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Privacy - Inim Websites
Privacy Notice for visitors and users of the websites: www.inim.it, www.inimdns.biz, and www.inimcloud.com
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This Privacy Notice applies to visitors and users of the following websites: inim.it, inimdns.biz, and my.inimcloud.com, which are owned by INIM ELECTRONICS S.R.L., a sole proprietorship (hereinafter “INIM”), and does not apply to other websites accessed by the user via internal links.
Pursuant to Articles 13 and 14 of EU Regulation 2016/679 (the “General Data Protection Regulation” or “GDPR”), we wish to inform you that, by using the aforementioned websites, INIM, as the Data Controller (hereinafter the “Controller”), necessarily becomes aware of personal data relating to you.
For this reason, we are required to provide you with the following information in compliance with the obligation set forth in the aforementioned legislation.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller is INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10, Tax ID and VAT No. 01855460448. INIM has appointed a Data Protection Officer (DPO) who can be contacted at the following address: dpo@inim.it.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?
Whenever INIM collects and processes your personal data, it does so solely in accordance with the legal principles established by law and for the purposes described below.
2.1 Purpose of data processing
The data will be processed for the purposes listed below:
- for purposes related to the obligations established by laws and regulations (including accounting and tax purposes), as well as for purposes related to instructions issued by the competent authorities or supervisory and control bodies;
- for purposes strictly related to and/or necessary for the provision of the services requested by the User;
- operational purposes and/or purposes complementary to the activities carried out by INIM, which, by way of example but not limited to, and only after obtaining consent, include sending the User, via email, newsletters and promotional material or, more generally, so-called “direct marketing” activities relating to the products and/or services provided by INIM itself, provided, however, that such activities are of a nature similar to the subject matter of previous sales or supplies;
- User profiling, after obtaining consent, to enable INIM to analyze the User’s preferences, habits, and tendencies and, consequently, to send the User targeted offers related to INIM’s products and services.
2.2 Categories of recipients to whom the data may be disclosed
To achieve the purposes described in paragraph 2.1 above, INIM may need to disclose the data provided by the User to third parties belonging to the following categories: agents and/or regional distributors of products marketed by INIM; entities providing banking, financial, and insurance services; authorities and supervisory and regulatory bodies; and, in general, public or private entities acting in their capacity as public officials or persons appointed to public service roles; other companies within the group to which INIM belongs, or parent companies, subsidiaries, or affiliates; entities that perform data collection services; entities that perform data collection, processing, and services necessary for the execution of orders received from customers; entities that provide services for the management of INIM’s data and IT systems and telecommunications networks (including email); entities responsible for IT security and maintenance; entities that carry out data transmission, packaging, transport, and sorting of communications with users; entities that carry out document filing and data entry activities; entities that carry out customer support activities; entities that conduct surveys and companies within the scope of support and consulting relationships; entities that carry out activities for the promotion and sale of products and services on behalf of INIM and other companies belonging to the group of which INIM is a part.
With regard to the data provided to them, the individuals belonging to the aforementioned categories will be able to act, as appropriate, either independently as data controllers or as data processors or persons in charge of data processing.
At the same time, the data may also be disclosed to other data processors appointed by INIM, as well as to its employees acting as data processors, always for the purposes indicated in paragraph 2.1 above.
3. WHERE DO WE PROCESS YOUR DATA?
The data processing operations related to the web services of this website are carried out at INIM’s headquarters, as mentioned above, and are handled exclusively by technical staff responsible for or in charge of data processing, or by other individuals responsible for or in charge of occasional maintenance operations.
4. Will your data be transferred abroad?
INIM currently processes your personal data without transferring it to countries outside the European Union or to countries that do not ensure an adequate level of personal data protection. The General Data Protection Regulation (GDPR) permits the transfer of personal data abroad with the User’s consent, or where there is a legal basis for such transfer and an adequate level of data protection is guaranteed. INIM undertakes to ensure that if data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate security measures will be taken to protect personal data in such countries or territories.
5. HOW IS YOUR DATA PROCESSED AND FOR HOW LONG?
Data processing:
- is carried out through operations or a set of operations, including collection, recording, and organization; processing, including modification, comparison, and interconnection; use; consultation; storage; erasure or destruction; security and protection; integrity; and safeguarding;
- is carried out using manual, computerized, and telematic tools in accordance with procedures strictly related to the purposes referred to in paragraph 2.1 above, and in such a way as to ensure the security and confidentiality of the data.
INIM will retain your personal data only for as long as is strictly necessary to achieve the purposes for which it was collected and processed, unless required to retain it longer in accordance with specific legal provisions.
The data collected for the purpose of registering on the INIM CLOUD SERVICES portal is governed by a specific, detailed notice included on the registration form. The data will be processed in connection with the services offered by INIM through its portal, exclusively for purposes that fall within the company’s institutional responsibilities or to fulfill obligations required by law or regulations. As part of these purposes, data processing also pertains to data regarding subscriptions/registrations to the portal required for the management of business relations with INIM, as well as to facilitate effective institutional communication and to comply with any legal, regulatory, or contractual obligations. The data will be stored in accordance with the terms of the service offered or, alternatively, until your consent is revoked.
The data processed for marketing and profiling purposes (provided, of course, that you have given your express consent) will be stored in accordance with applicable law and, in any case, until you withdraw your consent to the processing of your personal data.
The data processed following your purchase of products will be used exclusively for sending emails in accordance with the provisions of Article 130, paragraph 4, of the Data Protection Act.
In all cases, the User has the right to withdraw consent to the processing of personal data for marketing and profiling purposes at any time: each marketing communication includes a section that allows the User to easily withdraw their consent. Upon revocation of consent, even if expressed before the expiration of the retention period for data collected for the aforementioned purposes, such data will be automatically deleted or permanently anonymized, and our Company may ask the User to renew consent to its processing. Data transmitted to any service providers will be processed by them for the time strictly necessary to perform the tasks entrusted to them.
Specific security measures will be in place at all times to prevent data loss, unauthorized or improper use, and unauthorized access.
6. WHAT ARE YOUR RIGHTS?
As the data subject, you may exercise, using the methods described in section “11 EXERCISE OF THE DATA SUBJECT’S RIGHTS,” the rights set forth in Articles 15 through 22 of the Regulation, and in particular:
- to obtain confirmation as to whether or not personal data concerning you is being processed, even if not yet recorded, and to receive such data in a comprehensible form;
- obtain information regarding: a) the origin of the personal data; b) the purposes and methods of processing; c) the logic applied in the event of processing carried out with the aid of electronic tools; d) the identification details of the Data Controller, data processors, and the designated representative pursuant to Article 3(1) of the GDPR; e) the subjects or categories of subjects to whom the personal data may be disclosed or who may become aware of such data in their capacity as designated representative within the territory of the State, persons in charge, or data processors;
- obtain: a) the updating, rectification, or, where applicable, supplementation of data; b) the erasure, anonymization, or blocking of data processed unlawfully, including data no longer necessary for the purposes for which it was collected or subsequently processed; c) confirmation that the operations referred to in points a) and b) have been brought to the attention, including regarding their content, of those to whom the data may have been disclosed or disseminated, except where such fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
- objecting, in whole or in part: a) on legitimate grounds, to the processing of personal data concerning you, even if such data is relevant to the purpose of collection; b) to the processing of personal data concerning you for the purpose of sending advertising or direct sales material, or for conducting market research or commercial communications, through the use of automated calling systems without operator intervention, by email, and/or through traditional marketing methods (telephone and/or postal mail). It should be noted that the data subject’s right to object, for the purposes of direct marketing through automated methods, also extends to traditional methods and that, however, the data subject retains the option to exercise the right to object even if only partially. The data subject, however, may choose to receive only certain types of communications—that is, solely via traditional methods or automated communications, or neither of the two types of communication.
Where applicable, you may also exercise the rights set forth in Articles 15 through 22 of the GDPR (right to rectification, right to be forgotten, right to restriction of processing, right to data portability, right to object), as well as the right to lodge a complaint with the Data Protection Authority.
7. WHAT DATA DO WE PROCESS?
7.1 Navigation data
The computer systems and software procedures used to operate the Websites acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified individuals but, by its very nature, could, through processing and association with data held by third parties, allow Users to be identified. This category of data includes IP addresses or domain names of the computers used by Users connecting to the Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the response provided by the server (successful, error, etc.) and other parameters relating to the operating system and the computer environment of the User. This data will be used for the sole purpose of obtaining anonymous statistical information regarding the use of the Website and to verify its proper functioning and will be deleted immediately after processing. Such data may be used to ascertain responsibility in the event of hypothetical computer crimes against the Website.
7.2 Data provided voluntarily by the User
Following the optional, explicit, and voluntary consent provided in advance by the data subject through the forms available on the Website or by using the contact information provided therein, INIM collects and stores the data received, including the email address, for the time necessary to respond to requests, for the purpose of exchanging information or maintaining contact. Specific summary information will be progressively provided or displayed on the pages of the Website dedicated to specific services available upon request or to specific categories of data.
7.3 Cookies
For information on the Cookie Policy, please refer to the Cookie Policy in the dedicated section of the Website.
8. Does INIM process data relating to minors?
As a general rule, we do not intentionally collect personal data from minors. If we discover that we have inadvertently collected personal data from such individuals, INIM takes steps to delete such data as soon as possible, unless applicable law requires us to retain it.
9. OPTIONALITY OF DATA SUPPLY
In addition to the information required for navigation, the User is free to provide the personal data contained in the request forms or indicated in the contact sections to request, for example, the sending of informational material or other communications. Failure to provide such data may make it impossible to obtain what has been requested. For the sake of completeness, it should be noted that in some cases (not subject to the ordinary management of this Website), the authorities may request information for the purpose of verifying the processing of personal data. In such cases, a response is mandatory under penalty of an administrative sanction.
9.1 Provision of Data and Consent
Without prejudice to the User’s right to choose, the provision of data for the purposes referred to in paragraph 2.1 is optional.
However, it should be noted that:
- If the User ultimately refuses to provide the data for the purposes referred to in paragraph 2.1, subparagraphs (a) and (b), or if such data is deleted at the User’s request, INIM will be unable to guarantee access to the restricted area of the Website and, consequently, the User will be unable to use the requested services;
- the User’s eventual refusal to provide data for the purposes referred to in paragraph 2.1, point (c) [or the deletion of such data, following a request by the User] will make it impossible for INIM to offer other functional or complementary promotional and advertising activities that benefit the User, without prejudice to the User’s ability to access the restricted area of the Website and use the requested services;
- If the User refuses to provide the data for the purposes referred to in paragraph 2.1, point (d), or deletes such data, INIM will be unable to profile the User based on their indicated consumer choices, habits, and preferences, thereby preventing INIM from providing the User with information and communications tailored to their preferences. Refusal to provide the Data referred to in paragraph 2, point (d) does not, however, affect the User’s ability to access the reserved area of the Website and benefit from the requested services.
With regard to the purposes set forth in subparagraph 2.1, points (a) and (b), we inform the User that the processing of data by INIM, including the disclosure of such data to the parties referred to in paragraph 2.2, does not require the User’s consent, as such processing is necessary to provide the services requested by the User and to comply with legal obligations.
With regard to the purpose specified in paragraph 2, point (c), we hereby clarify that the consent provided for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Data Protection Act (so-called “Direct Marketing”) implies consent to receive such communications not only through automated means (e-mails), but also through traditional means (paper mail and telephone calls via an operator). However, the User has the right to consent to receiving the aforementioned communications exclusively through traditional contact methods. However, without prejudice to the provisions of Article 130, paragraph 4, of the Data Protection Act, which authorizes INIM to use the email address provided by the User for the direct sale of its products or services without the User’s prior consent, provided that these are services similar to those being sold and that the User, having been adequately informed, does not refuse such use initially or during subsequent communications. The User has the right to object to this at any time.
10. PURPOSES AND METHODS OF PROCESSING
10.1 Data collected from the Internet
When you visit this website, data relating to identified or identifiable individuals may be processed.
The provision of data is optional; however, in some cases, it may be essential for the performance of specific activities, and therefore, failure to provide it would hinder INIM’s ability to provide services and information.
Failure to provide all data, except for data that is not required by legal, tax, or contractual obligations, will be reviewed by INIM on a case-by-case basis, and INIM will make the resulting decisions based on the importance to INIM of the requested data that was not provided.
