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Check terms of use and privacy policy: Developer: The Newlab Smarthome portal, Newlab skills and connection services with third parties have been developed and are maintained by Newlab SRL Piazza Fulcieri Paolucci de Calboli 1 Genova 16161 Italy Tel. +390108937361 Email: software@newlablight.com The following General Conditions regulate access to the portal and its use. Specific terms and conditions may apply to specific content, data, materials or information. These specific terms are added to these General Conditions to the extent expressly indicated and may take precedence over the General Conditions. GENERAL CONDITIONS OF SMARTHOME 1. Definitions. Platform: The Smarthome Platform (hereinafter only "Platform") consists of the website, applications for portable devices and the technological infrastructure necessary for the provision of the Services and is managed by the Supplier. Supplier: the Supplier is Newlab Srl (hereinafter "Supplier") with registered office in Piazza Fulcieri Paolucci de Calboli 1, 16161 Genoa, Italy, Tel. +39 0108937361, Email: software@newlablight.com. The Services can be provided directly by Newlab Srl, or together with another company in the event that the hardware purchased bears the trademark of another company (in this case the term "Supplier" will refer cumulatively to Newlab Srl and to that other company). General Conditions: These General Conditions establish the legal reference framework for the use of the Services we offer. The User is therefore requested to read these General Conditions carefully because without their acceptance it will not be possible to register and use the Supplier's Services. Services: These are all the Services provided by the Supplier through the Platform. In particular, the Platform allows the User to use different Services through a computer connected to the website, or a smartphone connected to the website or Application, or through voice assistants or third party Services (for example Google Home or Amazon Alexa) , or other. The services mainly include the remote control of electronic devices equipped with specific hardware and the display of the usage history of the devices themselves and the statistics. The Services can only be used if you are in possession of compatible devices (for example, compatible smart switches produced or distributed by the Supplier). User: anyone who registers on the Platform and / or uses the Services. 2. Requirements for registration and use. To register on the Platform and use the Services, you must be of legal age and register by providing the requested data truthfully. To register the account, it is necessary to expressly accept these General Conditions of Registration, together with the Privacy Policy regarding the processing of personal data, using the appropriate "form" on the registration screen. The full text of the Privacy Policy is attached. If the User does not accept these Conditions, he cannot access or use the Platform. These General Conditions will be valid until the current version is canceled or modified from 1 January 2020. 3. Consideration. Unless otherwise indicated, the Provider (until otherwise specified) will not ask for any specific consideration for the provision of the basic Services and the use of the Platform. The provision of the Services may be linked to the purchase of a specific hardware product; in this case the provision of the Services will in any case be governed by these General Conditions. The Supplier reserves the right to request payment of a fee for some Services. In this case, the User must pay the price for the relative Services on the basis of what is specified in the specific conditions. 4. Registration. Use of the Platform requires a one-off free registration. The minimum registration age is 18 years in Italy and the age of majority in other countries. By registering, the User confirms that he meets the age requirements indicated in the applicable law and therefore has the legal right to enter into contracts. Registration is free and makes it possible for Users to access the Platform and use the Services. For registration purposes, the User must provide the data requested in the relevant registration form in a complete, correct and accurate manner, unless such data is marked as optional. In some cases, registration may also take place through the adoption by the Supplier of registration data provided by the User on other sites or social networks (eg Facebook or Google). Registration is only possible using the real name of the User, e.g. it is not possible to indicate invented names or pseudonyms. After registration, for security reasons we can send an e-mail in which we will ask you to confirm the registration by clicking on the appropriate button. In this case, by clicking on this button you will be redirected to our website where you can definitively confirm the registration; only at this point will the procedure be complete. By registering on the Platform, the User confirms that: - The data he has provided is correct, truthful and accurate; - The access credentials are sufficiently secure and will be kept confidential and not disclosed to third parties; - Will not allow unauthorized third parties to access the Platform; - He is not creating the account to abuse the Services or to impersonate another person. After confirming that the account has been registered, the User will have the possibility to access the Services made available on the Platform with his own Authentication credentials. It is understood that all the operations carried out through the Platform (apps, sites, voice assistants and others) with the use of the account entail the automatic, unambiguous and immediate attribution to the User, the account holder, of the will to perform said operations. 5. Suspension or termination of the contract The Supplier reserves the right to deactivate the Platform completely or partially, for any reason and at any time, without prior notification or authorization. The User has the right to cancel the profile at any time, without having to provide a reason, thus also concluding the contract of use at the same time. To do this, simply send an email to the address of the Supplier indicated above. Note that once the User profile has been deleted, we will delete or we may delete all the contents and data provided by the User or that have been collected during use (and therefore also the device usage statistics) and it will no longer be possible plus access to the Services. The User can also request to delete the profile and personal data at any time by contacting us directly. 6. Account security The User is obliged to protect his account from unauthorized access and fraudulent use. We therefore invite the User to promptly notify us via email at the address indicated above of any unauthorized or fraudulent use of his account, or any suspicion that his personal account may be at risk. The Supplier has the right to close or delete the account of any registered User in the event of unauthorized or fraudulent use of the account. With the registration of the account, the Authentication credentials defined by the User are uniquely connected to their account. The credentials, to be considered strictly personal and not transferable, must be diligently kept by the User, who will be required to adopt all the appropriate security measures aimed at the custody and maintenance of their confidentiality in order to prevent their use of unauthorized third parties. These security measures must be in line with the technical standards known by a prudent User, and such as to minimize the risks of unauthorized use, destruction, subtraction or loss of credentials. The User is therefore solely responsible for the safekeeping, maintenance and correct use of his credentials as well as the devices associated with the account. The Supplier reserves, at its sole discretion, not to perform and / or interrupt the services requested through the use of the Platform and the Services, where it has reasonable reason to believe that the User's account has been violated. In this context, the Supplier assumes no responsibility for the failure to perform the requested services. In any case, it is understood that the Supplier does not assume any obligation, express and / or implicit, to proceed to a systematic control of access to the Contents through the site and aimed at identifying any account violations and cannot in any way be considered responsible . Any consequence, damage and / or prejudice that may arise to the Supplier and / or the User due to incorrect use, loss, removal and / or compromise for any reason of confidentiality and / or integrity of the Credentials will be fully borne by the User with the express exclusion of any liability of the Supplier. 