Privacy Policy

We are firmly committed to protecting systserv users’ privacy and we collect the required data to support efficiently its innovative services.

Life People of Interest (systserv) supports people care during life-threatening events by enabling a number of useful services and helps seniors to take control of their lives enabling assisted living services. Via systserv users can create their own Safety Human Network of “People of Interest” e.g. Family, Relatives, teammates, colleagues or whoever matters most and gain piece of mind.

We (as Owners) are firmly committed to protecting systserv users’ privacy and we collect the required data to support efficiently its innovative services.

This privacy policy (the “Policy”) is designed to tell systserv users about our practices regarding collection, use, disclosure and transfer of personal information that users may provide.

Please read this Privacy Policy and Types of Data collected before using or submitting your information via our app/system.

 

Types of Data collected

Among the types of Personal Data that systserv collects, by itself or through third parties, there are: Cookies; Usage Data; email address; Universally unique identifier (UUID); Device ID, Crash information; device information; first name; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; Camera permission; Precise location permission (continuous); Precise location permission (non-continuous); GPS coordinates,  Approximate location permission (continuous); Approximate location permission (non-continuous); Sensors permission; Motion sensors permission; Bluetooth sharing permission; Biometric Data access permission; Health Data read permission; Health Data update permission ; Camera permission, without saving or recording; general activity data; body measurements & indexes; movement activity; food related activity ; sleeping activity; heart rate and other vital data; blood type; gender; date of birth; payment data; company name; Data communicated through messages to other family members / emergency contacts while using the service; geographic position; last name; password; picture.

As Owner we use this information to (i) remember information so that you will not have to re-enter it during your visit or the next time you visit the Service; (ii) provide custom, personalized content and information, including targeted content and advertising; (iii) track your location and movements; (iv) identify and contact you across multiple devices; (v) provide and monitor the effectiveness of our Service and our marketing campaigns; (vi) monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns; (vii) diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs; and (viii) detect or prevent fraud or other harmful activities; (xi) automatically update our mobile application on your system and related devices; and (x) otherwise plan for and enhance our Service.

 

Information we collect automatically

When you visit our website (systserv.com), use our mobile app, read our emails or otherwise engage with us, for safety reasons we and our business partners may automatically collect certain information about your computer or device through a variety of tracking technologies, including cookies, web beacons, log files, embedded scripts, location-identifying technologies, or other tracking/recording tools (collectively, “tracking technologies”), and we may combine this information with other personal information we collect about you.

We use these tracking technologies to collect usage and device information, such as:

  • Information about how you access the Service, for example, referral/exit pages, how frequently you access the Service, whether you open emails or click the links contained in emails, whether you access the Service from multiple devices, and other actions you take on the Service.
  • Information about how you use the Service, for example, the features you use, the links you click, the ads you view and click on, purchase transaction information, your location when you access or interact with our Service, and other similar actions.
  • Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, platform type, device type/ model/ manufacturer, operating system, phone number, mobile carrier, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device or your account (including, for example, a UDID, IDFA, Google Ad ID, Windows Advertising ID or other persistent device identifier or Ad ID), battery life, and other such information. With your permission, we may also access your photo or camera roll.

 

 

Recipients of personal information

We may share your personal information with the following:

  • Human Networks of POIs: we may share your personal information, including your name, location, with other users of our Service at your request and in accordance with your preferences.
  • Third parties for their marketing and related purposes with your consent. Where you have provided consent for us to do so, we may sell your personal information (specifically, your location data, information about your device, and unique identifiers or AdIDs) to third parties for their marketing and market research purposes.
  • Service providers, business partners and advisors: we may share your personal information with third party vendors and other service providers that perform services for us or on our behalf, which may include providing payment, email or chat services, fraud prevention, web hosting, or providing analytic services.
  • Purchasers and third parties in connection with a business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, re-organisation, financing, change of control or acquisition of all or a portion of our business.
  • Law enforcement, regulators and other parties for legal reasons: we may share your personal information with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements, including our Terms of Service; and/or (iii) exercise or protect the rights, property, or personal safety of systserv, its users or others.

 

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using systserv.


Unless specified otherwise, all Data requested by systserv is mandatory and failure to provide this Data may make it impossible for systserv to provide its services. In cases where systserv specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the us anytime.

Any use of Cookies – or of other tracking tools – by systserv or by the owners of third-party services used by systserv serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through systserv and confirm that they have the third party's consent to provide the Data to the Owner.

 

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or Artificial Intelligent and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

In addition to the Owner, in some cases, the Data may be accessible to certain types of collaborators in charge, involved with the operation of systserv (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.


If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Security

We implement appropriate, commercially reasonable technical and organisational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Registration and authentication, Remarketing and behavioral targeting, Advertising, Infrastructure monitoring, Hosting and backend infrastructure, Managing contacts and sending messages, Content performance and features testing (A/B testing), Device permissions for Personal Data access, Handling activity data, Handling payments, Managing data collection and online surveys, Location-based interactions, Platform services and hosting, Traffic optimization and distribution, User database management and Displaying content from external platforms.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Permissions for Personal Data access

Depending on the User's specific device, systserv may request certain permissions that allow it to access the User's device Data as described below.

