General conditions
Developer:

The Newlab Smarthome portal, voice assistant connection called Newlab, and third-party connection services have been developed and maintained by
Newlab S.r.l.
Fulcieri Paolucci de Calboli Square 1
Genoa 16161
Italy
Phone: +390108937361
E-mail: software@newlablight.com

The following General Conditions govern access to the portal and its use.
Specific terms and conditions may apply to specific content, data, materials, or information contained.

General conditions

1. Definitions.

Platform: The Newlab Smarthome Platform (hereinafter only 'Platform') consists of the website, mobile applications 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”) based in Piazza Fulcieri Paolucci de Calboli 1, 16161 Genova, Italy, VAT number: IT01443720998, Phone: +390108937361, Email: software@newlablight.com. The Services may be provided directly by Newlab SRL, i.e. together with another company if the hardware purchased carries the trademark of another company (in this case with the term 'Supplier') cumulatively refer to Newlab SRL and that other company).
General Conditions: These General Conditions establish the legal framework for the use of the Services we offer. The User is therefore asked to read these General Conditions carefully because without their acceptance it will not be possible to register and use the Services of the Provider.
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 the Application, or through the voice assistants or Third-Party Services, or other. The Services include mainly the remote control of electronic devices equipped with special hardware and the display of the usage history of the devices themselves and statistics. The Services can be used only if you have 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. Registration and usage requirements.

To register on the Platform and use the Services it is necessary to be of age and register by truthfully providing the requested data.
For account registration, it is necessary to expressly accept these General Conditions of Registration, together with the Privacy Policy on the processing of personal data, through the special “form” on the registration screen. The full text of the Privacy Policy is set out in the annex.
If the User does not accept these Terms, he cannot access the Platform or use it.
These General Conditions will be valid until the cancellation or modification of the current version in force from 1 January 2020.

3. Fee.

Unless otherwise indicated, the Supplier (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 ask for payment of a fee for some Services. In this case, the User must pay the price for the related Services on the basis of what is specified in the appropriate conditions.

4. Registration.

The use of the Platform requires a one-time free registration. The minimum age for registration 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 that he is therefore legally entitled to enter into contracts. Registration is free of charge and makes it available to Users the ability to access the Platform and use the Services.
For the purposes of registration, the User must provide the data requested in the relevant registration form in a complete, correct and accurate manner, unless such data are marked as optional. In some cases, registration may also take place through the adoption by the Provider of registration data provided by the User on other sites or social networks (eg Facebook or Google).
It is possible to register only using the real name of the User, for example, it is not possible to indicate fancy names or pseudonyms.
Upon registration, for security reasons we can send an e-mail in which we will ask 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 from where you can permanently confirm the registration; only at this point the procedure will be complete.
By registering on the Platform, the User confirms that:
- The data you provided are correct, truthful and accurate;
- The login credentials are sufficiently secure and will be kept confidential and not disclosed to third parties;
- It will not allow third parties without authorization to access the Platform;
- You are not creating an account to abuse the Services or to impersonate another person.
After confirming that the account has been registered, the User will have the opportunity to access the Services made available on the Platform with his Authentication credentials. It is understood that all operations carried out through the Platform (apps, sites, voice assistants and more) with the use of the account involve the automatic, unique and immediate attribution to the User, account holder, of the willingness to carry out these transactions.

5. Suspension or Termination of 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 delete the profile at any time, without having to provide a reason, thus ending the use contract at the same time. To do this, simply send an email to the address of the Supplier indicated above. Note that once you delete your User profile, we will delete or may delete all the contents and data provided by the User or that were collected during use (and therefore also the device usage statistics) and you will no longer be able to access the Services.
The User can also ask to delete the profile and personal data at any time by contacting us directly.

