Privacy Policy
1. Preamble
In accordance with Articles 13 and 14 of the European Regulation (EU) 2016/679 (hereinafter GDPR) and concerning the personal data that the Data Controller will have available, we communicate the following:
Controller: INNOVA S.r.l., via 1° Maggio 8, 38089 Storo (TN), Italy – VAT IT01827470228 – info@innova.it. Innova designs, manufactures and sells the devices and provides the connected service (app, cloud, and firmware) through its technology platform partner.
Technology platform provider (data processor): SOLUTION TECH S.r.l., Via Vittorio Veneto 1/C, 38086 Rovereto (TN), Italy. Solution Tech operates the cloud infrastructure, app, and firmware on behalf of Innova under a data processing agreement (Art. 28 GDPR).
Data Protection Officer: SAPI S.r.l., via Brennero 182, 38121 Trento, Italy – privacy@sapi.artigiani.tn.it
Contact: Lawyer Michele Pizzini – michelepizzini@neonomos.it
2. What this policy covers
This policy covers the Innova app for iOS and Android, the Innova web dashboards, the cloud system, and the firmware of Innova connected devices. All servers are in the European Union, in data centres and/or machines we either own or rent.
3. What data we process
| Category | What it includes | Where it comes from | Stored? |
|---|---|---|---|
| Account data | First name, last name, email, password (stored only in hashed form). If you sign in with Google or Apple, we receive only your email address (or Apple’s relay address) | You, or Google/Apple | Cloud system, until you delete your home |
| Home configuration | Home name, time zone, room names, device names, calendars, schedules, enabled features and preferences | You | Cloud system, until you delete your home |
| Device identifiers | MAC address, serial number, device type, manufacturing IDs, firmware version | Your devices | Cloud system, until you delete the device or home |
| Real-time operating data | Current state of your devices, commands you send, status updates | Your devices and app | Not stored: passes through the cloud only in transit |
| Connection and service data | Connection and disconnection events, IP address, connection quality, firmware version, OTA update status and result | Our servers | Google BigQuery (EU), under pseudonymous identifiers, up to 365 days |
| Historical telemetry (only if you turn it on) | Operating measurements listed in the Data Act Information Sheet, sampled at the rates stated there | Your devices | Google BigQuery (EU), under pseudonymous identifiers, up to 365 days |
| Support data (only if you open a customer support ticket) | Content of your tickets, attachments, contact details and any device information you share | You | Jira Service Management, Undefined |
| App usage data (anonymised) | Anonymised and aggregated usage metrics: screens viewed, features used, app version, device model, operating system. No user or device identifiers are linked. | Your phone or tablet, via Google Firebase Analytics (configured with IP masking, no Google data sharing, aggregated output only) | Google, up to 60 days |
| Crash reports | Crash traces, app version, device model, operating system, installation identifier | Your phone or tablet, via Firebase Crashlytics | Google, up to 60 days |
| Push notification token | Identifier that lets us send notifications to your device | Your phone or tablet | Cloud system, until you sign out or delete your home |
We do not collect your home’s address or geographic location, the location of people, or presence in the home. The only location-related data we store is your time zone. During device pairing, the app asks you to turn on location services, because your phone’s operating system requires it to search for nearby devices over Bluetooth. The app does not read your location for any other purpose, and it is never sent to or stored on our servers.
The operating history of heating and cooling equipment can indirectly show when a home is in use. We do not use telemetry to infer presence or occupancy.