7. Obligations and prohibitions for the User. It is expressly forbidden for the User to copy, reproduce, redistribute, modify or otherwise intervene on the software or on the platform's computer code. The user agrees to use the Platform only for private and personal use and therefore not for commercial or industrial purposes or for any other different purpose (in particular, but without limitation, for dangerous activities or medical activities), expressly exempting the Supplier from any consequences related to any unauthorized use. It is forbidden to license, sell, rent, transfer, issue the Services in any form or use them for other commercial purposes. Due to the limitations of the Platform and the software adaptation terminals, it is possible to use the Services only within the Platform and in the manner defined by the Supplier. Unauthorized use could damage the hardware or software function. The User acknowledges that he can use the Platform and the Services only for non-commercial purposes. The User must use the licensed software in a normal way. The following activities (indicated as an example and not exhaustively) are in violation of the application standard: 1) issue or share computer viruses, worms, malicious codes or software that deliberately damages or modifies the system or data of the Platform; 2) collect information or data from other Users without authorization, for example email address and the like; 3) use the Platform fraudulently or maliciously or automatically, or causing an overload of the server or interfering or damaging the server and network connections in other forms; 4) copy part of the Platform or part of its code to other applications, sites or Services; 5) interfere, modify, damage or corrupt part of the Platform or part of its code; 6) attempt to access server data or product communication data without authorization; 7) use the Platform without having verified that your device is virus-free; 8) interfere or damage the Platform. The User agrees not to undertake any act in violation of improper laws or behavior using the Service, such act and behavior include (among others): 1) unauthorized uploading, transferring or sharing of information; 2) opposition to the fundamental principles determined by law; 3) spread of obscenity, porn, gambling, violence, murder and terror or aiding and abetting a crime; 4) insult or slander other Users and violate their legal rights and interests; 5) engage in fraud, damage, threats, violation of others' privacy, harassment, roughness, indecency or otherwise enter morally repulsive content; 6) in any way insert other elements subject to restrictions or prohibited by laws, regulations, norms, provisions and other applicable legal standards. 8. Third party content. The Supplier is in no way responsible for the contents of third party owned sites that can be connected to the Platform (also via hyperlink). All links available from the Platform to another site do not represent an endorsement of the contents of that site and therefore the accuracy, precision or suitability of the contents of the site to which the link points are not guaranteed. The software made available for download is licensed in accordance with the terms of the applicable license agreement. The User acknowledges that certain Services may be based on software or services provided by third parties. The Platform may include third party information and services. The Supplier does not control or assume responsibility for third-party information and services. 9. Connection with voice assistants. The User through the Platform can connect their devices to the voice assistants (for example Amazon Alexa or Google Home) in order to control them through these services. In any case, the words spoken for voice commands are treated by other subjects (Google or Amazon) and the Supplier merely receives the electronic on / off command and in some cases communicates the status of the devices to this other company (for example to allow the voice assistant to answer if a light is on or off). The Supplier is in no way involved in the management of the recordings made by the voice assistants and therefore cannot be considered responsible for any damages or problems deriving from this activity. This information is managed directly by the voice assistant suppliers (Google or Amazon) on the basis of specific and separate agreements with the User with respect to which the Supplier is totally extraneous. 10. Rights of use on contents and copyright. The Services offered by the Supplier may contain content protected by copyright or other and of which the Supplier does not hold the rights. However, the Supplier guarantees a non-exclusive and non-transferable right to use these contents for non-commercial uses within the scope of these contractual clauses. For the sole purpose of dispelling any doubts, we point out in particular that the distribution of our content or their publication is not allowed, e.g. on other sites. The right of use expires upon deactivation of your access to the corresponding Service (e.g. after canceling your account) or at the end of the contract of use. The copyright and all other proprietary rights relating to the Platform and the Services of the Supplier, by its subsidiaries, affiliates and / or its partners, the software to use and publish content on the Platform, the data set on the Platform and the code of the Platform, the order, sequence and organization of the Platform are owned by the Supplier and / or its partners or licensors. All rights relating to the Platform and Services not expressly granted in this document are reserved. The use and registration of the Newlab name and the Smarthome name are reserved exclusively for Newlab SRL. It is not allowed to register or use a company name, a legal name, a commercial name, a domain name or any other name, indication or description which includes the name Newlab SRL or Smarthome or any similar name or which consists of a part of the name Newlab SRL or Smarthome, nor include any other registered trademark owned by Newlab SRL or Smarthome. All registered trademarks of Newlab SRL and its affiliates are important resources of Newlab SRL. The correct use of these brands is of fundamental importance and the User must follow the instructions of Newlab SRL when referring to the company's products and services. Part of the Platform is public in nature and any information sent to it is considered non-confidential. The User also acknowledges that the User Content sent and / or presented on the Platform may be protected by patents, copyrights, trademarks and other intellectual property rights of the Supplier, its subsidiaries, affiliates, its partners or third parties. 11. Availability of the Services and errors. The Supplier does not represent or guarantee that the Platform and Services will always be available or that they are completely error-free. 12. Rights of the Supplier. The Supplier reserves the right to stop or suspend the operation of the Platform. The Supplier reserves the right to refuse Users without giving explanations. In this case, the transmitted data will be immediately deleted. If the User provides false, incorrect, outdated or incomplete data, or the Supplier has reasonable grounds to suspect that such data is false, incorrect, outdated or incomplete, the Supplier has the right to immediately suspend or close the account of the 'User in question without notice and to refuse any current or future use of the Services without the User being entitled to a refund of any amount paid previously. In any case, the Supplier reserves the right to contact the User at any time to verify the registration data. The Provider reserves the right to modify options or functionality of the Platform. In most cases, changes will be made to the Platform to enhance or improve it. The Supplier reserves the right to stop the operation of the Platform or make changes or updates to it at any time, without notice. All modifications, suspensions or interruptions will not give any right to claims or compensation in favor of the User. The Supplier can modify these General Conditions at any time. The changes take effect at the time of publication (unless otherwise specified). Continuing to use the Platform and the Services after the publication of these changes is equivalent to accepting them. It is advisable to periodically consult the General Conditions. The Supplier also reserves the right to limit, refuse or block access to the Piattagorma or part of it with immediate effect and without notice, at any time and for any reason at its own discretion. 