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PRIVACY POLICY SMART APP

PRIVACY POLICY SMART APP

 

PRIVACY POLICY SMART APP

This privacy policy aims to provide a clear and transparent overview of how users' personal data is processed when using the Mobile App SOS Yachting SmartApp, in compliance with Regulation (EU) 2016/679 ("GDPR").

 

1. What Data Do We Collect and Why?

To enable access to and use of the App, users must provide certain personal data during registration. Specifically, we request:

  • First and last name;

  • Email address;

  • Password for account creation.

Additionally, users may choose to provide optional information, such as their professional role, company name, phone number and if they would like to participate to future fiscal trainings. If provided, these details may be used for commercial communication and market analysis, but only with the user’s explicit consent.

While using the App, we automatically collect certain technical information, such as IP address, log data, and device characteristics. This information is necessary to ensure service security and improve performance.

 

2. Why Do We Process the Data?

The collected data is used for the following purposes:

  • Providing and managing the service: Data is required for account creation, access to the App, and the proper functioning of the platform.

  • Improving service quality: We analyze App usage to identify technical issues and implement improvements.

  • Legal compliance: Data may be processed to meet regulatory obligations or requests from competent authorities.

  • Marketing and commercial communication: With user consent, data may be used to send promotional communications or conduct market research.

 

3. What Are the Legal Bases for Processing?

Data processing is based on different legal grounds, depending on its purpose:

  • For account management and service provision: Processing is necessary to execute the contract between the user and the data controller (Art. 6(1)(b) GDPR).

  • For performance analysis and App security: Processing is based on the data controller’s legitimate interest in ensuring a reliable and secure service (Art. 6(1)(f) GDPR).

  • For legal compliance: Data is processed when necessary to fulfill legal obligations (Art. 6(1)(c) GDPR).

  • For marketing and commercial communication: Processing occurs only with the user’s consent, which can be revoked at any time (Art. 6(1)(a) GDPR).

 

4. How Long Do We Retain the Data?

Personal data is retained for the period necessary to fulfill its intended purposes:

  • Account data: Kept for the duration of service use and for up to 10 years thereafter, as required by tax and accounting regulations.

  • Usage and service analysis data: Retained for a maximum of 12 months.

  • Marketing data: Retained until the user withdraws consent, and in any case, for a maximum of 24 months from the last interaction.

At the end of the retention period, data is deleted or irreversibly anonymized.

 

5. Who Has Access to the Data?

Personal data may be processed by authorized personnel of the data controller and by external service providers supporting the App's operation, such as:

  • IT and hosting service providers;

  • Marketing and market analysis companies (only with user consent);

  • Competent authorities in the event of legal obligations or requests.

All external entities processing data on behalf of the data controller are bound to comply with data protection regulations.

 

6. Is Data Transferred Outside the European Union?

Currently, data is not transferred outside the European Union. If future transfers are necessary, we will ensure appropriate protective measures, such as Standard Contractual Clauses approved by the European Commission.

 

7. How Do We Protect Personal Data?

We are committed to maintaining a high level of security to protect personal data from unauthorized access, loss, or alteration. Measures include:

  • Encryption of sensitive data;

  • Advanced protection systems against unauthorized access;

  • Restricted data access policies, limited to authorized personnel only.

 

8. What Are Users' Rights?

Users may exercise the following rights at any time:

  • Access to their data to understand how it is used;

  • Correction of inaccurate or incomplete data;

  • Deletion of data, where legally applicable;

  • Restriction of processing, under legal conditions;

  • Data portability, to receive data in a structured and readable format;

  • Objection to processing for marketing purposes, without needing to provide a reason;

  • Withdrawal of consent at any time.

 

To exercise their rights, users can contact the data controller at privacy@sosyachting.com.

If users believe that data processing does not comply with regulations, they have the right to file a complaint with the Data Protection Authority.

 

9. Data Controller

 

SOS Holding S.r.l.
Registered office: Viale Monte Nero 84, Milan (MI), Italy
Email: privacy@sosyachting.com

 

10. Changes to This Privacy Policy

This policy may be updated periodically. In case of significant changes, users will be notified through the App or via email.

 

Last updated: March 1, 2025.