Cloud User Privacy Policy

Notice for users registered in the reserved area of the "Inim Cloud" service portal

This Privacy Policy regards Users who register on the INIM CLOUD SERVICES portal accessible from the Websites www.inim.biz, www.inimdns.biz, www.inimcloud.com and my.inimcloud.com property of ‘INIM ELECTRONICS S.R.L’ SOLE PROPRIETOR COMPANY (henceforth INIM).

Pursuant to Articles 13 and 14 of EU Regulation 2016/679 (‘General Data Protection Regulation’ or ‘GDPR’), we wish to inform you that, by registering with the portal, INIM, as Data Holder (henceforth ‘Holder’) will be made aware of your personal data.

For this reason, it is necessary for INIM to provide you with the following information in fulfillment of the obligation imposed by the aforementioned legislation.

This Privacy Policy supplements the general Privacy Policy of INIM Websites and that of the ‘INIM HOME,’ ‘INIM HOME P2P,’ ‘INIMTECH SECURITY’ and ‘INIM FIRE’ Apps.

1. WHO IS THE HOLDER OF YOUR PERSONAL DATA?

The Holder is ‘INIM ELECTRONICS S.R.L.’ SOLE PROPRIETOR COMPANY with registered office in Monteprandone (AP), District of Centobuchi, Via dei Lavoratori n. 10 Tax Code and VAT no. 01855460448.

2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?

Your data is processed for the creation and management of your personal account in INIM CLOUD. Additionally, INIM might process the data as necessary both for the execution of a contract of which you are a party and for the execution of pre-contractual measures adopted at your request.

Every time INIM acquires and processes your personal data, it guarantees its availability, integrity and confidentiality.

INIM processes your data in compliance with the following principles of lawfulness provided for by law:

  1. pursuant to art. 6.1 (b) of the Regulations, in order to allow registration and;
    • allow the creation of a Personal Account on the INIM Cloud and the use of the related dedicated services;
    • allow INIM to respond to your contact requests and provide the necessary assistance;
    • allow INIM to provide the services activated by you;
  2. pursuant to art. 6.1 (a) of the Regulation, or subject to your specific and explicit consent, for the purpose of conducting marketing activities, both through automated tools (SMS, MMS, messaging platforms, e-mail, push notifications) and through traditional channels (paper mail, telephone call with operator);
  3. pursuant to art. 6.1 (a) of the Regulation, or subject to your specific and explicit consent, for profiling purposes, i.e. to identify your preferences, interests and consumption choices, in order to be able to provide you with services that are more suited to your expectations and needs;
  4. pursuant to art. 6.1 (c) of the Regulation, to fulfill legal obligations to which INIM is subject;
  5. pursuant to art. 6.1 (f) of the Regulation, for the pursuit, under the conditions and in compliance with legal constraints, of a legitimate interest of INIM or third parties, such as for example the prevention of fraud, the improvement of processes management, the exercise and defense of one’s own rights, the organizational and strategic optimization of INIM.

2.1. Purpose of processing data

Your personal data will be processed by INIM for:

  1. creation of your own INIM CLOUD account;
  2. purposes functional to the management of your alarm control panels such as, by way of example and not limited to, sending notifications by e-mail, SMS or, if the INIM HOME APP is used, Push notifications regarding alarms, events and status information. Notifications can be deactivated and reactivated at any time via the INIM CLOUD account page of the User. Included in these purposes is the backup service offered in relation to the data of INIM control panels and P2P devices that can be integrated with them, for example the configuration of home-automation systems or video cameras;
  3. purposes functional to the management of your alarm control panels by your Installer. The above notifications can in turn be sent to the reference INSTALLER Account. For such data processing, see point 3.2 of this Privacy Policy;
  4. purposes functional and/or complementary to the activity carried out by INIM such as, by way of example and not limited to, the sending to Users, by e-mail, of newsletters and promotional material or, more generally, ‘direct marketing’ relating to the products and/or services marketed by INIM itself, having, however, a nature similar to those subject to previous sales or supplies;
  5. your profile in order to allow INIM to process your choices, habits and propensity to consume and, consequently, to send you specific offers relating to INIM products and services;
  6. your enrollment in courses and events organized by INIM, both in presence and remote, as well as participation in promotions related to them, when consent for commercial activities has previously been acquired. For such data processing, see point 3.5 of this Privacy Policy.

