Privacy Policy e4life App

Privacy Policy of the mobile app E4Life, concerning the processing of personal data of data subjects who download, access, and use the app within the territory of Saudi Arabia

The following information is provided in accordance with Article 4, paragraph 1, of the Personal Data Protection Law issued by Royal Decree No. (M/19) dated 16/9/2021 and its subsequent amendments (“PDPL “) as well as Article 4 of the Implementing Regulations which came into force on 6/9/2023 (“the Implementing Regulations”) and the Personal Data Transfer Regulations which came into force on 6/9/2023 (“the Data Transfer Regulations”), concerning the processing of personal data of data subjects/users (hereinafter referred to as “Users” or singularly the “User”) who download, access, and use the mobile app “E4Life” (hereinafter “APP”). 

Users are urged to carefully read this Notice before installing the APP and/or registering on the APP. 

1. DATA CONTROLLER 

Please be informed that the data controller is the company ELETTRONICA S.p.A. (VAT Number 00886951003 with registered office at via Tiburtina, Valeria km 13,700, Rome, (hereinafter referred to as “Elt” or the “Data Controller”) email: privacy@e4.life. The complete list of data processing managers is available upon written request sent to the email address above. 

2. COLLECTED PERSONAL DATA 

Elt processes data provided by Users, in accordance with this Notice. 

Specifically, for the purposes indicated in Article 3, the following data will be processed: (i) user’s name and surname, (ii) email, (iii) e4life device identifier. 

The mentioned data is processed only to the extent necessary to achieve the purposes described in paragraph 3 of this Notice. 

Personal data is provided by the User during registration. Failure to provide them prevents User registration. 

3. PURPOSES OF PROCESSING 

The purposes for which Users are asked to provide their personal data to Elt are as follows: 

1. Allow the User to register on the APP; 
2. Update the firmware of the device; 
3. Send communications related to the operation and update of the device, as well as new features and/or services associated with it (via email or push notifications, if allowed by the User); 
4. Monitor and analyze data on the use of the device/APP, in order to resolve errors and/or improve and evolve the service in favor of the User’s experience 

4. LEGAL BASIS OF PROCESSING 

The Data Controller processes the personal data of the User under the following conditions: 

For the purposes indicated in Article 3 preceding, letters a) to d), as necessary for access to the APP and for the use of the firmware update service through the APP (Art. 6, paragraph 2, PDPL ). 

5. PROCESSING METHODS 

User personal data is processed with the support of computerized means and is protected through adequate security measures suitable for ensuring confidentiality and security. 

In particular, Elt adopts appropriate organizational and technical measures to protect the personal data in its possession, aimed at preventing unauthorized access, disclosure, alteration, loss, and destruction of such data. 

6. SCOPE OF DATA COMMUNICATION AND DISCLOSURE 

For the purposes outlined in Article 3, Elt may disclose User data in strict correlation with the treatment purposes to the following categories of entities: 

• Collaborators, employees, and suppliers of Elt within the scope of their respective duties and/or any contractual obligations related to commercial relationships with Users. 
• Suppliers and/or subcontractors/subsidiaries engaged in activities related to the execution of services and products offered by Elt. 
• Other companies within the “Elettronica Group” in Saudi Arabia, Italy and abroad, both nationally and internationally, as detailed in Section 7 below. 

User personal data will not be disclosed to undetermined parties other than those mentioned above.

7. PROCESSING OF PERSONAL DATA OUTSIDE THE KINGDOM OF SAUDI ARABIA 

To achieve the purposes outlined in this Notice, personal data may be transferred outside the national territory to countries or to entities located outside the Kingdom of Saudi Arabia. 

The potential transfer of User personal data to countries outside the Kingdom of Saudi Arabia will, in any case, occur in compliance with applicable laws, without prejudice to the rights of the User as provided by law. 

Where applicable, Elt will use data protection safeguards provided by Articles 5   and subsequent    of the the Data Transfer Regulations, such as, for example, standard contractual clauses. In other cases, the transfer of personal data may be based on an adequacy decision under Article 3 of the Data Transfer Regulations. The User can obtain a copy of the safeguards implemented by Elt, approved by competent authorities, by sending a specific request to the address privacy@e4.life. 

8. DATA RETENTION PERIOD 

Elt will retain personal data for the period necessary to fulfill the purposes for which they were collected, as outlined in this Notice. 

To determine the most appropriate retention periods for User personal data, Elt has taken into consideration, among other factors, the quantity, nature, and sensitivity of the personal data and the reasons for which they were collected. For example: 

• Data collected for purposes a), b), c) in Article 3 above will be retained until the deletion of the profile, which can be done by uninstalling the App or by sending a written request to the email address privacy@e4.life, unless legitimate reasons require further retention. 
• Data collected for purpose d) in Article 3 above is associated with the device ID and, once the profile data is deleted (disconnecting the link to the user-device), is retained permanently as it is no longer attributable to an user. 

9. DATA SUBJECTS RIGHTS 

The User may, at any time, exercise the rights provided in Articles 4 and subsequent of the “Personal Data protection Law” (Issued pursuant to Royal Decree No. (M/19) dated 09/02/1443 AH corresponding to 16/09/2021 G Amended pursuant to Royal Decree No. (M/148) dated 05/09/1444 AH corresponding to 27/03/2023 G) and 3 and subsequent of the Implementing Regulation of the Personal Data protection Law, including: access to personal data, request rectification and/or deletion of information we hold/process about you, object to the processing of your data, request a copy of the information we hold/process about you, withdraw consent to the processing of your information (to the extent that such processing is based on consent), obtain restriction of the processing of your data by us, request that the personal data you provided to us be transferred to you or to third parties in machine-readable formats, and request data portability. 

Some of these rights are not absolute, may not always apply, and exceptions may be allowed. In response to a request, Elt may ask the User to verify his identity and provide information to help Elt better understand the request. 

If you wish to exercise the above rights, change contact preferences, notify Elt of any updates to their data, request profile deletion, or obtain further information about Elt’s use of your personal data please contact Elt at the email address privacy@e4.life. 

Otherwise, to protect your rights, you can contact the “Saudi Data & AI Authority” to the email: dmo@sdaia.gov.sa. 

10. CHANGES AND UPDATES 

This Notice is effective from the date of its publication on the APP. Elt may make changes and/or additions to it, also as a result of any subsequent legislative changes and/or additions. The latest version of our Notice is always available in the dedicated section on the APP. 

ELETTRONICA S.p.A