MYKEYS Pro App Information

SILCA Spa a socio unico, with headquarters in Vittorio Veneto (TV), Via Podgora, 20, email data.protection@silca.it, as owner of the processing of personal data (hereinafter "SILCA" or "Data Controller"), issues this information in compliance with European and Italian legislation on the protection of personal data to clarify and illustrate the processing of data carried out for purposes related to the installation and use of the MYKEYS Pro platform provided through the APP and / or access through a dedicated website (hereinafter "MyKeys Pro"). The Data Controller has appointed a data protection officer (DPO), that can be contacted by writing to the following address: data.protection@silca.it.

Purposes of the processing and legal basis

SILCA will process your data for the following purposes:

A. SERVICE PURPOSES

to download, activate and operate the MYKEYS Pro APP or for the activation and registration on the dedicated website;

to diagnose problems in the MYKEYS Pro APP or on the website;

to process any payment;

to investigate and respond to any comments or complaints that the User may send;

to detect, prevent or otherwise deal with fraud, technical or security problems and piracy by helping to protect the User;

to exercise the rights of the Data Controller.

For these "Service Purposes" the legal basis of the processing is the need to ensure the installation and the correct functionalities of the requested platform or to fulfill a legal obligation.

(for users of Silca GmbH, Silca Key Systems S.A., Silca Ltd, Silca S.A.S., Minda Silca Engineering Ltd, H. Cillekens B.V., Flexonsilca S.A., Kaba do Brasil Ltda, Advanced Diagnostics Ltd, Kaba Ilco Corp., Silca South America S.A., Distributor (specific for each country)) to meet a specific request to transfer data to a third data controller for the purposes of e-ordering. For such processing, on activating your request you will be asked for separate consent, not through this privacy policy.

B. PROMOTIONAL PURPOSES

to send informative material (e.g. Newsletter) and promotional material regarding initiatives, promotions and events organized by SILCA or in which SILCA participates ( Marketing ): for this purpose, your express consent is required.

analyze the tastes, preferences, habits and behaviors of the interested party in order to transmit personalized commercial communications based on the commercial and behavioral profile thus created. This data processing tool relates the data collected from the products purchased in order to offer you a personalized communication. For this purpose, express consent is required, distinct from the one referred to in the previous point ("Profiling").

communicate the data subject s email address and registration details to third parties so that they can pursue their interests through the marketing operations mentioned in the item Marketing : Express consent is necessary for this purpose, separate from that in the item Marketing .

Existence of automated individual decision making (Profiling)

The Data Controller intends to pursue the aims described in the item Profiling by analysing information about the data subject (for example, inferred from purchases made), for the purpose of sending customised commercial communications and implementing targeted promotional and business intelligence activities. Processing shall be carried out by data/information processing instruments, which when they are cross-referenced will create a web-based commercial and behavioural profile for the data subject. Furthermore, for the same purposes, such data and/or information will be associated to data and/or information provided by the data subject or already in the Data Controller s possession, also as a result of using the services it makes available.

Data retention period

The Owner will process your data:

A. FOR SERVICE PURPOSES

Up to 2 years of inactivity either of the user or of the devices associated with their account.

B. FOR PROMOTIONAL PURPOSES

For Marketing: for 24 months from the last communication, always before the withdrawal of consent takes place.

For Profiling: for 12 months.

In any case, uninstalling the APP MYKEYS Pro or erasure of the profile from the website will immediately interrupt the collection of any further information by the Owner.

The latter, however, will still retain the data for the time necessary to carry out the aforementioned purposes, which in any case will not exceed five years from the elimination of the profile.

Provision of data and consequences on failure to provide data

Providing data:

A. FOR SERVICE PURPOSE

it is necessary for the operation of the MYKEYS Pro platform and for the fulfillment of the connected obligations. If missing, the user will not be able to proceed with the processing.

B. FOR PROMOTIONAL PURPOSES

it is optional and any refusal to provide data and to provide the relative consent will make it impossible for the Data Controller to carry out the corresponding activities. However, failure to consent will not prevent the installation and use of the MYKEYS Pro platform.

Categories of recipients

Exclusively for the purposes specified above, SILCA may communicate your data to the following categories of subjects: internal figures authorized to process data according to their respective duties, companies entrusted with the creation of promotions and / or commercial communications, companies that handle the sending of promotional and advertising material, companies for the management of payments and billing, companies that manage and keep the archives (computer and / or paper) of SILCA, public and private bodies, also following inspections and verifications, companies, consultants and professionals that operate on behalf of SILCA for the pursuit of the aforementioned purposes.

These recipients, if they process data on behalf of the Data Controller, will be appointed as data controllers with a specific contract or other legal act.

As mentioned above, if the e-ordering service is activated, your data may be transmitted to the Silca HQ competent for the country involved (France, Germany, Spain, etc.). In this case, your specific consent will be required.

Data transfer to a third country and / or an international organization

Your personal data will not be transferred to non-European Countries.

Rights of interested parties

It is the data subject's right to ask the Data Controller to access their personal data and to rectify them if they are inaccurate, to delete them or limit their processing if the conditions are met, and to obtain the portability of the personal data communicated.

To exercise their rights, the interested party can write to the Owner at the following address: data.protection@silca.it.

The interested party also has the right to lodge a complaint with the competent control authority, the Guarantor for the protection of personal data (www.garanteprivacy.it).

UPDATE DATE: June 2026