App Privacy Policy

ver. 1.1APP21

PRIVACY INFORMATION NOTICE

We invite you to read our Privacy Policy, which is applicable whenever when you use the smartwatch (device) and/or the App installed on your smartphone. We would also invite you to read the App’s General Terms and Conditions of Use, since they also contain information on the privacy and the security systems adopted by the device and by the App. The possible processing of personal data of the website device/app’s users will be carried out in Italy in compliance with applicable European legislation: European Data Protection Regulation no. 2016/679 (GDPR), which regulates the processing of personal data performed by anyone resident or based in Italy. MORELLATO SPA, with registered office in Via Commerciale no. 29, 35010 Santa Giustina in Colle, Padua, Italy, tax code / VAT IT13442590157 (“MORELLATO SPA “), is involved in the provision of e-commerce services and the sale of products via the Website.

1. OUR POLICY

Everyone has the right to the protection of their personal data. MORELLATO SPA respects the right of its users to be informed about the collection and processing of their personal data. We always try to comply with the principle of strict necessity in the processing of data that can identify you, even indirectly. This is why we have configured the Website device and the app to ensure the minimal use of your personal data, and therefore excludes processing when the purposes pursued in individual cases can be achieved through the use of anonymous data or by other means that allow the identification of the data subject only in case of necessity or at the request of the authorities or police forces. This Privacy Policy provides useful information to understand how any information that identifies users of the Device or App is collected and used. For more information on our Privacy Policy, you can send requests via e-mail to privacy@morellato.com.

2.IDENTITY AND CONTACT DETAILS OF THE HOLDER OF THE TREATMENT AND OF THE DATA PROTECTION OFFICER (D.P.O.).

The MORELLATO SPA with registered office in Santa Giustina in Colle (PD) Via Commerciale, 29, fraction Fratte, VAT number 13442590157, is the Controller of the any Personal Data of users of the App/Website, for the management, and execution of sales transactions, communication of a commercial nature, via this App (the “Purpose”).

If you wish to receive further information on how MORELLATO SPA processes your personal data, please write an email to the following email address: privacy@morellato.com. To learn about your rights and keep up-to-date on the legislation on the protection of individuals with regard to the processing of personal data, we recommend that you visit the website of the Guarantor for the protection of personal data at the address http://www.garanteprivacy.it /.

The Data Protection Officer (R.D.P.) pursuant to art. 37 et seq. of Regulation (EU) 2016/679 appointed by the Company is Adriaflor S.r.l., with registered office in Cervignano del Friuli, via San Francesco n. 33, (subject identified as contact person for the Data Controller: lawyer Enrico Menin), domiciled for the purpose at the Morellato SPA offices and can be contacted for all matters relating to the processing of your personal data and for the exercise of your rights to following e-mail address: dpo@morellatogroup.com.

3.PURPOSE AND PERIOD OF CONSERVATION OF YOUR PERSONAL DATA.

3.1Access and use of the app or device

When you access the App or your device, no data is collected or processed by us.

The user who uses the device or the app has the possibility to insert his own personal data, even sensitive ones (personal data such as name, height, weight, age, gender but also profile picture uploaded from gallery or camera APP prior authorization from the user).

Such personal data will not be processed by us in any way as they will not be saved on any server and we will not have access to them under any circumstances.

This data is processed by your own device and can be synchronized for the only purpose of exercise feedback and in order to provide a better health management service. This data includes activity such as: type of sports activity, activity information, sleep information, heart rate, blood oxygen saturation, blood pressure, weight, pace, exercise time.

Morellato Group APPs such as SECTOR&MORELLATO SMARTWATCHES and CHRONOSTAR SMARTWATCHES could transfers steps, distance, calories, heart rate, blood pressure, oxygen saturation, exercise session and sleep data to Google Health in case you decide to allow data transfer to this APP.

Connect to the following link full disclosure about Google API Services User Data Policy (https://developers.google.com/terms/api-services-user-data-policy#additional_requirements_for_specific_api_scopes), including limited use requirements.

If you want to be notified by your Device when you receive a text message, email, or app alert, you need to activate this in the App settings. In order for certain features to function, access to your contact list by the App is necessary. Please note that your contact related settings including your contact list will remain on your mobile device and cannot be accessed by us. Furthermore, we do not store content of any notifications, we only track that a notification occurred.

3.2 Device repair

Your personal data may be processed only if the need arises to give you assistance for a possible failure of the device or if the device is taken in for repair.

Since it is not necessary to enter your name and surname or other personal data that can, aggregated with others, identify or make your person identifiable in the app, there may not be any data processing in this case either. Nonetheless, we still considered it appropriate to draft this information to ensure maximum transparency even in such remote cases.

we list below the data that could be processed

Obligation and consequence of failure to communicate your personal data.

The provision of your personal data is mandatory for the purposes described above. The refusal to communicate the personal data referred to above will result in the impossibility of repair your device.

✔ Retention period of your personal data processed by us.

The treatment will begin at the time of collection of the data which will be kept by us for the time strictly necessary to fulfill the purposes indicated above.

