Datenschutz: eLoxx 365 Cloud Application and LockPal 365 Mobile Application

Depending on the specific processing activity we may process your personal data under the role of data controller or data processor as specified in the following.

Where we act as controller, the responsible legal entity will be Gantner Electronic GmbH ("GANTNER") with registered address at Bundesstraße 12, 6714 Nüziders (Vorarlberg) – Austria.

Subject to the conditions described in section 4 “Why and what for will we process your personal data?”, GANTNER may transfer its personal data to SALTO Group entities – which can be consulted at the “Group entities” and to the required public authorities, on the grounds and for the purposes set forth in said section. 

Furthermore, GANTNER relies on the collaboration with some third-party service providers which may have access to your personal data and process it as data processor in the name and on behalf of GANTNER for the provision of the services. In this sense, GANTNER follows strict criteria of selection of service providers in order to comply with its obligations in terms of data protection and undertakes to sign with them the corresponding Data Processing Agreement, under which it will impose, among others, the following obligations: applying appropriate technical and organizational measures; processing the personal data for the purposes agreed and strictly following the written instructions of GANTNER; and deleting or returning the data once the provision of services ends.

We inform you that GANTNER does not sell your information to any third party.

The aforementioned recipients can be located, in some particular cases, outside the European Economic Area (EEA). In those cases, GANTNER requires that said recipients comply with the measures designed to protect the personal data established in a binding written contract, such as the standard contractual clauses, except in cases where the European Commission has determined that the country where the recipient is located provides an adequate level of personal data protection. You may obtain a copy of GANTNER's required measures by contacting GANTNER at the address indicated at the end of this policy.

If you want to use our cloud solution, i.e., the Platform, the Service managed by the Platform or the Mobile Application, GANTNER will need to process your personal data and, additionally, you will generate certain personal data through your use of the cloud solution.

The types of personal data processed depend on whether you are a web application user (“Administrator”), a security contact person or an End User (i.e., a locker User of a lockers system managed with our Platform) or a Mobile Application User. Please note, that for contact persons of our Clients for managing the business relationship the general Gantner Privacy Policy (business relationships with interested parties, customers and suppliers) will apply in addition. 

4.2.1 WHICH PERSONAL DATA DOES OUR CLOUD APPLICATION PROCESS?

4.2.2 WHY AND FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

4.3.1 WHICH PERSONAL DATA DOES OUR CLOUD APPLICATION PROCESS?

4.3.2    WHY AND FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

4.4.1 WHICH PERSONAL DATA DOES OUR MOBILE APPLICATION PROCESS?

4.4.2 WHY AND FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?

Our Platforms may use cookies and similar technologies that allow storing and retrieving information from Users’ devices in order to improve your usage experience and gain a better understanding of how Users interact with the Platform for further improvement of our services, as it is described in the corresponding Cookies Policy of the Platform or the mobile application. Where required by the applicable regulations, the installation of such cookies will take place, provided that you have consented it.

We keep your personal information for no longer than necessary for the purposes for which it is processed as specified above, and as required to comply with applicable laws and/or as set out in our data retention policy and information management standards.

Basically, we can distinguish the following retention periods in relation to the use of our Platforms, depending on the type of data processed:

• Administrator account metadata: The personal data related with your interaction with the Platform as an Administrator will be kept for the period determined by the Client in the Platform and automatically deleted thereafter. The retention period may range from 1 day to 1 year and is set to 3 months by default. As an exception, your data will also be deleted after the client terminates its subscription to the Platform.
• Administrator account information: Your login credentials and account information will be processed until our Client deletes your account.
• Contact details and other user data of End Users: Contact details and other user data of End Users required to manage the Service will be processed until our Client deletes the respective End User. 
  
  

In certain circumstances, GANTNER may be entitled to remove your access to the Platform as well as to deactivate your account, after giving notice, if you do not access the Platform for a certain period.