13. Responsibility. The following conditions regulate the Supplier's liability and apply for claims related to defects in the Services or related problems. The Supplier (and its affiliates and affiliates and its partners, licensors, distributors and suppliers) declines all responsibility for direct and indirect damages that may arise from the Platform, from its use and from any malfunction. In light of the type of services offered (which are limited to making software and digital content available and the management of some personal data), the Supplier declines all responsibility for possible damages that the User may suffer while using the Services. except as required by law. Compliance with any guidelines or instructions provided by the Supplier is essential. If the User uses electrical or electronic equipment connected to the Platform, he must ensure that installation of the same takes place by qualified personnel who act under their own responsibility with exemption and indemnification against the Supplier. The Supplier (and its affiliates and affiliates and its partners, licensors, distributors and suppliers) is not responsible for any malfunctions or damage (including indirect) related to the devices used to connect to the Platform (smartphone, tablet, PC, assistants voice, remote control devices, other connected devices, etc.) It is therefore the responsibility of the User to ensure the safety of electronic devices and their installation. The User is aware of the characteristics and risks of electronic devices and the Internet and therefore accepts these risks. Although the Supplier makes every effort to provide a reliable solution, errors are still possible. In no case can the Supplier be considered responsible. The User is responsible for updating, checking, and security of the devices and elements of the Platform. The Provider is not responsible for the presence of viruses or other malicious software. It is the User's responsibility to ensure the presence of suitable safety measures on the devices. The Supplier can interrupt access to the Platform to guarantee its security. In any case, the Supplier cannot be held responsible for any damage deriving from a use of the Platform which conflicts with these General Conditions, with the law or with common sense. If the User lives in a country or area where the aforementioned disclaimers or limitations of liability or some of the disclaimers provided for herein are not admitted, these exclusions or limitations will be applied only to the extent permitted. in such cases, the exclusions or limitations must be limited to the provisions of the current regulations. Consumer rights are however guaranteed. 14. Personal data The Supplier manages the User's personal data in compliance with its privacy policies. The updated version is available on the Platform. Each User has access only to information concerning him. The information of each User is accessible only by him. The Supplier has provided and implemented security measures aimed at ensuring that the personal data processed in the functioning of the Platform are kept secure. In any case, the Supplier points out that no IT solution can guarantee total data security and warns the User against possible risks regarding privacy and confidentiality of the data. By accepting these General Conditions, the User accepts that the Supplier will manage the data as described in these General Conditions and in the Privacy policy, as long as no changes are made. 15. Online dispute resolution The Supplier informs the User, if he holds the quality of consumer referred to in art. 3, paragraph 1, lett. a) of the Consumer Code, which established a European platform for the online resolution of consumer disputes (the so-called ODR platform). The ODR Platform can be consulted at the following address https://ec.europa.eu/consumers/odr/ through the ODR Platform the consumer User can consult the list of ADR organizations, find the link to the site of each of them and start an online dispute resolution procedure in which he is involved. We are neither willing nor obliged to participate in a dispute resolution procedure before a consumer arbitration office. Our e-mail address is listed in these Terms and Conditions. 16. Changes to the General Conditions The Supplier reserves the right to modify and adapt these general contractual conditions with future effect; however, these changes will be made in good faith. The User will be informed of the changes by e-mail (at the address provided during registration) at the latest within two weeks before the expected entry into force of the new version of the General Conditions. In the absence of any opposition to the validity of the new version of the General Conditions within this period and by continuing to use the Platform, the new version of the General Conditions will be considered accepted. In case of non-acceptance, the User will no longer be able to use the Platform. 17. Applicable law The relationship between the parties is governed by Italian law with the exclusion of the UN Convention on International Sales Contracts (CISG). As regards commercial transactions with customers within the European Union, the law of the consumer's country of sale can also be applied only if it contains provisions on consumer rules that it is mandatory to apply. 18. Safeguard clause If any of the clauses of the General Conditions is or becomes completely or partially invalid, this will not affect the remaining clauses. 19. Option to save and revise the contract language These General Conditions can be checked on the Platform. To save a permanent copy of these General Conditions on a data medium, you can download the "pdf" version for free. Refer to your browser's help for information on how to save files. To open a "pdf" file you need special software such as the free program Acrobat Reader or a similar program that uses "pdf" files. You can consult any other information and contractual data on the Platform, or print or save the order confirmation received after completing a purchase. PRIVACY POLICY SMARTHOME USERS For Newlab SRL your privacy is important. We have drafted this Privacy Policy (hereinafter also "Information") in a simple and understandable way, in order to help you understand who we are, what personal data relating to you we collect, why we collect it and how we use it. Please note that personal data (in the following of this information, also "data" or "information") means all that information or set of information from which it is possible to identify it personally, directly or indirectly, in particular by referring to a certain number or identification code. We invite you to take a few minutes to read this information in full. If you do not accept this information, please do not provide us with your data and stop using our services. If you do not want the processing of your data relating to the use of the platform, we invite you to stop browsing and ask us to delete your account and your data. 1. Treatment and Data Controller. Smarthome (hereinafter the Platform) is a Platform created by for the remote control of electronic devices and works in connection with compatible hardware devices. The service provided through the Platform consists in the control (remote and not) of electronic devices also through third party voice assistants and in the supply of usage statistics of the devices themselves. The Platform is accessible for Users via smartphone application and website and is managed by the company Newlab Srl which performs the function of Data Controller (hereinafter Newlab, with registered office in Piazza Fulcieri Paolucci de Calboli 1 - Genoa - Italy PI 01443720998, email: privacy@newlablight.com). The data controller you can contact is therefore Newlab Srl (email address privacy@newlablight.com). In the event that the device purchased bears the mark of another company, this other company will play the role of independent owner and as such will be able to access your personal data. 2. Personal data processed The Owner processes the personal data of