More in detail :

• the data contained in the device will not be saved or communicated in any way either by us or by the repair person who will only proceed with the repair of the product in the short term;

after the retention periods indicated, these data are automatically deleted or communicated by transmission to the interested party within his device.

✔ Recipients or categories of recipients of your personal data.

On this point, please refer to what is specified below in the relevant section.

✔ Cookies and other tracking systems.

We also point out that no cookies or other tracking systems are used in our App.

4.TO WHOM WE COMMUNICATE YOUR PERSONAL DATA AND EXTRA EU TRANSFER

✔ Categories of recipients of personal data.

Your data that may be processed may be processed by third parties who provide repair services for your device. We remind you that your personal data is an important component of our work and it is not one of our activities to pass them on to others. Therefore, any personal data processed solely for the aforementioned purposes will be communicated within the Morellato Group and may be brought to the attention of its employees and/or collaborators (appointed in writing as authorized subjects pursuant to art. 2 quaterdecies co. 2 Legislative Decree 196/2003) as well as communicated to the following subjects:

• companies that provide the assistance service aimed at repairing your device. For greater prudence, these companies are appointed as data processors pursuant to art. 28 GDPR.
• companies that provide virtual assistance services, live chat or management of the interaction with the user

✔ Non-EU transfer.

Your personal data, as mentioned above, will not be stored on any server, neither within the European Union nor outside it

5.SECURITY MEASURES

Your data that may be present in your device delivered for repair will also be processed with IT, telematic, paper and manual tools, in compliance with the rules of confidentiality and security established by law.

We have adopted security measures in order to minimize the risk of destruction or loss, even accidental, of the data, unauthorized access or processing that is not permitted or does not comply with the collection purposes indicated in our Privacy Policy.

However, since it is not possible to ensure that the measures taken for the security of the Website and the transmission of data and information on the Website limit or exclude any risk of unauthorised access or data loss, we urge you to ensure that your computer is equipped with up-to-date antivirus software for the protection of both inbound and outbound data transmission and that your Internet service provider has adopted firewalls and anti-spam filters suitable for the security of data transmission over the web.

6. LINKS TO OTHER WEBSITES OR INTEGRATION WITH THIRD PARTY PLATFORMS

Our App does not provide links to third-party websites, and there are no third-party content in it, except for the following cases:

• Location permission might be asked through our Smartwatch APPs on Google Play Console or iTunes App Store. In case the user agrees to share their location with the APP, it is solely used to enable weather function and to enhance the user experience. It is not stored or collected in any servers and there is no other reason to collect it. The user can also opt-out from sharing their location by turning the sharing location settings OFF from the iOS or Android menu in any moment.

7. YOUR RIGHT TO ACCESS DATA AND OTHER RIGHTS

As required by articles 15 - 22 of the GDPR, you always have the right to obtain confirmation of the existence or not of personal data concerning you, even if not yet registered, and their communication in an intelligible form. You also have the right to obtain information about the origin of your personal data, the purpose and method of processing your personal data, the logic applied in the event of processing carried out with the aid of electronic instruments, the identification details of the owner and of the data controllers, the indication of the subjects or categories of subjects to whom the personal data may be communicated or who can learn about them as, for example, managers or persons in charge of the treatment. In part, this information is contained in our Privacy Policy; to find out more, you can send an email to privacy@morellato.com You always have the right to obtain from MORELLATO S.P.A:

- updating, rectification or, when interested, integration of your personal data;

- the cancellation, transformation into anonymous form or blocking of your personal data, possibly processed in violation of the law, including those whose retention is not necessary in relation to the purposes for which the data were collected or subsequently processed;

- the attestation that the above operations have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right.

You will, however, have the right to object in whole or in part:

- for legitimate reasons, to the processing of personal data concerning you, even if pertinent to the purpose of the collection;

- to the processing of personal data concerning you for the purpose of sending advertising material or direct marketing or for carrying out market research or commercial communication.

Finally, we remind you that you have the right to contact the Guarantor for the Protection of Personal Data (whose contact details are available at the following link https://www.garanteprivacy.it/home/footer/contatti), in order to enforce your rights in relation to the processing of personal data.

You will be able to freely and at any time exercise your rights, provided that they are within the limits of the law, with a request addressed to MORELLATO S.P.A at the email address privacy@morellato.com to which we will provide an appropriate reply.

8. APPLICABLE LAW

This Privacy Policy is defined on the basis of the GDPR. The GDPR guarantees that the processing of personal data is carried out in compliance with fundamental rights and freedoms, as well as the dignity of the interested party, with particular reference to confidentiality, personal identity and the right to protection of personal data.

9. CHANGES AND UPDATES TO THE SITE'S PRIVACY POLICY

Morellato S.P.A may modify or simply update, in whole or in part, the Privacy Policy of the Site also in consideration of the modification of the laws or regulations that govern this matter and protect your rights. Changes and updates to the Website's Privacy Policy will be notified to users on the Website's Home page as soon as they are adopted and will be binding as soon as they are published on the website in this same section. We therefore ask you to access this section regularly to check the publication of the most recent and updated Privacy Policy of the App.