6. Account security

The User is required to protect his account from unauthorized access and fraudulent use. We therefore invite the User to inform us promptly by email at the address indicated above any unauthorized or fraudulent use of his account, or any suspicion that his personal account may be at risk. The Provider has the right to close or delete the account of any registered User in the event of unauthorized or fraudulent use of the account.
By registering the account, the Authentication credentials defined by the User are uniquely connected to your 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 guarding and maintaining the confidentiality of the same in order to prevent their use by unauthorized third parties. These security measures must be in line with the technical standards known by an advised User, and such as to minimize the risks of unauthorized use, destruction, subtraction or loss credentials.
The User is, therefore, solely responsible for the custody, keeping safe and proper 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 hacked. In this context, the Supplier assumes no responsibility for the non-performance of the requested services.
In any case, it is understood that the Supplier does not assume any obligation, express and/or implicit, to proceed with a systematic control of access to the Contents through the site and aimed at identifying any account violations and cannot be held liable in any way. Any consequence, damage and/or prejudice that may arise to the Supplier and/or the User due to the incorrect use, loss, subtraction and/or compromise for any reason the confidentiality and/or integrity of the Credentials will be entirely 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 computer code of the Platform.
The user undertakes 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 uses.
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 Provider. Unauthorized Use may damage the hardware or software function. The User acknowledges that he may 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 in an example and not exhaustive) are in violation of the application standard:
1) issue or share computer viruses, worms, malicious codes or software that deliberately damage or modify the system or data of the Platform;
2) collect information or data of other Users without authorization, such as email address and the like;
3) use the Platform fraudulently or malicious or automatically, or causing the server to overload or interfering or damaging 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 free of viruses;
8) interfere or damage the Platform.
The User undertakes not to take any act in violation of laws or improper 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 the Law;
3) dissemination of obscenity, porn, gambling, violence, murder and terror or aiding a crime;
4) insulting or slandering other Users and violating the rights and legal interests of the same;
5) put in place fraud, damage, threats, violation of the privacy of others, harassment, crude, indecency or in any case enter morally repulsive content;
6) in any way insert other items subject to restrictions or prohibited by applicable laws, regulations, regulations, provisions and other legal standards.

8. Third-party content.

The Supplier is in no way responsible for the contents of the sites owned by third parties that may be linked to the Platform (including through hyperlink).
All links available from the Platform to another site do not represent an approval of the contents of that site and therefore the accuracy, accuracy or suitability of the site contents are not guaranteed. to which the link points. The software made available for download is licensed in accordance with the terms of the applicable license agreement.
You acknowledge that certain Services may be based on software or services provided by third parties. The Platform may include information and services from third parties. The Provider does not control or assume responsibility for the information and services of third parties.

9. Connecting with voice assistants.

-> Google Nest Narrator

The User through the Platform can connect their devices to Google Nest voice assistants in order to control them through these services.
In any case, the words spoken for voice commands are handled by other subjects (Google Nest) and the Supplier merely receives the electronic on/off command and in some cases to communicate This other company has the status of the devices (for example to allow the voice assistant to respond if a light is on or off).
The Supplier is in no way involved in the management of the recordings made by voice assistants and therefore cannot be considered liable for any damages or problems arising out. from that activity. This information is managed directly by the providers of voice assistants Google Nest on the basis of special and separate agreements with the User with respect to which the Provider is totally foreign.

-> Amazon Alexa Narrator

The User through the Platform can connect their devices to Amazon Alexa voice assistants in order to control them through these services.
In any case, the words spoken for voice commands are handled by other subjects (Amazon) and the Supplier merely receives the electronic on/off command and in some cases to communicate to This other company has the status of the devices (for example to allow the voice assistant to respond if a light is on or off).
The Supplier is in no way involved in the management of the recordings made by voice assistants and therefore cannot be considered liable for any damages or problems arising out. from that activity. This information is handled directly by Amazon Alexa voice assistant providers based on special and separate agreements with the User with respect to which the Provider is totally unrelated.

10. Content usage rights and copyrights.

The Services offered by the Provider may contain content protected by copyright or otherwise and for which the Provider does not hold the rights. However, the Supplier guarantees a non-exclusive and non-transferable right to use these contents for non-commercial purposes within the purpose 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 permitted, e.g. on other sites. The right of use expires upon deactivation of your access to the corresponding Service (e.g. after deleting your account) or at the end of the usage agreement.
The copyright and all other proprietary rights relating to the Platform and Services of the Supplier, 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 Platform code, the order, sequence and organization of the Platform, are the property of the Supplier and/or its partners or concessors of licence. All rights relating to the Platform and Services not expressly granted herein are reserved.
The use and registration of the Newlab name and the smarthome name are reserved exclusively for Newlab SRL. It is not permitted to register or use a company name, legal name, business name, domain name, or any other name, indication or description of which the Newlab SRL or smarthome name is part or any similar name or that consists of part of the name Newlab SRL or smarthome, nor include any other registered trademark owned by Newlab SRL or smarthome.
All the registered trademarks of Newlab SRL and its affiliates are important resources of Newlab SRL.
Proper use of these brands is of paramount importance, and the User must follow Newlab SRL's instructions when referring to the company's products and services.
Part of the Platform is of a public 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, partners or third parties.

