Privacy Policy

We are committed to protecting your personal information and being transparent about what we do with it, no matter how you interact with us. That’s whether you want to work, buy goods or use our services, want information, training or want to learn more about what we do.

We are committed to using your personal information in accordance with our responsibilities. We are required to provide you with the information in this Privacy Notice under applicable law which includes:

the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) and the Data Protection Act 2018 (subject to Royal Assent) (‘DPA’) referred to as the ‘data protection legislation’
the Privacy and Electronic Communications Regulation (2003)

We won’t do anything with your information you wouldn’t reasonably expect.

Processing of your personal information is carried out by or on behalf of MAIS Srl, registered in Italy.

This notice, together with our website Terms and conditions and our Cookies policy tells you about how we collect, use and protect your personal information.

If you have any queries about our Privacy Notice, please get in touch with our Information Governance team:

Email	privacy@maistech.it
Post	VIA GIUSEPPE MAZZINI 20 CAP 34121 - TRIESTE (TS)

How and when we collect information about you

When you directly give us information

We may collect and store information about you when you interact with us. For example, this could be when you:

register for an event
buy goods from our online shop
submit an enquiry completing a contact form
register for or use our services using our Apps
participate in our training
give us feedback
make a complaint
use one of our apps
apply for a job
enter into a contract with us
partecipate to contest and survey
participate in activities that we promote and that might require information about you

When you indirectly give us information

When you interact with us on social media platforms such as Facebook, WhatsApp, Twitter or LinkedIn we may also obtain some personal information about you. The information we receive will depend on the privacy preferences you have set on each platform and the privacy policies of each platform. To change your settings on these platforms, please refer to their privacy notices.

We may obtain information about your visit to our site, for example the pages you visit and how you navigate the site, by using cookies. Please visit our Cookies policy for information on this.

What information we might collect

When you engage with us by phone, mail, in person or online, we may collect information about you (referred to in this Privacy Notice as 'personal information'). This may include your name, address, email address, telephone number, date of birth, job title and details of your education and career, why you are interested in MAIS S.r.l., and other information relating to you personally which you may choose to provide to us.

Data protection law recognises that certain types of personal information are more sensitive. This is known as 'sensitive' or 'special category' personal information and covers information revealing racial or ethnic origin, religious or philosophical beliefs and political opinions, trade union membership, genetic or biometric data, information concerning health or data concerning a person's sex life or sexual orientation.

Sensitive information will only be collected where necessary, for example, we may need to collect health information from you when you register to our service through our App. Clear notices will be provided at the time we collect this information, stating what information is needed, and why. SmairtHero will only use sensitive information in the operational circumstances for the supply of the services that you have purchased. To complete the registration on SmairtHero Apps and being enabled to use our services, you will be required to supply the following information:
Name
Address
Telephone number
Email address
Other data collected that could directly or indirectly identify you.
Age
Date of birth
Gender
Preferred Language for the App interface and for any contact with our Service Operational Room
Weight
Height
Secondary contact number at your choice
Medical Status and chronic pathologies
Biometric Data stream
Position and position in background: we need your position when SmairtHero app is in background and in foreground. The position will be used only from the operator of the Operation Center and only for rescue purposes.

All data, except for personal data, recorded using SmaritHero service are deleted after 30 days. Only alert history is saved for 60 days in case of legal problems.

Those data are mandatory in order to fulfil the services of 24/7 Health and Security monitoring, supported by our AI and Service Operational Room, offered by SmairtHero.

By purchasing the service and confirm your registration to the app you give explicit consent to the collection and storage of your data.

With your explicit consent, we may also collect sensitive personal information if you choose to tell us about your experiences relating to our services for use in a case study.

If you're 16 or under

If you're aged 16 or under, you must get your parent/guardian’s permission before you buy our services, provide any personal information to us, during the registration on our system.

How and why we use your information

We will use your personal information for the following purposes:

Responding to a request: If you contact us with a query, we may use your personal information to provide you with a response.
Direct marketing: We will only send you marketing information by email, if you have given us specific consent. If you withdraw your consent and then subsequently opt in to receive marketing information again, then your most recent preference may supersede.

Email	privacy@maistech.it
Post	MAIS S.r.l. VIA GIUSEPPE MAZZINI 20 CAP 34121 - TRIESTE (TS)

Monitoring and Evaluating: We may use your information in order to improve current and future delivery of our services.
Processing an application to work with us: We may process your information if you send or fill in an application form or send us your CV or details in respect of an opportunity to work with us in order to evaluate your suitability and respond to you.
Transactional purposes: We will need to use your personal information in order to carry out our obligations arising from any contracts entered into between you and us for goods or services, for example, processing your order and payment for a product from our online shop.
Providing and developing our website: We may use your personal information to help provide you with access to our website, personalise your experience, and improve and develop it further.
Administration: We may use your personal information to record and deal with a complaint, record a request not to receive further marking information, and for other essential internal record keeping purposes.
Protecting your vital interests: We may process your personal information where we reasonably think that there is a risk for your health and security or of serious harm or abuse to you or someone else, as a user of SmairtHero services.
Market research and surveys: We may invite you to participate in surveys or market research to help us improve our website, services and strategic development. Participation is always voluntary and no individuals will be identified as a result of this research, unless you consent to us publishing your feedback.
Legal, regulatory and tax compliance: Where required we are subject to a legal obligation, we may process your personal information to fulfil that obligation.