The granting of consent for the purposes referred to in letter a) is necessary and eventual refusal will prevent you, the user, from completing the process of creating an account.
The release of consent for the purposes referred to in letters b), c), d), e), f), is optional; your refusal does not prejudice in any way your existing relationship with INIM, nor the successful outcome of the process of creating a personal User account on the ‘INIM’ Website.

2.2. Further purposes of data processing

The data might be processed for purposes functional to the management of commercial relationships between the Data Controller and interested parties belonging to the Installer and Distributor categories or existing relationships between the latter.

2.3. Categories of subjects to whom the data can be communicated

To achieve the purposes described in paragraphs 2.1 and 2.2 above, INIM may need to communicate your Personal Data to third parties belonging to the following categories: agents and/or area dealers of products marketed by INIM; subjects who provide banking, financial and insurance services; authorities and supervisory and control bodies and, in general, subjects, public or private, in their role as Public Officials or subjects appointed to Public services; other companies in the group of which INIM is part or, however, parent, subsidiary or associated companies; entities that perform acquisition services, subjects who perform the services of data acquisition and processing necessary for the execution of the orders received from customers; subjects who provide services for the management of INIM’s data and IT systems and telecommunication networks (including e-mail); subjects in charge of IT security and maintenance; subjects who carry out data transmission, enveloping, transport and the sorting of communications with users; subjects who carry out document filing and data entry activities; subjects who carry out customer assistance activities; subjects who carry out surveys and companies in the ambit of assistance and consultancy relations; subjects who carry out activities for the promotion and sale of products and services on behalf of INIM and of other companies belonging to the group of which INIM is part.
With reference to the data communicated to them, the subjects belonging to the previously-mentioned categories will be able to operate, as the case may be, in complete autonomy as distinct Holders, or even, as managers or persons in charge of data processing.
At the same time, the Data may also be communicated to other data processors appointed by INIM as well as to its employees operating as data processors, always for the purposes indicated in the previous paragraphs 2.1 and 2.2.

3. CATEGORIES OF INTERESTED PARTIES AND RELATED SPECIFICATIONS OF PERSONAL DATA PROCESSING

Detailed indications are provided to the various categories of interested parties, depending on their involvement and the related processing of Personal Data.

3.1 Private

The creation of a Private account in the Cloud means that the individual who registers can control and manage the associated control panel (s). The registration of the private account involves the entry of a series of data, including personal data, in the appropriate online form. The Private individual is made aware that, to manage the installation and management processes of their alarm system for the purposes referred to in point 2.1 c) of this Privacy Policy, they must necessarily communicate some data – User name and surname and serial number of the control panel – the reference Installer by means of a manual procedure (to be carried out by accessing the keypad of the control panel of the private individual) for the association of the control panel with the respective User account.

We wish to specify that this conferment is necessary in order to follow up the execution of the activation and management services of the control panels through INIM CLOUD.

Following this communication, the installer will control and process the data of the Private individual as an independent Data Holder also through their own auxiliary installers (if any). Any personal data relating to ‘Private’ users, in addition to the User name and surname and serial number of the control panel, will be entered independently by the Installer, after the association of the control panels.

The association of one or more control panels by a ‘Private’ User, when the control panel is owned by the same, with the reference Installer, can be revoked at any time through the function present in the management panel of the Cloud.

3.2 Installer

The Installer account manages, on behalf of ‘Private’ accounts, the control panels associated with them and the related management and programming processes.

There are two types of ‘Installer Account’.

Admin Installer Account

The ‘Admin Installer’ account is that linked to an individual who, in any capacity, is part of a company/sole proprietorship and is fully responsible for managing the same and the ‘Auxiliary’ accounts.

If there are not yet any accounts associated with the company (VAT-Country combination), the first individual who registers as the ‘Installer’ account automatically becomes the ‘Admin Installer’ account.

Those who have the ‘Admin Installer’ account also have the right to:

  • control and view all the control panels enrolled directly by the ‘Admin’ as well as those enrolled by ‘Auxiliaries’;
  • manage groups of ‘Auxiliaries’ and limit viewing and control by the same on the installed control panels;
  • decide which group to assign the control panels to.

The registration of the ‘Admin Installer account’ involves the entry of a series of data, including Personal Data, in the appropriate online form.

The ‘Admin installer’ is made aware that, in order to manage all the processes relating to the activation of their account for the purposes referred to in point 2.1 c) of this Privacy Policy, they must complete the registration procedure.

Auxiliary installer account

An ‘Auxiliary installer account’ is subject to the control of the ‘Admin Installer account’ of the company/individual enterprise (VAT number/Company).