11. Availability of the Services and Errors.

The Supplier does not declare or warrant that the Platform and Services will always be available or that they are completely free from errors.

12. Supplier Rights.

The Supplier reserves the right to interrupt or suspend the operation of the Platform.
The Supplier reserves the right to refuse Users without providing explanations. In this case, the transmitted data will be immediately deleted. If the User provides false, inaccurate, outdated or incomplete data, or the Supplier has substantial reasons to suspect that such data is false, inaccurate, 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 Supplier reserves the right to modify options or functionalities of the Platform. In most cases, changes will be made to the Platform to enhance or improve it.
The Supplier reserves the right to discontinue 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 you any right to claims or compensation for the User.
The Supplier may modify these General Conditions at any time.
The changes become effective at the time of publication (unless otherwise specified).
Continuing to use the Platform and the Services after posting such changes is equivalent to accepting them. We recommend that you 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 to own discretion.

13. Responsibility.

The following conditions govern the Supplier's liability and apply for claims related to defects in the Services or related issues.
The Supplier (and its subsidiaries 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 possible malfunction.
In light of the type of Services offered (which are limited to the provision of software and digital content and to the management of certain personal data), the Supplier declines any responsibility in this regard to possible damages that the User may suffer during the use of the Services, except as provided by law.
Compliance with any guidelines or instructions provided by the Supplier is crucial.
If the User uses electrical or electronic equipment connected to the Platform, he must ensure that the installation of the same takes place by qualified personnel who act under his own liability with exemption and indemnification against the Supplier.
The Supplier (and its subsidiaries and affiliates and its partners, licensors, distributors and suppliers) is not responsible for any malfunctions or damages (even indirect) inherent in the devices used to connect to the Platform (smartphone, tablet, PC, voice assistants, remote control devices, other connected devices, etc.)
It is therefore the responsibility of the User to ensure the security 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, it is still possible that there are errors. Under no circumstances can the Supplier be considered liable.
The User is responsible for updating, controlling, and security of 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 appropriate security measures on the devices.
The Provider may terminate access to the Platform to ensure its security.
In any case, the Supplier cannot be held liable for any damage arising from a use of the Platform contrary to these General Conditions, with law or with common sense.
If you live in a country or area where the above-mentioned exclusions or limitations of liability are not allowed, or some of the disclaimers provided herein, such exclusions or limitations will be applied only to the extent permissible. In such cases, exclusions or limitations must be limited to what is required by the regulations in force. The consumer's rights are still guaranteed.

14. Personal data

The Provider 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 the information concerning him. The information of each User is accessible only by him.
The Supplier has envisaged and implemented security measures aimed at that the personal data processed in the operation of the Platform are kept safe. In any case, the Supplier points out that no IT solution can guarantee total data security and warns the User about possible risks regarding the privacy and confidentiality of the data.
By accepting these General Conditions, the User agrees that the Provider 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 revises the quality of consumer referred to in art. 3, paragraph 1, letter a) of the Consumer Code, that a European Platform for the online resolution of the consumer disputes (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 bodies, find the link to the site of each of them and initiate an online dispute resolution procedure in which it is involved.
We are not willing or obligated to participate in a dispute resolution procedure in front of a consumer arbitration office. Our e-mail address is set out in these Terms and Conditions.

16. Changes to the General Conditions

The Supplier reserves the right to modify and adapt these general terms and conditions with future effect; these changes will in any case be made according to good faith. The User will be informed of the changes by e-mail (to the address provided during registration) at most within two weeks before the planned entry into force of the new version of the Conditions Generals. In the absence of objections to the validity of the new version of the General Conditions within this period and continuing to use the Platform, the new version of the General Conditions will be considered as 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). With regard to commercial transactions with customers within the European Union, the right of the country of sale of the consumer can also be applied only if the consumer contains measures on consumer regulations 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, it will not affect the remaining clauses.

19. Option for saving and reviewing the contract language

These General Conditions can be verified on the Platform. To save a permanent copy of these General Conditions on a data medium, you can download the version in “pdf” format for free. Refer to your browser's guide for information on how to save files. To open a “pdf” file, you need a special software such as the free Acrobat Reader program or a similar program that uses the “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

For Newlab SRL, your privacy is important.