In particular, for the purposes set forth in section “10.2 Data provided voluntarily by the User and collected for the provision of services,” the User will be asked to give their free and informed consent to the processing of their data by signing the appropriate documentation prepared, where necessary, for such processing.
No data will be disclosed or disseminated unless expressly specified in the privacy notices prepared for the specific processing operation for which the User will be asked to provide explicit and separate consent to the data subject.
Similarly, if the collection of sensitive data is necessary, the User will be asked to provide explicit and separate consent to the data subject.
Technical data related to the User’s access to the Website, as well as data collected from any emails sent by the User, will not, under any circumstances, be disclosed to third parties or made public.
10.2 Data provided voluntarily by the User and collected for the purpose of providing the services
The collection and processing of the User’s personal data comply with the general principles of necessity, accuracy, relevance, and proportionality; specifically, the data will be processed for the following purposes:
- registration for the personal account or subscription to the services offered by INIM through the Websites;
- response to questions and provision of information requested by the User;
- handling of user requests, whether technical or commercial, regarding the status of orders as well as general inquiries;
- the performance of activities related to or necessary for the provision of services by INIM, including the disclosure of data to third-party companies that, for example, perform activities related to or necessary for the provision of INIM services or the management of payments on the Website;
- registrations and communications required by law;
- assessment of the user's level of satisfaction and preferences;
- to grant the User access, following registration and the creation of the User profile on the INIM CLOUD SERVICES portal, to the restricted area for the provision of services, products, and any other type of request, as well as the subsequent independent management of the User’s own profile via the control panel;
- management of payments, including anti-fraud measures for credit card payments;
- the sending, after obtaining consent, of advertising material, information, and commercial communications, as well as the transfer to third parties of the data processed for commercial purposes, including for the purpose of sale or potential sale, or for any commercial and/or statistical purposes permitted under current legislation. The consent given for the sending of commercial and promotional communications pursuant to Article 130, paragraphs 1 and 2, of the Code (so-called “Direct Marketing”) implies consent to the receipt of communications not only via automated methods, but also through traditional methods (paper mail and telephone calls via an operator). In these circumstances, the User is also given the right to express consent to the receipt of the aforementioned communications exclusively through traditional methods of contact;
- the profiling of the User, after obtaining consent, in order to enable INIM to analyze their consumer choices, habits, and preferences and, consequently, to send the User specific offers related to INIM products and services;
- subscription to the ‘NEWSLETTER’. Users can sign up when registering in the members-only area. This information will not be disclosed to third parties. For further details, please refer to the specific privacy notice.
11. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
The data subject may at any time exercise the rights set forth in Articles 15 through 22 of the Regulation by contacting INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori No. 10. Tax ID and VAT No. 01855460448, email: privacy@inim.it.
12. UPDATES TO THIS POLICY
This Privacy Policy governs the processing of personal data provided by the User when browsing INIM websites and may be amended by INIM or simply updated, in whole or in part, including in light of changes to the laws or regulations governing the protection of personal data. Any changes or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon publication on the Website. INIM therefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of its last update.
Last updated: April 7, 2026
Privacy - Inim Cloud Users
Notice for users registered in the restricted area of theInim Cloudservices portal
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This Privacy Policy applies to Users who register on the INIM CLOUD SERVICES portal, accessible via the websites inim.it, inimdns.biz, and my.inimcloud.com, which are owned by “INIM ELECTRONICS S.R.L.”, a sole proprietorship (hereinafter “INIM”).
Pursuant to Articles 13 and 14 of EU Regulation 2016/679 (the “General Data Protection Regulation” or “GDPR”), we wish to inform you that, by registering with the portal, INIM, as the Data Controller (hereinafter the “Controller”), will receive your personal data.
For this reason, INIM is required to provide you with the following information in compliance with the obligation set forth in the aforementioned legislation.
This Privacy Policy supplements the general Privacy Policy of INIM Websites and that of the “INIM HOME,” “INIM HOME P2P,” “INIMTECH SECURITY,” and “INIM FIRE” apps.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The Data Controller is “INIM ELECTRONICS S.R.L.,” a sole proprietorship with its registered office in Monteprandone (AP), in the municipality of Centobuchi, at Via dei Lavoratori 10, Tax ID and VAT No. 01855460448.
INIM has appointed a Data Protection Officer (DPO) who can be contacted at the following address: dpo@inim.it.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?
Your data is processed for the creation and management of your personal account in INIM CLOUD. In addition, INIM may process your data as necessary both for the performance of a contract to which you are a party and for the implementation of pre-contractual measures taken at your request.
Whenever INIM collects and processes your personal data, it ensures its availability, integrity, and confidentiality.
INIM processes your data in accordance with the following legal grounds established by law:
- pursuant to Article 6.1(b) of the Regulations, in order to allow registration and;
- allow the creation of a Personal Account on the INIM Cloud and the use of the related dedicated services;
- allow INIM to respond to your inquiries and provide the necessary assistance;
- allow INIM to provide the services you have activated;
- pursuant to Article 6(1)(a) of the Regulation, or subject to your specific and explicit consent, for the purpose of conducting marketing activities, both through automated means (SMS, MMS, messaging platforms, email, push notifications) and through traditional channels (mail, telephone calls with an operator);
- pursuant to Article 6(1)(a) of the Regulation, or subject to your specific and explicit consent, for profiling purposes, i.e., to identify your preferences, interests, and consumption choices, in order to provide you with services that are better suited to your expectations and needs;
- pursuant to Article 6.1(c) of the Regulation, to comply with legal obligations to which INIM is subject;
- pursuant to Article 6(1)(f) of the Regulation, for the pursuit, under the conditions and in compliance with legal constraints, of a legitimate interest of INIM or third parties, such as, for example, the prevention of fraud, the improvement of process management, the exercise and defense of one’s own rights, and the organizational and strategic optimization of INIM.
2.1. Purpose of data processing
INIM will process your personal data for the following purposes:
- creating your own INIM CLOUD account;
- purposes related to the management of your alarm control panels, such as, by way of example and not limited to, sending notifications via email, SMS, or—if the INIM HOME APP is used—push notifications regarding alarms, events, and status information. Notifications can be deactivated and reactivated at any time via the User’s INIM CLOUD account page. Included in these purposes is the backup service offered in relation to the data of INIM control panels and P2P devices that can be integrated with them, such as the configuration of home automation systems or video cameras;
- for purposes related to the management of your alarm control panels by your installer. The above notifications may in turn be sent to the designated installer account. For information regarding such data processing, see section 3.2 of this Privacy Policy;
- for purposes that are functional and/or complementary to the activities carried out by INIM, such as, by way of example and without limitation, sending Users, via email, newsletters and promotional materials or, more generally, “direct marketing” relating to the products and/or services marketed by INIM itself, provided, however, that such products and/or services are similar in nature to those previously sold or supplied;
- your profile so that INIM can analyze your preferences, habits, and spending patterns and, as a result, send you targeted offers for INIM products and services;
- your enrollment in courses and events organized by INIM, both in-person and online, as well as your participation in related promotions, provided that consent for commercial activities has been obtained in advance. For information regarding this data processing, please refer to section 3.5 of this Privacy Policy.
Consent for the purposes referred to in letters b), c), d), e), and f) is optional; your refusal does not in any way affect your existing relationship with INIM, nor the successful completion of the process of creating a personal user account on the ‘INIM’ website.
2.2. Other purposes of data processing
The data may be processed for purposes related to the management of business relationships between the Data Controller and interested parties in the Installer and Distributor categories, or existing relationships between such parties.
2.3. Categories of recipients to whom the data may be disclosed
To achieve the purposes described in paragraphs 2.1 and 2.2 above, INIM may need to disclose your Personal Data to third parties belonging to the following categories: agents and/or regional distributors of products marketed by INIM; entities providing banking, financial, and insurance services; authorities and supervisory and regulatory bodies; and, in general, public or private entities acting in their capacity as public officials or persons appointed to public service roles; other companies within the group to which INIM belongs, or parent, subsidiary, or affiliated companies; entities that provide procurement services, entities that perform the data collection and processing services necessary for the fulfillment of orders received from customers; entities that provide services for the management of INIM’s data and IT systems and telecommunications networks (including email); entities responsible for IT security and maintenance; entities that carry out data transmission, packaging, transport, and sorting of communications with users; entities that carry out document filing and data entry activities; entities that carry out customer support activities; entities that carry out surveys and companies within the scope of support and consulting relationships; entities that carry out activities for the promotion and sale of products and services on behalf of INIM and other companies belonging to the group of which INIM is a part.
With reference to the data communicated to them, the subjects belonging to the aforementioned categories will be able to operate, as the case may be, in complete autonomy as separate Data Controllers, or even as data processors or persons in charge of data processing.
At the same time, the Data may also be communicated to other data processors appointed by INIM as well as to its employees acting as data processors, always for the purposes indicated in paragraphs 2.1 and 2.2 above.
3. CATEGORIES OF DATA SUBJECTS AND RELATED SPECIFICATIONS REGARDING THE PROCESSING OF PERSONAL DATA
Detailed information is provided to the various categories of data subjects, depending on their involvement and the related processing of personal data.
3.1 Private
Creating a Private account in the Cloud allows the individual who registers to control and manage the associated control panel(s). Registering for a Private account requires entering a series of data, including personal data, into the appropriate online form. The Private individual is informed that, in order to manage the installation and operation of their alarm system for the purposes referred to in section 2.1(c) of this Privacy Policy, they must provide certain data – first and last name and serial number of the control panel – the installer’s reference via a manual procedure (to be performed by accessing the control panel’s keypad) to link the control panel to the respective user account.
We would like to clarify that this authorization is necessary in order to monitor the provision and management of control panel services via INIM CLOUD.
Following this notification, the installer will collect and process the data of the private individual as an independent data controller, including through its own subcontractors (if any). Any personal data relating to “private” users, in addition to the user’s first and last name and the control panel’s serial number, will be entered independently by the installer after the control panels have been registered.
A "Private" user may revoke the association of one or more control panels—which they own—with the designated installer at any time using the function available in the Cloud management panel.
3.2 Installer
The Installer account manages, on behalf of "Private" accounts, the control panels associated with them and the related management and configuration processes.
There are two types of "Installer Account".
Admin Installer Account
The “Admin Installer” account is linked to an individual who, in any capacity, is part of a company or sole proprietorship and is fully responsible for managing that account and the “Auxiliary” accounts.
If there are not yet any accounts associated with the company (VAT-country combination), the first person to register as the “Installer” account automatically becomes the “Admin Installer” account.
Users with the "Admin Installer" account also have the right to:
- control and view all control panels registered directly by the ‘Admin’ as well as those registered by ‘Auxiliaries’;
- manage groups of "Auxiliaries" and restrict their access to and control of the installed control panels;
- decides which group to assign the control panels to.
Registering for the “Admin Installer account” requires entering a series of details, including personal data, into the appropriate online form.
The ‘Admin installer’ is informed that, in order to manage all processes related to the activation of their account for the purposes described in section 2.1(c) of this Privacy Policy, they must complete the registration process.
Auxiliary installer account
An "Auxiliary Installer Account" is subject to the control of the "Admin Installer Account" of the company or sole proprietorship (VAT number/Company).
Registering an “Auxiliary Installer account” requires entering a series of data, including Personal Data, into the appropriate online form. The ‘Auxiliary’ installer is informed that, in order to manage all processes related to the activation of their account for the purposes referred to in section 2.1(c) of this Privacy Policy, they must complete the registration procedure and will simultaneously receive an email containing details regarding the ‘Admin’ (first and last name); the ‘Admin’ is also informed, in the same manner, of the Personal Data of the ‘Auxiliary’ (first and last name).
3.3 Distributor
The Distributor account (provided, along with the relevant password, directly by INIM) manages the relevant installers as assigned under the agreements with the Owner and may display certain data regarding existing relationships between the parties, in order to best ensure the performance of management and support activities.
INIM hereby informs interested parties, distributors, and installers that INIM may retain such data for statistical purposes.
3.4 Data processing specifications for the categories of data subjects “Installer,” “Private,” “Designer,” and “Distributor”
The ‘Admin’ Installer processes the data provided by the ‘Auxiliary’ Installer in its capacity as an independent Data Controller. It should be noted that this transfer of data from the ‘Auxiliary’ to the ‘Admin’ is necessary in order to follow up on the activation of the specific profile.
An "Auxiliary" installer can control and view only the control panels associated with their group, in accordance with the permissions granted by the "Admin" installer.