the Users of the Platform. These natural persons are also identified below as "Interested", in accordance with the definitions provided by current legislation. To create an account and use the Platform, the user must be at least 18 years old. Below we briefly explain which data we use and for what purposes. Identity data, including: name (first name, surname), e-mail address, password, preferred language, IP address. We use this data to verify your identity and to provide the service. Contact details, including e-mail address and any other communication channel that you used to contact us for the purpose of obtaining further information. We use this data to contact you for different reasons depending on the purpose. Additional information necessary for customer support: if you contact us for assistance you may provide us with further information that we will treat in accordance with this information. Data about your location, taken from the IP address. We use this data for the provision of the service, to manage our products and to adapt your experience with the products to your geographical area, as well as for marketing purposes and to generate anonymous usage statistics. Information on the device connected to the Platform and on its use, including: switch name, switch IP, hardware type, IMEI code and other unique device identifiers, data relating to the on / off commands of the devices, usage statistics, consumption, and other diagnostic, technical, error and usage information. The information is provided by you and collected during the use of the Platform. This information is used for the provision of the remote control service of the device also through the voice assistants, for the supply of usage statistics that you can view within the Platform, for the supply of technical support, for the security of the Platform, Information on the device used to access the Platform and on its use including type of device, mac address, IP address, version of the operating system and device settings, other information provided by the device or browser, date and time of the visit, duration of the sessions on our website and on the App, volume of data transmitted, the reference URL (if you came to our site through another website or an advertisement), the pages visited on our site, the type of browser (including browser software language and version) and add-ons, device identifier and features, device type, versions, operating system and other diagnostic, technical, error and usage information. This is often necessary for purposes related to network security, Preferences data, including: preferred language, preferences for data collection and use, device preferences and access location. We use this data to provide you with our service. 3. Purpose of the processing Personal data are processed by the Data Controller for the purposes described in the previous point, that is to: Manage the Platform and provide the service to Users, and therefore to authenticate your access to an account and to the Platform, to provide you with the service remote control, track the use of the devices to provide you with the related statistics within the Platform. Customer support, and therefore to investigate, respond to your requests, and resolve complaints and service problems, e.g. to contact you following a question you asked the customer support team. Fulfillments connected with the execution of the contractual relationship, and therefore manage the fulfillments of an administrative, accounting, civil and fiscal nature. Business and research and development needs, and therefore to manage our business needs, including the creation (anonymous and aggregate) of statistics on the use of our services (also divided by type of users, type of devices, location and other), monitor, analyze and improve the use of our products, as well as to protect the safety or integrity of the products themselves and their performance and functionality. For example, we analyze user behavior and research how our products are used. We process the data, to conduct research for the further development of our Products, in order to offer you and other people a better, more intuitive and personalized experience, and support the growth and involvement of users in our Products. General marketing. We process data to provide you with (customized) marketing material on online products and services. Marketing and communications via email / push message. Your email address communicated when registering with the Platform will be used to provide you with communications, promotions and information on the service provided on the Platform. With your consent, we may send you personalized e-mails or marketing push messages, as well as related and non-related products. Defense in case of legal actions and therefore for the initiation, exercise or defense in legal actions of which we are or could be part. 4. Legal basis of the processing The legal basis of the processing is represented by the need to provide the service (art.6.1.b of the GDPR), by the consent expressed during the registration phase (art.6.1.a of the GDPR), by the pursuit of the legitimate interests of the owner related to management of its economic activity (art.6.1.f of the GDPR), from the pursuit of the legitimate interests of the Data Controller relating to the marketing activity (art.6.1.f of the GDPR), from the pursuit of the legitimate interests of the interested party to use the services ( art.6.1.f of the GDPR) and the legal obligation (art.6.1.c of the GDPR). 5. Data provided by the user and data collected during the use of the Platform The provision of data is necessary for the provision of the owner's service, and in some cases to comply with the law and to protect the legitimate interest of the owner. Therefore, the failure, partial or incorrect provision of such personal data will result in the objective impossibility for the Data Controller to establish or regularly conduct the contractual relationship. Most of the Personal Data are recorded by us when the user himself spontaneously communicates them to us, for example when he contacts us, especially when registering an account on the Platform, when registering a device, when forwarding a command, or enter or edit information or request information. Some data are collected during the use of the service for the purpose of providing the remote control and tracking service. 6. Access authorizations We need these access and information possibilities for the technical functionality of our apps and for making available the services offered with the app, in particular to be able to access bluetooth and to send push notifications. During the installation procedure and / or before the first use, we request permission to access the individual functions and information and we will access these functions only to the extent that the user releases their consent. You can manually block access rights in the settings according to the respective operating system. How to proceed is indicated in the manufacturer's instructions for each device. However, please note that in the absence of the relevant authorization, the use of the Platform will be limited or impossible. 7. Options available to the user The user can choose not to record certain types of information, for example those relating to the tracking of the use of the devices and the related statistics. This may limit the possibility of using the services offered. 8. Processing methods The Data are processed in accordance with the General Regulation on the Protection of Personal Data (EU Reg. 2016/679, hereinafter also GDPR), as well as with the other current provisions of law including the Privacy Code (Legislative Decree no. Legislative Decree 96/2003) and Legislative Decree 101/2018. Personal data are used only to the extent that they are necessary to fulfill and perform our services or for other purposes as described in this statement. The processing of personal data is based on the principles of correctness, lawfulness and transparency. The treatment can be carried out using manual, paper, electronic and IT tools with methods strictly related to the purposes for which the data are processed and in any case in compliance with the provisions of art. 32 GDPR on security measures and through the use of suitable procedures that avoid the risk of loss, unauthorized access, illicit use and disclosure. The Data Controller does not carry out treatments that consist of automated decision-making processes that produce legal effects that concern him or that significantly affect his person in a similar way. The data are used and processed in a computerized and automated way only for the creation of the training plan. Some profiling activities can be carried out for the purpose of sending emails and communications. With reference to the data processed through the use of cookies, see below. 