We have drafted this Privacy Policy (hereinafter also “Policy”) in a simple and understandable way, in order to help you understand who we are, what personal data we collect about you, why them we collect and how we use them. Please note that personal data (as a result of this Policy, including '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 spend a few minutes to the full reading of this Policy.
If you do not accept this Policy, please do not provide us with your Data and stop using our Services.
If you do not wish to process your Data relating to the use of the Platform, we invite you to stop browsing and ask us to delete your account and 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 provision of statistics on the use of the devices themselves.
The Platform is accessible to Users through smartphone application and website and is managed by the Newlab SRL company that performs the function of Data Controller (hereinafter Newlab SRL, with based in Piazza Fulcieri Paolucci de Calboli 1 - Genova - Italy VAT number: IT01443720998, email: privacy@newlablight.com).
The data controller to which you can contact is therefore Newlab SRL (privacy@newlablight.com e-mail address). In the event that the purchased device carries the brand 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 Data Controller processes the personal data of Users of the Platform. These individuals 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 what data we use and for what purposes.
Identity data, including: first name (first name, surname), e-mail address, password, preferred language, IP address. We use this data to verify your identity and for the provision of the service.
Contact details, including email address and any other communication channel you used to contact us for the purpose of obtaining more information. We use this data to contact you for different reasons depending on the purposes.
Additional information needed for customer support: If you contact us for assistance, you may provide us with additional information that we will process in accordance with this disclosure.
Location data from the IP address. We use this data for the provision of the service, to manage our products and adapt your experience with the products themselves to your geographical area, as well as for marketing purposes and to realize usage statistics anonymously.
Information about the device connected to the Platform and usage, including: switch name, switch IP, hardware type, IMEI code and other unique device identifiers, data related to device power on and off controls, usage statistics, power consumption, and other diagnostic, technical and 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 voice assistants, for the provision of usage statistics that you can view at the internal the Platform, for the provision of technical support, for the security of the Platform, for the creation of anonymous statistics on the use of the Platform and for marketing purposes.
Information on the device used to access the Platform and usage including device type, mac address, ip address, operating system version and device settings, other information provided by the device or browser, date and time of the visit, duration of sessions on our website and on the App, volume of data transmitted, the referring URL (if you have arrived on our site through another website or advertising), the pages visited on our site, the type of browser (including language and version of the browser software) and add-ons, device and characteristics identifier, device type, versions, operating system and other diagnostic, technical and error and usage information. This is often necessary for purposes related to network security, as well as for the owner's needs related to tracking the use of the service and for the development and improvements of services.
Preference data including: preferred language, data collection and usage preferences, 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, namely for:
Manage the Platform and provide the service to Users, and therefore to authenticate your access to an account and to the Platform, provide you with the remote control service of devices, track the use of devices to provide you with the related statistics within the Platform.
Customer service, and then to carry out assessments, respond to your requests, and resolve complaints and service issues, e.g. to contact you following a question you asked to the support team customers.
Compliments related to the execution of the contractual relationship, and then manage administrative, accounting, civil and fiscal obligations.
Business and research and development needs, and therefore to manage our business needs, including the creation (in anonymous and aggregate form) of statistics on the use of our services (also divided by type of users, type of devices, location and more), 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 data, to conduct research for further development of our Products, in order to offer you and others a better, more intuitive and personalized experience, and support growth and the involvement of users in our Products.
General marketing. We process data to provide you with marketing material (customized) on online products and services.
Marketing and communications via e-mail/push message. Your email address communicated when you register 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 can send you personalized emails or push marketing messages, as well as on related and non-related products.
Defense in case of legal action and therefore for the initiation, exercise or defence in legal actions of which we are or may be a party.

4. Legal basis for processing

The legal basis for the processing is represented by the need to provide the service (Art. 6.1.b of the GDPR), by the consent expressed during registration (Art. 6.1.a of the GDPR), the pursuit of interests the Data Controller's legitimate related to the 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 from 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 Data Controller'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 inaccurate provision of such personal data will result in the objective impossibility for the Owner to establish or regularly conduct the contractual relationship.
Most Personal Data is recorded by us when it is the user himself who communicates it spontaneously to us, for example when you contact us, especially when registering a account on the Platform, when registering a device, when it forwards a command, or inserts or changes information or requests information. Some data is collected during the use of the service in order to provide the remote control and tracking service of the same.