For all data processing activities carried out, the “Auxiliary” installer acts under the responsibility of their “Admin” installer, in the capacity of the person authorized (in charge) of processing or the data controller.
For the processing of data relating to “Private” users, the “Main User” acts as an independent data controller, and it is their sole responsibility to inform the “secondary” user (if any) through their own privacy policy and to obtain any necessary consent.
For the “Designer” profile, there are no additional processing specifications beyond what is generally set forth in this Privacy Policy.
For the “Distributor” profile, there are no processing specifications other than those outlined, in general terms, in this Privacy Policy.
3.5 Data Processing Specifications for Participants in INIM Courses and Events
If you enroll in INIM courses and events, your personal data will be processed in order to fulfill all administrative, logistical, and organizational obligations related to your participation, including the issuance of certificates and the administration of satisfaction surveys, which you are free to complete or not. Upon registration, your personal data may be shared, as provided for in section 2.1, to ensure the proper conduct of the courses.
If your participation in the courses is linked to promotional offers and you have provided consent for commercial activities, your Personal Data may be shared with one or more INIM distributors in your area so that they can contact you and allow you to take advantage of the special benefits. Personal Data will not be disclosed beyond what has been described, unless required by legal obligations or by regulations governing the issuance of certificates for the courses or events you have attended.
3.6 Specifications regarding the processing of personal data for users of the voice assistant services named “MARILYN” and “MARILYN MORE”
If you wish to use, following your consent, the voice assistant services named “MARILYN” and “MARILYN MORE, ” INIM informs you that it processes the following types of data:
- data collected automatically, such as server logs and data transmitted by the Actions on Google/Dialogflow API during the user’s interaction with Google Actions;
- data collected automatically, such as server logs and data transmitted by the Skill to Amazon servers during the user’s interaction with inim-skill;
- data obtained from the user, either directly or through the Authorization API;
- pre-existing identification data (such as the user ID of the user’s My Inim profile).
The computer systems and software processes used to operate voice commands, during their normal operation, collect certain personal data from the respective servers of service providers that transmit the conversations recorded by the Voice Assistant within the scope of its functional capabilities; the transmission of this data is inherent in the operation of the voice commands. This data is not collected for the purpose of linking it to the identity of the data subjects, but by its very nature allows users to be identified. This category of data includes the commands issued, the Inim anti-intrusion systems involved, and, in general, all conversation data that the voice assistants provide to the Inim servers for the execution of commands and instructions.
This data is stored for a limited period of time, solely for the purpose of providing diagnostic information to resolve any issues related to the operation of the voice assistant functions and to keep a record of activities performed via voice commands for purposes required by law (for example, in response to a request from law enforcement, the judiciary, or other competent authorities). The data that Inim retains for the aforementioned purpose of technical support, relating to actions on voice assistants, are deleted twelve months after their collection.
User data is used to provide the services offered by the Inim Apps and can be activated through the apps or the Inim Cloud for the management of the users’ alarm systems and the home automation devices connected to them, and includes the ability to identify and recognize users for subsequent use of the app.
INIM does not use any collected data for the purposes of customer profiling, to offer products and services, or for any other commercial purposes.
The personal data processed by INIM is collected for purposes strictly related to the activation and operation of the voice functions enabled by the user.
However, please be advised that the computer systems and software processes of third parties responsible for certain functions may, in the course of providing their services, collect certain data relating to the user, the transmission of which is implicit in the use of voice assistant functions on smartphones and other compatible devices. Inim is not involved in such processing, which is carried out independently and exclusively by the respective data controllers, nor can Inim be held responsible for it.
Therefore, before activating the services, we encourage you to review the privacy policies of the Google and Amazon voice assistant services, which are available on their respective websites.
3.7 Processing specifications for users of services dedicated to the management of video surveillance via the INIM Cloud and the INIM App
If, after activating the Services (offered via the Cloud and the INIM App) for video surveillance management, you wish to use them, INIM informs you that it processes the following types of data:
- information such as images and short videos (maximum duration of 15 seconds) that are captured and stored solely in response to an automatic presence detection or alarm triggered by the installed systems;
- information regarding the zone in alarm and the event that triggered it.
The IT systems and software procedures responsible for operating the video surveillance system collect this information from users' respective systems during normal operation.
This data is stored for a limited period of time, for the sole purpose of providing users with information about events that may be of interest to them, based on their legitimate interest in the collection and storage of such data. The data that INIM retains for the aforementioned purposes are deleted at the user’s request or, in any case, thirty days after their collection. INIM may access such data exclusively for technical purposes and in response to requests for assistance from the user, thereby fulfilling the role of Data Protection Officer, pursuant to Article 28 of the GDPR. This designation is included in the DPA (Data Processing Agreement).
User data is used to provide the services offered by Inim Apps, which can be activated through the apps themselves or in the Inim Cloud, for the management of users’ video surveillance systems. This includes the ability to identify and recognize users for subsequent use of the apps.
The personal data processed by INIM are collected for purposes strictly related to the functions activated by the User.
Please note, however, that the IT systems and software procedures of third parties responsible for the operation of the entire system may, in the course of providing their services, collect certain data that can be traced back to the User; the transmission of such data is implicit in the use of the functions available on smartphones and other compatible devices. INIM is not involved in such processing, which is carried out independently and exclusively by the respective data controllers, nor can INIM be held responsible for it.
Therefore, we encourage you to review the privacy policies of your hardware, software, and related service providers and operators before activating the services.
3.8 Specifications for the processing of personal data for users of the INIM DRIVE service dedicated to file management and sharing
If the Installer User uses the Service for file management and sharing (via the Cloud and the INIM App), INIM may process the following types of data:
- files uploaded to the general Drive environment, which can be shared with other company accounts (administrator and auxiliary installer accounts) registered under the same VAT number;
- files uploaded to the checklist and storage areas associated with individual systems, which can be shared with other accounts within the relevant company organization and/or with private user accounts registered on a specific system.
The files located in the INIM DRIVE space are the exclusive property of the Installer User. The data that INIM stores for the aforementioned purposes are managed and shared exclusively at the discretion of the Installer User. INIM may access such data exclusively for technical purposes and in response to requests for assistance from the Installer User, thereby acting as a Data Processor, pursuant to Article 28 of the GDPR. This designation is set forth in the specific Data Processing Agreement (DPA) for the service, which can be viewed in the dedicated area of the INIM Cloud.
4. WHERE DO WE PROCESS YOUR DATA?
The data processing operations related to the web services of this website are carried out at INIM’s headquarters, as mentioned above, and are handled exclusively by technical staff responsible for or in charge of data processing, or by other individuals responsible for or in charge of occasional maintenance operations.
5. Will your data be transferred abroad?
INIM currently processes your personal data without transferring it to countries outside the European Union or to countries that do not ensure an adequate level of personal data protection. The General Data Protection Regulation (GDPR) permits the transfer of personal data abroad with the User’s consent, or where there is a legal basis for such transfer and an adequate level of data protection is guaranteed. INIM undertakes to ensure that if data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate security measures will be taken to protect personal data in such countries or territories.
6. HOW IS YOUR DATA PROCESSED AND FOR HOW LONG?
Data processing:
- is carried out through operations or a set of operations, including collection, recording, and organization; processing, including modification, comparison, and interconnection; use; consultation; storage; erasure or destruction; security and protection; integrity; and safeguarding;
- is carried out using manual, computerized, and electronic means, in accordance with procedures strictly related to the purposes referred to in paragraphs 2.1 and 2.2 above, and in such a way as to ensure the security and confidentiality of the data.
INIM will retain your personal data only for as long as is strictly necessary to achieve the purposes for which it was collected and processed, unless required to retain it longer in accordance with specific legal provisions.
The personal data processed for the creation of your personal account and for the use of the services available to personal account holders will be stored and processed until your personal account is closed.
With regard to system logs, INIM handles them as follows:
- System logs related to user activities and the intrusion detection devices/NVRs connected to them in the cloud, which are collected for support and maintenance purposes as well as to improve the services offered, are retained by INIM for a period of 12 months from the date of collection;
- System logs related to user activities and the fire protection devices connected to them in the cloud, which are collected for security, technical support, and maintenance purposes, as well as to improve the services offered, are retained by INIM for a period of 24 months from the date of collection;
- System logs, collected for statistical purposes, are deleted or anonymized by INIM within 12 months of their collection;
- System logs related to user activities in the Cloud are retained by INIM for 12 months from the date of collection, unless retention is required to comply with laws or regulations pertaining to the specific services used;
- System logs related to the activities of users who use the MARILYN and MARILYN MORE voice assistants are retained by INIM for 12 months from the date of collection for the purposes of support and maintenance, as well as to improve the services offered;
- System logs related to communications with users for the purpose of managing the services offered are retained by INIM for 12 months from the date of collection, unless there is a need to retain them in the legitimate interest of the data controller for legal protection purposes or to comply with current regulatory requirements.
Please note that any requests for an extension of the retention period, made for valid reasons, should be directed to the contact information provided in section 10 of this privacy notice.
The data processed for marketing and profiling purposes (provided, of course, that you have given your express consent) will be stored in accordance with applicable law and, in any case, until you withdraw your consent to the processing of your personal data.
The data processed following your purchase of products will be used exclusively for sending emails in accordance with the provisions of Article 130, paragraph 4, of the Data Protection Act.
In all cases, the User has the right to withdraw consent to the processing of personal data for marketing and profiling purposes at any time: each marketing communication includes a section that allows the User to easily withdraw their consent.
Upon revocation of consent—even if such consent was given prior to the expiration of the retention period for data collected for the aforementioned purposes—the data will be automatically deleted or permanently anonymized, and our Company may ask the User to renew consent to its processing.
The data transmitted to any service providers will be processed by them for the time strictly necessary to perform the tasks entrusted to them.
With regard to data backup management, it should be noted that:
- the data is backed up in the cloud;
- Backup is activated automatically upon login;
- The user can disable data backup before configuring their security system;
- The user can disable data backup after configuring their security system via the appropriate option in the app: ‘Settings’ > ‘Data backup to the cloud’ and deselect ‘Backup active’;
- Once the backup is disabled, the user can choose whether or not to cancel the backup via the Cloud.
Specific security measures will be in place at all times to prevent data loss, unauthorized or improper use, and unauthorized access.
7. WHAT ARE YOUR RIGHTS?
The privacy legislation (Articles 15–22 of the Regulation) guarantees you the right at all times to access data concerning you, as well as to correct and/or supplement such data if it is incorrect or incomplete, to request erasure or restriction of processing if the conditions are met, to object to processing for reasons related to your particular situation, and to data portability regarding the data you provided, where processed automatically for the services you requested, within the limits of the provisions of the Regulation (Art. 20).
8. Does INIM process data relating to minors?
As a general rule, we do not intentionally collect personal data from minors. If it is discovered that personal data from such individuals has been collected inadvertently, INIM reserves the right to take steps to delete such data as soon as possible, unless applicable law requires us to retain it.
9. OPTIONALITY OF DATA SUPPLY
Apart from the registration data required to create your account and manage the requested services, you are free to provide the personal data contained in the request forms or otherwise indicated in the contact sections to request, for example, the sending of informational materials or other communications. Failure to provide such data may make it impossible to fulfill your request. For the sake of completeness, it should be noted that in certain cases (not related to the ordinary management of this Website), the authorities may request information for the purpose of verifying the processing of personal data. In such cases, a response is mandatory, subject to an administrative penalty.
In particular, please note that if you choose not to consent to the processing of your personal data for marketing purposes, INIM will not be able to include you in its promotional activities, including periodic updates via the newsletter service.
If you decide not to consent to the processing of your personal data for profiling purposes, this will not affect your participation in INIM’s promotional communications program; it will simply prevent INIM from sending you personalized promotional communications.
10. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
The data subject may at any time exercise the rights set forth in Articles 15 through 22 of the Regulation by contacting “INIM ELECTRONICS S.R.L.”, a sole proprietorship, at its registered office in Monteprandone (AP), in the municipality of Centobuchi, at Via dei Lavoratori No. 10. Tax ID and VAT No. 01855460448, email: privacy@inim.it.
11. UPDATES TO THIS POLICY
This Privacy Policy governs the processing of your Personal Data provided when registering on the INIM CLOUD SERVICES portal and may be amended or updated, in whole or in part, including in light of changes to the laws or regulations governing the protection of Personal Data. Any changes or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon publication on the Website. INIM therefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of its last update.
