PRIVACY POLICY FOR APPS PUBLISHED BY EOS SOLUTIONS GROUP
On this page, EOS Solutions Group (EOS) explains how it handles data for the users who download and use the apps published by EOS and available for download to users.
This Privacy Policy is provided in compliance with article 13 of GDPR 2016/679 (General Data Protection Regulation, the European regulation on the protection of personal data), the Guidelines of the Garante Privacy of 26 November 2020, the Guidelines EDPB 5/2020 on consent, the ECJ Judgment 1 October 2019 C-673/17, the general Act of the Garante Privacy [the Italian Data Protection Authority] on cookies no. 229 of 8 May 2014, the Working Document 02/2013 providing guidance on obtaining consent for cookies”, the opinion of WP 29 no. 4/2012 on cookie consent exemption, the Directive 2002/58/EC, the Recommendation no. 2/2001 by the Workgroup under article 29.
The following information applies only to the the apps published by EOS.
The data controller is EOS Solutions Group (wich consistes of the companies EOS SpA, EOS Solutions SpA, EOS Online SpA and Entity SpA), with legal offices at Giuseppe di Vittorio Street 23, 39100 Bolzano/Bozen (BZ), Italy. The data controller has also assigned a data protection officer (DPO), the company Effizient Srl, with offices at Galvani Street 6/A, 39100 Bolzano/Bozen (BZ), Italy.
To exercise your rights under the regulations, you can contact the data controller at his/her office or by sending an email to privacy@eos-solutions.it, or to the data protection officer by writing an email to dpo@eos-solutions.it .
The EOS Solutions Group handles data provided by the user of the apps for the following purposes:
a. Fulfilment of obligations established by law, by regulations, or by community regulations
The provision of data for this purpose is mandatory and the legal basis for processing it is the fulfilment of a legal obligation to which the data controller is subject (e.g. service contract registration, invoicing), as established by article 6, paragraph 1c of the GDPR. The processing of personal data for these purposes does not require the user's consent. The processed data will be kept for the time foreseen by the referenced legislation.
b. Statistical analysis on aggregate or anonymous data
This processing doesn't allow for the identification of the user, but simply collects usage and performance data (e.g. number of app downloads, execution of app functions) used to identify potential areas within the app that may need performance optimization and/or functional extensions. The processing of aggregate or anonymous data, which does not allow for the identification of the user, does not fall within the scope of the application of the law on the protection of personal data and therefore no consent is required for its processing.
c. Request for information, contact and support
The provision of the requested data is necessary to provide feedback to your request. The legal basis of the processing is indicated by Article 6 paragraph 1b of the GDPR, and it is the execution of a contract of which the interested party is party to or the execution of pre-contractual measures adopted at the request of the same, as well as by Article 6 paragraph 1f, and is the pursuit of a legitimate interest of the data controller or third parties. The data processed and relating to your request will be kept by us for one year.
d. Service provision, advanced functionalities, additional features
Some apps may require some personal data to provide the user with a service, to carry out specific functionality or to activate additional features in the app. Submitting the requested data is not necessary to use the app, but is necessary to provide/activate the services, functionalities or features requested. If the user declines to submit the requested personal data, the service, functionality or feature can not be activated/provided. The legal basis of the treatment is indicated by Article 6 paragraph 1b of the GDPR, and is the execution of a contract of which the interested party is part or the execution of pre-contractual measures adopted at the request of the same, as well as by Article 6 paragraph 1f, and is the pursuit of a legitimate interest of the data controller or third parties. The processed data will be kept for the time foreseen by the referenced legislation.
e. Licence usage
The provision of the requested data is necessary to control correct usage of the granted licence. The requested data is collected automatically by the app to control licence validity and licence limits. The legal basis of the treatment is indicated by Article 6 paragraph 1b of the GDPR, and is the execution of a contract of which the interested party is part or the execution of pre-contractual measures adopted at the request of the same, as well as by Article 6 paragraph 1f, and is the pursuit of a legitimate interest of the data controller or third parties. The processed data will be kept only for the time necessary to carry out the above mentioned control actions.
The processing of your data takes place electronically, although potential paper-based processing is not excluded.
The processed data will be retained for the time periods specified for the single purposes in section “Purpose and legal basis for data collection and processing”.
To guarantee the functionality of our apps, we may rely on use third-party suppliers such as IT service providers and hosting companies. The legal basis of the communication is the fulfilment of contractual and regulatory obligations, as well as the execution of pre-contractual measures adopted at your request. It is understood that we will only communicate to the recipients the data necessary to be able to perform the requested service, preferring, where possible, the anonymization of the data. The information you provide will not be disclosed without your specific prior consent.
The data you have provided will not be transferred by us to third countries or international organizations outside the EU. The hosting of the data is within the European Community.
You have the right to request access to your data at any time, its modification, integration, or deletion, limitation or opposition to its processing, where legitimate reasons exist, as well as the portability of the data to another Data controller. We will reply in writing to any requests within 30 days. You can revoke, at any time, consent given through a downloaded app for the processing of your personal data by contacting one of the addresses listed in this Privacy Policy. You may also submit a complaint to the National Control Authority, if you believe that your data has been illegitimately processed.