Notice on the processing of personal data in accordance with Article 13 of the EU Regulation 2016/679 ("GDPR")

This Notice describes which of your personal data are collected by Alientech S.r.l. (referred to in this notice as “we” or “Alientech srl”), for what purposes and how they are processed. Below you will also find the information you need to exercise your rights as provided by the GDPR.

We ask you to share some of your personal data with us to enable us to serve you better and ensure your smooth interaction with us.

Below you will find in detail the information we are required to provide, in accordance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and the Council, dated April 27, 2016 concerning the protection of individuals with regard to the processing of personal data and the free movement of such data (hereinafter simply referred to as GDPR).

1. To whom this Notice applies

This Notice applies to all customers and users of the “POWERGATE” App available for mobile devices (smartphones and tablets), reserved for the management of the Powergate tool.

2. Data controller

The Data Controller of your data is Alientech S.r.l. a socio unico – VAT ID IT02007510023, with registered office at Via dei Cordari 1 – 13039 Trino (VC) – Italy.

For any information regarding the processing of personal data, you may contact us using the contact details provided in section 10) How to exercise your rights.

3. Personal data processed, purposes of processing, legal bases and data provision

Your personal data is collected and used exclusively for the purposes set out in the sections below. For each purpose, the categories of personal data processed, the legal basis for the processing, and whether the provision of the data is mandatory or optional are indicated.

To find out how long we retain your personal data, please refer to section 7) Retention period, which applies to all the purposes listed below.

3.1 Creation and management of the ALIEN_id account

For the creation and management of the ALIEN_id account, we process the following categories of personal data:

• Identification and contact data: first name, last name, email address, country
• Authentication data: email address and password
• Optional data provided by the user: phone number, full address, profile photo or image

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR).

The provision of data required for the creation of the account is mandatory, while the provision of optional data is voluntary.

3.2 Use of the Powergate App

During the use of the Powergate App, we process the following categories of personal data:

• Server connection logs: date and time of access, IP address
• App-related data: selected language, software version used
• Technical data of the mobile device: device characteristics (e.g. screen size), battery status
• Mobile device signal data: Bluetooth data and approximate location data of the device
• Network data: information on the Wi-Fi network or Hotspot used to enable and maintain the connection with the Powergate tool, including the network name, the information required to establish the connection (e.g. access credentials), the IP address of the mobile device and the IP address of the connectivity provider
• Data processed through SDKs and software components integrated into the App, which are necessary for the proper functioning of the App itself, for managing user preferences (e.g. language), authentication sessions, and communications with the servers

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR).

The provision of the data is mandatory; without such data, it is not possible to use the Powergate App or to provide the related services.

3.3 Use of the Powergate tool

During the use of the Powergate tool, we process the following categories of personal data:

• Data relating to the Powergate tool: serial number, firmware version
• Data relating to the vehicle associated with the tool: make, model, version, vehicle identification number (VIN)
• Tool usage data: data generated by the operations performed by you during the use of the tool, including the functions used, date and time, duration of usage sessions, operations carried out by the tool, managed files, and information relating to the operating mode
• Location data generated by the GPS system integrated into the Powergate tool, collected during the use of features that require it and used to ensure their proper functioning, as well as for activities related to performance evaluation and the provision of technical support

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR).

The provision of the data is mandatory; without such data, it is not possible to provide the services related to the use of the Powergate tool.

3.4 Improvement and development of Powergate services

In order to improve, maintain and develop the Powergate services, we use information derived from the use of the App and the tool, including in aggregated and statistical form.

In this context, we process the following categories of personal data:

• Usage data of the Powergate App and tool: information generated during use (e.g. functions used and duration of sessions)
• Technical and operational data relating to the operation of the App, the tool and the Powergate services
• Aggregated and statistical information processed on the basis of usage data (e.g. number of uses of specific functions or protocols within a given period), aimed at performance analysis, identification of errors or anomalies, development of new features, and improvement of the services

The legal basis for the processing is the legitimate interest of the Data Controller in improving and developing the products and services offered (Article 6(1)(f) GDPR).

The processing of such data is necessary for the improvement, maintenance and evolution of the Powergate services. Any objection to this processing does not affect the use of the main functionalities of the service.

3.5 Provision of technical assistance and support

In order to provide you with technical assistance and support, we process the following categories of personal data:

• Identification and contact data
• Data relating to the ALIEN_id account
• Technical and usage data of the App and the Powergate tool
• Information and data necessary for handling support requests, including any reports of malfunctions

Such data is used by Alientech to provide assistance relating to the Powergate App and the management of the account. Within the scope of the Powergate service, the data is also made available to your designated Powergate Manager in order to enable them to provide you with technical support in the use of the Powergate tool.

