title: Privacy Notice author: Enetec SpA version: 1.0.2 date: 2018-11-29

Data protection notice

According to Regulation 27/04/2016, n. 679 ("GDPR") you are hereby informed as follows.

The Controller is Enetec of Pillhof, 89, 39057 Frangarto (BZ) It can be contacted at privacy@mysmart365.app

Data are collected for [legal basis is]:

• Performing activities and/or complying with these TOS [consent is therefore not necessary]
• Sending you information as to similar services [based on the relevant interest of performing direct marketing activities on own clients]
• Sending you commercial proposals for products or services of a different nature [based on your optional consent, which you can revoke at any time, see further]

Data can be shared with:

• @OEM to perform certain measurements as to your use of the Device or provide you with support services, and ‒ based on your optional consent provided herewith, which you can revoke at any time ‒ to send you further commercial offers.
• Cloud providers which are nominated Processors under the GDPR (including Google Inc or its successors and Amazon Web Services - AWS). Please note that we are keeping Your data within the EEA, even if You are based outside it. However, depending on the policies of the processors, they may be in the need to transfer Your data outside the EEA. This may be done under the Privacy Shield, for the USA, and/ir based on model clauses.
• Based on your request or on the activation of a separate agreement, to installers or other technical people to prepare their on-site or off-site technical assistance. They will proceed under our direct authority and their access to Your data will cease as soon as the relevant ticket is closed by @OEM
• Based on your request to activate a third party's service, to the providers of these services, based on their own data processing (please check their data protection notice before proceeding)

Providing personal data is a requirement; failure to provide such data will result in the impossibility to perform the activities provided for in these ToS or in the Subscription.

Data retention policy

Your data pertaining to the use of the Device will be preserved until these ToS are effective. Should you cancel the Activation or let the Subscription expire, Your data will be logically or physically separated. Account data will be preserved for a period of no less than [XXX 6 months] from the date of expiration of the Subscription. After that period, the data will be permanently deleted at any time, but in any case before one year since the expiration of the Subscription.

Contractual data (data concerning the Activation, Subscription, signing these ToS, your personal details) will be preserved offline for the entire current Statute of Limitation ("prescrizione") under Italian Law, currently 10 years after expiration of the ToS.

We might use your usage data to provide you with more tailored commercial offers and to improve your experience. In order to do that, you might be automatically profiled. No decision will be made on purely automated processing.

Your rights

You have the right to request from the controller access to and rectification or erasure of personal data or restriction of processing concerning the data subject or to object to processing as well as the right to data portability; please contact Enetec SpA – Mail privacy@mysmart365.app, preferably indicating your user name.

You have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;

You have the right to lodge a complaint with a supervisory authority.