The registration of an ‘Auxiliary Installer account’ requires the entry of a series of data, including Personal Data, in the appropriate online form. The ‘Auxiliary’ installer is made aware that, in order to manage all the processes relating to the activation of their account for the purposes referred to in point 2.1 c) of this Privacy Policy, they must complete the registration procedure and contextually receive an e-mail containing details relating to the ‘Admin’ (name and surname); the ‘Admin’ is also made aware, in the same manner, of the Personal Data of the ‘Auxiliary’ (name and surname).

3.3 Distributor

The Distributor account (provided, together with the relevant password, directly by INIM) manages the relevant installers as assigned by the agreements with the Owner and might display some data relating to existing relationships between the parties, in order to best guarantee the carrying out of management and support activities.

INIM informs the Interested parties, Distributors and Installers that INIM may retain such data for statistical purposes.

3.4 Data processing specifications for the categories of interested parties ‘Installer,’ ‘Private,’ ‘Designer’ and ‘Distributor’

The ‘Admin’ Installer processes the data of the ‘Auxiliary’ installer in the role of an independent Data Holder. It should be noted that this provision of Data from the ‘Auxiliary’ to the ‘Admin’ is necessary in order to follow up on the activation of the specific profile.

An ‘Auxiliary’ installer can control and view only the control panels associated with their group, in accordance with the permission granted by the ‘Admin’ Installer.

For all the Data processing that is carried out, the ‘Auxiliary’ installer operates under the responsibility of his ‘Admin’ Installer, in the role of the person authorized (in charge) of processing or responsible for processing.

For the processing of Data relating to ‘Private’ user typology, the ‘Main User’ operates as an independent Data Holder and it is their exclusive task to inform the ‘secondary’ (if any) via their own Privacy Policy and collect eventual consent.

For the ‘Designer’ profile, there are no further processing specifications with respect to what is indicated, generally, in this Privacy Policy.

For the ‘Distributor’ profile there are no further processing specifications than those indicated, in a general manner, in this Privacy Policy.

3.5 Data processing specifications for those enrolled in INIM courses and events

If you enroll in INIM courses and events, your Personal Data will be processed in order to fulfill all the administrative, logistical and organizational obligations related to the use of the same, including the sending of any certificates and the administration of satisfaction questionnaires to which you are free to answer or not. Your Personal Data, on registration, may be communicated, as provided for in point 2.1, to allow the correct fruition of the courses.

If participation in the courses is related to promotions and you have provided consent for commercial activities, your Personal Data may be communicated to one or more INIM distributors in your area in order to allow you to be contacted and thus allow you to benefit from the dedicated advantages. Personal Data will not be disclosed further than has been described, unless required by legal obligations or by regulations relating to the issue of certifications for the courses/events attended.

3.6 Specifications of data treatment for users of the voice assistant services named ‘MARILYN’ and ‘MARILYN MORE’

In the event you wish to use, following your consent, the voice assistant services named ‘MARILYN’ and ‘MARILYN MORE’, INIM informs you that it processes the following types of data:

  • data collected automatically, such as server logs and data transmitted by Actions on Google/Dialogflow API during the user’s interaction with Google Actions;
  • data collected automatically, such as server logs and data transmitted by the Skill to Amazon servers during the user’s interaction with inim-skill;
  • data obtained from the User, directly or through the Authorization API;
  • pre-existing identification data (such as user ID of the user’s My Inim Cloud profile).

The computer systems and software processes used for the functioning of voice commands, during their normal operation, acquire, from the respective servers of service providers that send the conversations collected by the Voice Assistant within the scope of the manageable functions, some personal data whose transmission is implicit in the operation of the voice instructions. This data is not collected for the purpose of association with the identity of the interested parties, but which, by their very nature allows users to be identified. This category of data includes the commands given, the Inim anti-intrusion systems involved and in general all the conversation data the voice assistants provide to the Inim servers for the operation of commands and instructions.

These data are stored for a limited period of time, for the sole purpose of having diagnostic information for the resolution of any problems relating to the functioning of the actions and to keep track of the activities carried out via voice commands for purposes provided for by law (for example for example, in the case of a request made by the police or the judiciary or other competent bodies). The data that Inim keeps for the aforementioned purpose of technical assistance, relating to the actions on voice assistants, are deleted twelve months after their collection.

The data of users is utilized for providing the services offered by the Inim Apps and is activatable through them or the Inim Cloud, for the management of the alarm systems they possess and the home-automation devices that can be connected to them, and include the possibility of their identification and recognition for subsequent uses of the App.