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR).

The processing of such data is necessary for handling your support requests; without this information, it is not possible to provide the requested technical support.

3.6 Service communications

In order to keep you informed about the status of your ALIEN_id account and the Powergate services, we process the following categories of personal data:

• Identification and contact data
• Data relating to the ALIEN_id account
• Information relating to the status of the account, the App, the tool and the Powergate services

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR). These communications are considered an integral part of the contractual relationship between the User and Alientech srl.

The processing of such data is necessary; without it, it is not possible to provide communications relating to the status of the account or the Powergate services.

3.7 Sending of push notifications

For the purpose of sending push notifications relating to the operation of the Powergate services, we process the following categories of personal data:

• Account identification data
• Technical identifiers of the mobile device necessary for the delivery of push notifications
• Information relating to the status of tool sessions, the status of protocol usage, and the files made available and/or modified by your Powergate Manager

The legal basis for the processing is the performance of a contract (Article 6(1)(b) GDPR).

The processing of such data is optional; failure to provide the data does not affect the use of the App and the Powergate services, but results in the non-receipt of push notifications.

3.8 In-app rating request

In order to occasionally display a request to rate the Powergate App, we process the following categories of personal data:

• Technical data stored locally on the device (e.g. a counter or flag relating to the number of times the App is opened), used to display rating requests on an occasional basis and to avoid excessive repetition

The legal basis for the processing is the legitimate interest of the Data Controller in improving the quality and user experience of the App and the Powergate services, as well as in avoiding repetitive or excessive rating requests (Article 6(1)(f) GDPR).

The processing of such data is optional; failure to interact with the rating request does not affect the use of the App and the Powergate services.

3.9 Direct marketing activities (soft spam)

In order to inform you about products or services that are similar or complementary to those already used with the Powergate tool, we process the following categories of personal data:

• Identification and contact data
• Data relating to the ALIEN_id account and the associated tool, limited to the information necessary to propose similar or complementary products or services

The legal basis for the processing is the legitimate interest of the Data Controller in promoting products or services that are similar or complementary to those already used by the user, including those that can be activated on the Powergate tool (Article 6(1)(f) GDPR), pursuant to Article 130(4) of the Italian Privacy Code.

The processing of such data is optional: you may object at any time to the receipt of such communications (opt-out) by using the unsubscribe link included in each email received or by sending a request to the address legal@alientech.to. The objection takes effect for the future and does not affect the use of the App and the Powergate services.

3.10 System security, prevention of misuse and malfunctions

In order to ensure the security, integrity and proper functioning of the App, the Powergate tool and the related services, as well as to prevent and address non-compliant or unlawful uses, we process the following categories of personal data:

• Usage data of the App and the Powergate tool
• Access and system logs, including IP address, date and time of access, and other technical data relating to the operation of the App, the tool and the Powergate services, which are necessary for monitoring and security purposes
• Information necessary to identify, prevent or manage unlawful conduct or non-compliant use of the Powergate services

The legal basis for the processing is the legitimate interest of the Data Controller in ensuring the security, integrity and proper functioning of the Powergate systems and services, as well as in preventing and addressing non-compliant or unlawful uses (Article 6(1)(f) GDPR).

The processing of such data is necessary; without it, it is not possible to ensure the security of the Powergate systems and services.

3.11 Compliance with legal obligations and protection of rights in legal proceedings

In order to comply with obligations arising from applicable laws, regulations or other binding provisions, as well as for the establishment, exercise or defense of a right in judicial or out-of-court proceedings, we process the following categories of personal data:

• Personal data necessary to comply with obligations arising from applicable laws, regulations or other binding provisions
• Data requested by judicial, administrative or supervisory authorities
• Data necessary for the establishment, exercise or defense of a right

The legal basis for the processing is compliance with legal obligations (Article 6(1)(c) GDPR) and, where applicable, the legitimate interest of the Data Controller in the establishment, exercise or defense of a right in judicial or out-of-court proceedings (Article 6(1)(f) GDPR).

The processing of such data is necessary; failure to provide the data may prevent the Data Controller from complying with legal obligations or from protecting its rights.

3.12 Additional information on the operation of the Powergate App and tool

Mobile device permissions and App operation

The Powergate App requires the activation of specific permissions on your mobile device, such as Bluetooth, location services and connection to a Wi-Fi network or Hotspot. Failure to grant such permissions does not allow the App to function properly or the tool to be used.