9. Measures taken to protect user information Newlab takes the protection of user data seriously and has taken appropriate technical and physical measures to protect the information collected. However, please be aware that although Newlab takes reasonable precautions to protect information, no application, website, transmission via the internet, computer or wireless connection is completely secure. The user is therefore aware of the risks associated with the use of the platform. 10. Recipients of the data The personal data processed by the Data Controller will not be disclosed, that is, it will not be disclosed to indeterminate subjects, in any possible form. The Data Controller's collaborators will be able to access the data. In particular, based on the roles and job duties performed, some of the Data Controller's collaborators have been authorized to process personal data within the limits of their competences and in accordance with the instructions given to them by the Data Controller itself. They may also be communicated, within the strictly necessary limits, to external subjects who collaborate with the Data Controller designated as Data Processors. They may be communicated to subjects who need it for management purposes such as the server provider, the database service provider, the suppliers of e-mail and newsletter services. Finally, they may be communicated to subjects entitled to access them by virtue of legal provisions, regulations, community regulations. We will share the Data with third parties if necessary, for the purposes, or following a request by a national authority, or following a court order, or if required by law, or if necessary to investigate and defend ourselves from requests or accusations from third parties, or to exercise and protect the rights and safety of Newlab, our members and staff; or if you have (explicitly) given your consent. 11. Sharing data with Google and Amazon and their role. You can decide to use the appropriate Skills to connect your account on the Platform to Google Home or Amazon Alexa in order to control the device with voice assistants. In this case Amazon and Google will operate as independent data controllers and an exchange of data will take place with these subjects for the purpose of providing the remote voice control service. In any case, the words spoken for voice commands are treated by other subjects (Google or Amazon) and the owner simply receives the electronic on / off command and in some cases to communicate the status of the devices to this other company (for example to allow the voice assistant to answer if a light is on or off). The owner is in no way involved in the management of the recordings made by the voice assistants and therefore cannot be considered responsible for any damage deriving from this activity. This information is managed directly by the voice assistant suppliers (Google or Alexa) on the basis of specific and separate agreements with the User with respect to which the owner is totally unrelated. The user can at any time connect or disconnect his account on the Platform from the Google Home and Amazon Alexa services. 12. Data sharing with the manufacturer, distributor or reseller of the devices and their role. When the device purchased and connected to the Platform bears the mark of another company, this other person will have access to the user's data. Registration on the Platform in this case will lead to the establishment of a relationship with two different data controllers, that is, with Newlab as a supplier of the technical service relating to the Platform and with the other manufacturer / distributor. This other person will use the data for the purpose of the necessary technical support, as well as for any other purposes, under his exclusive responsibility and subject to appropriate information that will be provided by the latter. 13. Other forms of sharing and data transfer Like many companies, we may outsource some data processing activities to trusted service providers, with the task of carrying out specific functions and services, such as, for example, ICT services, consultancy, freight forwarding and forwarding agents. We can share your data with third parties, including professional consultants, such as banks, insurance companies, auditors, lawyers, accountants, other professional consultants, provided that this is lawful and justified. The data could therefore be shared with service providers, i.e. carefully selected companies that provide services in the name or on behalf of Newlab, such as companies that collaborate in the field of repairs, customer contact centers, customer support activities, advertising, customer satisfaction surveys or billing or sending e-mails on behalf of Newlab. These providers also undertake to protect your data. Occasionally, we may also share your data in the course of corporate transactions, such as the sale of a company or business unit to another company, or a reorganization, merger, joint venture, or other transfer of a company, assets or equity investments (also in connection with bankruptcy or insolvency proceedings). The data may be transferred outside the European Union, in particular in the USA. This transfer will take place in the presence of the legal conditions or on the basis of an adequacy decision adopted by the European Commission. 14. Data retention The Data Controller stores and processes personal data for the time necessary to fulfill the purposes indicated and as long as there is a contractual relationship and / or legitimate interest. Subsequently, personal data will be kept for the time established by the current civil and fiscal provisions. We store user data for the time required for the fulfillment of the intended purpose and / or until the user cancels their account or until the retention periods established by law make their storage necessary. Finally, in accordance with the legislative provisions, the data are deleted or their treatment is limited. We will keep your data for the entire period during which you have an account with us. If you decide to delete your account, all the data on your account held by Newlab will be removed (or kept in an anonymous and no longer identifiable form), except for the following: the data necessary for the fulfillment of contractual obligations or compliance with the statutory retention obligations will not be eliminated, but reduced to the minimum to the extent necessary. A request for deletion does not affect the data, if their storage is required by law or for other specific purposes. 15. Information relating to the sending of newsletters and commercial communications. For the purposes of the operation and use of the Platform, the Data Controller will use the data provided by registered users for sending communications relating to the products and services offered, and other information communications, newsletters, promotional communications, also of a commercial nature (referring to services similar to those to which the user has subscribed) with automated methods of contact by e-mail or via push notifications. This treatment does not require the explicit consent of the interested party as the sending of these communications is necessary for the purpose of providing the service or is authorized pursuant to the fourth paragraph of art. 130 of the Privacy Code. In relation to this treatment, the indications referred to in this statement apply with the addition of the following clarifications: 1) In case of consent of the interested party, other commercial communications that do not fall among those indicated above may also be sent; 2) Without prejudice to the possibility for the interested party to oppose this treatment using the methods illustrated by the Data Controller, using the link contained in the communication, or by contacting the Data Controller at the email address indicated above. The interested party is however informed that the refusal to receive such communications could compromise the experience of using the Services. 