PRIVACY POLICY art. 13 of Regulation (EU) 2016/679 ('GDPR')

 

For E.L. Easy Life UK Limited ('EASY LIFE') your privacy and the security of your personal data are very important. This privacy statement ('Privacy Statement') explains how EASY LIFE collects, stores, uses and processes your personal data, acquired during use of the famil.care application ('App'), pursuant to the (EU) Regulation 2016/679 (the 'GDPR') of Legislative Decree 196/2003 (and subsequent amendments) and in compliance with all other provisions of the European Union or Member States applicable to privacy matters.

 

1) Who is the Data Controller?

The data controller is E. L. Easy Life UK Limited, with registered office in London, Cavendish Square Chandos Street 7/10, W1G 9DQ, Great Britain ('Owner'). It is possible to contact the Owner at privacy@famil.care or phone number +39 02 5656 9425

 

2) Who are the subjects affected by the treatment?

EASY LIFE treats the personal data of the following categories of interested parties ('Users'):

  • Caregiver: the parent or carer through the App;
  • Senior: user of the App that needs assistance (eg elderly), with full capacity to act, disabled or subject to support administration;
  • Junior: user of the App aged between 8 and 13 years.

 

3) What data do we process and why?

EASY LIFE treats the personal data of its Users, with electronic or manual tools, such as: name, surname, telephone number, email address, password, technical and traffic data relating to the device, unique identifier associated with the device, geographical position, speed cruise, data consumption, information on the apps installed on the device and related usage times, special categories of personal data, information on the frequency and taking charge of emergency events and other data relating to the operation of the service.

EASY LIFE treats the aforementioned types of data for the following purposes and on the basis of the following legal bases, which are distinguished according to the user's qualifications such as Caregiver, Senior and Junior:

  1. Caregiver, Senior and Junior: allow you to take advantage of the services offered through the App and provide you with adequate assistance (eg to allow you to create or modify your user profile, to allow you to use the App, to send you a code to enter during your first authentication, etc.). In these cases, the processing of your data is necessary for the execution of a contract of which you are a party or for the execution of pre-contractual measures adopted at your request pursuant to art. 6 par.1 lett. b) of the GDPR;
  2. Caregiver, Senior and Junior: fulfill legal obligations, respond to requests from the authorities or carry out anti-fraud activities. In this case, the legal basis of the processing is to be identified in the fulfillment of a legal obligation to which the Owner is subject pursuant to art. 6 par. 1 letter c) of the GDPR;
  3. Senior and Junior: allow you to monitor your movements and your activities to use the service. In this case, the legal basis of the processing is to be identified in the consent of the interested party, pursuant to art. 6 par.1 lett. a) of the GDPR;
  4. Caregiver, Senior and Junior: receive commercial communications, event invitations and participate in customer satisfaction surveys relating to products / services of the Owner of the App by telephone, push notifications or email. In this case, the legal basis of the processing is to be identified in the consent of the interested party, pursuant to art. 6 par.1 lett. a) of the GDPR;
  5. Caregiver, Senior and Junior: receive telephone communications, push notifications or e-mail communications concerning third party products / services. In this case, the legal basis of the processing is to be identified in the consent of the interested party, pursuant to art. 6 par.1 lett. a) of the GDPR;
  6. Caregiver, Senior and Junior: receive commercial communications of products / services based on your specific interests and characteristics. In this case, the legal basis of the processing is to be identified in the consent of the interested party, pursuant to art. 6 par.1 lett. a) of the GDPR;
  7. Caregiver, Senior and Junior: perform statistical activities, carry out extraordinary operations and exercise and defend the rights of the Owner. In this case, the legal basis of the processing is to be identified in the pursuit of the legitimate interest of the Data Controller pursuant to art. 6 par. 1 letter f) of the GDPR;
  8. Caregiver, Senior and Junior: receive commercial communications via email, in the event that such information is provided in the context of the sale of a product or service, communications are inherent to products or services similar to those purchased and you have not refused such treatment. In this case, the legal basis of the processing is to be identified in the pursuit of the legitimate interest of the Data Controller pursuant to art. 6 par. 1 letter f) of the GDPR.

 

It is possible that the App will allow the processing of special categories of personal data of Senior and Junior: in this case, these subjects will be asked to provide consent (or, if the consent cannot be validly given by the Senior or Junior , the Caregiver will be asked to provide it, after verifying its requirements) pursuant to art. 6 par. 1 letter a) of the GDPR. For example, we remind you that you can only give your consent if you are at least 14 years old: therefore, if the person concerned is less than 14 years old, the consent must be given by a parent or by anyone with responsibility. parenting (in this case, EASY LIFE will make reasonable efforts to verify that the consent is given or authorized by the holder of parental responsibility).

