Privacy statements



Dear User,
in this document we provide the main privacy statements about what we do with and how we manage your data when you use our app "CleisHFinder" (herein the "App") as well as the CleisHFinder portal where we publish the data gathered through the App in a management console, pursuant  to Legislative Decree no. 196/2003 and subsequent amendments ("Privacy Code") as well as Regulation EU no. 2016/679 ("GDPR").



Owner of the data treatment

The owner of the treatment is cleis Tech S.r.l. (herein the "Owner" or the "Company"), with registered headquarter in – Via Paolo Emilio Bensa, 2 – 16124 Genoa – Italy -  e-mail [cleistech@legalmail.it], in the person of its legal representative.


    
Type of processed data

Browsing data, such as IP addresses and other parameters relating to the Mobile device and the operating system you use ("Browsing Data"). During its normal operation, the App acquires some anonymous data whose transmission is implicit in the use of Internet communication protocols. Theese are informations that are collected not yet to be associated with identified interested parties, but due to their nature could allow, togeter to data held by third parties, the identification of some characteristics of the devices in use by users (for instance an Operating System version and revision). This category of data includes the IP addresses of the mobile devices used by users who use the App, the addresses in URI (Uniform Resource Identifier) notation of the resources requested by the App, the time of the request, the method used to submit the request to the server, the size of the message obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's IT environment.
No identification, contact and access data, such as name, surname, username, email address, telephone number (herein "Identification Data" and together with the Navigation Data, the "Data") is collected by the App nor transmitted to any Server by the developer or a third party. Theese are exclusively functional data to anonymously detect road surface anomalies and to collect and transmit their characteristics, time and geographical position during the movement of a vehicle where is placed the user's device (usually a SmartPhone) that runs the App.
Starting from the collected data, the Company is unable to identify the device that generated them.    


    
Purpose and legal basis of the processing of the collected data

The Data will be processed for the achievement of the following purposes:

     - to allow the Owner to provide its services;
     - to allow the Company to create a geographic database containing data on the presence and distribution of road surface anomalies;
     - to view the collected data on digital cartographic systems;
     - to share data with government organizations, public administrations, or private organizations for the purpose of producing statistics, planning road maintenance activities as well as other types of activities aimed at improving the safety of road traffic.
    

    
In particular, the Company will process the Data when one of the following condition happens:

     - when a device start the App;
     - when the App on a device detects the presence of a road surface anomaly;
     - when the App on a device requests the list of road surface anomalies near the current device position;
     - when the user requires the display and geographical distribution of road surface anomalies points through the portal of the cartographic system published by the Company;
     - when statistical processing or reports are produced on the Company's server(s) relating to registered road surface anomailes;
     - when data of registered anomalies are requested by related apps (for example when using apps for on-field inspection and certifications of road surcace anomalies);
     - when government organizations as well as public administrations should request it:
     - when the Company is required by law to process the Data.


     
Place of data processing

The data processing referred to the App and their related services take place at the Company's premises and are only handled by authorized personnel, or by persons in charge of occasional maintenance operations. No data deriving from the services is disclosed to third parties.



Data retention period

The Data being processed for the aforementioned purposes will be kept in compliance with the principles of proportionality and necessity, and in any case until the purposes of the processing have been pursued and for the time necessary to perform the services provided by the Company.
The Data may be kept for a period even exceeding the term indicated in this paragraph in the case of the retention is imposed as well as it is necessary to fulfill an obligation imposed by national or European Union laws, within the terms strictly necessary for the fulfillment of such obligation, in order to fulfill an order of the authority, or still in order to protect the Company's legitimate rights or interests, even in court, within the terms strictly necessary for this purpose.



Processing methods

The Data are processed with automated and non-automated tools, for the purposes for which they was collected. Specific security measures are observed to prevent data loss, illicit or incorrect use and unauthorized access. The collected Data may be used on behalf of the Company, by the administrators in charge of carrying out processing services and for the correct performance of the Company's activities related to the App.



Transfer of your information abroad

The Data collected by the App may be transferred to other countries by us or by our agents for the purpose of fulfilling contractual obligations and the mandatory intra-group and/or franchise communication obligations.



More info

Further information in relation to the processing of data may be requested at any time to the Company using the contact information.
 

 
Changes to this Privacy Policy

The Company reserves the right to make changes to this privacy policy at any time by giving it evidence on this page. Users are therefore invited to consult this page often, referring to the date of the last modification shown at the bottom of the information itself.



Rights of the interested parties and how to exercise them

Since the information system supporting the App does not collect personal data of any kind, there is no need to protect them for the purposes of the GDPR.



Last update date: March, 1 2023