6. Access permissions

We need such access and information for the purposes of the technical functionality of our apps and the provision of the services offered with the app, in particular to be able to access the bluetooth and to send push notifications. During the installation process and/or before the first use, we require permission to access the individual functions and information and we will access these functions only to the extent that the user releases them. consent. You can manually block access rights in the settings based on the respective operating system. How to proceed is indicated in the manufacturer's instructions for each device. It should be borne in mind, however, that in the absence of the relative authorization, the use of the Platform will be limited or impossible. When you first use the app, you are prompted for permissions for the purposes described.

7. Options available to the user

You can choose that certain types of information are not recorded, such as those related to tracking device usage and related statistics. This may limit the possibility of using the services offered.

8. Methods of processing

The Data are processed in accordance with the General Regulation on the Protection of Personal Data (Reg. 2016/679, hereinafter also GDPR), as well as with the additional provisions in force of law including the Privacy Code (Legislative Decree 96/2003) and Legislative Decree 101/2018.
Personal data is used exclusively to the extent that it is necessary to perform 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 processing may be carried out through 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 of the GDPR on security measures and through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illegal use and dissemination.
The Data Controller does not carry out processing that consist of automated decision-making processes that produce legal effects concerning him or that significantly affect his person in a similar way. The data is 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 your information

Newlab SRL takes the protection of your data seriously and has taken appropriate technical and physical measures to protect the information collected. However, keep in mind that although Newlab SRL takes reasonable precautions to protect information, no application, website, transmission over 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. Data recipients

The personal data processed by the Data Controller will not be disseminated, i.e. it will not be given knowledge of it to undetermined subjects, in any possible form.
The data may be accessed by the collaborators of the Data Controller. In particular, on the basis of the roles and work duties performed, some collaborators of the Data Controller have been authorized to process personal data within the limits of their competence and in accordance with the instructions given to them by the Data Controller himself.
They may also be communicated, within the limits strictly necessary, to external subjects who collaborate with the Data Controller designated as Data Processors. They may be communicated to subjects who need it for purposes of managing the service such as the server provider, the database service provider, the mail service providers electronics and newsletters. Finally, they may be communicated to subjects entitled to access them by virtue of provisions of law, regulations, community regulations.
We will share the Data with third parties if necessary, for purposes, or as a result of a request from a national authority, or following the judgment of a court, or if required by law, or if necessary to carry out investigations and defend against requests or charges from third parties, or to exercise and protect the rights and security of Newlab SRL, our members and staff; or if you have (explicitly) provided the your consent.

11. Data sharing

-> Sharing data with Google and their role.

You can decide to use the appropriate Skills to link your account on the Platform to Google Next in order to control the device with voice assistants.
In this case, Google Nest will operate as an independent data controller and a data exchange will take place with this subject in order to provide the remote voice control service.
In any case, the words spoken for voice commands are handled by other subjects (Google) and the owner merely receives the electronic on/off command and in some cases to communicate to This other company has the status of the devices (for example to allow the voice assistant to respond if a light is on or off).
The holder is in no way involved in the management of the recordings made by the voice assistants and therefore cannot be considered liable for any damages arising from this activity. . This information is managed directly by the providers of voice assistants (Google) on the basis of special and separate agreements with the User with respect to which the owner is totally foreign.
You can at any time link or disconnect your account on the Platform from Google Nest services.

-> Sharing data with Amazon and their role.

You can decide to use the appropriate Skills to link your account on the Platform to Amazon Alexa in order to control the device with voice assistants.
In this case, Amazon Alexa will operate as an independent data controller and an exchange of data will take place with this subject in order to provide the remote voice control service.
In any case, the words spoken for voice commands are handled by other subjects (Amazon) and the owner merely receives the electronic on/off command and in some cases to communicate to This other company has the status of the devices (for example to allow the voice assistant to respond if a light is on or off).
The holder is in no way involved in the management of the recordings made by the voice assistants and therefore cannot be considered liable for any damages arising from such activity . This information is managed directly by the providers of voice assistants (Amazon) on the basis of special and separate agreements with the User with respect to which the holder is totally foreign.
You may at any time link or disconnect your account on the Platform from Amazon Alexa services.


12. Sharing data with the device manufacturer, distributor, or retailer and their role.

When the device purchased and connected to the Platform reports the brand of another company, that other person will have access to the user's data. Registration on the Platform in this case will result in the establishment of a relationship with two different data controllers, namely with Newlab SRL as a technical service provider related 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 other possible purposes, under his sole responsibility and subject to appropriate information that will be provided by this last.