INIM does not use any collected data for the purposes of customer profiling, for offering products and services or for any other commercial purposes.

The personal data that INIM processes are collected for purposes strictly related to the activation and operation of the voice functions activated by the user.

However, we inform you that the computer systems and software processes of third parties in charge of functions, may acquire, in providing their services, some data referable to the user whose transmission is implicit in the use of the voice assistant functions on smartphones and on other compatible devices. Inim is not involved in such processing, carried out autonomously and exclusively by the respective Data Controllers, nor can Inim be held responsible for them.

Therefore, prior to the activation of the services, we invite you to consult the privacy policies of the Google and Amazon voice assistant services published on their respective websites.

3.7 Processing specifications for users of services dedicated to the management of Video surveillance via INIM Cloud and INIM App

In the event that you wish to use, following activation by you, the Services (offered via Cloud and INIM App) dedicated to the management of Video surveillance, INIM informs you that it processes the following types of data:

  • information such as images and short films (maximum duration of 15 seconds) which are acquired and stored exclusively following the automatic signalilng of presence or alarm by the installed systems;
  • information relating to the zone in alarm and the event that generated it.

The IT systems and software procedures responsible for the operation of the Video surveillance system, during their normal operation, acquire this information from the respective systems of users.

This data is recorded for a limited period of time, for the sole purpose of making information available on events that could be useful to users based on their legitimate interest in carrying out such collection of data and storage. The data that INIM keeps for the aforementioned purposes are deleted by choice of the user or in any case thirty days after their collection. INIM may have access to such data exclusively for technical purposes and following requests for assistance from the User, thus covering the role of Privacy Manager, pursuant to art. 28 of the GDPR. This nomination is present in the D.P.A. (Agreement for the processing of personal data).

The User data is utilized to provide the services offered by Inim Apps that can be activated via the same or in the Inim Cloud, for the management of the video surveillance system of the Users and includes the possibility of identifying them and recognizing them for subsequent use of the Apps.

The personal data that INIM processes are collected for purposes strictly connected to the functions activated by the User.

We inform you, however, that the IT systems and software procedures of third parties responsible for the functioning of the entire system may acquire, in providing their services, some data in any case referable to the User, the transmission of which is implicit in the use of the functions present on Smartphones and other compatible devices. INIM is not involved in such processing, carried out autonomously and exclusively by the respective Data Controllers, nor can INIM be held responsible for them.

Therefore, we invite you to consult, before activating the services, the privacy policies of your suppliers and managers of hardware, software and related services.

4. WHERE DO WE PROCESS YOUR DATA?

The processing operations connected to the Web services of this Website take place at the aforementioned headquarters of INIM and are handled solely by technical staff responsible for or in charge of data processing, or by other persons responsible for or in charge of occasional maintenance operations.

5. WILL YOUR DATA BE TRANSFERRED ABROAD?

INIM currently processes your personal data without transferring it to countries other than those belonging to the European Union or that do not ensure adequate levels of personal data protection. The privacy regulation allows the transfer of personal data abroad with the consent of the User, or where there is a legal justification and where an adequate level of data protection is guaranteed. INIM undertakes to ensure that if the data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate safety measures will be taken to protect personal data in such countries/territories.

6. HOW IS YOUR DATA PROCESSED AND FOR HOW LONG?

Data processing:

  1. is carried out by means of the operations or set of operations amongst which the collection, registration and organization, processing, including modification, comparison/interconnection, use, consultation, conservation, cancellation/destruction, security/protection, integrity and safeguarding;
  2. takes place using manual, computerized and telematic tools with logic strictly related to the purposes referred to previously in paragraphs 2.1 and 2.2 above and, however, in such a way as to guarantee the security and confidentiality of the data.

Your personal data will be stored by INIM only for the time strictly necessary to achieve the purposes for which collected and processed, unless subject to requirements for further conservation in the face of specific provisions of the Law.

The Personal Data processed for the creation of the personal account and for the use of the services dedicated to those with a personal account, will be stored and processed until your personal account is closed.

In relation to system logs, these are treated by INIM as follows:

  • system logs relating to user activities, collected for assistance and maintenance purposes as well as to improve the services offered, are kept by INIM for 12 months from their collection;
  • system logs, collected for statistical purposes, are deleted or anonymised by INIM within 12 months of their collection;
  • system logs, relating to the activities of users in the Cloud, are kept by INIM for 12 months from their collection except for the need to keep them in compliance with laws or regulations relating to the specific services used;
  • system logs, relating to the activities of users who make use the MARILYN and MARILYN MORE voice assistants are kept by INIM for 12 months from their collection for the purpose of assistance and maintenance as well as to improve the services offered;
  • system logs, relating to communication activities addressed to users for the management of the services offered are kept by INIM for 12 months from their collection except for the need to keep them in the legitimate interest of the data controller for legal protection purposes or on the basis of compliance with current regulatory requirements.