The activation of such permissions is managed by the mobile device’s operating system. You may manage or disable the granted permissions at any time through your device settings; in such case, some App features may not be available, and the tool may not be usable.

Data collection and interruption via the App

You may stop the collection of information by the App by uninstalling it from your mobile device.

You may also request the deletion of your ALIEN_id account; in such case, in order to continue using the Powergate tool, you will need to create a new account.

Deletion of the ALIEN_id account and data retention

In the event of a request to delete the ALIEN_id account, the personal data associated with the account are deleted or anonymized, except for data whose retention is necessary to comply with legal obligations, to manage any disputes or protect the rights of the Controller, to ensure the security of the systems and prevent abuse, and to maintain the technical and operational consistency of the Powergate systems and services.

In such cases, the data are retained for the time strictly necessary to achieve the aforementioned purposes and are limited to what is essential in relation to those purposes.

Transfer of the Powergate Device

The Powergate App allows the User to transfer their Powergate device to another User through the dedicated transfer feature.

During the transfer process, the e-mail address associated with the new User’s ALIEN_id account is processed solely for the purpose of completing the transfer.

If the Powergate device is not associated with a vehicle, the new User must associate the Powergate device and the vehicle with their own ALIEN_id account and will not have access to any technical information relating to the previous use of the Powergate device.

If the Powergate device is already associated with a vehicle, the new User will be able to access the technical and operational information associated with the Powergate device (including, by way of example, identification operations, reading, writing, DataLogger data, and other technical information generated during the use of the Powergate device). The identifying information of the previous User will not be made available to the new User.

Profile photo or image

The photo or image associated with your user profile is stored exclusively on the mobile device from which it was uploaded and is not stored on our servers. If you access your account from another device, your profile image will not be available, and you will need to upload it again.

Technical assistance and file management

We use your personal data to provide you with direct technical assistance in relation to the use of the Powergate App and the management of your account.

Within the scope of the Powergate service, your designated Powergate Manager accesses the data necessary to manage the Powergate tool, prepare and provide files, and provide technical support regarding the use of the tool and its protocols.

The assistance activities carried out by Alientech and your designated Powergate Manager are part of separate processing operations; each performed as an independent data controller.

Push notifications

When you first install the Powergate App, your mobile device asks for permission to send you push notifications, i.e. short instant messages received on your device.

If you consent to receiving such notifications and enable this feature, push notifications are used exclusively to provide you with real-time updates on the status of your tool sessions, the status of protocols, and the files made available and/or modified by your Powergate Manager.

You may disable push notifications at any time through your mobile device settings. In such case, you will still be able to use the App, but you will no longer receive these notifications.

Use of GPS, Bluetooth, Wi-Fi and Hotspot signals of the mobile device

In order to enable pairing between the App and the tool and the use of protocols, the App requires the activation of GPS, Bluetooth and Wi-Fi on your mobile device.

The activation of such features constitutes a necessary technical requirement and is managed by your device’s operating system.

Use of the GPS system integrated into the Powergate tool

Some features of the Powergate tool, for example the DataLogger protocol, require the use of the GPS system integrated into the tool in order to function properly. In such cases, location data is collected during the use of the protocol and is used in the provision of the service, including for performance evaluation and provision of technical support by your Powergate Manager.

The location data generated during the session may be displayed on a map and made available to your Powergate Manager, solely for the purpose of enabling the interpretation of the acquired data and the provision of the technical assistance you have requested.

In-app rating request

The Powergate App may occasionally display a request to rate the App through the features made available by the official app stores. For this purpose, the App uses exclusively technical information stored locally on your device (for example, a counter or a flag relating to the number of times the App is opened), solely in order to avoid repetitive or excessive rating requests.

No personal data relating to the rating request are transmitted to Alientech srl’s servers.

Any review content is managed directly by the relevant app store, in accordance with their own terms and privacy notices.

4. Data collection and processing methods

Personal data is collected directly from you through the use of the App and the tool and is processed through the information systems and technical software components necessary for the operation of the services.

Personal data is processed by our employees and collaborators, acting as persons authorized to process personal data, as well as, within the limits of their respective roles, by third parties involved in the provision of the Powergate services, through our information systems.

The processing of personal data is carried out in compliance with the applicable data protection legislation and through the adoption of appropriate technical and organizational measures designed to ensure the security, integrity and confidentiality of the data.