13. Other forms of sharing and transferring data

Like many companies, we may outsource certain data processing activities to service providers of our trust, with the task of performing specific functions and performance, such as, for example services ICT, consultancy, freight forwarding activities and freight forwarders.
We may share your Data with third parties, including professional consultants, such as banks, insurance companies, auditors, lawyers, accountants, other professional advisors, 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 SRL, such as companies that collaborate within the framework of repairs, customer contact centers, customer service activities, advertising, customer satisfaction or billing surveys, or sending emails on behalf of Newlab SRL . These providers are also committed to protecting your data.
Occasionally, we may also share your Data during corporate transactions, such as the sale of a company or branch of business to another company, or a reorganization, merger, joint venture, or other sale of a company, assets or holdings (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 however 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 retains and processes personal data for the time necessary to fulfill the purposes indicated and as long as there is a contractual and/or legitimate interest relationship. Subsequently, personal data will be kept for the time established by the current provisions on civil and fiscal matters.
We store your data for the time required for the purpose of fulfilling the intended purpose and/or until you delete your account or as long as the retention terms established by law thereof make it necessary to store it. Finally, in accordance with the legislative provisions, the data is deleted or its processing is restricted.
We will retain your data for the entire period during which you have an account with us.
If you decide to delete your account, all data about your account held by Newlab SRL will be removed (or kept exclusively anonymous and no longer identifiable), except for the following: i data necessary for the fulfillment of contractual obligations or compliance with legal retention obligations will not be deleted, but minimized to the extent necessary.
A deletion request does not affect the data, if their storage is provided by law or for other specific purposes.

15. Information regarding 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 communications information, 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 through push notifications. Such processing 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 case of explicit consent of the interested party (expressed by clicking on the check during registration), additional commercial communications may also be sent for different services.
In relation to such processing, the indications set out in this statement apply with the addition of the following clarifications:
1) In the event of the consent of the interested party, other commercial communications may also be sent outside those indicated above;
2) It is without prejudice to the possibility for the interested party to oppose this processing through the methods illustrated by the Data Controller, using the link contained within the communication, or by contacting the Owner to the email address indicated above. The Data Subject is however informed that 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 the same will be active, unless they are necessary for the other purposes indicated above.
4) Only for the purpose of sending communications, the Data Controller uses profiling mechanisms, making differentiations based on the type of customer, sectors of interest and the elements of relief. The consequence of such processing is represented only by the sending of specific communications.
5) For the purpose of sending such communications, contact data and other useful information may be transmitted to subjects providers of the newsletter service.

16. Information on the use of cookies and other tracking tools.

Our services may use (for technical reasons, to improve services, for marketing purposes and to track the user experience) different tracking tools including Google Analytics and others.
Cookies. This paragraph is intended to inform users of our site on how to manage their personal data by providing information on the processing of data through cookies.
Our site and app automatically collect certain data during user visits. These are data that are used in order to verify the proper functioning of the services.
Among the data collected with cookies are included: 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.
This data is 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 at the next visit. Instead, the cookies of the so-called “third parties” are set by a website other than the one that the user is visiting.
Cookies allow our site to recognize the device and are intended to facilitate 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, accept this installation by clicking on the appropriate button on the short information banner on the landing page.
Our site uses technical cookies: they are those necessary for the management of the log in functions, for the management of the functions of the Platform and the site for the operation of the site.
The use of these cookies does not provide for the collection of the user's consent: everyone can deactivate them through the settings of their browser.
Below 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
Google Chrome
Safari
Clearly, blocking cookies will directly affect the user's browsing experience on our website and may prevent the site from functioning, participation in games and the use of the services.
Our site may also use third-party cookies, that is, set by managers of websites 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 the user's use of our site (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.
At this link you will find more information about the use and management of 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 your behavior when reading emails with the help of so-called web beacons or tracking pixels. With this integrated information, we may create a user profile to customize 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 revoke your consent to marketing emails and push messages at any time by clicking on the link at the end of the email or changing your device settings for push messages. We store tracking information as long as you are subscribed to our marketing emails.

