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Privacy Policy

Last updated March 31, 2020

DNA10 Technology Srls, in this document named for brevity "DNA10", is firmly committed to the security and protection of our Users' personal information. This Privacy Statement describes how DNA10 will collect, use, share, and process personal information.
DNA10 Technology Srls will be responsible for processing your personal data. By accepting the Privacy Statement or using the Services, you consent to the collection, use, sharing, and processing of personal information as described in this document. If you provide us with personal information about someone else, confirm that they are aware that they have provided their information and that they consent to our use of their information under our Privacy Statement. You can withdraw at any time to prevent further use of information shared through the Services.
We process your data and the information communicated to provide, improve, analyze, and customize the Services.
We've improved our privacy center to give you greater access and control of your data. With the right to always get your prior consent, we can provide your information to third parties (such as Google or ad networks) to serve advertisements or communications.
When you register, you create a user profile and confirm that you own a certain phone/email number, DNA10 will collect the information you provide. To create a user profile, you must register your first name, last name, phone number, and email address. Further information can be provided to your option if requested.
When you use The Services, DNA10 will collect your information. This information may include geolocation; Your IP address; Unique device ID or identifier; manufacturer and type of the device.
DNA10 can collect some of this information automatically through the use of cookies (you can learn more about our use of cookies in our Cookie policy)
Some information, including, but not limited to, usage information and other information that may result from interaction with the Services, may be used to identify you by our appointees, either in combination with other information or otherwise, and will constitute personal information for the purposes of this policy.
You can optionally decide to provide us with additional information to allow the use of certain third-party services, e.g. social network access, so that the Services can be managed. You can then use these third-party services to create your own user profile or directly access our Services by sharing the information to connect your user profile with their respective third-party services. These third-party services may automatically provide us with access to certain personal information they keep about you (e.g. Unique identification information and information about the advertisements that were shown to you or clicked.) You may be able to control the personal information that authorizes us to have access through the privacy settings of the respective third-party service. We will never store any passwords created for third-party services.
You can also provide us with various information in relation to your interaction with our Services.
From time to time DNA10 can offer you the opportunity to provide information about your experience from the use of the Services or participate in surveys or other promotions. DNA10 will collect information provided by you in relation to that information, as well as any other information provided by you through the Services or when you communicate or interact with us.
DNA10 can use the personal information collected to provide, maintain, improve, analyze, and customize Services to your users, partners, and third-party vendors.
More specifically, DNA10 can use this information to:
  1. send push notifications and application reminders and send messages through the Services;
  2. allow you to use and share your information in connection with your registration, access or other use of third-party services, e.g. government agencies, social networking sites, and other third-party APIs;
  3. Provide customer support, answer your questions, investigate and resolve Service issues;
  4. improve our services;
We use aggregated or anonymous personal information for statistical and analytical purposes. We do not consider personal information to include information that has been made anonymous or aggregated so that it can no longer be used to identify a specific person, either in combination with other information or otherwise. We can collect, use, transfer and disclose non-personal information for any purpose.
Subject to your choices made at the time of registration and in your settings at any time, we may ask you to use the information collected, as mentioned above, to provide you with location and interest-based advertising, marketing messages, information and services. We may also ask you to use the information collected to measure the performance of our advertising and marketing services. In addition, we may contact you for verification purposes or with information related to Services or Special Offers, e.g. newsletter emails, SMS and similar notifications about THE services of DNA10 and our partners. We will also use the information collected to respond to you in case of your contact.
We may use the information collected to comply with applicable laws and to protect and defend the rights or security of DNA10, its Users or any other person, and verify your profile information provided with third-party providers to ensure the functionality and accuracy of the data to the technical service for troubleshooting, preventing or detecting fraud , security breaches or control of illegal activities.
In addition to sharing and disclosing personal information included as part of the Services feature as described in Section 2, DNA10 may disclose personal information if we believe such action is necessary to:
  1. comply with the law or a legal process reserved for us;
  2. protect and defend our rights and the application of our agreements; Or
  3. protect the safety of users or members of the public or other aspects of public importance, as long as such disclosure is lawful.
We transfer information to trusted providers, service providers, and other partners that support our business and services, such as providing technical infrastructure services, testing bugs, analyzing how our Services are used, measuring the effectiveness of ads and services, as well as potential partners who may want to work with us to provide other services that interact or are integrated with our Services. DNA10 will always require these third parties to take appropriate organizational and technical measures to protect personal information and comply with applicable legislation. Based on the choices you make when registering and in your settings, DNA10 can share personal information with any advertisers, agencies, and third-party networks (such as Google). These third parties may use this information for analytical and marketing purposes, such as providing targeted measurement and ad services, and to improve products and services. The information can be collected by these third parties through the use of cookies or similar technologies (you can learn more about the use of cookies in our Cookie Policy)
We may disclose and transfer your information to our associated organizations or affiliates or related entities and to any third party that acquires our business, regardless of whether that acquisition is made through the merger, consolidation or purchase of all or substantial portions of our business.
DNA10 will collect and process your personal information in order to execute the contract with you (for example to provide the Services), based on your consent (i.e. the choices you make at the time of registration and in your settings) or based on a legitimate interest of DNA10 (which is not overwritten by your fundamental interests or rights and freedoms). These legitimate interests of DNA10 include protecting and maintaining the security of the Services, understanding and improving our Services and user relationships, and administering our business and customer service. If we treat the data according to your consent, you can withdraw your consent at any time through your settings.
DNA10 will retain your personal information while maintaining a user profile in the Services. You can choose at any time to delete your user profile and personal information through your settings. If you make these choices, your personal information will no longer be visible to others in the Services. We will retain your personal information for as long as necessary to meet the purposes outlined in this Privacy Statement unless a longer retention period is required or permitted by law. We may also retain your personal information in order to meet your marketing choices.
For any dispute that arises in relation to the interpretation, validity and execution of this privacy policy and any act that will constitute its implementation, it will be competent to judge exclusively the Forum of Monza.
DNA10 gives you many options to control and manage your personal information through the settings in your privacy profile. Under applicable law, you may also have the following rights in relation to your personal information:
  • Right to access: You can request a confirmation whether or not DNA10 is processing personal information and obtain a copy of that information. We may refuse to process vexatious or frivolous or extremely impractical requests, jeopardize the privacy of others or for which access is not otherwise required by applicable law.
  • Right to rectify – You can request an adjustment if your personal information is inaccurate.
  • Right to delete: You can request the deletion of personal information in certain situations, for this day if you no longer need to provide the Services.
  • Opposition right: You can object to the processing of your personal data in certain situations, e.g. for using your data for ad targeting.
  • Right to Restriction: You can request restrictions on the processing of your personal data in certain situations, e.g. if your personal information is inaccurate or processed illegally.
  • Right to data portability: You can request to receive personal information provided by the user in a format readable by the machine.
You can exercise your rights above via THE DNA10 privacy profile where e.g. can access, edit, delete and download your personal information, and restrict or cancel the collection and use of your information for ad targeting and third-party promotions. You can also contact DNA10 for assistance using the contact information below and we will consider your request in accordance with applicable law.
We do not intentionally or knowingly collect or solicit information from minors under the age of consent under the laws of their respective jurisdictions or knowingly allow those persons to register for the Services. The Services are not intended for minors under the age of consent under the laws of their respective jurisdictions. If you believe we may have information from or about a child under consent, please contact us at [email protected] .
DNA10 can change this Privacy Statement at any time. DNA10 will notify Users of these changes by push alert or by alert in the Services or by other means. If you object to any changes, you can uninstall the DNA10 applications and stop using the Services. Continued use of the Services after DNA10 has disclosed the changes to this Privacy Statement, will mean that the collection, use, sharing, and processing of your personal information is subject to the new Privacy Statement. From time to time, we may provide more detailed information about how we treat your personal information in relation to particular Services in the Additional Privacy Information that must be incorporated and form part of this Privacy Statement.
As described in our Cookie Policy, we can use cookies, web beacons, flash cookies, HTML 5 cookies, pixel tags, and other software methods for Web applications, including mobile application identifiers, to help us recognize you through the Services, learn about your interests and disable the Services, improve your experience, increase security, measure the use and effectiveness of the Services, and serve advertising. You can control cookies through your browser settings and other tools. By interacting with the Services, you consent to the use and placement of cookies on your device in accordance with this Privacy Statement, which for reference incorporates our Cookie Statement.
If you have any questions or complaints about this Privacy Statement or the processing of your personal information, please contact our data protection officer through [email protected] .