3) The data provided will be used with IT and telematic tools for the sole purpose of providing the requested service and, for this reason, will be kept exclusively for the period in which it will be active, unless they are necessary for the other purposes indicated above. 4) Only for the purpose of sending communications the Owner uses profiling mechanisms making differentiations based on the type of customer, the sectors of interest and the relevant elements. The consequence of this treatment is represented only by the sending of specific communications. 5) For the purpose of sending these communications, the contact data and other useful information may be transmitted to subjects providing the newsletter service. 16. Information on the use of cookies and other tracking tools. Our services can use (for technical reasons, to improve the services, for marketing purposes and to track the user experience) various tracking tools including Google Analytics and others. Cookies. This paragraph is intended to inform users of our site on how they manage their personal data by providing information relating to the processing of data through cookies. Our site and app automatically collect some data during user visits. These are data that are used in order to verify the correct functioning of the services. The data collected with cookies include: IP address (Internet Protocol); type of browser used to connect to the site; date and time of visit to the site; web page of origin; number of clicks. These data are managed through cookies. Cookies are small text files that the sites visited by users send to their terminals, where they are stored and then retransmitted to the same sites on the next visit. The cookies of the so-called "third parties" are, however, set by a website other than the one the user is visiting. Cookies allow our site to recognize the device and are intended to encourage efficient navigation between pages. All cookies other than technical ones are installed only following the consent expressed by the user. The first time you visit the site, you accept this installation by clicking on the appropriate button on the brief information banner on the landing page. Our site uses technical cookies: they are necessary for the management of the log in functions, for the management of the functions of the Platform and of the site for the functioning of the site. The use of these cookies does not require the collection of the user's consent: everyone can disable them through the settings of their browser. Here are the links to the help desk of the main browsers where you can find information on how to disable or delete cookies: - Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet-explorer-delete-manage-cookies - Google Chrome: https://support.google.com/chrome/answer / 95647? Hl = it-IT - Mozilla Firefox: https://support.mozilla.org/it/kb/Gestione%20dei%20cookie - Safari: https://support.apple.com/kb/PH17191?locale= it_IT & viewlocale = it_IT Clearly the blocking of cookies will directly influence the user's browsing experience on our website and could prevent the functioning of the site, participation in games and the use of services. Our site may also use third-party cookies, that is, set by website managers or servers other than the Owner. Our site includes components transmitted by Google Analytics and Google Firebase (the analysis services provided by Google). These cookies are used to analyze information on the behavior of use of our site by the user (pages visited, time spent on the site, etc.). You can prevent the use of these cookies in the browser by installing a special add-on available at the following link https://tools.google.com/dlpage/gaoptout. At this link https://support.google.com/analytics/answer/6004245?hl=it you can find more information about the use and management of the data transmitted by Google Analytics. The data collected through social platforms and other cookies may be shared with services located outside the European Union area. Email opening tracking. We remind you that we can evaluate user behavior when reading e-mails with the help of so-called web beacons or tracking pixels. With this information integrated, we can create a user profile to personalize marketing emails / push messages. We collect data when you "click" on our emails, or any links, and combine that data with your actions in the products. You can withdraw your consent to marketing emails and push messages at any time by clicking on the link at the end of the email or by changing the settings of your device relating to push messages. We store tracking information as long as you are subscribed to our marketing emails. 17. Rights of the interested party The interested party, if the limitations provided for by the law do not exist, have the following rights: 1. Right to obtain from the Data Controller confirmation that personal data concerning him or her is being processed and in this case, the right to obtain access to data and further information listed in art. 15 GDPR; 2. Right to obtain from the Data Controller the correction of inaccurate personal data concerning him without undue delay; taking into account the purposes of the processing, the interested party also has the right to obtain the integration of incomplete personal data, also by providing an additional declaration; 3. Right to obtain from the Data Controller, without undue delay, the deletion of personal data concerning him, where one of the reasons indicated in Article 17 of the GDPR exists; 4. Right to obtain the limitation of processing from the Data Controller when one of the hypotheses listed in Article 18 of the GDPR occurs; oppose the processing of personal data, when possible; 5. Right to receive personal data concerning him; right to transmit such data to another data controller without impediments by the Data Controller, if the provisions of art. 20 GDPR. Each interested party can exercise their rights by sending a request via email to the Data Controller, to the email address indicated at the beginning of this information. The interested party also has the right to lodge a complaint if he believes that the processing of personal data does not comply with the provisions of the law; this complaint can be proposed by registered letter with return receipt addressed to the Guarantor for the protection of personal data, Piazza Venezia, 11, 00187 Rome, or by certified e-mail sent to protocol@pec.gpdp.it (or through the indicated contacts on the Guarantor website). 18. Changes to the Privacy Policy. The Owner reserves the right to make changes to this information (Privacy Policy) at any time, giving notice to the User through its publication on the Platform and in any other manner required by law. The User who continues to use Newlab after the publication of the changes accepts these changes without reservation. We will notify you when we make substantial changes that you need to be aware of. PRIVACY INFORMATION FOR THE USERS OF THE NEWLABLIGHT.COM SITE Information for the processing of personal data pursuant to and for the effects of art. 13 of EU Regulation no. 679/2016. For Newlab SRL your privacy is important. We have drafted this Privacy Policy (hereinafter also "Information") in a simple and understandable way, in order to help you understand who we are, what personal data relating to you we collect, why we collect it and how we use it. Please note that personal data (in the following of this information, also "data" or "information") means all that information or set of information from which it is possible to identify it personally, directly or indirectly, in particular by referring to a certain number or identification code. We invite you to take a few minutes to read this information in full. If you do not accept this information, please do not provide us with your data and we invite you to stop browsing our websites. This information concerns only the users of the Newlab Srl websites and not the users of the Smarthome platform for whom a specific and more extensive information is available on the website, or on the platform itself. 