17. Rights of the Data Subject

The interested party, if the limitations provided for by law do not fulfill, has the following rights:
1. Right to obtain from the Data Controller confirmation whether or not personal data concerning him is being processed and in this case, the right to obtain access to the data and to the further information listed by art. 15 of the 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 the right to obtain the integration of incomplete personal data, including by providing an additional statement;
3. Right to obtain from the Data Controller, without undue delay, the deletion of personal data concerning him, where there is one of the reasons indicated by art. 17 of the GDPR;
4. Right to obtain from the Data Controller the limitation of processing when one of the hypotheses listed in Article 18 of the GDPR occurs; to object to the processing of personal data, when possible;
5. Right to receive Personal Data concerning him; the right to transmit such data to another data controller without hindrance from the Data Controller, if the provisions of art. 20 of the GDPR complies with the provisions of art. 20 of the GDPR .
Each interested party can exercise their rights by sending a request via email to the Data Controller, to the e-mail address indicated at the beginning of this information.
The Data Subject also has the right to lodge a complaint if he considers that the processing of Personal Data does not comply with the provisions of the law; such a complaint may be proposed by registered letter A. /R addressed to the Guarantor for the Protection of Personal Data, Piazza Venezia, 11, 00187 Roma, or through certified e-mail sent to protocollo@pec.gpdp.it (or through contacts) indicated on the website of the Guarantor).

18. Changes to the Privacy Policy.

The Data Controller reserves the right to make changes to this information (Privacy Policy) at any time, notifying the User through his publication on the Platform and in the any further methods required by law. The User who continues to use Newlab Smarthome after posting the changes, accepts such changes without reservation. We'll notify you when we make substantial changes that you need to be aware of.

Privacy disclaimer
PRIVACY POLICY for users of the website

Information for the processing of personal data pursuant to and for the effects referred to in art. 13 of EU Regulation no. 679/2016.

For Newlab SRL, your privacy is important.

We have drafted this Privacy Policy (hereinafter also “Policy”) in a simple and understandable way, in order to help you understand who we are, what personal data we collect about you, why them we collect and how we use them. Please note that personal data (as a result of this Policy, including '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 spend a few minutes to the full reading of this Policy.
If you do not accept this Policy, please do not provide us with your Data and we invite you to stop browsing on our websites.

This Notice concerns only users of Newlab SRL websites and not to Users of the Smarthome Platform for whom a specific and wider information available inside is provided. of the website, that is, on the Platform itself.

1. Treatment and Data Controller.

The data controller is Newlab SRL (hereinafter Newlab SRL, with registered office in Piazza Fulcieri Paolucci de Calboli 1 - Genova — Italy VAT number: IT01443720998, email: privacy@newlablight.com) which, as part of its activity, deals with the capacity of Data Controller some personal data of users of the websites managed by it.
These individuals are also identified below as' Interested ', in accordance with the definitions provided by current legislation.
The personal data of users of the websites are those collected during the use of the sites themselves (including through cookies) and may include (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 purpose of the operation of the site, as well as any information possibly subject to processing by Google Analytics.
If the user fills out the contact form, the data entered will be processed including name, surname, telephone number, email address, company and message of request.

2. Purpose and legal basis of the processing.

Personal data are processed by the Data Controller for:
- manage the websites, maintain their functioning and monitor their use in a predominantly anonymous form;
- management of requests received through the contact form;
- provide for the related obligations;
- pursue the legitimate interests of the Data Controller, including carrying out marketing activities.
The legal basis for the processing is represented by the need to execute the contract (art. 6.1.b of the GDPR), by the consent expressed when providing data and by clicking on the button in the special banner or on the check on 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 processing is represented by the pursuit of the legitimate interests of the Data Controller relating to the management of its economic activity, and in particular to the dissemination of its brand and to the presentation of its products and services.

3. Provision of data.

The provision of data and consent to the processing are optional.
If the user of the site does not consider accepting that his data be processed according to 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 address, company and message of request.

4. Methods of processing.

The Data are processed in accordance with the General Regulation on the Protection of Personal Data (Reg. 2016/679, hereinafter also GDPR), as well as with the additional provisions in force 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 processing may be carried out through 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 what provided for by art. 32 of the GDPR on security measures and through the use of appropriate procedures that avoid the risk of loss, unauthorized access, illegal use and dissemination.
The Data Controller does not carry out processing 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. Data recipients and data transfer.

The personal data processed by the Data Controller will not be disclosed, i.e. they will not be given knowledge of it to undetermined subjects, in any possible form, including that of their provision or simple consultation.
Access to data is limited to the subjects who need it, each for their own skills. Each subject will have access only to the data necessary for the performance of their activities. All recipients have been educated, or are for professional responsibility, regarding current legislation and confidentiality.
They may also be communicated, within the limits strictly necessary, 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 taken by the European Commission.

