PRIVACY POLICY FOR SANELA APPLICATIONS
1. SCOPE OF APPLICATION
This privacy policy declaration Applies to the use of SANELA mobile Applications ("App") and the services offered through them. Because protecting your privacy when using the App is important to us, we would like to inform you below about what personal data we process when you use the App and how we handle this data.
2. RESPONSIBLE PERSON AND DATA PROTECTION
2.1 The operator of the Application and the person responsible for processing your personal data is Sanela spol. s r.o., Dukelských hrdinů 989, Lanškroun 563 01; ID No.: 25262955
2.2 For data protection issues, you can contact us at the e-mail address privacy@sanela.cz or at our above postal address with the addition "Data Protection Officer".
3. INFORMATION ABOUT THE PROCESSING OF YOUR DATA
Please find below further information about what personal data we collect from you and how we process it:
3.1. INFORMATION COLLECTED DURING DOWNLOADING
When you download an App, certain required information is transferred to the App store of your choice (e.g. Google Play or Apple App Store). This includes in particular your username, email address, your customer account number, the time of download, any payment details and the individual code of your terminal device. This data are processed exclusively by the respective App store and is beyond our control.
3.2 INFORMATION COLLECTED AUTOMATICALLY
When you use the App, we automatically collect certain data that are necessary for the use of the App. This includes: the internal Bluetooth (hereinafter referred to as BT) device ID, the version of the BT device. We store other data such as BT MAC address and passwords to paired BT devices in the internal encrypted database of the App stored on your mobile device.
The data are not automatically transferred to us, but we store them within the mobile device to make the App and related features available to you. This data processing is justified by the fact that the processing is necessary for the provision of the App (Article 6(1)(b) of REGULATION (EU) 2016/679) and we have a legitimate interest in the functionality and error-free operation of the App. For further information regarding legitimate interests pursuant to Article 6(1)(f) of REGULATION (EU) 2016/679, please contact us using the contact details above.
3.3 INFORMATION COLLECTED THROUGH THE USE OF THE APP
We do not collect any personal data as part of the user version of the App. For the service version of the App, registration of the service technician's mobile device is required. During this process, we collect only basic information about the mobile device (manufacturer and model of the mobile device), including the service technician's personal data, which we store in the database of the Processor's ERP system. We use the data for the following purposes:
3.3.1 If you connect the App to your BT device, we collect the internal BT device ID, the serial number of your device. We display the internal parameters of your BT device while you are connected to it. Connecting the App to a Sanela device is voluntary and based on your consent. The legal basis is Article 6(1)(a) of REGULATION (EU) 2016/679. You can cancel the pairing of your Sanela device with the App again at any time, without affecting the lawfulness of the processing carried out on the basis of your consent prior to the cancellation of the pairing.
3.3.2. If you are registered as a service technician and use the App in service mode, we collect your personal data (e.g. surname, first name, email address, address, phone number). We use these data to provide you with our services and to enable us to carry out a user relationship with you. The legal basis is Article 6(1)(a) and (b) of REGULATION (EU) 2016/679.
3.3.3. Sanela service technicians can retrieve anonymised technical data from your Sanela device using the service mode of the App (this Applies to Sanela ID and device, statistical and diagnostic data such as model, product number, date of manufacture, device settings, profile settings, counter states of device components, error codes, error history). We need the technical data to provide you with our services and to improve our service offering through anonymous data analysis. The legal basis is Article 6(1)(b) and (f) of REGULATION (EU) 2016/679). If you would like further information regarding legitimate interests in accordance with Article 6(1)(f) of REGULATION (EU) 2016/679, please contact us using the contact details above.
4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES
Your personal data will only be transferred without your explicit prior consent in the following cases:
4.1. FOR LEGAL REASONS
If necessary to clarify the illegal use of our services or for legal prosecution, personal data will be transferred to law enforcement authorities and, if necessary, to injured third parties. However, this only occurs if there are concrete indications of illegal or abusive behaviour. The transfer may also occur if it is to enforce terms of use or other agreements. We are also legally obliged to provide information to certain public authorities on request. These include law enforcement authorities, administrative offence prosecution authorities or tax authorities.
This data are transferred on the basis of our legitimate interest in combating abuse, prosecuting criminal offences and securing, applying and enforcing claims, Article 6(1)(f) of REGULATION (EU) 2016/679. If you require further information regarding the interest weighing to be carried out in accordance with Article 6(1)(f) of REGULATION (EU) 2016/679, please contact us using the contact options above.