Last updated: April 7, 2026
Privacy - Quote Requests
Privacy Notice for Users Requesting Quotes from Inim-Selected Installers and Information on Inim Products
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Dear User,
Pursuant to Articles 13 and 14 of Regulation (EU) No. 679/2016 –General Data Protection Regulation (hereinafter also “the Regulation”), we hereby inform you that, in order for you to be contacted by an installer selected by INIM and to receive a quote or further information about INIM products and services, it is necessary to collect and use certain data concerning you.
The service is available in the relevant sections of the inim.it website, along with an “Intrusion Detection System Configurator” that helps the installer selected by INIM understand your specific needs, thereby enhancing the quality of the service provided.
If the service is made available via links accessible through other channels, including social media platforms, please note that you may be required to review and/or accept specific privacy policies and terms and conditions over which INIM has no ownership or control.
This Privacy Policy supplements the Website’s General Privacy Policy, to which we refer you for any matters not detailed herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller is INIM ELECTRONICS S.R.L. (a single-member limited liability company) with its registered office in Monteprandone (AP), in the Centobuchi area, at Via dei Lavoratori 10, Tax ID and VAT No. 01855460448. INIM has appointed a Data Protection Officer (DPO) who can be contacted at: dpo@inim.it.
2. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR DATA?
Your data is processed based on your consent and for the legitimate interests of the Data Controller. When processing data that can, directly or indirectly, identify you, INIM adheres to the principle of strict necessity. Therefore, the processing of your data is excluded when the purposes pursued in individual cases can be achieved through the use of anonymous data (such as, for example, in market research aimed at improving services) or through other methods that allow the User to be identified only when necessary or upon request by authorities and law enforcement agencies (such as, for example, data regarding traffic and your time spent on the website or your IP address).
3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSES?
3.1 Data provided directly by the user
This includes personal data (such as first name, last name, address, landline and cell phone numbers, and email address), which is necessary to respond to your inquiry and to prepare a personalized quote. The data provided may be used, subject to your express consent, to provide—via electronic means (email, SMS, MMS) and/or in print, or through direct contact with an INIM representative—industry information and commercial promotions for products and services distributed by the Data Controller (including through automated processes such as profiling).
3.2 Cookies
For information regarding our Cookie Policy, please refer to the Cookie Policy in the dedicated section of the website.
4. WHO DO WE SHARE YOUR DATA WITH?
In order to process your requests, your data is processed by INIM through its employees and data processors within the scope of their respective duties and in accordance with the instructions received, using appropriate methods and procedures, including electronic ones. Your data is disclosed to trusted third parties, namely selected installers within the INIM network, who handle your requests and, following contact, act as independent data controllers.
5. Is your data transferred abroad?
INIM currently processes your data without transferring it to countries outside the European Union or to countries that do not ensure adequate levels of protection for individuals. Privacy laws permit the transfer of personal data abroad subject to the user’s consent or where there is another legal basis and an adequate level of data protection is guaranteed. INIM is committed to ensuring that, should data be transferred abroad, this is done in full compliance with local and European Union legal principles and requirements, and that appropriate security measures are adopted to protect personal data in such countries/territories.
6. HOW WE PROCESS YOUR DATA AND HOW LONG WE RETAIN IT
Your personal data is processed using appropriate methods and procedures, including electronic and telecommunications means, and is safeguarded through the implementation of adequate organizational, technical, and security measures. No further processing activities are carried out on the data provided except for the sole purpose of verifying the quality of the service offered by INIM partners; please note that in order to provide you with this service, INIM may use remote communication tools with automated contact methods (such as: SMS, email, messages on web applications) and traditional methods (such as: telephone calls with an operator). Your personal data is retained for twenty-four months following your request, solely for the purpose of verifying the status of your request and your satisfaction with the service provided. Data processed for commercial promotion and profiling purposes (if your express consent has been obtained) is retained in accordance with applicable law and, in any case, until you revoke your consent to the processing of personal data.
7. WHAT ARE YOUR RIGHTS?
Privacy regulations (Articles 15–22 of the Regulation) You have the right to access your personal data at any time, as well as to have it corrected and/or supplemented if it is inaccurate or incomplete, to have it erased or to restrict its processing if the conditions are met, to object to its processing for reasons related to your particular situation, and to the portability of the data you have provided, where it is processed automatically for the services you have requested, within the limits set forth in the Regulation (Art. 20).
8. EXERCISING THE DATA SUBJECT'S RIGHTS
The data subject may at any time exercise the rights provided for in Articles 15 through 22 of the Regulation by contacting the Data Controller, “INIM ELECTRONICS S.R.L.” (a single-member limited liability company) with registered office in Monteprandone (AP), Centobuchi, at Via dei Lavoratori 10, Tax ID and VAT No. 01855460448, via email: privacy@inim.it.
9. UPDATES TO THIS POLICY
This Privacy Policy governs the processing of personal data provided by the User for the requested service and may be modified or updated, in whole or in part, including in light of changes to the laws or regulations governing the protection of personal data. Changes and updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will be binding as soon as they are published on the Website. INIM therefore invites Users to visit this page regularly to check for the publication of the most recent and updated Privacy Policy. For this purpose, the document indicates the date of the last update.
Last updated: January 30, 2025
Privacy - Contact Us
Notice for users requesting information via the form on the Inim website
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‘INIM ELECTRONICS S.R.L.’, a sole proprietorship (hereinafter ‘INIM’ or ‘Controller’), wishes to inform you that your personal data will be processed in accordance with the provisions of EU Regulation 679/2016 (‘GENERAL DATA PROTECTION REGULATION’ OR ‘GDPR’) and any specific local regulations applicable to the protection of personal data.
Below you will find all the necessary information regarding the data processing that ‘INIM’ will carry out on the personal data you provide to us by filling out the Contact form.
This Privacy Policy supplements, where applicable, the general Privacy Policy of the Website, to which reference is made for anything not detailed herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller is INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10, Tax ID and VAT No. 01855460448. INIM has appointed a Data Protection Officer (DPO) who can be contacted at the following address: dpo@inim.it.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?
Your personal data will be processed in order to respond to your contact request, as this processing is necessary.
Such data may also be processed to fulfill any legal obligations or to pursue a legitimate interest of INIM or third parties, in compliance with the conditions and restrictions set forth by current legislation. Express consent is therefore not required.
Based on the specific and optional consent you have provided, personal data may be processed by INIM to send you commercial and promotional communications regarding INIM’s services and products.
3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSE?
3.1 Data provided directly by the User
This is personal data (such as first name, last name, address, landline and mobile phone numbers, and email address) required to respond to your request for information.
The data you provide may be used, subject to your express consent, to send you—via electronic means (email, SMS, MMS) and/or in writing, or through direct contact with an INIM representative—industry information and promotional offers for products provided by the Data Controller.
3.2 Cookies
For information on the Cookie Policy, please refer to the Cookie Policy in the dedicated section of the Website.
4. TO WHOM WILL YOUR DATA BE DISCLOSED?
In order to process your requests, your personal data will be processed by INIM, which will rely on designated personnel and data controllers acting within the scope of their respective duties and in accordance with the instructions received, using appropriate methods and procedures, including IT tools.
5. Will your data be transferred abroad?
INIM currently processes your personal data without transferring it to countries outside the European Union or to countries that do not ensure an adequate level of personal data protection. The General Data Protection Regulation (GDPR) permits the transfer of personal data abroad with the User’s consent, or where there is a legal basis for such transfer and an adequate level of data protection is guaranteed. INIM undertakes to ensure that if data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate security measures will be taken to protect personal data in such countries or territories.
6. HOW DO WE PROCESS AND STORE YOUR DATA?
Your personal data will be processed using appropriate methods and procedures, including IT and telematic methods, and stored using adequate organizational, technical, and security measures.
The processing of your personal data will be strictly limited to the time necessary to respond to your contact request and to carry out any activities or operations arising from the subject of your request.
If data processing is carried out on the basis of legal provisions or in the face of a legitimate interest of INIM or of third parties, the processing of your personal data will be strictly limited to the time necessary to achieve the purposes for which the data is processed.
The data processed for marketing purposes (if your express consent has been obtained) will be stored in accordance with the provisions of current legislation and, in any case, until your consent for the processing of personal data is revoked.
7. WHAT ARE YOUR RIGHTS?
The privacy legislation (Articles 15–22 of the Regulation) guarantees you the right at all times to access data concerning you, as well as to correct and/or supplement such data if it is incorrect or incomplete, to request erasure or restriction of processing if the conditions are met, to object to processing for reasons related to your particular situation, and to data portability regarding the data you provided, where processed automatically for the services you requested, within the limits of the provisions of the Regulation (Art. 20).
8. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
The data subject may at any time exercise the rights set forth in Articles 15 through 22 of the Regulation by contacting “INIM ELECTRONICS S.R.L.”, a sole proprietorship with its registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori No. 10. Tax ID and VAT No. 01855460448, email: privacy@inim.it.
9. UPDATES TO THIS POLICY
This Privacy Policy governs the processing of personal data you provide for the requested service and may be modified or updated, in whole or in part, including in response to changes in laws or regulations governing the protection of personal data. Any changes or updates to this Privacy Policy will take effect as soon as they are published on the Website. INIM therefore encourages you to visit this page regularly to review the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of its last update.
Last updated: January 30, 2025
Privacy - Job Applications
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“INIM ELECTRONICS S.R.L.” Sole Proprietor Company (hereinafter “INIM” or “Holder”) wishes to inform you that your personal data will be processed in compliance with the provisions of EU Regulation 679/2016 (“GENERAL DATA PROTECTION REGULATION” OR “GDPR”) and any specific local regulations applicable to the protection of personal data.
Below you will find all the necessary information regarding the processing of personal data that “INIM” will carry out on the personal data you provide to us by completing and submitting your application form for any job opening listed on the relevant pages of the “Contacts” section of the inim.it website.
This Privacy Policy supplements the Website’s general Privacy Policy, to which reference is made for any matters not covered herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller is INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10, Tax ID and VAT No. 01855460448. INIM has appointed a Data Protection Officer (DPO) who can be contacted at the following address: dpo@inim.it.
2. WHAT IS THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA?
The legal basis for the processing is INIM’s legitimate interest in selecting personnel in accordance with its needs.
The data subject’s consent is in any case given once the form has been completed and submitted.
Such data may also be processed to fulfill any regulatory and/or legal obligations, for example in the event that you wish to establish an employment relationship and/or a business collaboration with the data subject, or to pursue a legitimate interest of INIM, in compliance with the conditions and restrictions set forth by current legislation.
3. WHAT DATA DO WE COLLECT AND FOR WHAT PURPOSE?
3.1 Data provided directly by the User
Your personal data will be processed for the purpose of following up on your application and the submission of your Curriculum Vitae (hereinafter “CV”), as such processing is necessary.
In this context, INIM generally processes general personal data, including any photographs accompanying the CV.
In the event that your CV contains any specific or sensitive data, INIM will process only the data relevant to the assessment of the professional profile, within the limits in which the collection of such information is strictly necessary. For this reason as well, INIM kindly recommends that candidates always indicate their consent to the processing of the data in their CVs in accordance with the provisions of the Regulations.
Without prejudice to the data subject’s freedom to provide personal data, it should be noted that failure to provide such data makes it impossible for INIM to consider the candidacy in the context of personnel evaluation and selection.
3.2 Cookies
For information on the Cookie Policy, please refer to the Cookie Policy in the dedicated section of the Website.
4. WHO WILL YOUR DATA BE SHARED WITH?
Your personal data will be processed in an appropriate manner and using relevant procedures, including IT systems, by INIM employees and contractors who are involved in the recruitment process within their respective roles and in accordance with the instructions they have received. Such data may also be disclosed:
- to third parties, designated as data processors, who provide ancillary services that are essential to INIM’s business operations;
- to the companies within the group to which INIM belongs, or, in any case, to parent companies, subsidiaries, or affiliates, in order to assess the possibility of collaboration or hiring, in accordance with the legitimate interests of the Data Controller.
Your personal data will not be published, displayed, or disclosed, unless required by law, regulation, or EU legislation.
5. Will your data be transferred abroad?
INIM currently processes your data without transferring it to countries outside the European Union or to countries that do not ensure an adequate level of personal data protection. The General Data Protection Regulation (GDPR) permits the transfer of personal data abroad with the User’s consent, or where there is a legal basis for such transfer and an adequate level of data protection is guaranteed. INIM undertakes to ensure that if data is transferred abroad, it will be done in full compliance with the principles and requirements of local and European Union law, and that appropriate security measures will be taken to protect personal data in those countries or territories.
