Pursuant to Article 13 of EU Regulation 2016/679, you are informed that the Facility (company, hotel, hostel, B&B, restaurant, etc.) where you are currently present or where you will be in the future as a guest, or for which you are the Reference Person (i.e., the manager of a single unit), has installed an access system using Smart Locks. These are intelligent locks that, through a cloud platform, allow you to open access points to the Facility using Credentials generated by this application.
The Facility will therefore process personal data consisting, in particular, of the Credentials and the individual access events, with reference to the areas for which the Credentials are enabled, as well as the date and time of each access.
The Controller of the data collected and used is the Facility. The details and contact information of the data Controller will be communicated to you by the Facility itself; thus, this notice aims solely to inform you of the fundamental characteristics of how your data is processed.
Pursuant to Article 13 of EU Regulation 2016/679, the Reference Person of the private unit where you are currently present or where you will be in the future has been informed that an access system using Smart Locks has been installed. This allows you to open the access points of the private unit using Credentials generated by this application.
The Reference Person will process your personal data consisting, in particular, of the Credentials and the individual access events, with reference to the private unit for which the Credentials are enabled, as well as the date and time of each access.
The Controller of the data collected and used is the Reference Person. Their name and contact details will be communicated to you by the Reference Person; hence, this notice is intended solely to inform you of the main characteristics of how your data is processed.
If you are the Reference Person of a private unit or a guest of such person, the data related only to access to common areas will be processed by the Facility as the Data Controller and by Iseo (along with its sub-processors, including in particular Sofia) as the Data Processor.
If you are a guest of a Reference Person, the data related to your access to that private unit will be processed by the Reference Person as the Data Controller and by Iseo (along with its sub-processors, including in particular Sofia) as the Data Processor. In this case, the central Facility will not have access to these data, which remain under the responsibility of the private owner.
The personal data identified above will be processed, following installation and use of this application, in an automated form solely for the purposes strictly connected to fulfilling the contract and, therefore, for the creation and management of the Credentials needed to access the areas.
Such data processing will adhere to the principles of lawfulness, purpose limitation, transparency, accuracy, data minimization, and accountability, respecting your rights and fundamental freedoms and your dignity, with particular reference to confidentiality and personal identity protection. Data will not be used for profiling your habits or behaviors.
The data will be processed, without requiring your consent, for performing the contract you entered into or to fulfill requested services, thus enabling creation and management of the Credentials necessary for accessing areas within the Facility or private unit.
Providing the data requested during installation and use of this application, as well as those collected when creating and using the Credentials, is not mandatory; however, refusing to provide them may prevent the Facility from granting you access to the areas.
You may also prevent data collection by refusing to install the application or by uninstalling it later via your device’s settings. In such cases, the Data Controller cannot be held responsible if you cannot access the areas.
Except as required for providing the requested services, data processed within the application context and for its specific purposes will neither be disseminated nor disclosed but will be made available to the designated Data Processor for managing access services.
Your data will also be accessible to employees and collaborators of the Data Controller and the Data Processor who are specifically authorized, instructed, and trained on data protection obligations.
You have the right to access your personal data and, where applicable, to request correction, deletion, or portability of your data to another Controller, as well as to request restriction or object to its processing.
If you believe there has been a breach of data protection laws, you have the right to lodge a complaint with the supervisory authority of the EU member state where you reside, work, or where the breach occurred. In Italy, this authority is the Data Protection Authority. For more information, visit www.garanteprivacy.it.