1. Treatment and Data Controller. The data controller is Newlab Srl (hereinafter Newlab, with headquarters in Piazza Fulcieri Paolucci de Calboli 1 - Genoa - Italy PI 01443720998, email: privacy@newlablight.com) which, within the scope of its business, deals with the quality of Data Controller some personal data of users of the websites managed by it. These natural persons are also identified below as "Interested", in accordance with the definitions provided by current legislation. The personal data of the users of the websites are those collected during the use of the sites (also through cookies) and may include (but not limited to): IP address, place of access, device used, type of browser, date and time of the visit, web page of origin, activity on the site, and any other data necessary for the functioning of the site, as well as any information that may be processed by Google Analytics. If the user fills out the contact form, the data entered will be processed including name, surname, telephone number, email, company and request message. 2. Purpose and legal basis of the processing. Personal data are processed by the Data Controller for: - manage the websites, keep them functioning and monitor their use in a predominantly anonymous form; - management of requests received through the contact form; - provide for related obligations; - pursue the legitimate interests of the Data Controller, including carrying out marketing activities. The legal basis of the processing is represented by the need to execute the contract (art.6.1.b of the GDPR), by the consent expressed at the time of providing the data and by clicking on the button in the appropriate banner or on the tick in the contact form (art.6.1.a of the GDPR) and from the pursuit of the legitimate interest of the Data Controller (art.6.1.f of the GDPR). The legal basis of the treatment is represented by the pursuit of the legitimate interests of the owner relating to the management of its economic activity, and in particular to the dissemination of its brand and the presentation of its products and services. 3. Providing data. The provision of data and consent to treatment are optional. If the user of the site does not believe that he accepts that his data is processed on the basis of this information, he is invited to stop browsing the site. If the user fills out the contact form, the data entered will be processed including name, surname, telephone number, email, company and request message. 4. Processing methods. The Data are processed in accordance with the General Regulation on the Protection of Personal Data (EU Reg. 2016/679, hereinafter also GDPR), as well as with the other current provisions of law including the Privacy Code (Legislative Decree 96/2003 ) and Legislative Decree 101/2018. The processing of personal data is based on the principles of correctness, lawfulness and transparency. The treatment can be carried out using manual, electronic and IT tools with methods strictly related to the purposes for which the data are processed and in any case in compliance with the provisions of art. 32 GDPR on security measures and through the use of suitable procedures that avoid the risk of loss, unauthorized access, illicit use and disclosure. The Data Controller does not carry out treatments that consist of automated decision-making processes on your personal data. With reference to the data processed through the use of cookies, see below. 5. Recipients of the data and data transfer. The personal data processed by the Data Controller will not be disclosed, that is, it will not be disclosed to indeterminate subjects, in any possible form, including that of making them available or simple consultation. Access to data is limited to those who need it, each for their own skills. Each subject will have access only to the data necessary for the performance of its activities. All recipients have been educated, or are for professional responsibility, regarding current legislation and confidentiality. They may also be communicated, within the strictly necessary limits, to external subjects who collaborate with the Data Controller designated as Data Processors. The data may be transferred outside the European Union, in particular in the USA. This transfer will take place on the basis of an adequacy decision adopted by the European Commission. 6. Data retention The Data Controller stores and processes personal data for the time necessary to fulfill the purposes indicated and as long as a situation of legitimate interest exists. Subsequently, Personal Data will be kept for the time established by the current provisions. The Data will be retained for the time necessary to carry out the above activity. The Data Controller also keeps your Data for marketing purposes for 24 months. 7. Information relating to the sending of newsletters and commercial communications. For the purposes of the operation and use of the Platform, the Data Controller will use the data provided by registered users for sending communications relating to the products and services offered, and other information communications, newsletters, promotional communications, also of a commercial nature (referring to services similar to those to which the user has subscribed) with automated methods of contacting by e-mail. This treatment does not require the explicit consent of the interested party as the sending of these communications is necessary for the purpose of providing the service or is authorized pursuant to the fourth paragraph of art. 130 of the Privacy Code. In relation to this treatment, the indications referred to in this statement apply with the addition of the following clarifications: 1) In case of consent of the interested party, other commercial communications that do not fall among those indicated above may also be sent; 2) Without prejudice to the possibility for the interested party to oppose this treatment using the methods illustrated by the Data Controller, using the link contained in the communication, or by contacting the Data Controller at the email address indicated above. The interested party is however informed that the refusal to receive such communications could compromise the experience of using the Services. 3) The data provided will be used with IT and telematic tools for the sole purpose of providing the requested service and, for this reason, will be kept exclusively for the period in which it will be active, unless they are necessary for the other purposes indicated above. 4) Only for the purpose of sending communications the Owner uses profiling mechanisms making differentiations based on the type of customer, the sectors of interest and the relevant elements. The consequence of this treatment is represented only by the sending of specific communications. 5) For the purpose of sending these communications, the contact data and other useful information may be transmitted to subjects providing the newsletter service. 8. Information on the use of cookies. This paragraph is intended to inform site users of how they manage their personal data by providing information relating to the processing of data by means of cookies. The site automatically collects some data during user visits. These are data that are used in order to verify the correct functioning of the website and are automatically deleted after their processing. The data collected with cookies include: IP address (Internet Protocol); type of browser used to connect to the site; date and time of visit to the site; web page of origin; number of clicks. These data are managed through cookies. Cookies are small text files that the sites visited by users send to their terminals, where they are stored and then retransmitted to the same sites on the next visit. The cookies of the so-called "third parties" are, however, set by a website other than the one the user is visiting. Cookies allow our site to recognize the device and are intended to encourage efficient navigation between pages. All cookies other than technical ones are installed only following the consent expressed by the user. The first time you visit the site, you accept this installation by clicking on the appropriate button on the brief information banner on the landing page. Our site uses technical cookies: they are those necessary in general for the operation of the site and for the management of its functions. The use of these cookies does not require the collection of the user's consent: everyone can disable them through the settings of their browser. Here are the links to the help desk of the main browsers where you can find information on how to disable or delete cookies: - Internet Explorer: https://support.microsoft.com/it-it/help/17442/windows-internet- explorer-delete-manage-cookies - Google Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT - Mozilla Firefox: https://support.mozilla.org/it/kb/ Management% 20of% 20cookie - Safari: https://support.apple.com/kb/PH17191?locale=it_IT&viewlocale=it_IT Clearly the