However, please note that GANTNER may retain such data for a longer period to comply with statutory retention obligations (e.g., commercial and tax retention obligations), if the assertion of legal claims prevent erasure or as long as responsibilities can derive for GANTNER for the execution of our relationship. Your data will be kept properly blocked and GANTNER will not process the data unless it is necessary for the formulation, exercise or defense of claims or when it is required by the Public Authorities, Judges and Courts during the period of prescription of rights or legal obligations.

In accordance with current legislation, you can exercise your rights of access, rectification, erasure, restriction, objection, data portability and not to be subject to a decision based solely on automated processing, by previously proving appropriately your identity (including, if necessary, providing a copy of your ID or equivalent), by sending an email to privacy@gantner.com. If we are not able to identify you as a user, we may ask for additional information to this regard.

Equally, in case any processing of your data is based on your consent to GANTNER, you have the right to withdraw your consent for the processing based on it, at any time by writing an email to the mentioned email address. However, the withdrawal of consent shall not affect the lawfulness of processing performed before your withdrawal of consent.

If you believe that GANTNER or any of SALTO’s Group entities has not respected any of the aforementioned rights, you will have the right to submit a claim to the competent Control Authority. 

Finally, note that you can only exercise these rights towards GANTNER in relation to the data we are processing under the role of Controller. As we process certain personal data mentioned above as data Processor on behalf of our Clients, you must directly contact the Client (i.e., the organization that provides the Services to you) if you have any questions or want to exercise your rights in regard to such data.

Cookies, pixels or similar technologies are considered web tools that allow storing and retrieving information from users in order to offer them a better experience in the use and navigation of the Platform.

In this sense, Cookies fulfil different functionalities depending on their nature and the way they are implemented in the Platform. 

Cookies are essential for the operation of the Internet; they cannot damage the user's computer/device and, if activated in the settings of your browser, help us to identify and resolve possible errors in the operation of the Website. Cookies serve many purposes, including allowing you to navigate between pages efficiently, remembering your preferences and generally improving your user experience. They also help ensure that the ads you see online are the ones most relevant to your interests.

Based on the above, the Cookies used in the Platform will be explained in detail:

• Cookies
  A cookie can be defined as a small text file or device of general use that is downloaded to the User's terminal equipment when browsing the Platform in order to store data that can be updated and retrieved by the entity responsible for its installation to improve browsing and the user's experience. Currently, all websites, regardless of the service they provide, use Cookies, i.e., they store a minimum amount of information on the use made by the User.

• Pixels and similar technologies
  Pixels are Cookies introduced on the Platform, usually by inserting a small piece of source code that allow the Platform to transfer and/or collect information by means of a request to the server linked to this pixel to see whether you have interacted with specific web or email content - as do many other services. This helps us to measure and improve our services and to personalize your experience, including the ads and content you see.

Specifically, Gantner uses its own Cookies generated directly by this domain and third-party Cookies generated from other websites that do not belong to Gantner, but to third parties, for the specific purposes that are set out below. If Gantner uses other Cookies in the future with the purpose of providing more and better services, the user will be informed about it.

2.1. Technical Cookies

These are Cookies that allow the user to navigate through the Website and use the different options or services that exist therein, such as, for example, controlling traffic and data communication, identifying the session, accessing restricted access areas, remembering the elements that make up an order, carrying out the purchase process of an order, managing payment, controlling fraud linked to the security of the service, make the application for registration or participation in an event, count visits for the purpose of billing licenses of the software with which the service works (website, platform or application), use security features while browsing, store content for broadcasting videos or sound, enable dynamic content (for example, animation of loading a text or image) or share content through social networks.

Gantner does not need your consent to install Cookies on your device that are necessary to activate the functionalities of the Website, and when their use is based on the need to provide the requested services. If you disable or block all Cookies in your device, your navigation through the Website may be affected and some of the features available on the Website may not work properly.

