Mese: Agosto 2020

Privacy Policy

Data Policy

This policy describes the information we process to provide users with the services available in Green App.

I. What types of information do we collect?

Upon registration, we collect the following information, which is classified as personal data under current European regulations:

• User’s first and last name;
• Email address.

Data collection methods may involve direct provision by the user.

Additionally, we collect information from mobile phones and/or tablets on which the user uses the application to enable service functionality and to use certain device features.

The information we collect from these devices, which is not classified as personal data, includes:

• Identifiers: Unique device identifiers (tag ID);
• Device settings: Information received through device settings activated by the user, such as GPS location, camera access, or photos;
• Network and connections: Information such as mobile operator or ISP name, language, time zone, phone number, IP address, connection speed, and, in some cases, information about other devices nearby or on the same network.

II. How do we use this information?

We use the information in our possession in the ways described below to provide and support Green App. Here’s how:

a. We use the user’s geolocation to help them select the municipality or district for which they want information regarding waste sorting methods.

b. We use the mobile device’s tag ID to send notifications to users regarding waste collection and/or to respond to reports about products.

c. We use geolocation and the area selected by the user to allow them to receive timely information via the app about collection schedules and waste disposal methods.

III. Is this information shared?

The data provided and their usage are processed solely by Baron S.r.l. and the relevant Municipality.

The data, in aggregated and anonymous form, is used exclusively for statistical purposes regarding app usage and is shared with subscribed municipalities.

For municipalities where the degradation reporting service is active, Baron shares the data with the administration, which handles the issue and notifies the user via email once resolved.

We may share information with law enforcement or respond to legal requests when required by law or ordered by a magistrate through a legally binding directive applicable to Baron S.r.l.

If the user has agreed to receive targeted advertising information, we may share their data with Google.

IV. What are our legal bases for data processing?

The legal bases for processing include:

• Service execution under Article 6 GDPR – in relation to data processed to ensure the correct use of Green App and its functionalities;
• Consent under Article 6 GDPR – regarding data provided to Google to enable the sending of targeted advertising information.

We collect, use, and share data in our possession as previously described:

• As necessary to comply with Baron S.r.l. and Green App’s Terms of Use;
• Consistently with the granted consent, which can be revoked at any time by sending a request to the Data Controller via email at info@baron.it;
• As necessary to comply with our legal obligations;
• As necessary for public interest.

V. What are users’ rights?

Under the General Data Protection Regulation (GDPR), users have the following rights regarding their data:

1. Right of access: Users can request information about how their data is processed, third parties to whom it has been communicated, and how it is stored. They may also request a copy, for which reimbursement of any costs incurred may be required.
2. Right to rectification: Users can request correction of inaccurate or incomplete data.
3. Right to erasure: Users can request the deletion of their personal data. In such cases, Green App may become inaccessible. To erase account and data the user must contact the service provider directly.
4. Right to restrict processing: Users can request partial restriction or deletion of data. Green App may become inaccessible as a result.
5. Right to data portability: Users can receive their personal data in a commonly used format for automatic transmission to another entity without prior notification to Baron.
6. Right to object to processing: Users can object at any time to the processing of personal data and request its cessation. If the processing is no longer necessary or the objection is justified, Baron will comply. This right does not apply if data was provided for the conclusion or execution of an agreement with Baron.
7. Right to withdraw consent: Users can partially or fully revoke previously granted consent. This may affect Green App’s functionality.

VI. How to exercise the right to be forgotten, partial deletion, and data portability?

Users can request total or partial deletion of their personal data at any time by contacting the Data Controller.

Requests can be sent via email to info@baron.it in the following cases:

• If consent for usage is withdrawn;
• If data is no longer necessary for the purposes for which it was collected;
• If the user lawfully objects to processing.

Upon request, Baron will act promptly, within 36 hours, within the technical feasibility limits.

The right to be forgotten may be limited only in the following cases:

• To ensure freedom of expression or the right to defense in legal proceedings;
• To protect public interest;
• When anonymized data is needed for historical, statistical, or scientific research.

Users can also request the transfer of their personal and usage data to another data controller offering the same Green App service by emailing info@baron.it.

VII. How and for how long is user data stored?

User data is stored on Amazon servers located in ??? and ???? (specify the countries where these servers are located).

The features and certifications of the machines used ensure maximum security and minimize risks of violations and data breaches.

Data is not communicated, processed, or sent outside the European Union.

If an account is deleted, we will immediately erase all personal user data. We may retain only anonymous usage information for statistical and service improvement purposes.

In case of data loss, theft, or destruction, Baron will notify the relevant authorities within 36 hours, in accordance with its internal policy.

VIII. How do we comply with legal requests or prevent harm?

We access, store, and share information with regulatory bodies, law enforcement, or other entities in the following cases:

• In response to a legal request when we believe in good faith that the law requires it;
• When necessary to detect, prevent, and address unauthorized use of products, violations of our terms or policies, or other harmful or illegal activities, to protect ourselves (including our rights, property, or products), including in regulatory investigations, or to prevent imminent death or physical harm.

IX. How Will We Notify Users of Changes to This Policy?

Baron will inform users about the release of a new version of this policy via in-app communication or email.

X. How to Contact Baron S.r.l. for Any Questions

You can obtain more information about the privacy practices of the Green App. If you have any questions about this policy, contact us using the methods described below.

The data controller responsible for your information is Baron S.r.l., represented by CEO Andrea Baron, whom you can contact online or by mail at the following address:

Via Dell’Industria, 8/1, 36051 Creazzo (Vicenza), Italy

You can also contact the Data Protection Officer for Baron S.r.l. by writing to info@baron.it.

Last updated: July 1, 2021