4.2 CONTRACTUAL PARTNERS
We rely on contractually affiliated third party companies and external service providers ("Processors") to provide services. In such cases, personal data will be transferred to these Processors to enable further processing. These partners are carefully selected and regularly audited by us. Processors may only use the data for the purposes specified by us and are also contractually obliged to treat your data only in accordance with this data protection statement and Applicable data protection laws.
In particular, we use the following processors:
1. HJ-Soft s.r.o. for the purpose of technical support of Sanela Control Applications (all platforms)
2. Oknenet s.r.o. for the purpose of providing central IT services for other companies of the Group (Sanela spol. s r.o., HJ-Soft s.r.o.)
3. Logistics service providers to send you products, marketing materials or other items you have ordered from us
4. Payment service provider to process any payments from you to us or vice versa
7. Service providers for service work or after-sales services
8. Service provider for sending newsletters or conducting customer surveys
The transfer of data to processors is based on Article 28(1) of REGULATION (EU) 2016/679 or, where Applicable, on our legitimate interest in the economic and technical advantages associated with the use of specialist processors and the fact that your rights and interests in protecting your personal data are not overridden, Article 6(1)(f) of REGULATION (EU) 2016/679. If you require further information regarding the weighing of interests to be carried out in accordance with Article 6(1)(f) of REGULATION (EU) 2016/679, please contact us using the contact options above.
5. YOUR RIGHTS
As a data subject, you have the rights described below in relation to the processing of your personal data. To exercise your rights, please send us a written request using the contact options above or to the following email address: privacy@sanela.cz
5.1. THE RIGHT TO INFORMATION
You have the right to obtain information from us at any time about the personal data we have processed concerning you within the framework of Article 15 of REGULATION (EU) 2016/679.
5.2. RIGHT TO RECTIFICATION OR ERASURE
You have the right, under the conditions described in Articles 16 and 17 of REGULATION (EU) 2016/679, to ask us to correct incorrect data or to erase personal data concerning you. In particular, these requirements provide for the right to erasure if the personal data is no longer necessary for the purposes for which it was collected or otherwise processed. Pursuant to Article 17(3) of REGULATION (EU) 2016/679, the exercise of this right is limited in particular if we need your data to comply with a legal obligation or to assert legal claims.
5.3 RIGHT TO RESTRICTION OF PROCESSING
You have the right to request that we restrict processing in accordance with Article 18 of REGULATION (EU) 2016/679.
5.4 RIGHT TO OBJECT
You have the right to object at any time, for reasons arising from your particular situation, to the processing of personal data concerning you based on, inter alia, Article 6(1)(e) or (f) of REGULATION (EU) 2016/679, in accordance with Article 21 of REGULATION (EU) 2016/679. We will stop processing your personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or the processing is for the establishment, exercise or defence of legal claims.
5.5 RIGHT TO DATA PORTABILITY
You have the right to receive from us the relevant personal data you have provided to us in a structured, common, machine-readable format in accordance with Article 20 of REGULATION (EU) 2016/679.
5.6 THE RIGHT TO LODGE A COMPLAINT WITH THE RELEVANT DATA PROTECTION REGULATORY AUTHORITY
You have the right to lodge a complaint with a supervisory authority, in particular in the Member State where you live, work or where the alleged breach occurred, if you believe that the processing of your personal data is in breach of Applicable data protection law.
6. ERASURE OF YOUR DATA
To delete your data, simply send us an email at privacy@sanela.cz. We will generally delete or anonymise your personal data once they are no longer required for the purposes for which we collected or used them in accordance with the paragraphs above. If the data must be stored for legal reasons, they will be blocked. The data are then no longer available for further use. If you would like more information about our deletion and storage periods, please contact us using the contact details above.
7. CHANGES OF PURPOSE
Your personal data will be processed for purposes other than those described if permitted by law or if you have consented to the changed purpose of processing the data. In the event of further processing for purposes other than those for which the data were originally collected, we will inform you of these other purposes and provide you with all other relevant information before further processing.
8. CHANGES TO THIS PRIVACY STATEMENT
The current version of this data protection declaration can always be called up in the Application under the menu item "Information".
Status: February 2023