List of technical cookies

Google reCAPTCHA:
Gantner uses “Google reCAPTCHA” (hereinafter “reCAPTCHA”) to protect the Website. The provider is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).
reCAPTCHA is used to determine whether data entered on the Website (e.g., via a form) is submitted by a human or an automated program. For this purpose, reCAPTCHA analyzes the behavior of Website visitors based on various characteristics. This analysis begins automatically as soon as the Website visitor enters the website.

To perform this analysis, reCAPTCHA evaluates various information, including:

• IP address
• Time spent on the website
• User mouse movements
• Browser type and version
• Operating system

The data collected during the analysis is transmitted to Google.

The use of reCAPTCHA is intended to protect the Website against spam and bot attacks.

The reCAPTCHA analysis runs entirely in the background; Website visitors are not informed that such an analysis is taking place.

Legal Basis
Data processing is based on Art. 6 (1) lit. f GDPR.
Gantner has a legitimate interest in protecting its online services against abusive automated surveillance and spam.

Storage Period
The data will be deleted as soon as they are no longer required for processing.

2.2. Analytical Cookies

These Cookies collect information about how visitors use the Website, for example, which pages they visit most frequently, whether they receive error messages from websites, which sections of the Website they access or which buttons on the Website they click. The function of these Cookies is to obtain statistics and reports that allow to improve the operation and functionalities of the website.

These Cookies are only installed on the user's device when the user has accepted them (Art. 6 (1) lit. a GDPR.

List of analytical cookies

Datadog Real User Monitoring (RUM)

Gantner uses Datadog RUM, a web analytics service provided by Datadog Inc., where data is collected by cookies about your use of our Website (including your IP address). This information will be transmitted to and stored by Datadog on behalf of us. We use website analytics for the purpose of evaluating usage of the Website’s features to improve the Website and develop new features as well as troubleshooting. More information about how Datadog uses cookies can be found at https://docs.datadoghq.com/data_security/real_user_monitoring/.

We will store your personal data collected through Cookies for as long as is necessary for the purposes for which it is processed. Depending on the country from which you access the Website or App, the retention period for the storage of Cookies may differ from each other. In any event, the maximum retention period of Cookies will be two (2) years.

However, in certain jurisdictions, the legally established period may be shorter, and will therefore be limited.

Some of the personal data obtained through third-party Cookies may be subject to international data transfers, in which case we guarantee that the necessary safeguards will be adopted to protect the confidentiality, integrity and availability of the data. For further information on the international transfers made by each third party, please access their Privacy policies shown in this Cookie Policy.

You can set your preferences and configure the use of Cookies in the settings panel available in the Platform. Consent for strictly necessary cookies cannot be withdrawn since they are necessary for the functionality of the Websites.

In addition, you can block or delete Cookies from your browser's settings tools, or you can set your browser to alert you when a server wants to save Cookies:

If you use Microsoft Edge, you will find the option in the menu Settings > Privacy, search, and services > Cookies. To find out more visit: https://support.microsoft.com/de-DE/edge/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use.

If you use Firefox, you will find the option in the menu Tools > Options > Privacy > Cookies. To find out more visit: How to accept, reject, block or delete Cookies https://support.mozilla.org/en-US/kb/block-websites-storing-cookies-site-data-firefox and https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox. 

If you use Chrome, you can find the option in the Options > Advanced > Privacy section. To find out more: https://support.google.com/accounts/answer/61416?hl=en&sjid=17541849181566228735-EU

If you use Opera, under the Security and Privacy option, you can configure the browser. To find out more visit: https://help.opera.com/en/latest/web-preferences/#cookies

If you use Safari, you will find the option in the Preferences/Privacy menu. More information can be found at: https://support.apple.com/en-gb/HT201265

You can obtain more information about the processing of your data by Gantner, as well as how to exercise your rights in our Privacy Policy.

You can also contact Gantner by email: privacy@gantner.com