parties who carry outassistance/maintenance on said systems.
Transfer of data to third countries or internationalorganisations
The data are not transferred outside the European Union.
Rights of the Data Subjects
The party to whom the personal data refer shall havethe following rights:
Access: you can find out if your personal data are beingprocessed, and if they are, obtain them and ask for a copy.
Rectification: you can ask for your personal data to be updated,corrected (if inaccurate) and to have incomplete data completed.
Erasure: you can have your personal data erased if certainconditions are met (please contact the Data Controller for furtherinformation).
Restriction: you can ask for your data to be tagged to limitprocessing in the future if certain conditions are met (please contact the DataController for further information).
Objection: you can object to the processing of your personaldata for reasons connected to your own specific situation if the processing isbased on legitimate interests or is necessary for the performance of a taskcarried out in the public interest or connected to the exercise of officialauthority vested in the Data Controller; you can also object to the processingof personal data for direct marketing purposes.
Portability: you can receive the personal data provided to theData Controller in a structured format and send them to another data controllerif the processing is based on consent or on a contract and is carried out withautomated methods.
Withdrawalof consent: you can withdraw consent for thepurposes for which they were requested subject to the lawfulness of theprocessing carried out up to that time.
The actual rights that can be exercised with respectto the processing carried out are:
In order to exercise the rights set out above, theform available at the following link can be used https://www.garanteprivacy.it/web/guest/home/docweb/-/docweb-display/docweb/1089924 and should be sent to the following address:privacy@dlradiators.com. The data subject may make a request to the sameaddress to obtain further details in relation to the information set out above(for example balancing test on the legitimate interests or the list of dataprocessors).
You may also lodge a complaint with a supervisoryauthority: for Italy the Data Protection Supervisory Authority (www.garanteprivacy.it).