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PRIVACY POLICY – NDS ENERGY Dometic Mobile App

This information, prepared in accordance with Legislative Decree. n. 196/2003 (“Codice Privacy”), of the Reg. EU n. 679/2016 (“GDPR”) and the UE Directive n. 2002/58/EC (‘e-Privacy’) as amended and supplemented, describes how Dometic Mobile Power Italy S.r.l. (‘Dometic’, ‘Data Controller’) uses and manages the Personal Data of users collected through this Mobile Application (‘App’).

The information provided with this document supplements that provided with the Dometic Entry Information. The use of the App, in fact, entails the acquisition of additional Data to those already collected.

The App is a tool that Dometic makes available free of charge to the end-user customers of its products (batteries, battery chargers, inverters and converters, voltage regulators, multi-battery managers, photovoltaic panels, for motorhomes, boats, professional vehicles, aerial platforms, cleaning, electric vehicles) to enable them to manage these devices organically. Specifically, through the App, the user can:

  • check the activity status of their devices and/or batteries;
  • interact with the devices, limited to the technical settings of the device itself and the devices in the network ;
  • update the Firmware of connected devices, if the device provides for it. Unless otherwise specified by Dometic, to be considered on a case-by-case basis;
  • monitor the performance of solar panels;

Data Controller

The data controller is Dometic Mobile Power Italy S.r.l. (‘Dometic’, ‘Data Controller’), with registered office in Cappelle sul Tavo (PE, Italy) via Giovanni Pascoli n.96/98, C.F. and VAT number IT02065080687, REA number: PE-150854, a company belonging to the Dometic Group – Dometic Group AB, no. reg. 556829-4390, Hemvärnsgatan 15, SE-171 54 Solna, Svezia.

For any request concerning the processing of Personal Data and for the exercise of the rights of the data subject, please send an e-mail to [email protected].

The Data Protection Officer is Dr Sergio Accorona, who can be contacted at [email protected].

Type of data processed

The following types of data are collected through the App:

  • Data provided voluntarily by the user: first name, surname, state of residence, email, password (encrypted),
  • Data relating to the devices installed in the vehicle and collected by the App: type and serial number of the devices installed in the vehicles, firmware version, MAC address, date and type of updates performed by the user;
  • Device performance data.

Purpose and legal basis of processing

Personal Data is processed for:

  • be able to use the App and complement the functionality of other electronic devices;
  • be able to use the App and complement the functionality of other electronic devices;
  • evaluate the functionality and performance of its products with a view to making improvements;
  • prevent abuses;
  • fulfil legal obligations, regulations and orders of the Authority.

The processing of Personal Data takes place predominantly with the consent of the person concerned, which is requested for the first time when installing the App.

  • Data provided to enable the operation of the App and to provide technical support are processed on the basis of the fulfilment of a contract.
  • Data processed for App security and abuse prevention, as well as Data processed – in aggregate and anonymous form – for performance evaluation of devices connected to the App, are processed on the basis of the relevant legitimate interest of the Data Controller, respectively the security of the App and users, and the pursuit of its own business purposes.
  • Personal Data collected to fulfil legal obligations, regulations and orders of the Authority are processed on the relevant legal basis.

Method and place of processing

Personal Data are processed by manual and automated, computerised and electronic means and may be stored at the data controller’s premises and at the data centres of the server and hosting provider (Amazon AWS) located within the EU/EEA. Technical and organisational measures are taken to prevent unauthorised access and to prevent the loss, misuse and alteration of processed Data.

Data Retention

Personal Data are kept for the time strictly necessary to carry out the activities for which they were collected, for as long as the contract is performed or as long as there is an active user account, subject to the exercise of revocation and opposition rights by the person concerned; in any case for no more than 5 years, for the fulfilment of any obligations arising from the law. On expiry, the Data will be deleted or anonymised.

Third-party recipients of Personal Data

The Personal Data collected may be shared, within the EU/EEA, with:

  • subjects carrying out activities related or instrumental to the provision of the service requested by the user, or performing security checks and optimisation of the App (such as third-party technical service providers, hosting providers, server providers);
  • public authorities in cases established by law;
  • the parent company and with the other companies belonging to the Dometic Group of companies, for internal administrative purposes on the basis of its own legitimate interest.

Data transfer to countries outside the European Union

Personal Data collected by the App is not transferred to countries outside the EU/EEA.

User rights

At any time, the user may exercise the following rights under data protection laws:

  • obtain information on the existence of and access to their Personal Data;
  • request that they be updated, rectified, supplemented and transformed into anonymous form;
  • request deletion of Data;
  • request the restriction of the processing of Data;
  • to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have them transferred without hindrance to another data controller;
  • object at any time to the processing of his Data when it is carried out on a legal basis other than consent, although the processing carried out prior to the objection will remain valid;
  • revoke previously given consent, although the processing carried out prior to the revocation of consent will remain valid;
  • file a complaint with the Data Protection Authority.

To exercise their rights, Users may address a request to the Controller’s contact details indicated in this document.

The request can be made free of charge and the Controller will reply as soon as possible, in any case within one month, providing the User with all the information required by law. In the event of a manifestly unfounded or repetitive request, the Controller may request a fee from the data subject or refuse to comply with the request.

Any rectification, deletion or restriction of processing shall be communicated by the Controller to each of the recipients, if any, to whom the Personal Data have been transmitted, unless this proves impossible or involves a disproportionate effort. The Controller shall inform the User of these recipients if the User requests it.

Dometic will inform interested parties of any changes to this policy via the App or through other usual communication channels.

This privacy policy is updated as of 16 . 04 .2024.