6. HOW DO WE PROCESS YOUR DATA AND FOR HOW LONG
Your personal data will be processed using appropriate methods and procedures, including IT and telematic methods, and stored using adequate organizational, technical, and security measures.
Your personal data will be stored for a maximum period of 36 months from the date of receipt of your CV, or from the last update of your CV that you provide to us.
If the processing is carried out on the basis of legal provisions or in the face of a legitimate interest of INIM or of third parties, the processing of your personal data will be limited exclusively to the time strictly necessary to achieve the purposes for which the processing of the data is required.
7. WHAT ARE YOUR RIGHTS
The privacy legislation (Articles 15–22 of the Regulation) guarantees you the right at all times to access data concerning you, as well as to correct and/or supplement such data if it is incorrect or incomplete, to request erasure or restriction of processing if the conditions are met, to object to processing for reasons related to your particular situation, and to data portability regarding the data you provided, where processed automatically for the services you requested, within the limits of the provisions of the Regulation (Art. 20).
8. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
The data subject may at any time exercise the rights provided for in Articles 15 through 22 of the Regulation by contacting INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Locality Centobuchi, Via dei Lavoratori, No. 10. Tax ID and VAT No. 01855460448 or by email: privacy@inim.it
9. UPDATES TO THIS POLICY
This Privacy Policy governs the processing of personal data provided by the User when submitting job applications through the pages of the Contacts section of the Website inim.it and may be modified or updated, in whole or in part, including in light of any changes to the laws or regulations governing the protection of personal data. Any changes to or updates of this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective as soon as they are published on the Website. INIM, therefore, encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of its last update.
Last updated: January 30, 2025
Privacy - Webinar
Privacy Notice for participants in online courses and events organized by “Inim Electronics s.r.l.” (a single-member limited liability company) via the GoToWebinar platform
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EU Regulation 2016/679 (hereinafter, “General Data Protection Regulation” or “GDPR”) sets forth both the rules regarding the protection of individuals with respect to the processing of personal data and those regarding the free movement of personal data. The Regulation protects the fundamental rights and freedoms of individuals, and in particular their right to the protection of personal data.
This Privacy Policy is provided pursuant to Articles 13 and 14 of the General Data Protection Regulation, in compliance with the principles contained therein.
Any personal data will be collected only to the extent necessary for the purposes described in this Privacy Policy, and processing will be based on the principles of fairness, lawfulness, and transparency.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller is INIM ELECTRONICS S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10, Tax ID and VAT No. 01855460448. INIM has appointed a Data Protection Officer (DPO) who can be contacted at the following address: dpo@inim.it.
2. PURPOSE OF PROCESSING, LEGAL BASES, AND RETENTION PERIODS FOR PERSONAL DATA
The personal data you have provided will be used by “INIM ELECTRONICS S.r.l.”, a sole proprietorship (Data Controller), based on the consent you provided upon registration, for the following purposes:
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the management of your participation in the course and/or web event, including all administrative, logistical, and organizational requirements, such as, for example:
- notification by INIM of the course results, where required;
- the issuance of a Certificate of Participation in the course and/or certification, where applicable;
- the distribution of questionnaires regarding satisfaction with the training course you attended, which you are free to complete or not.
The collected data will be retained for a period not exceeding the time required to achieve the purposes for which it was processed (“Principle of data minimization,” Article 5 of the GDPR) and/or for the time necessary to comply with legal obligations.
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the sending, via email, of invitations to future events and courses organized by INIM: for this processing, the data will be retained until the data subject unsubscribes;
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the sending of commercial communications: for such processing, the expected retention period is 24 months.
3. COMMUNICATION AND/OR DISCLOSURE OF PERSONAL DATA
Upon registration, your personal data will be shared with LogMeIn, Inc., the owner of the GoToWebinar platform, to enable you to access the courses. GoToWebinar’s privacy policy is available on the registration form.
Your personal data will not be disclosed to any third parties beyond those described above, unless required by law or regulations governing the issuance of certificates for the courses you have attended.
4. MANDATORY CONSENT
The provision of your personal data for the purposes referred to in point 2(a) is mandatory. Failure to provide this data will prevent you from registering for and/or participating in the course. For the additional purposes referred to in point 2(b) and (c), consent is optional and does not preclude your ability to participate in INIM courses and events.
5. PROCESSING METHOD
Your personal data will be processed both in paper form and using computer and data transmission methods, in accordance with organizational procedures and logic strictly related to the aforementioned purpose and in compliance with the security measures prescribed by the GDPR. The collected data will not be transferred abroad. Privacy legislation permits the transfer of personal data abroad with the User’s consent, or where there is a legal basis for such transfer and where an adequate level of data protection is guaranteed. Any transfer of data to countries outside the European Union will take place, in all cases, in compliance with the provisions of European legislation regarding the transfer of personal data to third countries or international organizations, in particular pursuant to Articles 44, 45, 46, 47, and 49 of the General Data Protection Regulation.
6. Automated Decision-Making Processes
“INIM” does not process your personal data using automated decision-making processes.
7. RIGHTS OF THE DATA SUBJECT
You, as the data subject, have the right to request from “INIM ELECTRONICS S.r.l.” Sole Proprietorship (Data Controller), at any time by means of a specific request, the cessation of the processing of the data covered by this privacy policy, as well as access to your personal data, the correction or deletion of such data, or the restriction of any processing concerning your personal data, or to object to such processing, as well as the right to data portability, pursuant to Articles 15 through 22 of the GDPR, and the right to lodge a complaint with the supervisory authority (Guarantor for the Protection of Personal Data).
8. EXERCISE OF THE RIGHTS OF THE DATA SUBJECT
You, as the data subject, may at any time exercise the rights set forth in Articles 15 through 22 of the GDPR with respect to the Data Controller “INIM ELECTRONICS S.R.L.”, a sole proprietorship with its registered office in Monteprandone (AP), in the municipality of Centobuchi, at Via dei Lavoratori No. 10. Tax ID and VAT No. 01855460448, email: privacy@inim.it.
9. UPDATES TO THIS PRIVACY POLICY
This Privacy Policy governs the processing of your Personal Data provided when registering for courses and events organized by INIM via the GoToWebinar platform and may be amended or updated, in whole or in part, including in response to changes in the laws or regulations governing the protection of Personal Data. Any changes or updates to this Privacy Policy will be communicated to Users as soon as they are adopted. For this purpose, the document includes the date of its last update.
Last updated: January 30, 2025
Privacy - Inim App
Privacy Notice for Users of theInim HomeApp
Read the Inim Home document
INIM S.R.L., a sole proprietorship (hereinafter alsoINIMor “Supplier”), thanks you for your interest in this app. Protecting your privacy as an app user is a priority forINIM”.
Hereinafter, “INIM” provides you with information regarding the processing of personal data in connection with the App. “Personal data” refers to information relating to an identified or identifiable natural person.
This Policy supplements the INIM CLOUD Policy, which should be consulted for any matters not covered in detail herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The Data Controller is INIM S.R.L., a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori No. 10, Tax ID and VAT No. 01855460448.
INIM appointed a Data Protection Officer (DPO) who can be contacted at the following address: inim.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA
2.1 Categories of data
“INIM” processes the personal data that the User provides when registering on the INIM CLOUD with a Private User profile and when installing and using the App. Consent to the transmission of such data is not required by law, nor is it necessary for the purposes of entering into a contractual agreement; however, any refusal or withdrawal of consent may compromise the proper functioning of the App or limit its use. The User can enable or disable data transmission at any time via their profile settings in the INIM CLOUD.
2.2 Purpose of data processing
INIMprocesses the personal data described above in accordance with the principles of the data protection regulations currently in force. The processing is carried out for the purposes described below.
a) Management of the services offered by the app
‘INIM’ processes personal data for the purpose of fulfilling the User’s request to register for use of the App (including the provision of the App and its features) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing ceases. Any further storage or processing of data will be permitted only under the conditions set forth in section 5.
With regard to data backup management, it should be noted that:
- the data is backed up in the cloud;
- Backup is activated automatically upon login;
- The user can disable data backup before configuring their security system;
- Users can disable data backup after configuring their security system by selecting the appropriate option in the app: ‘Settings’ > ‘Data backup to the cloud’ and deselecting ‘Backup active’;
- Once the backup is disabled, the user can choose whether or not to cancel the backup via the cloud.
With regard to video surveillance, it should be noted that:
- The relevant service is activated by the user in the cloud and in the app
- The information collected consists solely of images and short videos (stored in the cloud with a maximum duration of 15 seconds) related to the event that triggered the alarm and the affected area, and these remain available in the app for a limited period of time set by the primary private user in the “Cloud Storage and Privacy” section of the app
b) Consent to the processing of personal data
Where the User has given consent to the Supplier for the processing of their personal data for additional purposes (see point 4), such data processing will be based on this consent. Consent is always optional and may be freely revoked at any time, including by sending a written email to
privacy@inim.it.
The withdrawal of consent does not affect the lawfulness of any data processing carried out up to that point on the basis of the previously given consent, nor the right to further process the aforementioned data on another legal basis, for example to fulfill legal obligations (see point d).
c) Pursuit of legitimate interests
Where necessary, “INIM” processes the User’s personal data to protect its own legitimate interests or those of third parties. Maintaining the functionality and security of “INIM”’s IT systems falls within the scope of these legitimate interests. Generally, personal data will be deleted when further processing or storage of such data is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be permitted solely under the conditions referred to in point 5.
d) Compliance with legal obligations or matters related to purchases made by the user
INIMis subject to compliance with legal obligations and provisions, such as those related to data retention in accordance with commercial and tax laws. Therefore,INIMprocesses the User’s personal data to the extent necessary to fulfill legal obligations; however, it is understood that a User’s personal data will be disclosed only when there is a legal obligation to do so in relation to public order and judicial authorities.
3. Push Notifications
Users may consent to receiving push notifications on their devices, either at the time of registration or at a later date, by enabling the relevant features in the INIM CLOUD control panel. The push notifications sent by the app to users may pertain to:
-
Technical information derived from events:
- resulting from events recorded on the control panels linked to the account (e.g., faults, anomalies)
- relating to alarms from the control panel or from a video surveillance device (NVR – network video recorder)
- related to the management of the User's Cloud account (e.g., insufficient Cloud storage space, expiration of services)
- related to the broader operational management of the Cloud (e.g., the Cloud will be down on [date] at [time]...)
- regarding new product features, firmware and software updates, etc.
Users can enable these notifications in their personal area of the CLOUD or in the app.
-
Commercial information.
These notifications are based on the consent provided by the user when registering on the CLOUD to receive such information. Push notifications can be managed, disabled, and re-enabled at any time directly through the pages of the user’s INIM CLOUD account.
4. RECIPIENTS OF PERSONAL DATA
4.1 Disclosure to third parties
If the User uses services provided by service providers and other third parties within the App,INIMmay transfer the User’s personal data to such third parties, but only to the extent necessary for the development and use of the App and its respective functions (see section 2.2 a), for the purpose of pursuing legitimate interests of its own or those of third parties (see section 2.2 c), or where the User has previously consented to such transfer (see section 2.2 b). Service providers, carefully selected byINIM, are regularly monitored by “INIM”, particularly with regard to the accuracy of the processing and protection of personal data made available from time to time. All service providers are bound byINIMto maintain confidentiality and to comply with applicable laws.
4.2 Recipients of data in third countries
The Supplier will not transfer the User’s personal data to recipients located in countries outside the EU/EEA.
4.3 State institutions or authorities
Personal data is disclosed to government agencies or authorities only to the extent permitted by applicable law (see section 2.2(d)).
5. TERMS OF STORAGE AND CANCELLATION
INIMstores and processes the User’s personal data solely for the period strictly necessary for the respective purpose (see section 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms permitted for further purposes pursuant to section 2.2, such as for the fulfillment of legal obligations (e.g., retention obligations under tax and commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis for such further processing.
6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION
In addition to the aforementioned rules, in accordance with the provisions of the General Data Protection Regulation (GDPR) and within the scope of its application, the following provisions apply.
6.1 Legal basis
The processing of personal data described in section 2.2 is based on the legal grounds listed below.
