We are committed to protecting your privacy and will only use the information that we collect about you lawfully. This notice is intended to give you an understanding of how and why we use the information you provide to us both online and otherwise, in relation to the App and your use of the Mission.
Please read this notice carefully to understand how we will collect, use and store your data. We may update this notice from time to time without notice to you, so please check it regularly.
1. What information we collect from you
While using our App, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you, or our product. This includes:
- your name/surname;
- your user name;
- email address;
- country of residence;
- Mission model and serial number;
- GPS localisation (see more below)
- Lawn shape, size and location;
- records of your communication with us;
- any other information you provide to use in relation to the App and your Mission.
Please note that your Mission does not contain any GPS locator. Therefore, information related to localisation of your product will be submitted once, when you will use your mobile device to communicate the location of the product at the time of the first initialisation/booting of your App, and again if you submit a change location via the App. At no time will there be a continuous geolocation of your product.
2. How will we use your information?
We use will use your personal information for the following purposes:
- making the App available to you;
- providing updates and improvements to the App and the Mission;
- aftersales service and support purposes for the Mission;
- send marketing information to you about our other products and services;
- manage our business, including for accounting and auditing purposes;
- for our own internal administrative purposes and keep a record of your relationship with us;
- to manage your communication preferences;
- to conduct research, for example, via surveys about your opinion of our products and services;
- to improve our products and services; and
- to comply with applicable laws and regulations, and requests from statutory agencies.
3. Our legal bases
We need a lawful basis to collect and use your personal data under data protection law. The law allows for six ways to process personal data (and additional ways for sensitive personal data). Four of these are relevant to the types of processing that Positec carries out. This includes information that is processed on the basis of:
- A person’s consent (for example, the GPS localisation information);
- Processing necessary for the performance of a contract with you (for example, when we provide aftersales support to you);
- Processing that is necessary for compliance with a legal obligation (for example, ensuring our products meet the relevant legal requirements); and
- Our legitimate interests (please see below for more information).
Personal data may be legally collected and used if it is necessary for a legitimate interest of the organisation using the data, as long as that interest is not overridden by the privacy rights of the individual whose data is being used. Positec’s legitimate interests include responding to solicited enquires, providing information, performing research and internal governance.
If you would like to change our use of your personal data in this manner, please get in touch with us using the details in the “How to contact us” section below.
4. Will we share your information?
We may share your personal information with our group and affiliate companies. We have in place measures to ensure the adequate protection of your data with these companies.
We may allow our staff, consultants and/or external providers acting on our behalf to access and use your information for the purposes for which you have provided to us (e.g. to deliver mailings, to analyse data and to process payments). We only provide them with the information they need to deliver the relevant service under contract, and we make sure your information is treated with the same level of care as if we were handling it directly.
We will not otherwise disclose your personal information unless required to do so by a regulatory agency or law.
5. How do we protect your information?
We aim to ensure that there are appropriate physical, technical and managerial controls in place to protect your personal details. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
The information we collect from you may be transferred to and processed and/or stored at a destination outside the European Economic Area (“EEA”), for example to our Positec affiliates based in China or the US. If we send your personal data outside the EEA we will ensure that there are adequate and appropriate measures in place to protect your information.
6. How long do we keep your information?
We will keep your personal data for no longer than is necessary for the purposes for which it is processed, in accordance with our internal policies.
The length of time that data will be kept may depend on the reasons for which we are processing the data and on the law or regulations that the information falls under such as financial regulations, statutory limitation periods, Health and Safety regulation etc., or any contractual obligation we might have.
Subject to the above, we will typically store data relating to contracts for 6 years after the conclusion of the contract.
Once the retention period has expired, the information will be confidentially disposed, permanently deleted, or in some cases archived.
7. Your rights
Please let us know if your personal information changes during your relationship with us.
Under certain circumstances, by law, you have the right to:
- Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a confirmation from us as to whether we process any of your personal information or not, and if this is the case, to receive a copy of such personal information and to check that we are lawfully processing it.
- Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
- Request erasure of your personal information (often referred to as “the right to be forgotten”). This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal information where you have exercised your right to object to processing (see below).
- Object to the processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground. You also have the right to object if we are processing your personal information for direct marketing purposes.
- Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example, if you want us to establish its accuracy or the reason for processing it, or if we no longer need your data for our legitimate interests but we need to hold some of it for the purpose of legal proceedings.
- Request the transfer of your personal information to another party.
If you would like to exercise any of the above rights, please:
- email, call or write to us (see our contact details below);
- let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill). This is to allow us to verify your identity and prevent disclosure to unauthorised third parties; and
- let us know the details of your request, for example by specifying the personal data you want to access, the information that is incorrect and the information with which it should be replaced.
8. Contacting us or the relevant supervisory authority
Please contact us if you have any questions about this privacy notice or the information we hold about you.
You can email us: [email protected]
You can write to us at Positec Italia s.r.l., Contra Riale, 8, 36100, Vicenza, Italy
You can also contact the relevant supervisory authority in your location.
9. Changes to the privacy notice
We may change this privacy notice from time to time. This privacy notice was last updated on June 11, 2018.