For the purposes of using the services offered, the Data Controller will process your biometric data until the date shown in the invitation as, once you have identified your person in front of the entrance gate of the company that invited you , this data will be completely deleted.

We will collect your data at the end of the invitation acceptance phase through a guided procedure that will ask you to register a small video.

Your data, together with this video, will be transmitted to our servers to allow the processing and acquisition of information relating to the biometric characteristics of your face and will be transferred to the local access control system of the company that invited you so to automate your access on the days indicated.
The personal data of a biometric nature that will be processed by the system as part of the Access Control Service, concern only the specific and individual biometric values ​​that make your person uniquely traceable when you present yourself in front of a deo entry and exit gates of the company that invited you.

The biometric data will therefore be processed exclusively for the purposes relating to the access control service and will be deleted after use so as to no longer have them available on days other than those of the invitation.

For the processing and sharing of biometric personal data necessary to provide this automatic access control service, the Data Controller requires your specific consent.

However, if you decide not to give consent, it will not be possible to automatically access the premises. Access will still be possible by manually registering with the relevant company using the guest registration mode which will be available on a Tablet located at the entrance gate or by manual mode on paper if the Tablet functionality is not available.

To counter the spread of COVID-19, we offer innovative solutions for access control using facial recognition, body temperature measurement and contact tracking technologies in full respect of privacy. IntellyScan® is a registered trademark.

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