SBS S.p.A., with registered office in Via Circonvallazione s/n, 28010 Miasino, C.F. and P. IVA 01888310032 (hereinafter, the "Company", or the "Data Controller"), is strongly committed to privacy and the protection of personal data. Therefore, we hereby intend to inform you about how we will process your personal data in accordance with the European Data Protection Regulation (the "Regulation" or "GDPR") in the context of your usage of our "SBS AI Connect" (hereinafter, the "App").
- a) Account creation and access management for Website Services and Platform Services,
- b) IoT device management,
- c) Reports and Statistics,
- d) Assistance service, and
- e) Translation service.
1. What types of personal data are processed?
Your personal data is processed for the purposes listed in the next paragraph.
More specifically, we will be able to collect, for:
a) Account creation and access management
- Personal information (name, surname)
- account data (email address), unique account identifier;
- if applicable, location information (country, time zone);
- Language preference.
b) IoT device management
- Wi-Fi information (SSID, BSSID, Wi-Fi Mac address, Wi-Fi password);
- device information: device name, device virtual ID, device mac address, online status, activation time, firmware version, device power (optional), voltage (optional), battery capacity (optional), power-on status;
- connection information: IP address.
c) Reports and Statistics: technical logs, browsing activity information.
d) Assistance service
- account data, device information: device name, device virtual ID, device mac address, online status, activation time, firmware version, device power (optional), voltage (optional), battery capacity (optional), power-on status;
- connection information: IP address.
e) Translation service:
if you activate the service, content captured by the earbuds’ microphones during a phone call. Once the transcription and translation have been processed, the system will immediately delete the original audio file.
2. How was my personal information obtained?
Personal data is collected in the following ways:
- account data (including unique account identifier) is required directly from you during the account’s creation;
- technical features, such as Wi-Fi and device information, IP address, technical logs, or browsing history, may be automatically detected / collected via the App.
3. For what purposes of processing will my personal data be processed?
We will process your personal data for the following processing purposes:
| Purpose | Legal Basis | Retention period |
|---|---|---|
| Account creation and access management for Website Services and Platform Services | The need to execute a contract to which you are a party of (Art. 6(1)(b) GDPR). | Your account data will be stored for as long as your account remains active and will be deleted immediately after your account is closed. Your contractual data will be kept for as long as necessary to fulfil contractual obligations and obligations imposed by law (e.g., in tax matters 10 years). |
| IoT device management | The need to execute a
contract to which you are a
party of (Art. 6(1)(b)
GDPR). The legitimate interest of the Company to keep connected devices functional, secure and efficient (Art. 6(1)(f) GDPR). |
Your personal data will be kept
for as long as necessary to fulfil
contractual obligations and
obligations imposed by law
(e.g., in tax matters 10 years). Where your data is processed on the basis of legitimate interests, it will be kept for as long as the legitimate purpose remains valid and the data is necessary to achieve that purpose. |
| Reports and Statistics | The legitimate interest of the Company to analyse trends, improve services, or generate business intelligence (Art. 6(1)(f) GDPR). | Your data will be kept for as long as the legitimate purpose remains valid and the data is necessary to achieve that purpose. |
| Marketing | Your consent (Art. 6.1.a. of
the GDPR). The Company will process your personal data to send you commercial communications and/or promotional material related to the services offered by the Company and to involve you in market research and surveys. For example, we may send you emails or use instant messaging services (including via whatsapp) or contact you by phone through an operator to explain commercial offers, initiatives and promotions related to our services. Consent is not mandatory and if you decide not to provide it you will still be able to use the requested services. |
Your data will be kept for this purpose until you withdraw your consent. |
| Profiling | Your consent (Art. 6.1.a. of
the GDPR). The Company may create a profile based on your personal information, preferences and interests, your previous purchases (e.g., booking history), in order to send you personalized promotional information, targeted advertising material and tailored commercial offers. Consent is not mandatory and if you decide not to provide it you will still be able to use the requested services. |
We will process your personal data for profiling purposes until your consent is revoked. Details of your previous purchases will be kept for 12 months. |
| Assistance service | The need to execute a
contract to which you are a
party of (Art. 6(1)(b)
GDPR). The legitimate interest of the Company to carry out support functions that are not directly covered by the contract (Art. 6(1)(f) GDPR). |
Your personal data will be kept
for as long as necessary to fulfil
contractual obligations and
obligations imposed by law
(e.g., in tax matters 10 years). Where your data is processed on the basis of legitimate interests, it will be kept for as long as the legitimate purpose remains valid and the data is necessary to achieve that purpose. |
| Translation service | The need to execute a
contract to which you are a
party of (Art. 6(1)(b)
GDPR). For special categories of personal data, e.g., data related political opinions, religious beliefs, or health, your explicit consent (Art. 9(2)(a) GDPR). If you decide to voluntarily provide information such information you do so freely and deliberately. You have the right to withdraw your consent at any time; however, the withdrawal might result in the service no longer being provided. |
The Company will only process
the content captured by the
earbuds in order to provide
the Service and will not store,
except for the time strictly
necessary to provide the
Service, share, other than with
providers who provide
translation services, or use it
for any other purpose, not
even to train the AI system. Your contractual data will be kept for as long as necessary to fulfil contractual obligations and obligations imposed by law (e.g., in tax matters 10 years). The audio file will be stored solely for the duration required to provide the instant translation and transcription. After this time, it will be deleted immediately. The transcription and translation will be stored for one year, after which they will be deleted. However, you can use the App to request deletion before this deadline. |
| Fulfilment of legal obligations | Fulfilling a legal obligation (Art. 6(1)(c) GDPR). | Your personal data will be kept for as long as necessary to fulfil legal obligations (e.g., in tax matters 10 years). |
| Rights protections | The legitimate interest of the Company to establish, exercise or defend one’s right, including in court (Art. 6(1)(f) GDPR). | Your data will be kept for as long as the legitimate purpose remains valid and the data is necessary to achieve that purpose. |