- Data processing for the performance of the contract: Article 6(1)(b) of the GDPR
- Data processing based on the data subject’s consent: Article 6(1)(a) of the GDPR
- Data processing for the purpose of pursuing legitimate interests: Article 6(1)(f) of the GDPR
- Data processing for the purpose of complying with legal obligations: Article 6(1)(c) of the GDPR
6.2 Protection in the case of suppliers in third countries
Where, in the opinion of the European Union, an “adequate level of protection” for the processing of personal data in compliance with EU standards cannot be guaranteed, the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules, or approved codes of conduct shall apply as suitable safeguards pursuant to Article 46 of the GDPR in the event of the use of service providers (see point 4). An electronic copy of the relevant extracts can be provided upon specific request submitted to the Data Protection Officer.
6.3 Rights of the data subject
As the data subject, the User has the right to access personal data (Art. 15 of the GDPR), to have it corrected (Art. 16 of the GDPR), to have it erased (Art. 17 of the GDPR), to restrict processing (Art. 18 of the GDPR), and to data portability (Art. 20 of the GDPR).
6.4 Right to object
For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of Article 6(1)(e) of the GDPR (processing necessary for the public interest) or Article 6(1)(f) of the GDPR (processing based on a balancing of interests). In the event of an objection by the User, the relevant personal data will be processed by the Supplier where it is possible to demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or where the processing is necessary for the establishment, exercise, or defense of legal claims.
6.5 Complaints
If the User believes that the processing of their personal data may constitute a violation of the law, they have the right to file a complaint with a competent data protection authority (Art. 77 of the GDPR).
7. EXERCISE OF RIGHTS
The User may exercise the rights referred to in section 6 by sending a written email to inim.
8. UPDATES TO THIS PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL DATA
The Supplier reserves the right to amend or update, in whole or in part, this Privacy Policy, including in light of changes to the laws or regulations governing the protection of personal data. Such amendments or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon their publication on the Website. “INIM” therefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of the last update.
Last updated: January 30, 2025
Read the Tech Security document
“INIM ELECTRONICS S.R.L.” Sole Proprietorship (hereinafter also “INIM” or “Supplier”) thanks you for your interest in this App. Protecting your privacy as a User of the Installer App (hereinafter “User” or “Users” or “Installer(s)”) is a priority for “INIM”.
Hereinafter, “INIM” informs you about the processing of personal data carried out in relation to the App. “Personal data” is information that refers to an identified or identifiable natural person.
This Policy supplements that of the INIM CLOUD, to which reference should be made for anything not mentioned in detail herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller isINIM S.R.L.”, a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10. Tax ID and VAT No. 01855460448.
INIM appointed a Data Protection Officer (DPO) who can be contacted at the following address: inim.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA
2.1 Categories of data
“INIM” processes the personal data that the User provides when registering on the INIM CLOUD with an Installer User profile and during the installation and use of the App. Consent to the transmission of such data is not required by law, nor is it necessary for the purposes of entering into a contractual agreement; however, any refusal or withdrawal of consent may compromise the proper functioning of the App or limit its use. The User can enable or disable data transmission at any time via their profile settings in the INIM CLOUD.
2.2 Purpose of data processing
INIMprocesses the personal data described above in accordance with the principles of the data protection regulations currently in force. The processing is carried out for the purposes described below.
a) Management of the services offered by the app
‘INIM’ processes personal data for the purpose of fulfilling the User’s request to register for use of the App (preparation of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing of such data ceases. Any further storage or processing of data will be permitted only under the conditions set forth in point 5. Please note that, as provided for in the INIM CLOUD, the data of Private Users with control panels linked to the Installer’s profile are processed by the Installer as an independent Data Controller.
With regard to video surveillance, it should be noted that:
- The relevant service is activated by the Installer in the Cloud and in the app
- The information collected consists exclusively of images and short videos (stored in the cloud with a maximum duration of 15 seconds) related to the event that triggered the alarm and the affected area. These can only be viewed by the installer if their supervision is active, and solely for the purpose of verifying that the system is functioning correctly. These images and videos remain available in the app for a limited period, as configured by the primary private user in the “Cloud Space and Privacy” section of the INIM HOME app.
b) Consent to the processing of personal data
Where the User has given consent to the Supplier for the processing of their personal data for additional purposes (see point 4), such data processing will be based on this consent. Consent is always optional and may be freely revoked at any time, including by sending a written email to privacy@inim.it.
The withdrawal of consent does not affect the lawfulness of any data processing carried out up to that point on the basis of the previously given consent, nor the right to further process the aforementioned data on another legal basis, for example to fulfill legal obligations (see point d).
c) Pursuit of legitimate interests
Where necessary, “INIM” processes the User’s personal data to protect its own legitimate interests or those of third parties. Maintaining the functionality and security of “INIM”’s IT systems falls within the scope of these legitimate interests. Maintaining the functionality and security of “INIM”’s IT systems falls within the scope of these legitimate interests.
Generally, personal data will be deleted when further processing or storage of the same is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be permitted solely under the conditions referred to in point 5.
d) Compliance with legal obligations or matters related to purchases made by the user
INIMis subject to compliance with legal obligations and provisions, such as those related to data retention in accordance with commercial and tax laws. Therefore,INIMprocesses the User’s personal data to the extent necessary to fulfill legal obligations; however, it is understood that a User’s personal data will be disclosed only when there is a legal obligation to do so in relation to public order and judicial authorities.
3. Push Notifications
Users may consent to receiving push notifications on their devices, either at the time of registration or at a later time, by enabling the relevant features in the INIM CLOUD control panel or in the app.
The push notifications the app sends to the installer may include:
-
Technical information:
- resulting from events recorded on the control panels connected to the account (e.g., faults, anomalies);
- relating to alarms from the control panel and, if monitoring is active, from a video surveillance device (NVR – network video recorder);
- related to the management of the User's Cloud account (e.g., insufficient Cloud storage space, expiration of services);
- related to the broader operational management of the Cloud (e.g., the Cloud will be down on [date] at [time]...)
- regarding new product features, firmware and software updates, etc.
Users can enable these notifications in their personal area of the CLOUD.
-
Commercial information.
These notifications are based on the consent provided by the data subject upon registering on the CLOUD to receive such information.
Push notifications can be managed, disabled, and re-enabled at any time directly through the pages of the User’s INIM CLOUD account.
4. RECIPIENTS OF PERSONAL DATA
4.1 Disclosure to third parties
If the User uses services provided by service providers and other third parties within the App,INIMmay transfer the User’s personal data to such third parties, but only to the extent necessary for the development and use of the App and its respective functions (see section 2.2 a), for the purpose of pursuing legitimate interests of its own or those of third parties (see section 2.2 c), or where the User has previously consented to such transfer (see section 2.2 b). Service providers, carefully selected byINIM, are regularly monitored by “INIM”, particularly with regard to the accuracy of the processing and protection of personal data made available from time to time. All service providers are bound byINIMto maintain confidentiality and to comply with applicable laws.
4.2 Recipients of data in third countries
The Supplier will not transfer the User’s personal data to recipients located in countries outside the EU/EEA.
4.3 State institutions or authorities
Personal data is disclosed to government agencies or authorities only to the extent permitted by applicable law (see section 2.2(d)).
5. TERMS OF STORAGE AND CANCELLATION
INIMstores and processes the User’s personal data solely for the period strictly necessary for the respective purpose (see section 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms permitted for further purposes pursuant to section 2.2, such as for the fulfillment of legal obligations (e.g., retention obligations under tax and commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis for such further processing.
6. SUPPLEMENTARY REGULATIONS FOR THE EUROPEAN UNION
In addition to the aforementioned regulations, in accordance with the provisions of the General Data Protection Regulation (GDPR) and within the scope of its application, the following provisions apply.
6.1 Legal basis
The processing of personal data described in section 2.2 is based on the legal grounds listed below.
- Data processing for the performance of the contract: Article 6(1)(b) of the GDPR
- Data processing based on the data subject’s consent: Article 6(1)(a) of the GDPR
- Data processing for the purpose of pursuing legitimate interests: Article 6(1)(f) of the GDPR
- Data processing for the purpose of complying with legal obligations: Article 6(1)(c) of the GDPR
6.2 Protection in the case of suppliers in third countries
Where, in the opinion of the European Union, an “adequate level of protection” for the processing of personal data in compliance with EU standards cannot be guaranteed, the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules, or approved codes of conduct shall apply as suitable safeguards pursuant to Article 46 of the GDPR in the event of the use of service providers (see point 4). An electronic copy of the relevant extracts can be provided upon specific request submitted to the Data Protection Officer.
6.3 Rights of the data subject
As the data subject, the User has the right to access personal data (Art. 15 of the GDPR), to have it corrected (Art. 16 of the GDPR), to have it erased (Art. 17 of the GDPR), to restrict processing (Art. 18 of the GDPR), and to data portability (Art. 20 of the GDPR).
6.4 Right to object
For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of Article 6(1)(e) of the GDPR (processing necessary for the public interest) or Article 6(1)(f) of the GDPR (processing based on a balancing of interests). In the event of an objection by the User, the relevant personal data will be processed by the Supplier where it is possible to demonstrate compelling and legitimate grounds that override the interests, rights, and freedoms of the User, or where processing is necessary for the purposes of establishing, exercising, or defending legal claims.
6.5 Complaints
If the User believes that the processing of their personal data may constitute a violation of the law, they have the right to file a complaint with a competent data protection authority (Art. 77 of the GDPR).
7. EXERCISE OF RIGHTS
The User may exercise the rights referred to in section 6 by sending a written email to inim.
8. UPDATES TO THIS PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL DATA
The Supplier reserves the right to amend or update, in whole or in part, this Privacy Policy, including in light of changes to the laws or regulations governing the protection of personal data. Such amendments or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon their publication on the Website. “INIM” therefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. For this purpose, the document indicates the date of the last update.
Last updated: January 30, 2025
Read the Inim document
INIM S.R.L., a sole proprietorship (hereinafter alsoINIMor “Supplier”), thanks you for your interest in this app. Protecting your privacy as an app user is a priority forINIM”.
Hereinafter,INIMprovides you with information regarding the processing of personal data in connection with the App. “Personal data” refers to information relating to an identified or identifiable natural person.
This Privacy Policy supplements the INIM CLOUD Privacy Policy, which should be consulted for any matters not covered in detail herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller isINIM S.R.L.”, a sole proprietorship with its registered office in Monteprandone (AP), in the municipality of Centobuchi, at Via dei Lavoratori 10. Tax ID and VAT No. 01855460448.
INIM appointed a Data Protection Officer (DPO) who can be contacted at the following address: inim.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR PERSONAL DATA?
2.1 Categories of data
“INIM” processes the personal data that the User provides when registering on the INIM CLOUD (either with an Installer profile or a Private User profile) and when installing and using the App. Consent to the transmission of such data is not required by law, nor is it necessary for the purposes of entering into a contractual agreement; however, any refusal or withdrawal of consent may compromise the proper functioning of the App or limit its use. The User can enable or disable the transmission of personal data at any time through their INIM CLOUD profile settings.
2.2 Purpose of processing personal data
INIMprocesses the data described above in accordance with the principles of the data protection regulations currently in force. The processing is carried out for the purposes described below.
- Management of the services offered by the APP
“INIM” processes personal data for the purpose of fulfilling the User’s registration request for the use of the App (configuration of the App and its functions) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing ceases. Any further storage or processing of data will be permitted only under the conditions referred to in point 5. It should be noted that, as provided for in the INIM CLOUD, the data from the fire detection control panels of Private users connected to an Installer profile are processed by the Installer, who acts as an independent data controller. - Consent to the processing of personal data
Where the User has given consent to the Supplier for the processing of their personal data for additional purposes (see point 4), such data processing will take place on the basis of this consent. Declarations of consent are always optional and may be freely revoked at any time, including by sending a written email to inim. The withdrawal of consent does not affect the lawfulness of any data processing carried out up to that point on the basis of the previously given consent, nor the right to further process the aforementioned data on another legal basis, for example to fulfill legal obligations (see point d). - Pursuit of legitimate interests
Where necessary,INIMprocesses the User’s personal data to protect its own legitimate interests and/or those of third parties. Maintaining the functionality and security ofINIMIT systems falls within the scope of these legitimate interests. Generally, personal data will be deleted when further processing or storage of such data is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be permitted solely under the conditions referred to in point 5. - Compliance with legal obligations or obligations related to purchases made by the User
INIMis subject to compliance with legal obligations and provisions, such as obligations related to data retention in accordance with the provisions of commercial and tax law. Therefore,INIMprocesses the User’s personal data to the extent necessary for the fulfillment of legal obligations, provided, however, that an individual User’s personal data will be disclosed only in the event of a legal obligation toward public order and judicial authorities.
