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Appendix A – Data management disclaimer
Disclaimer of Adaptica S.r.l. pursuant to Article 13 of Legislative Decree No. 196 of 30
June 2003 (the “Privacy Code”)
We hereby inform that the utilisation of the 2WIN instrument will give rise to the processing
of some data relating to its status of operation (the “Telemetry Data”), which will be acquired
by the IT systems and software procedures for the functioning of this instrument whenever it
connects to a wireless network. The information in question is not collected in order to be
associated with specifically identified parties, but due to its nature it could – through
processing operations and associations with data in the possession of third parties – make it
possible to identify the users (hereafter the “Parties Concerned”). The Telemetry Data
include the software version, the firmware version, the device’s serial number and the number
of observations carried out; moreover, the instrument will transmit the list of the Applications
operating on the same. The sole purposes of the Telemetry Data processing are to enable
Adaptica S.r.l. to constantly monitor the efficiency of the proposed service based on the
utilisation of the 2WIN instrument and, in case of malfunctioning of the same, to transmit from
the remote server the technical data which are necessary to the reactivation of the relevant
parameters. Furthermore, Adaptica S.r.l. may, once a temporary session of remote control
has been activated by the user and the instrument has been connected to a wireless network,
connect to the 2WIN instrument and obtain parameters of a purely technical nature relating
to the handling and the state of health of mechanical, electronic and firmware parts (the
“Remote Control Data”). In this regard, Adaptica S.r.l. informs that, by way of the remote
control connection, also the data saved on the SD card might theoretically be downloaded
from the system, should such card be left inserted in the instrument at the moment of the
activation of the temporary session; despite this additional information is of no interest for
Adaptica S.r.l. and will neither be acquired nor treated by it, it is however advisable to remove
the SD card or delete any sensitive data before such activation, in order to avoid the transfer
of the same data.
Adaptica S.r.l. also informs that the Telemetry Data and the Remote Control Data do not
contain sensitive information relating to users, will be treated only and exclusively in the
framework of normal business, in accordance with purposes linked to the achievement of the
corporate purpose of the said Adaptica S.r.l., and will be kept by such company. The
Telemetry Data will be used only in order to acquire anonymous information on the use of
the instrument and to check that it is functioning correctly. The Remote Control Data will be
used in order to provide remote assistance to the 2WIN and enable Adaptica S.r.l. to check
its functioning and/or carry out particular procedures. The processing of the Telemetry Data
and the Remote Control Data will take place mainly through electronic (or in any case
automated), IT and telematic instruments, and will be memorised on IT devices, following
criteria strictly correlated to the aforementioned purposes, in compliance with the minimum
security provisions contemplated by Art. 34 of the Privacy Code and by Schedule B thereof
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