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58
Appendix A
–
Data management disclaimer
Disclaimer of Adaptica S.r.l. pursuant to Article 13 of Legislative Decree No. 196 of 30 June 2003
(the
“
Privacy Code
”
)
We hereby inform that the utilization of the 2WIN instrument will give rise to the processing of some
data relating to its status of operation (the
“
Telemetry Data
”
), which will be acquired by the IT
systems and software procedures for the functioning of this instrument whenever it connects to a
wireless network. The information in question is not collected in order to be associated with
specifically identified parties, but due to its nature it could
–
through processing operations and
associations with data in the possession of third parties
–
make it possible to identify the users
(hereafter the
“
Parties Concerned
”
). The Telemetry Data include the software version, the firmware
version, the device
’
s serial number and the number of observations carried out; moreover, the
instrument will transmit the list of the Applications operating on the same. The sole purposes of the
Telemetry Data processing are to enable Adaptica S.r.l. to constantly monitor the efficiency of the
proposed service based on the utilization of the 2WIN instrument and, in case of malfunctioning of
the same, to transmit from the remote server the technical data which are necessary to the
reactivation of the relevant parameters. Furthermore, Adaptica S.r.l. may, once a temporary session
of remote control has been activated by the user and the instrument has been connected to a
wireless network, connect to the 2WIN instrument and obtain parameters of a purely technical
nature relating to the handling and the state of health of mechanical, electronic and firmware parts
(the
“
Remote Control Data
”
). In this regard, Adaptica S.r.l. informs that, by way of the remote control
connection, also the data saved on the SD card might theoretically be downloaded from the system,
should such card be left inserted in the instrument at the moment of the activation of the temporary
session; despite this additional information is of no interest for Adaptica S.r.l. and will neither be
acquired nor treated by it, it is however advisable to remove the SD card or delete any sensitive data
before such activation, in order to avoid the transfer of the same data.
Adaptica S.r.l. also informs that the Telemetry Data and the Remote Control Data do not contain
sensitive information relating to users, will be treated only and exclusively in the framework of
normal business, in accordance with purposes linked to the achievement of the corporate purpose
of the said Adaptica S.r.l., and will be kept by such company. The Telemetry Data will be used only in
order to acquire anonymous information on the use of the instrument and to check that it is
functioning correctly. The Remote Control Data will be used in order to provide remote assistance to
the 2WIN and enable Adaptica S.r.l. to check its functioning and/or carry out particular procedures.
The processing of the Telemetry Data and the Remote Control Data will take place mainly through
electronic (or in any case automated), IT and telematic instruments, and will be memorized on IT
devices, following criteria strictly correlated to the aforementioned purposes, in compliance with the
minimum security provisions contemplated by Art. 34 of the Privacy Code and by Schedule B thereof
and, in any event, in such a way as to ensure the security and confidentiality of such Telemetry Data
and Remote Control Data.
The lack of consent by the Party Concerned to the processing of the Telemetry Data and the Remote
Control Data will make the use of the 2WIN instrument impossible to the same. The autonomous
owner (
“
titolare autonomo
”
) of the Telemetry Data and the Remote Control Data is Adaptica S.r.l., a
company with its registered office in Padua, Via San Marco 9/H.
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