If we become aware that personal information has been collected from a person under the age of 14, without the consent of a parent or anyone exercising parental responsibility, we will delete such data and close the related account as quickly as possible.

 

4) Is it mandatory to provide personal data?

With reference to the purposes referred to in letters a) and b) of the previous paragraph 3), the provision of your data is mandatory. In fact, failing that we may not be able to provide you with the services requested and fulfill legal obligations, respond to requests from the authorities or carry out anti-fraud activities.

 

In the case of special categories of personal data of Senior and Junior, the Owner may treat these categories only with the prior consent of the interested party or of the Caregiver (if the consent cannot be validly given by the Senior or Junior). In the absence of consent, we may not be able to provide you with the services requested, as part of these involve the processing of particular categories of data.

 

With reference to the purposes referred to in letters c), d), e) and f) of the previous paragraph 3), the provision of your data is optional and requires your prior consent. In any case, even in the absence of such consent, you will be able to use the service, but EASY LIFE may not be able to provide some services and send you commercial communications (even if they are profiled).

        

Finally, with reference to the purposes referred to in letters g) and h) of the preceding paragraph 3), the conferment of your data is optional and you have the right to oppose at any time, for reasons connected to your particular situation, to the processing of personal data concerning you and to request information from EASY LIFE on the relative balancing test.

 

5) How long do we keep your data?

We keep your data that is necessary to provide the services offered through the App and to fulfill the legal obligations and pursue the legitimate interests of the Owner, only for the period strictly necessary for these purposes and, in any case, not more than 10 (ten ) years from the termination of the contract (ie, from the time your account is canceled).

 

Your data processed for commercial and profiling purposes will be kept for a maximum of 2 (two) and 12 (twelve) months from their collection. In case you have consented to receive commercial communications concerning products / services of third parties, the provisions of the privacy policy of these subjects will apply, also in relation to the duration of storage.

 

Your geographic location data is processed only to allow the Caregiver to receive the alert according to the chosen settings (eg in the case of Senior falling or Senior or Junior removal from the safe area) but they are not kept.

 

At the end of this period, except for the renewal of your consent, your data will be deleted or made anonymous.

 

6) To whom are your data communicated and transferred?

Your personal data is processed by authorized and specifically trained EASY LIFE personnel.

 

Furthermore, your data may be disclosed to the following categories of subjects:

  1. third parties that carry out activities connected or instrumental to the activities of EASY LIFE, as external processors or autonomous owners (for example, suppliers entrusted with the maintenance and development service of the IT system of EASY LIFE, service providers cloud, computer and telematic or archiving service companies, automated call service providers);
  2. subjects, organizations or authorities, such as the police or the judicial authority, in cases where the communication is obligatory pursuant to law provisions or to allow EASY LIFE to ascertain, exercise or defend a right in court;
  3. companies, associations or professionals who provide assistance and advice to EASY LIFE.

The complete and updated list of these subjects is available at EASY LIFE and is available upon request.

Your data will not be disclosed, unless this is necessary to fulfill the obligations provided by law.

 

Your data may be transferred to countries outside the European Economic Area; in this case, EASY LIFE will verify that the destination country is considered adequate, that the recipient is certified as a Privacy Shield or that it has group rules approved by the competent authorities or will conclude agreements in this regard. A copy of the appropriate guarantees or appropriate guarantees is available at the EASY LIFE office and can be requested at any time.

 

7) What are your rights?

You can exercise your rights to:

  1. access to personal data;
  2. correction or cancellation of your personal data;
  3. limitation of the processing of your personal data;
  4. opposition, at any time, for reasons connected to your particular situation, to the processing of your personal data for the pursuit of the legitimate interest of EASY LIFE, unless there are legitimate cogent reasons to proceed with the processing that prevail over your interests, rights and freedom or to ascertain, exercise or defend a right of EASY LIFE in court;
  5. opposition, at any time, to the processing of your personal data carried out for direct marketing purposes, including profiling to the extent that it is connected to such direct marketing;
  6. opposition, at any time, to the processing of your personal data for the offer of products or services similar to those purchased;
  7. data portability (right to receive your data in a standard format and to transfer it directly to a person indicated by you);
  8. revocation of consent at any time, without prejudice to the lawfulness of the processing based on the consent given before the revocation.

 

In addition, you also have the right to file a complaint with the Guarantor for the protection of personal data.

 

In order to exercise these rights, you can contact EASY LIFE at the following email address: privacy@famil.care or phone number +39 02 5656 9425