4. Why we process it and on what legal basis
| Purpose | Data used | Legal basis |
|---|---|---|
| Create and manage your account and home, including sign-in with Google or Apple | Account data, home configuration | Contract (Art. 6(1)(b)) |
| Let you monitor and control your devices, run schedules and calendars, and send you notifications | Real-time data, device identifiers, home configuration, push token | Contract (Art. 6(1)(b)) |
| Pair new devices over Bluetooth | Location services on your phone (not collected by us) | Contract (Art. 6(1)(b)) |
| Deliver firmware and security updates (OTA) | Device identifiers, connection data | Contract, and legitimate interest in keeping devices secure (Art. 6(1)(f)) |
| Monitor the health and security of the cloud and app, and track OTA adoption and success rates | Connection and service data | Legitimate interest in a reliable, secure service (Art. 6(1)(f)) |
| Telemetry collection: store your device history so you can view and export it, and share it with third parties you choose | Historical telemetry | Your request under the EU Data Act and the legal obligation to give you access (Art. 6(1)(c)), and the contract (Art. 6(1)(b)) |
| Advanced monitoring: use your device history for advanced alerts and predictive maintenance | Historical telemetry, device identifiers | Your consent (Art. 6(1)(a)) |
| Product improvements: use anonymised and aggregated device data to improve products | Historical telemetry (anonymised and aggregated, without contact details) | Legitimate interest in improving product quality and reliability (Art. 6(1)(f)). Data is anonymised and aggregated before use: no personal data is processed for this purpose. |
| Advanced customer support: give your installer, service centres or support staff access to your device data | Device identifiers, device history | Your consent (Art. 6(1)(a)) |
| Handle support tickets you open | Support data, device identifiers | Contract, or steps taken at your request (Art. 6(1)(b)) |
| Understand how the app is used, to improve it | App usage data (anonymised and aggregated) | Legitimate interest in improving the quality and usability of the product (Art. 6(1)(f)). Analytics are configured to be fully anonymised and aggregated: no personal data is processed for this purpose. |
| Detect and fix crashes and bugs | Crash reports | Legitimate interest in keeping the service safe, secure, and reliable (Art. 6(1)(f)). |
| Comply with legal obligations (warranty, tax, requests from authorities) | As needed | Legal obligation (Art. 6(1)(c)) |
| Establish or defend legal claims | As needed | Legitimate interest (Art. 6(1)(f)) |
Account data, home configuration and device identifiers are needed to use the app. Without them we cannot create your account. Functionalities such as telemetry collection, advanced monitoring, and advanced customer support are optional and independent of each other. Declining any of them does not affect basic control of your devices. App analytics use only anonymised and aggregated data and do not process personal data. Crash reporting is based on our legitimate interest in maintaining a safe and reliable service.
Advanced alerts and predictive maintenance are generated automatically, but they only inform you. We make no decisions based solely on automated processing that have legal or similarly significant impacts and effects on you and your life (Art. 22 GDPR).
5. Historical telemetry and your choices
Your devices measure their operation continuously. The app always shows current and basic information. To see the full data from all internal sensors, it has to be stored in our cloud. The home owner decides how the data is used through four separate choices:
- Telemetry collection: we store your device data so you can view it in the web dashboards and the app, export it, and share it with third parties you choose. This is free of charge. Turning it on does not allow us to use the data for our own purposes.
- Advanced monitoring: we use your stored data to send advanced alerts and offer predictive maintenance for your devices. This functionality requires telemetry data collection to work.
- Product improvement: we use anonymised and aggregated device data to improve our products. No personal data is processed for this purpose.
- Advanced customer support: you let your installer, authorised service centres or selected support staff see your device data to help you.
All such functionalities can be enabled or disabled directly from the app or from the web dashboard. If you turn off options like advanced monitoring, the data is no longer used for that purpose. If you disable advanced customer support, access to your data to staff is immediately revoked. Your stored data stays available to you in the dashboards and the app as long as telemetry collection is active.
The home owner can turn each choice on or off at any time in the App or web dashboard. If you turn off telemetry collection, no new telemetry is stored, and the history already stored stays available to you in the dashboards and the app until it expires up to 365 days after collection. You can delete it sooner at any time with a request to info@innova.it.
Stored telemetry carries pseudonymous device and home identifiers, not your name or email. While your home exists we can still link it to your home, to show your dashboards and give you alerts and support, so we treat it as personal data. If other people live in your home, please tell them that the equipment’s operating history is recorded.