3. Push Notifications
Users may consent to receiving push notifications on their devices, either at the time of registration or at a later time, by enabling the appropriate settings in the INIM CLOUD control panel.
The push notifications the app sends to the user may include:
-
Technical information derived from events:
- recorded onINIMfire detection control panels linked to their account (e.g., faults, anomalies, compilation of the Installation Register);
- related to the management of the User’s Cloud account (e.g., running out of Cloud storage, expiration of services);
- related to the general operational management of the Cloud account (e.g., running out of Cloud storage, expiration of services);
- related to the broader operational management of the Cloud (e.g., the Cloud will be down on [date] at [time]…);
- for informational purposes (e.g., new product features, firmware and software updates).
Users can enable these notifications in their personal area of the CLOUD.
-
Commercial information.
These notifications are based on the consent provided by the data subject upon registering on the CLOUD to receive such information.
Push notifications can be managed, disabled, and re-enabled at any time directly through the pages of the user’s INIM CLOUD account.
4. RECIPIENTS OF PERSONAL DATA
4.1 Disclosure to third parties
If, within the App, the User uses services provided by service providers and other third parties,INIMmay transfer the User’s personal data to such third parties, but only to the extent necessary for the development and use of the App and its respective functions (see point 2.2 a), for the purpose of pursuing legitimate interests of its own and/or those of third parties (see point 2.2 c), or where the User has previously consented to such transfer (see point 2.2 b). Service providers, carefully selected byINIM,INIMare regularly reviewed by the company, particularly with regard to the accuracy of the processing and protection of personal data made available from time to time. All service providers are bound byINIMto maintain confidentiality and to comply with applicable laws.
4.2 Recipients of data in third countries
The Supplier will not transfer the User’s personal data to recipients located in countries outside the EU/EEA.
4.3 State institutions or authorities
Personal data is disclosed to government agencies or authorities only to the extent permitted by applicable law (see section 2.2(d)).
5. TERMS OF STORAGE AND CANCELLATION
INIMstores and processes the User’s personal data solely for the period strictly necessary for the respective purpose (see section 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms permitted for further purposes pursuant to section 2.2, such as for the fulfillment of legal obligations (e.g., retention obligations under tax and commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis for such further processing.
6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION
In addition to the aforementioned rules, in accordance with the provisions of the General Data Protection Regulation (GDPR) and within the scope of its application, the following provisions apply.
6.1 Legal basis
The processing of personal data described in section 2.2 is based on the legal grounds listed below.
- Data processing for the performance of the contract: Article 6(1)(b) of the GDPR.
- Data processing based on the data subject’s consent: Article 6(1)(a) of the GDPR.
- Data processing for the purpose of pursuing legitimate interests: Article 6(1)(f) of the GDPR.
- Data processing for the purpose of complying with legal obligations: Article 6(1)(c) of the GDPR.
6.2 Protection in the case of suppliers in third countries
Where, in the opinion of the European Union, an “adequate level of protection” for the processing of personal data in compliance with EU standards is not guaranteed, such as appropriate safeguards pursuant to Article 46 of the GDPR in the case of the use of service providers (see point 4), the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules, or approved codes of conduct shall apply. An electronic copy of the relevant extracts can be provided upon specific request submitted to the Data Protection Officer.
6.3 Rights of the data subject
As the data subject, the User has the right to access their personal data (Art. 15 of the GDPR), to have it corrected (Art. 16 of the GDPR), to have it erased (Art. 17 of the GDPR), to restrict processing (Art. 18 of the GDPR), and to data portability (Art. 20 of the GDPR).
6.4 Right to object
For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of Article 6(1)(e) of the GDPR (processing necessary for the public interest) or Article 6(1)(f) of the GDPR (processing based on a balancing of interests). In the event of an objection by the User, the relevant personal data will be processed by the Supplier where it is possible to demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or where the processing is necessary for the establishment, exercise, or defense of legal claims.
6.5 Complaints
If the User believes that the processing of their personal data may constitute a violation of the law, the User has the right to file a complaint with a competent data protection authority (Art. 77 of the GDPR).
7. EXERCISE OF RIGHTS
The User may exercise the rights referred to in section 6 by sending an email to inim.
8. UPDATES TO THIS PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL DATA
The Supplier reserves the right to amend or update, in whole or in part, this Privacy Policy, including in response to changes in the laws or regulations governing the protection of personal data. Any such amendments or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon publication.
INIMtherefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. To this end, the document includes the date of the last update.
Last updated: January 30, 2025
Read the Inim Home document
INIM S.R.L., a sole proprietorship (hereinafter alsoINIMor “Supplier”), thanks you for your interest in this App. Protecting your privacy as an App User is a priority forINIM”. Hereinafter,INIMinforms you about the processing of personal data carried out in relation to the App. “Personal data” is information that refers to an identified or identifiable natural person.
This Policy supplements the INIM CLOUD Policy, which should be consulted for any matters not covered in detail herein.
1. THE DATA CONTROLLER AND THE DATA PROTECTION OFFICER (DPO)
The data controller isINIM S.R.L.”, a sole proprietorship with its registered office in Monteprandone (AP), Centobuchi, Via dei Lavoratori 10. Tax ID and VAT No. 01855460448.
INIM appointed a Data Protection Officer (DPO) who can be contacted at the following address: inim.
2. WHAT IS THE LEGAL AND REGULATORY FRAMEWORK FOR THE PROCESSING OF YOUR DATA?
2.1 Categories of data
“INIM” processes the personal data that the User provides when registering on the INIM CLOUD with a Private User profile and when installing and using the App. Consent to the transmission of such data is not required by law, nor is it necessary for the purposes of entering into a contractual agreement; however, any refusal or withdrawal of consent may compromise the proper functioning of the App or limit its use.
Users can enable or disable data transmission at any time through their profile settings using the options available in the INIM HOME P2P app and INIM CLOUD.
2.2 Purpose of data processing
INIMprocesses the personal data described above in accordance with the principles of the data protection regulations currently in force. The processing is carried out for the purposes described below.
a) Management of the services offered by the app
INIMprocesses personal data for the purpose of fulfilling the User’s request to register for use of the App (including the provision of the App and its features) to the extent strictly necessary. Generally, personal data will be deleted as soon as the need for further processing ceases. Any further storage or processing of data will be permitted only under the conditions set forth in section 5.
With regard to data backup management, it should be noted that:
- the data is backed up in the cloud;
- Backup is activated automatically upon login;
- The user can disable data backup before configuring their security system;
- The user can disable data backup after configuring their security system via the appropriate option in the app: 'Settings' > 'Data backup to the cloud' and deselect 'Backup active';
- Once the backup is disabled, the user can choose whether or not to cancel the backup via the Cloud.
b) Consent to the processing of personal data
Where the User has given consent to the Supplier for the processing of their personal data for additional purposes (see point 4), such data processing will take place on the basis of this consent. Consent is always optional and may be freely revoked at any time, including by sending a written email to inim.
The withdrawal of consent does not affect the lawfulness of any data processing carried out up to that point on the basis of the previously given consent, nor the right to further process the aforementioned data on another legal basis, for example to fulfill legal obligations (see point d).
c) Pursuit of legitimate interests
Where necessary,INIMprocesses the User’s personal data to protect its own legitimate interests or those of third parties. Maintaining the functionality and security ofINIMIT systems falls within the scope of these legitimate interests. Generally, personal data will be deleted when further processing or storage of such data is no longer necessary for the protection of the legitimate interests pursued from time to time. Any further storage or processing of data will be permitted solely under the conditions referred to in point 5.
d) Compliance with legal obligations or matters related to purchases made by the user
INIMis subject to compliance with legal obligations and provisions, such as those related to data retention in accordance with commercial and tax laws. Therefore,INIMprocesses the User’s personal data to the extent necessary to fulfill legal obligations; however, it is understood that a User’s personal data will be disclosed only when there is a legal obligation to do so in relation to public order and judicial authorities.
3. Push Notifications
Users may consent to receiving push notifications on their devices, either at the time of registration or at a later time, by enabling the appropriate settings in the INIM CLOUD control panel.
The push notifications the app sends to the user may include:
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Technical information derived from events:
- recorded on the control panels linked to the User's account (e.g., faults, anomalies);
- related to the management of the User's Cloud account (e.g., insufficient Cloud storage space, expiration of services);
- related to the broader operational management of the Cloud (e.g., the Cloud will be down on [date] at [time]…);
- for informational purposes (e.g., new product features, firmware and software updates).
Users can enable these notifications in their personal area of the CLOUD.
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Commercial information
These notifications are based on the consent provided by the data subject upon registering with CLOUD to receive such information.
Push notifications can be managed, disabled, and re-enabled at any time directly through the pages of the User’s INIM CLOUD account.
4. RECIPIENTS OF PERSONAL DATA
4.1 Disclosure to third parties
If the User uses services provided by service providers and other third parties within the App,INIMmay transfer the User’s personal data to such third parties, but only to the extent necessary for the development and use of the App and its respective functions (see section 2.2 a), for the purpose of pursuing legitimate interests of its own or those of third parties (see section 2.2 c), or where the User has previously consented to such transfer (see section 2.2 b). Service providers, carefully selected byINIM, are regularly monitored by “INIM”, particularly with regard to the accuracy of the processing and protection of personal data made available from time to time. All service providers are bound byINIMto maintain confidentiality and to comply with applicable laws.
4.2 Recipients of data in third countries
The Supplier will not transfer the User’s personal data to recipients located in countries outside the EU/EEA.
4.3 State institutions or authorities
Personal data is disclosed to government agencies or authorities only to the extent permitted by applicable law (see section 2.2(d)).
5. TERMS OF STORAGE AND CANCELLATION
INIMstores and processes the User’s personal data solely for the period strictly necessary for the respective purpose (see section 2.2). Beyond this period, the storage and processing of personal data take place exclusively within the terms permitted for further purposes pursuant to section 2.2, such as for the fulfillment of legal obligations (e.g., retention obligations under tax and commercial law). In such cases, the Supplier limits the further processing of data to the aforementioned purposes and the legal basis for such further processing.
6. SUPPLEMENTARY RULES FOR THE EUROPEAN UNION
In addition to the aforementioned rules, in accordance with the provisions of the General Data Protection Regulation (GDPR) and within the scope of its application, the following provisions apply.
6.1 Legal basis
The processing of personal data described in section 2.2 is based on the legal grounds listed below.
- Data processing for the performance of the contract: Article 6(1)(b) of the GDPR
- Data processing based on the data subject’s consent: Article 6(1)(a) of the GDPR
- Data processing for the purpose of pursuing legitimate interests: Article 6(1)(f) of the GDPR
- Data processing for the purpose of complying with legal obligations: Article 6(1)(c) of the GDPR
6.2 Protection in the case of suppliers in third countries
Where, in the opinion of the European Union, an “adequate level of protection” for the processing of personal data in compliance with EU standards cannot be guaranteed, the standard data protection clauses approved and issued by the European Commission, binding internal data protection rules, or approved codes of conduct shall apply as suitable safeguards pursuant to Article 46 of the GDPR in the event of the use of service providers (see point 4). An electronic copy of the relevant extracts can be provided upon specific request submitted to the Data Protection Officer.
6.3 Rights of the data subject
As the data subject, the User has the right to access personal data (Art. 15 of the GDPR), to have it corrected (Art. 16 of the GDPR), to have it erased (Art. 17 of the GDPR), to restrict processing (Art. 18 of the GDPR), and to data portability (Art. 20 of the GDPR).
6.4 Right to object
For reasons related to their particular situation, the User has the right to object at any time to the processing of their personal data carried out on the basis of Article 6(1)(e) of the GDPR (processing necessary for the public interest) or Article 6(1)(f) of the GDPR (processing based on a balancing of interests). In the event of an objection by the User, the relevant personal data will be processed by the Supplier where it is possible to demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the User, or where the processing is necessary for the establishment, exercise, or defense of legal claims.
6.5 Complaints
If the User believes that the processing of their personal data may constitute a violation of the law, they have the right to file a complaint with a competent data protection authority (Art. 77 of the GDPR).
7. EXERCISE OF RIGHTS
The User may exercise the rights referred to in section 6 by sending a written email to inim.