4. Is the provision of data mandatory or optional?
The provision of personal data is voluntary but necessary - except for the data indicated as optional, since in case you decide not to provide it, it will not be possible to provide you with the requested services.
5. What parties may become aware of my personal data?
Your personal data may come to the knowledge of our employees and collaborators who are involved in the management of the contractual relationship and legal affairs. In addition, the following categories of persons may also become aware of your personal data, who, as data processors, provide us with services instrumental to the carry out our business activities: providers of IT services (such as the translation service), management services, administrative services; external professionals and consultants, including auditors; external auditing firm, where present.
A complete list of these companies will be made available by sending a written request to the contacts below.
6. Will my personal data be disclosed to third parties?
Your data may be communicated to third parties belonging to the following categories: to banks and payment institutions, to the extent necessary to make or receive payments in connection with the contract; to competent tax and fiscal authorities to the extent required by law; to judicial authorities or police forces, in the cases provided for by law; to lawyers and law firms, where necessary to pursue our legitimate interest in exercising or defending a right in judicial and extrajudicial proceedings; to parties who are assignees of the contract, our company, or one of our business branches.
7. Will my personal data be transferred outside the European Economic Area?
If required for the purpose of using certain of services (e.g., IT, or for the translation service), the Company may transfer your personal data outside the European Economic Area, in particular in the United States of America and China. In this case, the transfer will take place in compliance with the provisions of the GDPR; in particular, the data will be transferred only after signing the Standard Contractual Clauses approved by the EU Commission by Decision No. 2021/914/EU or to countries that can guarantee an adequate level of protection of personal data and therefore recipients of an Adequacy Decision adopted by the EU Commission.
8. What are my rights and how can I exercise them?
You have the right to exercise at any time, free of charge and without formalities the following rights set out in Articles 15 to 22 of the Regulation:
- the right to request access to personal data (i.e., the right to obtain confirmation as to whether or not personal data concerning you is being processed and, if so, to obtain access to the personal data, obtaining a copy thereof, and to the information referred to in Art. 15 of the Regulations);
- the right of rectification (i.e., the right to obtain rectification of inaccurate personal data or the completion of incomplete data pursuant to Art. 16 GDPR);
- the right to erasure (i.e., the right to have your personal data deleted, where one of the grounds specified in Art. 17 GDPR applies);
- the right to restriction of processing (i.e., the right to obtain, in the cases indicated by Art. 18 of the Regulations, the marking of the data stored with the aim of limiting their processing in the future);
- the right to data portability (i.e., the right, in the cases indicated by Art. 20 of the Regulations, to receive your personal data in a structured, commonly used and machine-readable format, and to transmit it to another controller without hindrance);
- the right to object (i.e., the right to object at any time, on grounds relating to your particular situation, to the processing of your personal data pursuant to Article 6(1)(e) (performance of a task carried out in the public interest or in connection with the exercise of official authority) or (f) (legitimate interest) of the GDPR, including profiling on the basis of these provisions), and
- the right to withdraw consent (i.e., where processing is based on your consent, you have the right to withdraw that consent at any time). However, revocation of consent does not affect the lawfulness of processing carried out prior to revocation.
Please note that the provision of services you requested is in no way contingent on the provision of the above consents.
We remind you that you always have the right of filing a complaint with the Data Protection Authority (www.garanteprivacy.it) or the different Supervisory Authority of the EU Member State where you reside, work, or the alleged violation occurred.
9. How can I contact you and exercise my rights?
Requests to exercise your rights, as set out above, may be submitted by e-mail to info@sbsmobile.it, or by mail to "SBS S.p.A., Via Circonvallazione s/n, 28010 Miasino."