Privacy | Sclak

This Privacy Policy (“ Informativa “) describes the treatment performed by UDINO S.r.l. (hereinafter “Company“ or “SCLAK“) of personal data (“Data“) provided by Users of the mobile application named “SCLAK“ (Hereinafter, “Application“), available on the iTunes Store and Google Play, as described in the license agreement for use of the Application. Terms of Use
Personal data provided by Users will be processed in accordance with the provisions of to which Legislative Decree 30 June 2003, n. 196 (“Privacy Code“) and Regulation (EU) 2016/679 (hereafter “GDPR“).
UDINO S.r.l. intends to guarantee the privacy and security of the personal data of each visitor in accordance with the provisions of this Notice and, in particular, in compliance with the principles of necessity, transparency, lawfulness, correctness and proportionality of the processing of personal data.

1. GENERAL INFORMATIONS

This document explains the way in which the company UDINO S.R.L., with registered office in via Amedeo Avogadro, 24 10121 Torino, VAT no. 11989000010, (hereafter referred to as the 'Company'), as data controller, uses the personal data provided by users ('Users' or, in the individual, 'User') who interact with the site web www.sclak.com ('Site').

2. TYPE OF DATA PROCESSED

Navigation data. The computer systems used to operate the Site acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols (for example, IP addresses of the devices used by the Users, the timetable of the request and other parameters related to the user's operating system). This information is not collected to be associated with identified subjects, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check its correct functioning and are deleted immediately after processing. These data could be used to ascertain responsibility in case of any computer crimes against the Company or its assignees.

Data provided voluntarily by users. The optional and voluntary sending of requests or messages through the Website entails the subsequent acquisition of the sender's address, necessary in order to respond to Users' requests, as well as any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the Site prepared for particular services on request.

1. Identifying information (name and surname, e-mail address and telephone number);
2. User codes and passwords;
3. Geolocation data;

3. OPTIONALITY OF DATA SUPPLY

Except as specified for navigation data, the User is free to provide personal data contained in the request forms available on the Site. Failure to provide such data may make it impossible to obtain what has been requested.

3.1 OPTIONALITY OF DATA SUPPLY

The application also provides for the possibility of access to passages or entrances subject to payment.
In this case, the bank transaction will be managed exclusively by the operator of the aforementioned passages or entrances, and the data related to the credit card used by the User for the payment of the entry price to the gate or entrance will be handled exclusively by the gate operator or entrance.
The Company will collect, in addition to the identification data of the Users, also the data related to the registration of entry and exit times from the gates and / inputs and billing information. The Company will decide which data, in any case limited to those strictly related to the provision of the service, provide the operator with the driveway and / or pedestrian entrance.

The Company will not process sensitive data, understood as personal data capable of revealing the User's racial and ethnic origin, its religious, philosophical or other beliefs, political opinions, membership of parties, trade unions, associations or organizations of a religious, philosophical, political or trade union nature, as well as personal data capable of revealing the User's state of health and sexual life.

The User is invited not to transmit sensitive data to the Company.

4. COOKIES

A cookie is a small text file that is sent to the browser and saved on the user's terminal when the latter visits a website. The Website uses the following technical cookies:

The Site doesn't use persistent cookies of any kind, or systems for tracking Users.

Almost all Internet browsers allow you to check which cookies are present on your hard drive, block all cookies or receive a warning each time a cookie is installed. In some cases, however, failure to install a cookie may make it impossible to use certain parts of the Website.

The technology used by the Company is based on high security standards, such as, for example:

• 128-bit AES cryptographic system, through which each message is encrypted,
• the 128-bit private key is never transmitted in plaintext;
  • communication between client and server is protected;
• data transmission and connection between "SCLAK" hardware device and application is via a Bluetooth interface 4.0 Low Energy;
  • the Bluetooth connection is without pairing;
• the encrypted transmission phase is preceded by a phase of authentication where it's verified that both the "SCLAK" device and the smartphone are able to encrypt a secret code in the same way, both having the same private key;
• all the messages are coded in Xor with the codes CODx generated from time to time for each individual message sent.

5. PROCESSING METHODS

Personal data are processed with automated tools for the time strictly necessary to achieve the purposes for which they were collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access.

• fulfillment of contractual obligations;
• management of services and functionality of the Application.

6. USER RIGHTS

In accordance with article 7 of the Privacy Code, Users have the right at any time to obtain confirmation of the existence or not of data referring to them and to know the content and origin, verify its accuracy or request the integration or updating, or correction. According to the same article, you have the right to request cancellation, transformation into anonymous form or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, to their treatment.

7. CONTACTS

For any information or request concerning the protection of personal data of Users, including the exercise of the rights referred to in clause 6 above, please contact the following email address: moc.kalcs@ofni.

• the access (Article 15 GDPR): may request confirmation of the existence or not of personal data concerning them and their communication in an intelligible form, within the limits of reasonableness , in addition to more clarifications about the information referred to in this Notice. They can ask to: know the origin of the data, the purposes and the modalities of the treatment; an indication of the identification details of the data controller, the persons responsible and the subjects or the categories of subjects to whom the personal data can be communicated.
• The adjustment (Article 16 GDPR) : they can ask to verify the accuracy of the data, correct them if inaccurate, integrate them if incomplete or update them.
• The cancellation (so-called oblivion - article 17 GDPR): may request that their data acquired or processed by SCLAK be deleted - (I) if they are no longer necessary for the purposes for which they were provided; (II) in case of revocation of consent or opposition to treatment; (III) in case of unlawful processing; (IV) if there is a legal obligation to cancel.
• The limitation (Article 18 GDPR): when one of the conditions mentioned in art. 18 of the GDPR. In this case, their data will not be processed, except for storage, without their consent, except for what is specified in the same article in paragraph 2.
• The portability (Article 20 of the GDPR): may request to receive their data, or send them to another owner indicated by them, in a structured format, commonly used and readable by automatic device.
• the< b> Opposition (Article 21 of the GDPR): may for legitimate reasons oppose the processing of their data at any time, unless SCLAK has reason to proceed with the processing (eg: for the defense in office) judiciary).
• The revocation : may, pursuant to art. 7, par. 3, at any time revoke the consent, without prejudice to the lawfulness of the treatment based on consent previously granted.

Finally, each interested party has the right to lodge a complaint with the Supervisory Authority, which in Italy is the Guarantor for the Protection of Personal Data (www.garanteprivacy.it).

8. CHANGES TO THE INFORMATION

The eventual entry into force of new sector regulations, as well as the constant examination and updating of the services to the User, could entail the need to modify the methods and terms described in this Notice. It's therefore possible that this document undergoes changes over time. We invite you, therefore, to periodically consult this page.
We will post any changes to this Statement on this page, notifying Users if the changes were relevant.