Ultimo aggiornamento dell’Informativa: [1/03/2019]

HeadCounter® (“HeadCounter” or the “Product”) is an innovative device that has the main purpose of providing numerical information about the flows and densities of the people that fall within its scope in outdoor and indoor
For this purpose, in order to reach the numeric data, the Product deals with some Personal Data as defined by the art. 4 (1) of EU Regulation 679/2016 (“General Data Protection Regulation” o “GDPR”).
The information is provided pursuant to art. 13 of the GDPR to all those who interact with the HeadCounter® product first in a simplified form and then, via link access or QR code, in an extensive manner.
The data are processed by adopting the necessary technical and physical protection measures
required by law. This privacy statement refers to the relationship between the Data Subject and THEmedia S.r.l., qualified as the data controller.

1. data processing
the data controller is:
THEmedia S.r.l.
Corso Monforte 50
Milano,
Contacts: info@themedia.it

2. Type of personal data processed
Head-Counter acquires photographic images within its radius of action, processing such data in an anonymous way in order to draw statistical reports from it.
The personal data thus collected remains for a few seconds inside the device, without lasting preservation; furthermore, the system does not adopt face recognition technologies, but only face detection, as it is not able to identify single individuals through the use of biometric data, nor to allow live access.
The Owner cannot trace back to the individual identity of the photographed subjects, nor to any personal data referring to them, having only aggregated and anonymous reports.
Data on how to use the device. 

The Owner collects the usage data of the Head-Counter device, including its switching on and off, the number of associated automated devices and their remote control.

3. Legal basis
I The processing takes place on the basis of a legitimate interest of the Data Controller, pursuant to Article 6.1.f of Regulation 679/2016, aimed at obtaining the necessary statistical reports, for example, for the improvement of its marketing strategies or for security purposes (eg for the recognition of overcrowded places).
This legitimate interest is considered valid and proportionate, as it is not possible for the Data Controller to obtain the consent of the interested party for technical reasons and being balanced with respect to the rights of the individual according to the provisions of Regulation 679/2016.
This balancing is achieved by minimizing the collection of personal data, creating no significant risk with respect to their use and adopting all the measures envisaged by current legislation and also requested by the Privacy Guarantor (as per provision no. 551 of 21 December 2017).

4. Purpose of the processing
The purpose of processing is to obtain statistical reports on the number of vehicles, persons, to allow the Owner to improve his marketing strategies.

5. Processing methods
The Owner processes the personal data of the users, anonymized, adopting the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or destruction of personal data.
It also guarantees the physical security of HeadCounter® devices with appropriate security measures, pursuant to Article 32 of Regulation 679/2016 and any sector legislation.
The processing is carried out using IT and non-IT tools and / or telematics with organizational methods and logic strictly related to the purposes indicated, so that an adequate level of protection of personal data is guaranteed.

6. Communication and widespread of data
Personal data may be viewed by the device manufacturer if it is necessary for the purposes of maintenance, assistance and calibration of the devices; these activities are governed by a contractual relationship between the parties, which guarantees the integrity, security and correctness of the processing. For this reason, and in compliance with the requirements of the legislation on the protection of personal data, the device manufacturer is appointed Data Processor pursuant to art. 28 GDPR.

7. Place of treatment
The data processing takes place at the place of placement of the Head-Counter devices and in any other place where the parties legitimately involved in the processing are located. The interested party can always request information regarding the place of treatment.

8. Data transfer
Personal data are not transferred in any way outside the European Union, given their immediate cancellation within the volatile memory of the HeadCounter device.

9. Data retention times
Personal data obtained from HeadCounter remains in the device for a few seconds, immediately undergoing anonymisation processes and / or cancellation. The Data Controller does not therefore keep data relating to the data subjects, except as described.

10. Rights of the interested party
The purposes of the processing described in this statement do not require the identification of potential interested parties, therefore the data controller, pursuant to article 11.1 of Regulation 679/2016, is not required to keep, acquire or process further information to identify the data subject solely for the purpose of complying with the regulation.
Since the holder is not able to identify the individuals concerned, pursuant to articles 11.2 and 12.2 of Regulation 679/2016, the articles relating to the right of access (article 15), right of rectification (article 16) are not applied , right to cancellation (art. 17), right to limitation to processing (art. 18), right to portability (art. 20).
You can in any case contact us directly at info@themedia.it to get more details on the point and to know how we protect your personal data.

11. Changes to the Privacy Policy
The data controller reserves the right to make changes to this privacy policy at any time by giving publicity to users on this page. Please therefore consult this page or section of the site periodically, taking as reference the date of last modification indicated at the bottom. In case of non-acceptance of the changes made to this privacy policy, the user is required to cease using the service and may request the data controller to remove his personal data.

12. Claims

In any case, the interested party has the right to lodge a complaint before the Privacy Guarantor,
writing, in the manner prescribed by law and available on the website
www.garanteprivacy.it