Notice on the processing of personal data in accordance with Article 13 of the EU Regulation 2016/679 ("GDPR")

This Notice describes which of your personal data are collected by Alientech S.r.l. (referred to in this notice as “we” or “Alientech srl”), for what purposes and how they are processed. Below you will also find the information you need to exercise your rights as provided by the GDPR.

We ask you to share some of your personal data with us to enable us to serve you better and ensure your smooth interaction with us.

Below you will find in detail the information we are required to provide, in accordance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and the Council, dated April 27, 2016 concerning the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter simply referred to as GDPR).

1. To whom this Notice applies

This Notice applies to all customers and users of the “POWERGATE” App for mobile devices (smartphones and tablets), reserved for the management of the Powergate tool.

2. Data controller

The Data Controller of your data is Alientech S.r.l. a socio unico – VAT ID IT02007510023, with registered office at Via dei Cordari 1 – 13039 Trino (VC) – Italy.

3. What data we collect - Types of data processed

We collect your personal data when you create an ALIEN_id account, add or update information to it, use our products and services or, more generally, interact with us.

Below we list the types of personal information we process.

3.1 When you create an ALIEN_id account

Upon registering an ALIEN_id account, you provide us with:

  • Data that identify you, such as your e-mail address, first and last name, country, and password, needed for creating and validating the account.
  • Later, you can choose whether to add other details to your account, such as your phone number, your full address and a picture or image of your profile.

3.2 When you use the POWERGATE App

When you use the POWERGATE App, we may automatically collect:

  • Connection logs to our servers, including the date and time of access and your IP address.
  • Data about our App, such as your language settings and the software version you are using.
  • Information sent by the mobile device on which our App is installed, such as your device’s screen size and battery level.
  • Signals from your mobile device, including Bluetooth signals and approximate location data from your mobile device. Please remember that most mobile devices allow you to manage or disable location services for all applications through the settings options.
  • Information about the Wi-Fi network or Hotspot you connect to using the Powergate tool, including the Wi-Fi network name, your mobile device’s IP address, and the IP address of the Internet service provider you use for the connection.

You can stop the collection of information by uninstalling the App from your mobile device. You can also delete your ALIEN_id account, but in that case, you will need to create a new account to use the Powergate tool.

3.3 When you use your Powergate tool

When you use your Powergate tool, we may automatically collect:

  • Data related to your tool, such as the tool’s serial number and firmware version.
  • Data about the vehicle to which you have linked your tool, such as make, model, version, and VIN (Vehicle Identification Number).
  • Data generated through your actions when you use the tool, such as the functions you use, the date, time, frequency, and duration of tool usage sessions, the operations performed by the tool, including managed files, and information regarding its operational mode.

4. Purposes of data processing

We process your personal data for various purposes, primarily to enable you to use your Powergate tool and provide and improve the features of the POWERGATE App we offer to our customers. These purposes include:

  • Product usage and service provision. We use your personal data to give you access to the App, the tool and their functionality and provide you with services to operate them.
  • Providing support. We use your personal data to assist you in the event of issues with our App or provide technical support for your tool through our partners.
  • Providing and improving our services and resolving issues. We use your personal data, generated during your use of our App and tool, to process information, including statistical data, necessary to introduce new features, analyze performance, correct errors, and enhance the usage and efficiency of our App, tool, and services.
  • Communications. We use your e-mail to send you important information about the status of your account or our services.
  • Marketing activities. We use your e-mail to keep you up-to-date on new features or services that are complementary to your tool or promote products and/or services similar to those you already have, unless you exercise your right to opt-out.
  • Photos. We use photos or images, with your consent, only for the purpose of providing you with this profile feature and not to identify you. The photo or image associated with your profile will be saved only on the mobile device from which you uploaded it, it will not be saved on our servers. In case you access your account from another device the photo will not be available in your profile and you will have to re-upload it.
  • Ensuring system security and compliance verification. We use your personal data to detect illicit behavior, protect and enforce our rights, prevent or prosecute unlawful acts, violations of our or third parties’ intellectual or industrial property rights, cybercrimes or offenses committed through computer networks, in order to protect the security of our customers, our App, our tools, Alientech srl and third parties.

5. Legal bases for data processing

The legal bases we use depend on the purpose for which we process your personal data. Specifically, we use the following legal bases:

  • Article 6 (1)(a) GDPR 679/16 – Consent. We require your consent to process your personal data for the specific purposes we inform you about. You may withdraw your consent at any time, in which case we will stop processing your data for that purpose.
  • Article 6 (1)(b) GDPR 679/16 – Performance of a contract. When we provide you with our services, communicate with you about them, or fulfill our obligations to you under our terms of use.
  • Article 6 (1)(f) GDPR 679/16 – Legitimate interest. It is in our interest to ensure the quality and safety of our products and services, protect our business assets, protect the safety of our customers, our own or third parties, improve the quality and security of our products and services, and offer information about complementary services that can be activated on the tool.

