APP - Privacy Policy

This information, provided by the Data Controller pursuant to Article 13 of Regulation (EU) 2016/679 (hereinafter referred to more simply as "GDPR"), relates exclusively to the mobile application "PLATUM E-MOBILITY".

1) DATA CONTROLLER

The data controller of personal data is M.T. Distribution S.r.l. (hereinafter referred to more simply as "the Data Controller"), with registered office in Via Bargellino, 10 c/d 40012 Calderara di Reno (BO), P.I. 04177060375, C.F. 01119840377, who can be contacted by writing to the e-mail address [email protected] or to the PEC [email protected]

2) PURPOSE OF PROCESSING

Through the 'PLATUM E-MOBILITY' app, each user owning one or more products that can be associated with the app, has the possibility - in particular - to view the data of his vehicle and control it via his mobile device, as well as to receive specific information on recall campaigns related to his vehicle.
As part of the use of the app, personal data of the user may be processed in order to enable:
1. users to create and manage their own account in order to be able to associate their vehicle and thus be able to receive communications concerning recall campaigns on their own, specific vehicle;
2. the user to use their mobile device's camera to facilitate vehicle pairing operations;
3. The user can view vehicle data on his mobile device regarding current driving speed, battery charge status, light status and total kilometres/miles travelled;
4. the user can manage (activate/deactivate) the following Speed shifters on their mobile device: gear engaged, carLock, cruise functionality, position lights;
5. the Controller to notify the user of any recall campaigns;
6. subject to the user's consent, allow the Controller to forward email marketing communications to the user and/or show him/her in-app advertising notifications;
7. the Controller to delete the user's account in the event of inactivity.

3) LEGAL BASES OF PROCESSING

The processing of personal data carried out for the purposes listed above is based on the existing contractual relationship between the Data Subject and the Data Controller, pursuant to Article 6(1)(b) of the GDPR., with the exception of the forwarding of e-mail marketing communications and/or in-app advertising notifications (purpose no. 6 of the preceding point), which is based on the consent of the user, pursuant to Article 6(1)(a) of the GDPR.
With regard to the purpose referred to in No. 5 of the previous point (recall or withdrawal campaigns), the processing is also based on specific legal obligations placed by the sector legislation on the Data Controller (Art. 6(1)(c) of the GDPR): in particular, Regulation (EU) 2023/988.

4) ADDITIONAL AUTHORISATIONS REQUIRED FROM THE USER

For greater user protection, the user is further asked for specific authorisations relating to specific functions, in the manner provided by the operating system installed on the user's mobile device and managed by the same; in particular, these authorisations concern the activation of Bluetooth (to enable the app to communicate with the vehicle), the activation of the camera (to be able to frame and automatically recognise the serial number/QR code of one's own vehicle, in order to associate it with one's own account), the activation of geolocalisation (to be able to activate Bluetooth in certain operating systems that necessarily also require this authorisation; without any acquisition of information by the Data Controller), the activation of the data connection (to enable the app to communicate with the server, limited to the purposes indicated above). In the absence of express authorisation by the user, the relevant functions are not activated.

5) NATURE OF DATA PROVISION

The data requested by the app during registration are the minimum data required to create an account. Access to the camera is limited to the acquisition of the QR-Code on the user's vehicle, in order to facilitate the association of the user's vehicle with the app; however, this function is optional, left to the decision (and specific authorisation) of the user. The activation of Bluetooth is necessary for the app to communicate with the vehicle. The activation of geolocation may be necessary - depending on what is required by the specific operating system installed on the user's device - in order to activate the bluetooth: where not required by the operating system, there is no need to activate geolocation, whose information is not, in any case, acquired by the Owner. The activation of the data connection on one's mobile device is necessary to make the app communicate with the server, limited to the purposes expressly listed in this information notice.

6) DATA RETENTION PERIODS

The account and its data are stored on the Controller's server for three years after the user's last access to the app, after which the account is deleted. Consent for e-mail marketing activities is valid for two years, unless renewed by the user.

7) PARTIES PROCESSING PERSONAL DATA

In order to process personal data, the Data Controller employs personnel who are authorised to do so and who are specially instructed and trained to do so. The Data Controller also makes use of its own "Data Processors", i.e. external parties (companies or professionals) who, pursuant to Article 28 GDPR, process personal data on behalf of the Data Controller, exclusively on the basis of the tasks assigned to them by the Data Controller. In particular, the Data Controller makes use of a Company entrusted with the supply and management of the cloud server on which the data are placed.

8) TRANSFER OF PERSONAL DATA OUTSIDE THE E.E.C.

The cloud server of the supplying company referred to in the preceding point, and therefore specifically classified as a Data Processor pursuant to Article 28 GDPR, is located outside the European Economic Area and more precisely in the United States of America. Said supplier company is certified under the new Data Privacy Framework. For the purposes of user authentication through Google or Apple systems (autonomous Data Controllers), the relative request (and therefore the information that a given user requires to use the services made available by the Data Controller) is transmitted to the relative Companies, which may transfer the data outside the European Economic Area and more precisely to the United States of America, where they have their headquarters. Google and Apple are both certified companies under the new Data Privacy Framework.

9) RIGHTS OF THE PERSONS CONCERNED

The GDPR grants all Data Subjects various rights, which they may exercise by contacting the Data Controller at the contact details set out in point 1) of this notice (it is suggested to indicate in the subject line of emails: "EXERCISE PRIVACY RIGHTS").
Among the rights that may be exercised, provided that the requirements of the law (in particular, Art. 15 et seq. of the GDPR) are met, are:
- the right to know whether the Controller is processing personal data concerning the applicant;
- the right for the applicant to have access to his or her own data being processed and to all information relating thereto;
- the right to have inaccurate personal data concerning the applicant corrected and/or incomplete personal data supplemented;
- the right to the deletion of the applicant's personal data: in particular, the user is free to delete his or her account at any time, also by means of a special function in the app;
- the right to restriction of the processing of the applicant's personal data;
- the right to object to the processing of the applicant's personal data;
- the right to the portability of the applicant's personal data;
- the right to revoke one's previous consent at any time: in particular, the user may easily revoke his/her consent to receive email marketing also by means of the unsubscribe link provided at the bottom of each marketing communication, as well as he/she may change his/her choice, also with regard to in-app advertising notifications, by means of the appropriate in-app functionality. Please note that revocation does not affect the lawfulness of the processing carried out by the Data Controller prior to revocation.
In any event, each Data Subject also has the right to lodge a formal Complaint with the Italian Data Protection Authority, according to the modalities available on the institutional website of that Authority: https://www.garanteprivacy.it.

10) UPDATES TO THIS POLICY

It should be noted that this information notice may be subject to periodic revision, also in relation to changes in legislation, case law and reference guidelines. The user is therefore invited to periodically consult the Owner's website https://www.platum.com/.

Last updated: 25/09/2024

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