Who do we share your information with?

We will only use your information for the purposes for which it was obtained. We will not, under any circumstances, sell or share your personal information with any third party for their own purposes, and you will not receive marketing from any other companies, charities or other organisations as a result of giving your details to us.

We will only share your data for the following purposes:

Third party suppliers: We may need to share your information with data hosting providers or service providers who help us to deliver our services. These providers will only act under our instruction and are subject to pre-contract scrutiny and contractual obligations containing strict data protection clauses.
Where legally required: We will comply with requests where disclosure is required by law, for example, we may disclose your personal information to the government for tax investigation purposes, or to law enforcement agencies for the prevention and detection of crime. We may also share your information with the emergency services if we reasonably think there is a risk for your health and security or of serious harm or abuse to you as a user of SmairtHero services.

We always aim to ensure that personal information is only used by those third parties for lawful purposes in accordance with this Privacy Notice.

How we protect your information

We use technical and corporate organisational safeguards to ensure that your personal information is secure. We limit access to information on a need-to-know basis and take appropriate measures to ensure that our people are aware that such information is only used in accordance with this Privacy Notice.

We undertake regular reviews of who has access to information that we hold to ensure that your information is only accessible by appropriately trained staff.

Our online forms, all transmissions between the wristband and the phone app, between the phone app and the AI on the cloud, and the visualization on the web app in use of our Service Operational Room, are always encrypted and our network is protected and routinely monitored.

If you use your credit or debit card to purchase our services from our shop online, we pass your card details securely to our payment processing partners. We do this in accordance with industry standards and do not store the details on our website.

However, please be aware that there are always inherent risks in sending information by public networks or using public computers and we cannot 100% guarantee the security of data (including personal information) disclosed or transmitted over public networks.

Vulnerable circumstances

We understand that additional care may be needed when we collect and process the personal information of our customers. In recognition of this, we observe good practice guideline in our interactions with every customer.

How long will we keep your information?

We will keep your personal information in respect of financial transactions for as long as the law requires us to for tax or accounting purposes (which may be up to six years after a particular transaction).

If you request that we stop processing your personal information for the purpose of marketing we may in some instances need to add your details to a suppression file to enable us to comply with your request not to be contacted.

In respect of other personal and sensitive information, we will retain it for no longer than necessary for the purposes for which it was collected, taking into account guidance issued by the Information Commissioner’s Office. In particular the biometric data stream are stored separately by the personal and sensitive data they circulate in our network fully encrypted and they are stored for 7 days only. After this period if no accident occurred, we will cancel those data. In case of accident we will record complete logs of the event, of activity of the operator, audio recording of the calls occurred with you and with the emergency services.

International transfers of information

We may, on occasion decide to use the services of a supplier outside the European Economic Area (EEA), which means that your personal information is transferred, processed and stored outside the EEA. You should be aware that, in general, legal protection for personal information in countries outside the EEA may not be equivalent to the level of protection provided in the EEA.

However we take steps to put in place suitable safeguards to protect your personal information when processed by the supplier such as entering into the European Commission approved standard contractual clauses. By submitting your personal information to us you agree to this transfer, storing or processing at a location outside the EEA.

Your rights to your personal information

Data protection legislation gives you the right to request access to personal information about you which is processed by MAIS S.r.l. and to have any inaccuracies corrected.

You also have the right to ask us to erase your personal information, ask us to restrict our processing of your personal information or to object to our processing of your personal information. Please be aware that in this case we will not be able to perform our 24/7 Health and Security services.

If you wish to exercise these rights, please write to us and send it along with copies of two separate identification documents which provide photo identification and confirm your address, such as a passport, driving licence, or utility bill.

Please also provide any additional information that is relevant to the nature of your contact with us, as this will help us to locate your records.

You can send us the documents via post to:

MAIS S.r.l. - VIA GIUSEPPE MAZZINI 20 CAP 34121 - TRIESTE (TS)

Alternatively email a copy of the form along with scans or photos of your two forms of identification to: privacy@maistech.it

We will respond within 30 days, on receipt of your written request and copies of your identification documents.

How to make a complaint or raise a concern

If you would like more information, or have any questions about this policy, to make a formal complaint about our approach to data protection or raise privacy concerns please contact the Governance Team:

Email	privacy@maistech.it
Post	MAIS S.r.l. - VIA GIUSEPPE MAZZINI 20 CAP 34121 - TRIESTE (TS)

If you are not happy with the response you receive, then you can raise your concern with the relevant statutory body:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Alternatively you can visit their website.

Changes to our Privacy Notice

Our Privacy Notice may change from time to time, so please check this page occasionally to see if we have included any updates or changes, and that you are happy with them.
(Last updated: 25 May 2018)