6. Who receives your data
We do not sell your data. Your data is processed by authorised Innova staff and by the following providers acting on our instructions (processors):
| Recipient | Role | Data |
|---|---|---|
| Solution Tech S.r.l. (technology platform provider) | Operates the cloud infrastructure, app, and firmware on our behalf | All data processed by the Service |
| Providers of rented data-centre space in the EU | Hosting | Everything stored in the Cloud system |
| Google Cloud (BigQuery, EU region) | Telemetry storage and analysis | Historical telemetry (pseudonymised) |
| Google (Firebase Analytics and Crashlytics) | App usage analytics and crash reporting | App usage data, crash reports |
| Google Firebase Cloud Messaging and Apple Push Notification service | Delivering notifications | Push token, notification content |
| Atlassian (Jira Service Management) | Support ticketing | Support data |
If you sign in with Google or Apple, those companies handle the sign-in under their own privacy policies and send us only your email address.
We also share data with installers and authorised service personnel you grant access to (advanced customer support), who lose access as soon as you revoke it and may not keep copies beyond the support case; with public authorities when the law requires it; and with third parties you ask us to share data with under the EU Data Act.
7. Transfers outside the EU
We store your data in the EU. Some of our providers belong to US groups:
- Google Cloud (BigQuery): telemetry is stored in EU locations. Google may access it from outside the EU for support or security, under the Google Cloud data processing terms, which include the Standard Contractual Clauses, and Google’s certification under the EU-US Data Privacy Framework.
- Google Firebase (Analytics, Crashlytics, Cloud Messaging): data may be processed in the United States, under the Firebase data processing terms (Standard Contractual Clauses) and Google’s Data Privacy Framework certification.
- Atlassian: support data may be transferred to the United States under Atlassian’s certification under the EU-US Data Privacy Framework, with Standard Contractual Clauses as a fallback.
8. How long we keep your data
| Data | Retention |
|---|---|
| Account data, home configuration, device identifiers | Until you delete the device or home, then deleted immediately. Inactive accounts: deleted after 5 years of inactivity, after an email warning. |
| Real-time operating data | Not stored |
| Location during pairing | Never collected by us |
| Connection and service data | up to 365 days from collection. After you delete your home, it can no longer be linked to you and is kept anonymously until it expires. |
| Historical telemetry | up to 365 days from collection. After you delete your home, it can no longer be linked to you and is kept anonymously until it expires. |
| App usage data (Firebase Analytics) | up to 60 days |
| Crash reports (Crashlytics) | up to 60 days |
| Push notification token | Until you sign out or delete your home |
| Support data | Indefinite |
| Data we must keep by law | For the period the law requires |
9. Deleting your home, or selling your devices or property
When you delete your home in the app, your contact details, preferences, schedules, settings and device associations are deleted immediately and automatically. The pseudonymous identifiers linking telemetry to your home are also deleted, so the stored telemetry can no longer be traced back to you. Support tickets are kept for the period in section 8.
Before selling your devices or property, delete your home in the app and reset the devices as described in the manual. The new owner then sets up their own home and account.
10. Security
We protect your data with measures including hashed passwords, encryption in transit, restricted access for our staff, and signed firmware updates. Your devices receive security updates for at least 3 years from the date the device model is first placed on the market.
11. Your rights
You have the right to:
- access your data and get a copy;
- correct inaccurate data;
- have your data deleted;
- restrict processing;
- receive your data in a portable format;
- object to processing based on our legitimate interests;
- withdraw your consent at any time, without affecting processing done before you withdrew it.
You can use many of these rights directly in the app (editing your profile, deleting devices or your home, managing telemetry). You can also write to info@innova.it or to our DPO at privacy@sapi.artigiani.tn.it. We reply within one month, which we can extend by two months for complex requests. We may ask you to confirm your identity.
You also have the right to lodge a complaint with the Italian data protection authority, the Garante per la protezione dei dati personali (Piazza Venezia 11, 00187 Rome – www.garanteprivacy.it), or with the authority in the EU country where you live or work.
Your rights to access and share device data under the EU Data Act are described in the EU Data Act page.
12. EU Data Act
For detailed information about the data your devices generate, including the full list of telemetry data points per device type, how to access and export your data, and your rights under Regulation (EU) 2023/2854, see the EU Data Act page.
13. Children
The app is intended for adults. We do not knowingly create accounts for people under 18.
14. Changes to this policy
If we make significant changes, we will tell you in the app before they take effect. Where a change needs your consent, we will ask for it.