By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document. The exact procedure for controlling app permissions may be dependent on the User's device and software.

Please note that the revoking of such permissions might impact the proper functioning of systserv.  If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by systserv.

Biometric Data access permission

Used for accessing the User's biometrical Data and/or authentication systems, such as for instance, FaceID.

Bluetooth sharing permission

Used for accessing Bluetooth related functions such as scanning for devices, connecting with devices, and allowing data transfer between devices.

Audio permissions

Used for accessing to identify external noise during a heart rate/HRV test in order to decrease the noise of the biometric measurement. We use the microphone in order to quantify the external noise in order to calibrate the biometric result.

Contacts permissions

systserv is Safety Network App/system and support assisted living. For this reason systserv needs permissions (android.permission.READ_CONTACTS") to read the user's contacts data and trigger a number of actions during a life-threatening case.

Camera permission

Used for accessing the camera to enable the Photoplethysmography (PPG) method for Heart Rate measurement and/or capturing/analyzing images and video from the device. User can test and manage his/her Heart Rate/HRV using PPG and smart algorithms.

Camera permission, with recording/saving

Used for accessing the camera or capturing images and video from the device.
systserv save or record the camera output supporting Heart Rate testing and managing using PPG and smart algorithms.

Health Data read permission

Allows reading the User’s health Data.

Health Data update permission

Allows the updating of the User’s health Data.

Motion sensors permission

Used for accessing the User's device motion sensors to measure the User's activity such as step counts, stairs climbed, and movement type (walking, cycling, etc.).

Precise location permission (continuous)

Used for accessing the User's precise device location. systserv may collect, use, and share User location Data in order to provide location-based services.

Precise location permission (non-continuous)

Used for accessing the User's precise device location. systserv may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for systserv to derive the exact position of the User on a continuous basis.

Sensors permission

Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on systserv, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below. Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside systserv. For more information, please check the privacy policies of the relevant services. In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain advertising features by visiting the Network Advertising Initiative opt-out page. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

Facebook Lookalike Audience (Facebook, Inc.)

Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of systserv or engagement with relevant content across the Facebook apps and services. On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on systserv. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Analytics for Firebase (Google LLC)

Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.

In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. systserv uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data collected: Application opens; Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Google Analytics (Google LLC)

Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of systserv, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Firebase Remote Config (Google LLC)

Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Device permissions for Personal Data access

systserv requests certain permissions from Users that allow it to access the User's device Data as described below.

Device permissions for Personal Data access (systserv)

systserv requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.

Personal Data collected: Approximate location permission (continuous); Approximate location permission (non-continuous); Biometric Data access permission; Bluetooth sharing permission; Camera permission; Camera permission, without saving or recording; Health Data read permission; Health Data update permission ; Motion sensors permission; Precise location permission (continuous); Precise location permission (non-continuous); Sensors permission.

 

Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of systserv and interact with them.

This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

 

Handling activity data

This type of service allows the Owner to use the activity data collected by your device in order for systserv to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings. Depending on what is described below, third parties may be involved in the activity tracking.

Most devices allow for the User to control which Data is accessed or stored.

 

Activity data tracked by your device (systserv)

systserv uses some activity data tracked by your device to operate or to provide specific features. Personal Data collected: blood type; body measurements & indexes; date of birth; food related activity ; gender; general activity data; heart rate and other vital data; movement activity; sleeping activity.

Apple HealthKit (Apple Inc.)

HealthKit is an activity data handling service provided by Apple Inc. that enables the Owner to access or store activity data.

Personal Data collected: blood type; body measurements & indexes; date of birth; food related activity ; gender; general activity data; heart rate and other vital data; movement activity; sleeping activity.

Place of processing: United States – Privacy Policy.

 

Handling payments

Unless otherwise specified, systserv processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. systserv isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

Payments processed via the Apple App Store (Apple Inc.)

systserv uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases. Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data collected: payment data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Payments processed via the Google Play Store (Google LLC)

systserv uses a payment service provided by Google LLC that allows the Owner to offer the purchase of the app itself or in-app purchases. Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

Personal Data collected: payment data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Paypal

Paypal is a payment service provided by Paypal.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable systserv to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of systserv. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Cloud Firestore (Google LLC)

Firebase Cloud Firestore is a hosting and backend service provided by Google LLC. Personal Data collected: Usage Data; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Amazon Web Services (AWS) (Amazon Web Services, Inc.)

Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.  Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Infrastructure monitoring

This type of service allows systserv to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved. Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of systserv.

 

Crashlytics (Google LLC)

Crashlytics is a monitoring service provided by Google LLC.

Personal Data collected: Crash information; device information; Universally unique identifier (UUID).

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Location-based Services

Geolocation (systserv)

systserv may collect, use, and share User location Data in order to provide location-based services.  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by systserv.

Personal Data collected: geographic position.

Non-continuous geolocation (systserv)

systserv may collect, use, and share User location Data in order to provide location-based services.  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by systserv.

The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.

Personal Data collected: geographic position.

Managing contacts and triggering actions

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.