6. Data collection and processing methods

Data will be collected directly from you through the use of the App and the tool, without the use of third-party tools.

Data will be processed by our employees and collaborators, acting as authorized data processors, through our information systems. Each processing operation will take place in compliance with the provisions of Articles 6 and 32 of the GDPR, through the application of appropriate security measures designed to ensure the security and confidentiality of the data.

7. Who we share your data with

Your data will be shared with our service providers, solely to enable them to provide the requested service, with your designated Powergate Manager so that they can manage the files necessary for the use of the tool and provide you with any technical support you may need, or with entities to whom we have legal obligations requiring disclosure. In some cases, your data may also be processed outside the European Economic Area.

More specifically, we will share your data with:

  • Service providers. We use third-party services (cloud services, authentication partners), who will only have access to the personal data necessary to perform their functions and may only use them for the purpose of executing these services on our behalf or to comply with legal requirements.
  • Powergate Managers, residing within or outside the European Economic Area. We share personal data related your account and tool, and they may use them only to provide you with the files required for the tool’s operation and technical support.
  • Judicial or administrative authorities. Where we believe it necessary to comply with a court or authority’s order or fulfill legal obligations or protect our interests or those of third parties, we may disclose your data to a Judicial Authority or an Administrative Authority of the State or the European Union.

Powergate Managers act as Data Processors and in accordance with the provisions regarding the transfer of data to third countries, where such data transfer actually occurs.

Alientech srl does not and will never sell your personal data.

8. Data transfer

Your personal data are stored on servers operated by third party companies, duly appointed as Data Processors.

Your personal data may be transferred outside the European Economic Area to provide you with our services, in accordance with Article 49(1)(b) of the GDPR.

9. Data retention

We keep your personal data according on the type of data and the purpose for which they were collected, as long as it is necessary to provide our services, fulfill our legal obligations, or protect our interests or those of third parties.

10. Mandatory data disclosure

Some information is necessary for the operation of the App and the tool. Other data are optional, but without them, you may not have access to all the tool’s functionalities.

  • If you do not provide us with your e-mail address, first and last name, and country, or if you object to the processing of these data, we will not be able to create or manage the account that allows you to use the App and the tool.
  • If you object to the processing of data about your tool and the associated vehicle, we will not be able to provide you with the services for the use of the tool.
  • If you object to the processing of data generated when you use your tool, we will not be able to provide you with the services for the use of the tool.
  • If you object to the processing of your IP address or data related to our app, we may not be able to provide you with assistance.
  • If you do not enable Bluetooth signals, location data, and a Wi-Fi network or Hotspot on your mobile device, the App, your tool, and our servers may not be able to communicate and, therefore, we will not be able to provide you with the services for the use of the App and the tool.
  • If you object to the transfer of your data outside the European Economic Area, your Powergate Manager will not be able to manage the files necessary to operate the tool or provide you with technical support.

11. Automated decision-making process

Your personal data will not be subject to automated decision-making and/or profiling.

12. Your rights

Pursuant to Articles 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR 679/16, in addition to managing your data processing preferences as described in the preceding paragraphs, you can contact us to:

  • obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet recorded, and their communication in an understandable form.
  • request access to your personal data, their update, correction, or integration.
  • request the deletion, transformation into anonymous form, and limitation of the processing of your data.
  • object, for legitimate reasons, to the processing of your personal data concerning, even if pertinent to the purpose for which they were collected.
  • request portability or a copy of your data.
  • withdraw consent, at any time, for the processing of your data for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication (this will not affect the lawfulness of the processing based on the consent given before withdrawal).
  • request the identification details of the data controller, data processors and the designated representative, as well as information about the subjects or categories of subjects authorized to process your data, the external data processors and the persons in charge of processing.

When you exercise your right of access, you also have the right to know:

  • whether your data are being processed.
  • the purpose and methods of the processing.
  • the categories of data being processed.
  • the data retention period (or the criteria for determining the retention period.)
  • whether there is any automated processing using electronic tools (e.g., profiling) and what the logic of such processing is.
  • the origin of the data (if not initially collected by us.)

You also have the right to file a complaint with the Data Protection Authority, using the appropriate forms available at www.garanteprivacy.it.

13. How to exercise your rights

You can exercise your rights at any time by sending a request to Alientech Srl through the following channels:

  1. Regular mail: Via dei Cordari 1 – 13039 Trino (VC) – Italy
  2. E-mail: legal@alientech.to
  3. PEC (Certified e-mail): alientechsrl@legalmail.it

When contacting us, be sure to include your name and contact information (e-mail, mailing address and/or number phone number, etc.) to make sure your request can be addressed properly.