8. UPDATES TO THIS PRIVACY POLICY REGARDING THE PROTECTION OF PERSONAL DATA
The Supplier reserves the right to amend or update, in whole or in part, this Privacy Policy, including in response to changes in the laws or regulations governing the protection of personal data. Any such amendments or updates to this Privacy Policy will be communicated to Users as soon as they are adopted and will become effective upon their publication on the Website.
INIMtherefore encourages Users to visit this page regularly to check for the publication of the most recent and updated version of the Privacy Policy. To this end, the document includes the date of the last update.
Last updated: January 30, 2025
Privacy - D.P.A.
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1. INTRODUCTION
1.1 This DPA (Data Processing Agreement) governs the processing of Personal Data carried out byINIM S.R.L.”, a sole proprietorship (hereinafter also referred to as the “Privacy Manager,” “Manager,” “Supplier,” orINIM), which is necessary to provide the services offered (hereinafter the “Services”) to the User.
The User is the Data Controller (hereinafter also the “Owner”).
1.2 If the User is required to perform processing operations on behalf of another Data Controller, he or she may act as Data Protection Officer. In this case, the User guarantees that the instructions provided and the activities undertaken in relation to the processing of Personal Data—including the User’s appointment of the Supplier as an additional Privacy Manager pursuant to this DPA—have been authorized by the relevant Data Controller, and undertakes to provide the Supplier, upon simple written request, with documentation certifying the foregoing.
2. REGULATORY REFERENCES
2.1 This DPA guarantees that the processing of Data carried out by the Supplier complies with EU Regulation 679/2016 (“GDPR”) and, more generally, with Italian and European legislation on privacy and the protection of personal data (the “Applicable Law”).
3. PROCESSING OF PERSONAL DATA
3.1 Purpose of Data Processing: the provision of Services by INIM, as specified in the “General Terms and Conditions for Website Navigation and Cloud Use.”
3.2 To provide the Services to the User, the Privacy Manager processes, on behalf of the Data Controller, certain categories of Personal Data collected by the Data Controller and entered by the latter into the IT systems responsible for managing the Services.
3.3 “Personal data” means any information relating to an identified or identifiable natural person (“data subject”) as defined in Article 4 of the GDPR.
The Privacy Manager processes the following types of Personal Data necessary to provide the “Services”: images and videos generated by the User’s alarm systems and captured by the User’s video surveillance equipment connected to the INIM Cloud.
The Privacy Manager carries out exclusively the processing activities necessary and relevant to ensure the provision of the Services to the Data Controller.
3.4 The Privacy Manager maintains a record of processing activities in accordance with Article 30(2) of the GDPR.
4. INSTRUCTIONS
4.1 The Privacy Manager may process Personal Data only in accordance with instructions from the Data Controller (the “Instructions”), unless otherwise provided by Applicable Law. Through this DPA, the Data Controller instructs the Privacy Manager to process the Personal Data solely for the purpose of providing the Services. Subject to the terms of this DPA and with the mutual agreement of the parties, the Data Controller may provide the Privacy Manager with further written instructions consistent with the terms of this Agreement.
4.2 The Data Controller guarantees that it will process Personal Data in compliance with current legislation on privacy and the protection of personal data. The instructions provided by the Data Controller must comply with Applicable Law. The Data Controller is solely responsible for the accuracy, quality, and limitation of storage of the Personal Data collected and processed. The Data Controller must also ensure that the Data is collected and processed in a lawful, fair, and transparent manner. 4.3 The Privacy Manager shall inform the Data Controller if he or she believes that the Instructions violate Applicable Law and shall not execute such Instructions until they are recognized as legitimate.
5. DUTIES OF THE PRIVACY MANAGER
5.1 Confidentiality
5.1.1 The Privacy Manager shall treat all Personal Data as strictly confidential information. Personal Data may not be copied, transferred, or processed in violation of the Instructions, unless authorized pursuant to further agreements with the Data Controller.
5.1.2 The individuals authorized by the Manager to process Personal Data are also obligated to maintain confidentiality and must have signed a specific authorization authorizing them to process the Data in a manner compliant with Applicable Law and the provisions contained in this DPA.
5.1.3 Personal Data shall be processed only by the personnel necessary to provide the Services.
5.1.4. The Privacy Manager shall also ensure that the authorized parties, who carry out processing operations on Personal Data, process only the categories of Personal Data provided for by this DPA and in accordance with the Instructions.
5.2 Security
5.2.1 The Privacy Manager must implement the appropriate technical and organizational measures as set forth in this DPA and in accordance with Article 32 of the GDPR. The Privacy Manager may update or modify the security measures from time to time, provided that such updates and modifications do not result in a reduction in the overall level of security. The security measures are available and may be reviewed upon request.
5.3 Data Protection Impact Assessments and Prior Consultation
5.3.1 If the assistance of the Privacy Manager is necessary and relevant, the Manager may assist the Data Controller in preparing data protection impact assessments in accordance with Article 35 of the GDPR, as well as any prior consultation pursuant to Article 36 of the GDPR.
Any personalized assistance requests may be subject to the payment of a fee by the User. It is understood that it is the exclusive responsibility and burden of the User, as Data Controller, to conduct the impact assessment based on the characteristics of the processing of Personal Data carried out by the User in the context of the Services.
5.4 Rights of Data Subjects
5.4.1 If the Data Controller receives a request from a data subject to exercise their rights under applicable law, and providing an accurate and legitimate response to such request requires the assistance of the Privacy Manager, the Manager shall assist the Data Controller by providing him or her, within a reasonable time, with the necessary information and documentation requested by the Data Controller.
5.4.2 If the Privacy Manager receives a request from a data subject to exercise their rights under Applicable Law and such request relates to Personal Data collected by the Data Controller, the Privacy Manager must immediately forward the request to the Data Controller and refrain from responding directly to the data subject.
5.5 Breach of Personal Data
5.5.1 In the event of a breach of Personal Data (“Data Breach”) that may result in the destruction, loss, alteration, disclosure, or unauthorized or accidental access to Personal Data processed on behalf of the Data Controller, the Manager must notify the Data Controller within forty-eight (48) hours of the Manager’s detection of the Data Breach.
5.5.2 The Privacy Manager must make every reasonable effort to identify the cause of such a breach and take such measures as deemed necessary to determine the cause and to prevent such a breach from recurring.
5.6 Compliance Documentation and Audit Rights
5.6.1 Upon request of the Data Controller, the Privacy Manager must provide the Data Controller with all relevant information necessary to demonstrate compliance with this DPA.
5.6.2 The Manager acknowledges the Data Controller’s right, in the manner and within the limits set forth below, to conduct audits to verify the Manager’s compliance with the obligations set forth in this DPA and applicable law. The Data Controller may use its own specialized personnel or external auditors for these activities, provided that these parties are previously bound by appropriate confidentiality agreements.
In the event of a request for audit activities, the User must first send a written request to the Manager via email. Following the request for an audit or inspection, the Manager and the User shall agree, before commencing the activities, on the details of such checks (start date and duration), the types of checks and the scope of the checks, the confidentiality obligations to which the User and those conducting the checks must be subject, and the costs that the Privacy Manager may charge for such checks, which will be determined based on the scope and duration of the verification activities.
5.6.3 The Manager may object in writing to the appointment by the Data Controller of any external auditors who are, in the Manager’s sole discretion, not adequately qualified or independent, are competitors of the Manager, or who are obviously inadequate. In such circumstances, the Owner is required to appoint other auditors or conduct the audits himself/herself.
5.6.4 The Manager undertakes to respond to requests for additional documentation or audit planning forwarded by the Owner within thirty (30) days from the date of receipt of the request.
5.7 Transfer of Data
5.7.1 Under normal circumstances, the Privacy Manager does not transfer the Data to countries outside the European Economic Area (EEA). Where transfer outside the European Economic Area (EEA) is necessary to carry out certain types of processing (for example: backup, hosting, etc.), the Data will be transferred only to Sub-Privacy Managers who have adopted the appropriate safeguards provided for in Articles 44–50 of the GDPR (for example: Adequacy Decisions of the European Commission, Standard Contractual Clauses, or similar).
6. GENERAL AUTHORIZATION FOR THE APPOINTMENT OF SUB-DATA PROCESSORS
6.1 The Privacy Manager is granted general authorization to appoint third parties (“Sub-Privacy Managers”) to process Personal Data without the need for further written and specific authorizations from the Data Controller.
The User expressly agrees that certain Personal Data processing operations are entrusted by the Supplier to other companies within the INIM and/or to third parties potentially identified in the DPA.
6.1.1. The User also agrees to the entrusting of Personal Data processing operations to additional third parties in accordance with the methods set forth in Article 6.1.3 below.
6.1.2. It is understood that the signing of the Standard Contractual Clauses (provided for in point 5.7.1 in the event of transfer of Personal Data abroad) by the User with an Additional Privacy Manager must be understood as consent to the assignment of processing operations to the third party.
6.1.3. In cases where the Supplier must engage Additional Data Processors for the performance of specific Personal Data processing activities, the Supplier:
6.1.3.1. undertakes to engage Additional Data Processors who guarantee adequate technical and organizational measures and ensure that access to Personal Data, and the related processing, will be carried out exclusively within the limits of what is necessary for the provision of the requested services.
6.1.3.2. At least 15 (fifteen) days before the start date of the Personal Data processing operations by the Additional Privacy Manager, INIM inform the User of the assignment to the third party (as well as the third party’s identification details, its location—and, where applicable, the location of the servers on which the data will be stored—and the activities entrusted) by sending a notification email or using other means deemed appropriate by INIM.
6.1.4. Any additional information regarding the list of Additional Privacy Managers (Sub-Data Processors), the processing entrusted to them, and their location is available upon request from the Data Controller.
6.1.5. The absence of any objections on the part of the Data Controller shall be understood as consent to the appointment of a new Sub-Privacy Manager.
6.2 The Privacy Manager must enter into a specific DPA with each new Sub-Privacy Manager. Such agreement must impose at least the same data protection obligations as those applicable to the Privacy Manager, including the obligations set forth in this DPA. The Privacy Manager undertakes to monitor and periodically verify the compliance of its Sub-Privacy Managers (Sub-Data Processors) with applicable law. Documentation of such monitoring must be provided to the Data Controller upon written request.
6.3 As of the effective date of this DPA, the Privacy Manager employs Sub-Privacy Managers (Sub-Data Processors). If the Privacy Manager enters into a contract with a new Sub-Privacy Manager, that Sub-Privacy Manager must be added to the relevant list, which is available upon request at the head office.
7. LIMITED WARRANTY
7.1 The Privacy Manager’s liability to the User for any losses caused by or in any way related to the provisions contained in this DPA is subject to the terms set forth in the “General Terms and Conditions for Website Navigation and Cloud Use.”
8. DURATION
8.1 This DPA shall remain in effect until the contract for the provision of the specific service is terminated.
9. DATA PROTECTION OFFICER (DPO)
9.1 The Privacy Manager shall appoint a Data Protection Officer (DPO) where such appointment is required by the GDPR.
10. DELETION OF DATA
10.1 Upon the expiration or termination of the service agreement, the Privacy Manager will delete or return to the Owner all Personal Data in its possession within the timeframe specified in the service agreement itself, except where the Privacy Manager is required by applicable law to retain some or all of the Personal Data (in which case the Privacy Manager will store the data and implement reasonable measures to prevent the Personal Data from being further processed). The terms of this DPA will continue to apply to such Personal Data.
10.1.1. The Manager shall keep the Personal Data available to the User for extraction requests for the period specified in the Service Supply Contract. Where this Contract does not specify a specific term, the Supplier will keep the Personal Data available to the User for this purpose for a period of 30 (thirty) days following the termination of the Contract or subscription to the Service.
10.1.2. The User acknowledges that he/she may extract Personal Data, upon termination of the Service, in the ways agreed upon in the Contract, and agrees that it is his/her responsibility to request, in whole or in part, only the Personal Data that he/she deems useful to retain, and that such extraction must be carried out before the expiration of the deadline referred to in point 10.1.
11. CONTACT INFORMATION
11.1 The contact details of the Data Privacy Manager are as follows:
INIM S.R.L.’ Sole Proprietorship with registered office in Monteprandone (AP), Municipality of Centobuchi, Via dei Lavoratori No. 10. Tax ID and VAT No. 01855460448.
Email: inim.
Last updated: May 6, 2024