These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

 

Firebase Notifications (Google LLC)

Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Firebase Cloud Messaging (Google LLC)

Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Managing data collection and online surveys

This type of service allows systserv to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.  The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.  These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Typeform (TYPEFORM S.L)

Typeform is a form builder and data collection platform provided by TYPEFORM S.L.

Personal Data collected: company name; Data communicated while using the service; email address; various types of Data as specified in the privacy policy of the service.

Place of processing: Spain – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of systserv, therefore allowing the provision of systserv from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Apple App Store (Apple Inc.)

systserv is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc. By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of systserv. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data collected: Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Google Play Store (Google LLC)

systserv is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC. By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis. Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.

Personal Data collected: Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

Registration and authentication

By registering or authenticating, Users allow systserv to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, systserv will be able to access some Data, stored by these third-party services, for registration or identification purposes.

 

Firebase Authentication (Google LLC)

Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.

Personal Data collected: Phone, email address; first name.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

 

 

Direct registration (systserv)

The User registers by filling out the registration form and providing the Personal Data directly to systserv.

Personal Data collected: date of birth; email address; name; gender;  password, Chronic diseases.

Remarketing and behavioral targeting

This type of service allows systserv and its partners to inform, optimize and serve advertising based on past use of systserv by the User. This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies for certain remarketing features by visiting the Network Advertising Initiative opt-out page.

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

 

Facebook Custom Audience (Facebook, Inc.)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of systserv with the Facebook advertising network. Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

Personal Data collected: Cookies; email address.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

Facebook Remarketing (Facebook, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of systserv with the Facebook advertising network.

Personal Data collected: Cookies; Usage Data.

Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.

 

Traffic optimization and distribution

This type of service allows systserv to distribute their content using servers located across different countries and to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between systserv and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

Cloudflare (Cloudflare Inc.)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

The way Cloudflare is integrated means that it filters all the traffic through systserv, i.e., communication between systserv and the User's browser, while also allowing analytical data from systserv to be collected.

Personal Data collected: Cookies; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to systserv, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving systserv.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on systserv.

 

Further information about Personal Data

Push notifications

systserv may send push notifications to the User to achieve the purposes outlined in this privacy policy. Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for systserv, some or all of the apps on the particular device.

Users must be aware that disabling push notifications may negatively affect the utility of systserv.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

 

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

 

Cookie Policy

systserv uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

 

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of systserv or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

 

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, systserv may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

 

System logs and maintenance

For operation and maintenance purposes, systserv and any third-party services may collect files that record interaction with systserv (System logs) use other Personal Data (such as the IP Address) for this purpose.

 

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

 

How “Do Not Track” requests are handled

systserv does not support “Do Not Track” requests.

To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

 

USERS' RIGHTS IN RESPECT OF THEIR PERSONAL INFORMATION

 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

(a) Right of access. You have the right to obtain:

(i) confirmation of whether, and where, we are processing your personal information;

(ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods;

(iii) information about the categories of recipients with whom we may share your personal information; and

(iv) a copy of the personal information we hold about you.

(b) Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal data to another person.

(c) Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.

(d) Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.

(e) Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.

(f) Right to object. You have a right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy.

You also have the right to lodge a complaint to your national data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

 

CHILDREN’S PRIVACY

Our Service allows parents to keep track of their children’s location on mobile devices that the Parent has added to the Family account. The Service is intended to be used by children under 13 only with significant parental involvement and approval. If a Parent wishes to add a User who is under 13 to the Family account, the Parent must first complete the Parental Consent Form and return it via mail, fax or email. The Parental consent form can be found here - https://www.systserv.com/pdf/consent.pdf

The child will then be able to participate in the systserv Service as a member of that Family Account. The child’s personal information, including name, user name, email, and location, will be shared with other members of the Family account and the child user will be permitted to contact, and be contacted by, other members of the Family account through the Service. systserv may collect, use, disclose, and store the child’s personal information as described in this Privacy Policy. However, we do not use or share personal information collected from the accounts of children under 13 for marketing or advertising purposes or permit our third party partners to collect and use such information for advertising purposes.

 

The Parent may contact us to review and/or delete any personal information we have collected from the child, or to withdraw permission for systserv to collect any additional information from the child. Please contact us at privacy@systserv.com if you have questions about your child’s account. If you believe that we might have inadvertently collected information from a child under 13 without parental consent, please contact us at privacy@systserv.com.

 

 

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within systserv and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

 

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

 

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

 

Usage Data

Information collected automatically through systserv (or third-party services employed in systserv), which can include: the IP addresses or domain names of the computers utilized by the Users who use systserv, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

 

User

The individual using systserv who, unless otherwise specified, coincides with the Data Subject.

 

Data Subject

The natural person to whom the Personal Data refers.

 

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

 

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of systserv. The Data Controller, unless otherwise specified, is the Owner of systserv.

 

systserv (or this Application)

The means by which the Personal Data of the User is collected and processed.

 

Service

The service provided by systserv as described in the relative terms (if available) and on this site/application.

 

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

 

Cookies

Small sets of data stored in the User's device.

 

Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

 

This privacy policy relates solely to systserv, if not stated otherwise within this document.