5. Who we share your data with

Your personal data is shared with our service providers in order to enable them to provide the requested services, with your designated Powergate Manager so that they can manage the files necessary for the use of the tool and provide you with the technical support related to the Powergate services, as well as with entities to whom disclosure is required by law. In some cases, your personal data may also be transferred to and processed outside the European Economic Area.

More specifically, we share your personal data with:

• Service providers. We rely on third-party service providers for the provision and management of the technological infrastructure and services necessary for the operation of the Powergate App and the related services (for example, cloud computing services, hosting, information system management, authentication, security, delivery of communications and notifications). Such providers process the personal data necessary to perform their functions and use it exclusively for the provision of the requested services or to comply with legal obligations.
• Powergate Managers, who may be established within or outside the European Economic Area. Powergate Managers, who may be established within or outside the European Economic Area. Powergate Managers access the personal data relating to your account and your Powergate tool in order to enable the operational management of the tool, including the preparation and provision of the necessary files, and to provide you with technical support related to the Powergate services. Powergate Managers act as independent data controllers, within the scope of their own and autonomous contractual relationship with you. We therefore invite you to refer to the privacy notice provided by your Powergate Manager for any processing of personal data carried out by the Powergate Manager for its own purposes.
• Judicial or administrative authorities. Where we consider it necessary in order to comply with a court order or an order issued by an authority, fulfil legal obligations, or protect our rights or those of third parties in legal proceedings, we may disclose your personal data to a Judicial Authority or an Administrative Authority of the State or of the European Union.

Alientech srl does not and will never sell your personal data.

6. Data transfer

Your personal data is stored on servers managed by third-party companies and, where applicable, duly appointed as Data Processors.

Where, in the context of the provision of the Powergate services, personal data is processed outside the European Economic Area, such transfers shall take place in compliance with the safeguards provided for by applicable data protection legislation, such as, as the case may be, an adequacy decision of the European Commission or the execution of Standard Contractual Clauses (SCC).

7. Data retention

We keep your personal data according on the type of data and the purpose for which they were collected, as long as it is necessary to provide our services, fulfill our legal obligations, or protect our interests or those of third parties.

Account-related data are retained until the account is deleted, except as otherwise specified in the preceding paragraphs. Certain technical and usage data may be retained thereafter, where necessary to comply with legal obligations, ensure the security of the systems, prevent abuse, and ensure the technical and operational consistency of the services.

8. Automated decision-making process

Your personal data is not subject to automated decision-making and/or profiling.

9. Your rights

Pursuant to Articles 15, 16, 17, 18, 19, 20, 21, 22 of the GDPR, in addition to managing your data processing preferences as described in the preceding paragraphs, you can contact us to:

• obtain confirmation of the existence or non-existence of personal data concerning you, even if not yet recorded, and their communication in an understandable form.
• request access to your personal data, their update, correction, or integration.
• request the deletion, transformation into anonymous form, and limitation of the processing of your data.
• object, for legitimate reasons, to the processing of your personal data concerning, even if pertinent to the purpose for which they were collected.
• request portability or a copy of your data.
• exercise the right to object (opt-out), at any time, to the processing of your personal data for direct marketing purposes (this will not affect the lawfulness of the processing carried out prior to the objection).
• request the identification details of the data controller, data processors and the designated representative, as well as information about the subjects or categories of subjects authorized to process your data, the external data processors and the persons in charge of processing.

When you exercise your right of access, you also have the right to know:

• whether your data are being processed.
• the purpose and methods of the processing.
• the categories of data being processed.
• the data retention period (or the criteria for determining the retention period.)
• whether there is any automated processing using electronic tools (e.g., profiling) and what the logic of such processing is.
• the origin of the data (if not initially collected by us.)

You also have the right to file a complaint with the Data Protection Authority, using the appropriate forms available at www.garanteprivacy.it.

10. How to exercise your rights

You can exercise your rights at any time by sending a request to Alientech Srl through the following channels:

1. Regular mail: Via dei Cordari 1 – 13039 Trino (VC) – Italy
2. E-mail: legal@alientech.to
3. PEC (Certified e-mail): alientechsrl@legalmail.it

When contacting us, be sure to include your name and contact information (e-mail, mailing address and/or number phone number, etc.) to make sure your request can be addressed properly.

11. Updates to this Privacy Notice

This Privacy Notice may be updated from time to time. In the event of material changes, we will inform you through the App or by other appropriate means.

Version 1.03 – Last updated: 2026/07/03