We inform you that any requests for extension of storage times, made for justified reasons, should be addressed to the contact details in point 10 of this informative notice.

The data processed for the purposes of marketing and profiling (always, of course, provided that your express consent has been given), will be stored in accordance with the applicable legislation and in any case until the revocation of your consent to the processing of your personal data.

The data processed following your eventual purchase of products, will be used exclusively for the sending of e-mails in accordance with the provisions of art. 130, paragraph 4, of the Data Protection Act.

In all cases, the User will have the right to revoke consent to the processing of personal data for marketing and profiling purposes at any time: in each commercial communication there is a section that will allow the User to easily revoke their given consent.

At the time of the revocation of consent, even if expressed before the expiry of the retention period of data collected for the aforementioned purposes, the same will be automatically deleted or permanently anonymised and our Company may ask the User to renew consent to its processing.

The data transmitted to any service providers will be processed by them for the time strictly necessary for the execution of the tasks entrusted to them.

In regard to data backup management, it is to be noted that:

  • the data is backed up on the Cloud;
  • backup is activated automatically at login;
  • the user can deactivate data backup before configuring their security system;
  • the user can disable data backup after configuring their security system via the appropriate option in the APP: ‘Settings’ > ‘Data backup on Cloud’ and deselect ‘Backup active;
  • once the backup is disabled, the user can decide whether or not to cancel backup via the Cloud.

Specific security measures will be observed at all times to prevent data loss, illicit or incorrect use and unauthorized access.

7. WHAT ARE YOUR RIGHTS?

The privacy legislation (articles 15-22 of the Regulation) guarantees you the right at all times to access data that concerns you, as well as to correct and/or integrate such data, if incorrect or incomplete, the cancellation or the limitation of processing, if the conditions are met, to oppose processing for reasons related to your particular situation, to the portability of the data you provided, where processed automatically for the services you requested, within the limits of the provisions of the Regulation (art. 20).

8. DOES INIM PROCESS DATA RELATING TO MINORS?

As a general rule, we do not intentionally collect personal data regarding minors. If it is discovered that inadvertently Personal Data from such individuals has been collected, INIM reserves the right to act in such a way as to eliminate the said data as soon as possible, except where the applicable law requires us to conserve it.

9. OPTIONALITY OF DATA SUPPLY

Apart from what is specified for the registration data necessary for the creation of your account and the management of the requested services, you are free to provide the personal data contained in the request forms or otherwise indicated in contacts to request, for example, the sending of material information or other communications. Failure to provide such data may make it impossible to obtain what has been requested. For completeness, it should be remembered that in some cases (not subject to the ordinary management of this Website) the Authorities may request information for the purpose of checking the processing of personal data. In such cases, a reply is mandatory under penalty of an administrative sanction.

In particular, it should be noted that, if you decide not to give consent to the processing of your personal data for marketing purposes, INIM will not be able to involve you in its promotional initiatives, including periodic updating via the newsletter service.

If you decide not to give consent to the processing of your personal data for profiling purposes, this would have no impact on your participation in the Inim promotional communications plan, but would simply make it impossible for INIM to send you personalized promotional communications.

10. EXERCISE OF THE RIGHTS OF THE INTERESTED PARTY

The interested party can at any time exercise towards the Data Holder the rights provided for in articles 15 to 22 of the Regulation, by contacting ‘INIM ELECTRONICS S.R.L.’ Sole Proprietor Company at their registered office in Monteprandone (AP), District of Centobuchi, in Via dei Lavoratori n. 10. Tax Code and VAT no. 01855460448, e-mail: privacy@inim.it.

11. UPDATING OF THIS POLICY

This Privacy Policy regulates the processing of your Personal Data released when registering on the INIM CLOUD SERVICES portal and may be amended or simply updated, in whole or in part, also in consideration of changes in the laws or regulations governing the protection of Personal Data. Any changes and updates to this Privacy Policy will be made known to Users as soon as they are adopted and will become binding in the moment they are published on the Website. INIM, therefore, invites Users to access this page regularly and check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date when it was last updated.

Last updated: 13th June 2024