6. Data Retention

The Data Controller retains and processes personal data for the time necessary to fulfill the purposes indicated and as long as there is a situation of legitimate interest. Subsequently, Personal Data will be kept for the time established by the provisions in force. The Data will be retained for the time necessary to carry out the above activity. The Data Controller also retains your Data for marketing purposes for 24 months.

7. Information regarding 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 communications information, 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. Such processing 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 case of explicit consent of the interested party (expressed by clicking on the check during registration), additional commercial communications may also be sent for different services.
In relation to such processing, the indications set out in this statement apply with the addition of the following clarifications:
1) In the event of the consent of the interested party, other commercial communications may also be sent outside those indicated above;
2) It is without prejudice to the possibility for the interested party to oppose this processing through the methods illustrated by the Data Controller, using the link contained within the communication, or by contacting the Owner to the email address indicated above. The Data Subject is however informed that 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 the same will be active, unless they are necessary for the other purposes indicated above.
4) Only for the purpose of sending communications, the Data Controller uses profiling mechanisms, making differentiations based on the type of customer, sectors of interest and the elements of relief. The consequence of such processing is represented only by the sending of specific communications.
5) For the purpose of sending such communications, contact data and other useful information may be transmitted to subjects providers of the newsletter service.

8. Information on the use of cookies.

This paragraph is intended to inform users of the site on how to manage their personal data by providing information on the processing of data through cookies.
The site automatically collects some data during users' visits. They are data that are used in order to verify the correct functioning of the website and are deleted automatically after their processing.
Among the data collected with cookies are included: IP address (Internet Protocol); type of browser used to connect to the site; date and time of the visit to the site; web page of origin; number of clicks.
This data is 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 at the next visit. Instead, the cookies of the so-called “third parties” are set by a website other than the one that the user is visiting.
Cookies allow our site to recognize the device and are intended to facilitate 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, accept this installation by clicking on the appropriate button on the short 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 provide for the collection of the user's consent: everyone can deactivate them through the settings of their browser.
Below 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
Google Chrome
Safari
Clearly blocking cookies will directly affect the user's browsing experience on our website and may prevent the operation of the site, and the use of the services.
Our site also uses third-party cookies, that is, set by managers of websites or servers 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 the user's use of our site (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.
At this link you will find more information about the use and management of 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 Data Subject

The interested party, if the limitations provided for by law do not fulfill, has the following rights:
1. Right to obtain from the Data Controller confirmation whether or not personal data concerning him is being processed and in this case, the right to obtain access to the data and to the further information listed by art. 15 of the 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 the right to obtain the integration of incomplete personal data, including by providing an additional statement;
3. Right to obtain from the Data Controller, without undue delay, the deletion of personal data concerning him, where there is one of the reasons indicated by art. 17 of the GDPR;
4. Right to obtain from the Data Controller the limitation of processing when one of the hypotheses listed in Article 18 of the GDPR occurs; to object to the processing of personal data, when possible;
5. Right to receive Personal Data concerning him; the right to transmit such data to another data controller without hindrance from the Data Controller, if the provisions of art. 20 of the GDPR complies with the provisions of art. 20 of the GDPR .
Each interested party can exercise their rights by sending a request via email to the Data Controller, to the e-mail address indicated at the beginning of this information.
The Data Subject also has the right to lodge a complaint if he considers that the processing of Personal Data does not comply with the provisions of the law; such a complaint may be proposed by registered letter A. /R addressed to the Guarantor for the Protection of Personal Data, Piazza Venezia, 11, 00187 Roma, or through certified e-mail sent to protocollo@pec.gpdp.it (or through contacts) indicated on the website of the Guarantor).

10. Changes to the privacy policy.

The Data Controller reserves the right to make changes to this information at any time, notifying the User through his publication on the site and in any further possible methods required by law.

Account and Data Cancellation

Omni application

In order to delete your Omni account and all related data, you need to do the following steps:

1) Log in to the Omni portal
https://smarthome.newlablight.com
2) Click on menu settings
3) Enter your account name for confirmation
4) Press the "delete account" button


Warning!
Deleting the account and all data associated with you is irreversible, your devices will be disconnected and you will have to reset them.

Newlab Go application

Within the Newlab Go application there is an optional feature for exporting the names of the lights from one device to another.
This procedure generates a temporary file on our server containing the identifiers of the Newlab SRL dimmers and the name selected by the user (example kitchen, living room, bathroom).
It is not possible in any way to link this information to the user who generated it.
These data are automatically deleted every night, so no action is required on the part of the user if he wants to delete them.

Newlab SRL IT01443720998