Notice for visitors to the websites inim.biz, inimdns.biz, inimcloud.com
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 and www.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” App.1. WHO IS THE DATA HOLDER?
The Data Holder is “INIM Electronics S.R.L.” Sole Proprietor Company with registered office in Monteprandone (AP), Locality 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 on the basis of your consent for the creation and management of your personal account in INIM CLOUD.2.1. Purpose of personal data processing
Your personal data will be processed by INIM for the purpose of creating and managing your personal account and, subject to your specific and explicit consent, for:
- 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;
- 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 3.3 of this Privacy Policy;
- 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;
- 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;
- 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 3.4 of this Privacy Policy.
2.2. Categories of subjects to whom your Personal Data may be communicated
To achieve the purposes described in paragraph 2.1 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 Data 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 paragraph 2.1.
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 b) 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 “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 b) 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 b) 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 Data processing specifications for the categories of interested parties “Installer”, “Private” and “Designer”
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 “Admin” operates as an independent Data Holder and it is their exclusive task to inform the “Auxiliary installer” (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.
3.4 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 2.2, 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.
3.5 Specifications of data treatment for users of the voice assistant service named “MARILYN MORE”
In the event you wish to use, following your consent, the voice assistant service named “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.