blocking of cookies will directly influence the user's browsing experience on our website and could prevent the functioning of the site, and the use of the services. Our site also uses third-party cookies, that is, set by website or server managers other than the Owner. The site includes components transmitted by Google Analytics (the web traffic analysis service provided by Google). These cookies are used to analyze information on the behavior of use of our site by the user (pages visited, time spent on the site, etc.). It is possible to prevent the use of these cookies in the browser by installing a special add-on available at the following link https://tools.google.com/dlpage/gaoptout. At this link https://support.google.com/analytics/answer/6004245?hl=it you can find more information about the use and management of the data transmitted by Google Analytics. The data collected through social platforms and other cookies may be shared with services located outside the European Union area. 9. Rights of the interested party The interested party, if the limitations provided for by the law do not exist, has the following rights: 1. Right to obtain from the Data Controller confirmation that personal data concerning him or her is being processed and not in this case, the right to obtain access to the data and further information listed in art. 15 GDPR; 2. Right to obtain from the Data Controller the correction of inaccurate personal data concerning him without undue delay; taking into account the purposes of the processing, the interested party also has the right to obtain the integration of incomplete personal data, also by providing an additional declaration; 3. Right to obtain from the Data Controller, without undue delay, the deletion of personal data concerning him, where one of the reasons indicated in Article 17 of the GDPR exists; 4. Right to obtain the limitation of processing from the Data Controller when one of the hypotheses listed in Article 18 of the GDPR occurs; oppose the processing of personal data, when possible; 5. Right to receive personal data concerning him; right to transmit such data to another data controller without impediments by the Data Controller, if the provisions of art. 20 GDPR. Each interested party can exercise their rights by sending a request via email to the Data Controller, to the email address indicated at the beginning of this information. The interested party also has the right to lodge a complaint if he believes that the processing of personal data does not comply with the provisions of the law; this complaint can be proposed by registered letter with return receipt addressed to the Guarantor for the protection of personal data, Piazza Venezia, 11, 00187 Rome, or by certified e-mail sent to protocol@pec.gpdp.it (or through the indicated contacts on the Guarantor website). 10. Changes to the privacy policy. The Owner reserves the right to make changes to this information at any time, giving notice to the User through its publication on the site and in any other manner required by law. GENERAL INFORMATION RELATING TO THE PROCESSING OF PERSONAL DATA OF CUSTOMERS AND SUPPLIERS. Newlab Srl (based in Genoa, Piazza Fulcieri Paolucci de Calboli 1, PI 01443720998, email: privacy@newlablight.com) as Data Controller, manages Personal Data of suppliers, customers, professionals, consultants, partners and other subjects with the which the owner interfaces with his business. It should be noted that this information does not concern the data processing of users of the Smarthome platform or of the websites managed by Newlab Srl: for these treatments, refer to the specific information on the sites or on the platform. These natural persons are also identified below as "Interested", in accordance with the definitions provided by current legislation. The Data are processed in accordance with the General Regulation on the Protection of Personal Data (EU Reg. 2016/679, hereinafter also GDPR), as well as with the other current provisions of the law. The Personal Data processed are collected directly from the interested party. Such Data may consist (by way of example and not limited to) by: name, surname, physical address, contact details, e-mail address, telephone number, job position, tax code, bank details, billing data as well as what may be necessary for the purposes identified below. Personal Data are used for the purpose of providing the service or managing the contractual, professional or social relationship and for legal protection. The legal basis of the processing is represented by: - implicit consent of the interested party who transmits the data; - Execution of the contract; - fulfillment of legal obligations (including those of a fiscal nature); - Legitimate interest of the data controller to document its activity (for scientific, training, management and legal protection purposes); - Need to ascertain, exercise and defend a right in court. The provision of data and consent to treatment are optional but in the absence of this it will not be possible to execute the contract or establish the relationship. The data will be retained for the time necessary to execute the contract and for that necessary in order to document this activity in case of any problems, disputes, claims for damages and complaints of any kind. The paper and electronic material will be archived by adopting protective measures to ensure the correct conservation and use of the data also by the collaborators. The Data Controller takes all the necessary measures to guarantee a high level of security and protection of Personal Data (and to minimize the risk of undue access, cancellation or unwanted modification), nevertheless, significant and unavoidable risks remain connected with both paper tools and archives. the telematic tools of which the interested party is made aware and informed here. Access to data is limited to those who need it, each for their own skills: employees, administrators and consultants. The data are not disclosed to third parties except when necessary or required by law. The Data may be transferred to third parties, such as professionals (e.g. lawyers and accountants), consultants (including employment consultants), external service providers (including cloud and site and database hosting services and email), other suppliers, public bodies, insurance companies, mutual bodies and subjects possibly involved in disputes. The subjects belonging to the aforementioned categories perform the function of Data Processing Manager, or operate in complete autonomy as separate Data Controllers. Each subject (recipient) will have access only to the data necessary for the performance of its activities. All recipients have been educated, or are for professional responsibility, regarding current legislation and confidentiality. Each interested party has the following rights that he can exercise his rights by sending a request via email to the Data Controller: - Right to obtain from the data controller confirmation that a processing of Personal Data concerning him or her is in progress and in this case , right to obtain access to data and further information listed in art. 15 GDPR; - Right to obtain from the data controller the correction of inaccurate Personal Data concerning him without undue delay; taking into account the purposes of the processing, the interested party also has the right to obtain the integration of incomplete personal data, also by providing an additional declaration; - Right to obtain from the data controller, without undue delay, the deletion of personal data concerning him, where one of the reasons indicated in Article 17 of the GDPR exists; - Right to obtain the limitation of processing from the Data Controller when one of the hypotheses listed in Article 18 of the GDPR occurs; - Right to receive personal data concerning him; right to transmit such Data to another data controller without impediments by the Data Controller, if the provisions of art. 20 GDPR. The interested party also has the right to lodge a complaint if he believes that the processing of personal data does not comply with the provisions of the law. This complaint can be made by registered letter with return receipt addressed to the Guarantor for the protection of personal data, Piazza Venezia 11, 00187 Rome, or by certified email sent to protocol@pec.gpdp.it. The Owner reserves the right to make changes to this information at any time, giving notice by publishing it on the site and posting on company premises.