The protection of personal data is an important concern to us. We value your privacy and we collect, process and use personal data in accordance with the laws and regulations of Italy as well as superordinate European legal requirements.

By agreeing to the following privacy policy you hereby consent to the collection, processing and use of personal data by Jotto S.r.l. Start-up, Via Isonzo, 11, 37126, Verona, Italy- hereinafter referred to as the Supplier - in compliance with the applicable legal requirements and the following provisions."



Data controller

Data controller for the collection, processing and use of personal data within the meaning of the Federal Data Protection Act is



Jotto S.r.l. Start-up

Via Isonzo 11

37126 Verona

Italy

Contact form available at  www.jotto.biz "


1 Your personal information

The protection of your personal information is important to us at Jotto S.r.l. Start-up (‘Jotto°’, ‘Jotto’, ‘we’, ’us’ or ‘our’). We respect your privacy and want you to understand what we do with the information we hold about you. This privacy policy explains how we collect, protect, share and use your personal information.

1.1 What is personal information and what is processing of personal information

Personal information (or data) is any information relating to you and that alone or in cumulation with other pieces of information gives the opportunity to the person that collects and processes such information to identify you as a person. It can be your name, your identification number, your location data, or information related to your physical, physiological, genetic, mental, economic, cultural or social life. Processing of the information means any action with your personal data, for example, collection, recording, organisation, structuring, storage, use, disclosure by any means and so on.

1.2 Personal information we collect

We may collect the following types of personal information from you when you use Jotto° services or products:


You are not required to provide any of the personal information described above to us, however, if you do not do so, you may not be able to use our products and services or the functionality of our products may be reduced.

1.3 What we use your personal information for

Purpose

Personal information used

Provide our services to you and maintain your account

All the personal information we collect

Take payment for our products and services

Transaction and payment information

Deliver products to you

Delivery information

Installation and servicing

Installation and service history Boiler Monitoring Data

Answer your queries or complaints

All the personal information we collect

Maintain and improve our products and services

All the personal information we collect

Data analytics and statistical research to help us better understand how our products are used in the home and make suggestions and recommendations to you about the use of our products

  • How you use our products

  • How you use our apps and website

  • Device information

  • Transaction information

  • Installation and service history

  • Records of your discussions with our customer support teams

Staff training

All the personal information we collect

Develop new products and services

All the personal information we collect

Determine products and services that may be of interest to you

All personal information we collect (but not your payment information)

Direct marketing

Contact details Products and services that we have determined may be of interest to you

Validating referral scheme applications

Contact details

Investigating misuse of your account, fraud and debt collection

All the personal information we collect

We may anonymise and aggregate any of the personal information we hold (so that it does not directly identify you). We may use anonymised and aggregated information for purposes that include testing our IT systems, research, data analysis, improving our site, apps and products and developing new products and services.


1.4 Sources we collect your personal information from

We will collect personal information from a number of sources. These include the following:


1.5 How we protect your personal information

We take technical and organizational measures to ensure the personal information is processed in a manner that ensures appropriate security of information, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage. For example, we use verified contractors that might have access to the data. With these the relevant data processing agreements are signed and the data is being processed is encrypted and/or anonymized. For example, we use Amazon Web Service data centers that are certified by ISO27001 and SSAE16 certificates.


1.6 Who we share your personal information with

We share personal information with the following parties:


We do not disclose personal information to anyone else except as set out above. We may provide third parties with aggregate statistical information and analytics about users of our products and services but we will make sure no one can be identified from this information before we disclose it.

Under no circumstances will we disclose data to third parties not specified here for advertising purposes.

1.7 Transferring your personal information internationally

The personal information we collect may be transferred to and stored in countries outside of the European Union. Some of these jurisdictions require different levels of protection in respect of personal information and, in certain instances, the laws in those countries may be less protective than the jurisdiction you are typically resident in. We will take all reasonable steps to ensure that your personal information is only used in accordance with this privacy policy and applicable European data protection laws and is respected and kept secure.


1.8 How long do we keep personal information

We will keep your personal information for as long as you have an account with us. After you close your account with us we will keep your personal information for a reasonable period to maintain our records and legal obligations to you. Sensitive personal information such as location information is automatically deleted after 2 weeks even when your account is active.



2 Marketing

2.1 Direct Marketing

In accordance with the marketing preferences you set when creating your account or that you set with us a later date, we may contact you by email, push notification, text, mail or phone with information about products and services we believe you may be interested in. If you tell us not to email, push notification, mail or phone you with direct market we won’t contact you in that way. You can let us know at any time that you do not wish to receive marketing messages by sending an email to us at jottosrl@pec.it .


2.2 Advertising on other websites and apps

We work with our advertising agencies to show you advertising about our products and services on websites or apps that you visit, at a time and in manner that we feel is relevant to you. To do this, our advertising agencies use anonymised information about the websites, apps, social media content and ads you interact with or view when connected to the Internet, to make sure the advertising you see is more relevant to you. The techniques our advertising agencies use (to determine what advertising to show you), recognise the device you are using but are not aimed at you as a named individual. Typically, cookies and similar technologies are used to target this type of advertising, read more in ‘Cookies’ Section.


3 Service notifications

The jotto° app will send service notifications by email, or directly to your device through the app, when we have something important or interesting to make you aware of or you have asked to be notified about certain events relating to your jotto° products.



4 Cookies

A cookie is a small amount of data, which often includes an anonymous unique identifier, that is sent to your browser from a web site’s computers and stored on your computer’s hard drive. You can configure your browser to be informed about the use of cookies and decide individually about their acceptance on a case by case basis or you can configure your browser to generally exclude cookies for certain cases. If you choose not to accept cookies, the functionality of our site may be reduced.



5 Your rights in relation to your personal information

You have the following rights in relation to your personal information:

To exercise any of the above rights, or if you have any questions relating to your rights, please contact us by using the details set out in the ‘Contacting us’ section below. If you are unhappy with the way we are using your personal information you can also complain your local data protection regulator. We are here to help and encourage you to contact us to resolve your complaint first.



6 Changes to this notice

Our activities may evolve over time and we may update this privacy policy accordingly. When we change this policy in a material way, we will update the version date at the bottom of this page. For significant changes to this policy we will try to give you reasonable notice unless we are prevented from doing so. Where required by law we will seek your consent to changes in the way we use your personal information.



7 Contacting us

7.1 Options to Contact us

In the event of any query or complaint in connection with the information we hold about you, please email our Data Protection Officer at: info@jotto.biz or by mail at:

Jotto S.r.l. Start-up

Strada della selva, 83

37047 San Bonifacio (Verona)

Italy

7.2 Time for reply and reaction

We will provide information on action taken on your request related to your rights specified above within one month of receipt of the request for the longest. That period may be extended by two further months if we are overwhelmed by the number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. You also have the right to lodge a complaint with a supervisory authority that is empowered to process such complaints in your country.