Privacy Policy Skill Inim Smarthome

This Privacy Policy is provided for Users of the Inim Smarthome Skills application for Amazon Alexa, accessible through the Alexa application and any related devices that make use of it, project name "Inim-smarthome" (hereinafter “Inim-smarthome”), property of Inim Electronics Srl., Sole Proprietor Company (hereinafter “Inim”). Pursuant to art. 13 and 14 of EU Regulation 2016/679 (hereinafter “Regulation” or “GDPR”), we wish to inform you that, by using the aforementioned application, Inim, as Data Controller (hereinafter “Controller”) 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.

1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)

The 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.
INIM has appointed a data protection officer (DPO) who can be contacted at the address: dpo@inim.it.

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

Your data will be processed for contractual obligations and subject to your specific and explicit consent. In the processing of data that can, directly or indirectly, identify the User, Inim respects the principle of Strict Necessity. Therefore, the processing of User data is excluded when the purposes pursued in individual cases can be achieved through the use of anonymous data (such as, for example, in market research aimed at improving services) or through other methods that allow identification of the User solely in case of necessity or at the request of the authorities and Police forces.
There are bases for processing for which the law provides for the exclusion of consent. For example, the processing of personal data may take place without obtaining the consent of the User when this is necessary to fulfill a legal obligation or when it is necessary to execute the obligations assumed contractually towards the User.

3. WHAT DATA DO WE PROCESS?

As Controller, we inform you that we process the following types of data:

• data collected automatically, such as server logs and the data transmitted by the Amazon Alexa API during the interaction of the User with Amazon Alexa;
• data obtained from the User, directly or through the Authorization API
• persistent identification data (such as the User ID of the User's My Inim Cloud profile).

The computer systems and software procedures in charge of operating Inim-smarthome, during their normal operation, obtain, from Amazon servers that send the commands collected by the Alexa application/devices in the context of Inim-smarthome, some personal data whose transmission is necessary for the operation of Inim-smarthome. Such data are not collected to be associated with identified interested parties, but which, due to its 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 data that the Amazon systems provide to Inim servers for the operation of Inim-smarthome. These data are logged for a limited period of time, for the sole purpose of having diagnostic information for the resolution of any problems relating to the operation of Inim-smarthome, and to keep track of the activities carried out via voice commands for purposes provided for by the law (for example, in the case of a request made by the police or the judiciary or other competent bodies).

4. HOW DO WE USE THE DATA IN OUR POSSESSION?

User data are used to provide the services offered by Inim-smarthome for the management of the alarm systems in their possession, and include the possibility of their identification and of recognition for subsequent uses of the app.
We do not use any data collected for the purpose of customer profiling, for the offer of products and services or for other commercial purposes. Only following the explicit consent expressed by the interested party, the data may be used for further purposes including those of marketing.

5. WILL YOUR DATA BE SHARED WITH THIRD PARTIES?

The personal data we process are, as a rule, collected directly from the interested party or, occasionally, collected from third parties; are processed in compliance with the GDPR and the Provisions of the Guarantor for the Protection of Personal Data; may be processed by third parties appointed as “Managers” for:

1. the fulfillment of the obligations established by laws, regulations and EU legislation, or provisions issued by Authorities legitimated by the law and by Supervisory and Control Bodies. The provision of personal data necessary for these purposes is mandatory and the relative processing does not require the consent of the interested party;
2. purposes strictly relating to the activation and operation of Inim-smarthome.

However, we inform you that the computer systems and software procedures of third parties responsible for the operation of Inim-smarthome (Amazon Alexa platform or other involved systems run by Amazon) may collect, in providing their services, some data, however, referable to the User whose transmission is implicit in the use of the voice assistant features 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 in advance the Privacy Policies published on the aforementioned platform.

6. WHERE DO WE PROCESS YOUR DATA?

The processing relating to data connected to Inim-smarthome, including those received from Amazon servers through the use of Amazon Alexa and other Amazon services, takes place at the aforementioned Inim headquarters and is handled solely by the technical personnel responsible for or in charge of processing, or by any appointees or personnel in charge of occasional maintenance operations.

7. HOW ARE YOUR DATA PROCESSED AND FOR HOW LONG?

Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected.
Your personal data will be kept by the Company for the period strictly necessary to guarantee the correct provision of services – except in cases when storage is required for a longer period in order to comply with applicable legislation and accounting.

8. WHAT ARE YOUR RIGHTS?

In your capacity as the Data Subject, you are entitled to exercise the rights granted in paragraph “9. EXERCISE OF THE DATA SUBJECT'S RIGHTS”, the rights referred to in art. 7 of the Privacy Code and art. 15 of the Regulation and in particular:

1. obtain confirmation of the existence or not of personal data concerning you, even if not yet registered and their communication in an intelligible form;
2. obtain indication: a) of the origin of such personal data; b) the purposes and methods of processing; c) of the logic applied in case of processing carried out with the aid of electronic tools; d) the identity of the Controller, manager and the representative appointed pursuant to art. 5, paragraph 2 of the Privacy Code and art. 3, paragraph 1, GDPR; e) the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as appointed representative in the State, as appointees or agents;
3. obtain: a) updating, rectification or, when interested, integration of data; b) the cancellation, transformation into anonymous form or blocking of data processed in violation of the law, including those that do not need to be kept for the purposes for which the data were collected or subsequently processed; c) the attestation that the operations referred to in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which such fulfillment proves impossible or involves the use of means that are manifestly disproportionate to the protected right;
4. object, in whole or in part, for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection.

Where applicable, you may also exercise the rights referred to in Articles 16 to 21 of the GDPR (Right of rectification, right to be forgotten, right to limitation of processing, right to data portability, right of opposition), as well as the right of complaint to the Guarantor Authority.
Removing the connection of your Amazon account from Inim-smarthome, through the appropriate command in the Alexa application, will immediately stop the collection of any further information by Inim through this application.

9. EXERCISE OF THE DATA SUBJECT'S RIGHTS

The interested party may at any time exercise the rights granted in Art. 7 of the Code and by Art. 15 to 22 of the Regulations, by contacting Inim Electronics S.R.L. Sole Proprietor Company with registered office in Via dei Lavoratori n. 10, Monteprandone 63076 (AP). Tax Code and VAT no. 01855460448, e-mail: privacy@inim.it.

10. UPDATING OF THIS POLICY

This Privacy Policy governs the processing of Data released by the User when using Inim-smarthome and may be modified or simply updated, in whole or in part, also in consideration of changes in the laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy will be made known to Users as soon as they are adopted and will be binding as soon as 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: 30 January 2025