Privacy Policy for the UP2PRO Home Automation Application

1. Introduction

This Privacy Policy describes how URMET S.p.A. (“URMET”, “we”, “us”, “our”) processes personal data in connection with the use of the UP2PRO Home Automation Application (“UP2PRO Application”) and its associated services (“Services”) by professional installers (“Installers”) and, indirectly, by their customers (“Customers”).

URMET acts as the data controller for personal data processed through the Application. Installers also act as controllers for personal data they collect directly from Customers during installation and configuration activities.

2. Data Controller

URMET S.p.A.
Registered office: Via Bologna 188/C, 10154 Torino, Italy
VAT no.: IT 06888290019
(As specified in the CGU preamble)

For technical questions, Installers may contact the Assistance Service:

Professionals: +39 011.1962.0029
Private users: +39 011.1962.0654

3. Types of Personal Data Processed

3.1 Installer Data

URMET processes the following Installer-related personal data as part of the creation and operation of the Installer Area:

Installer’s email address
Password
Company name
Commercial register identification number
Postal address
Supporting documents in case of theft or fraudulent use of credentials (e.g., ID copy)

These data are necessary to authenticate the Installer and enable access to the UP2PRO Application.
(Referenced from Article 3.2)

3.2 Project Data

During the creation and management of Projects, the Installer enters and uploads:

Project name
Customer’s name
Installation site address
Name of the project manager (if applicable)
Plans, drawings, and photographs of the installation site
Parameters and setup data for Home Automation Equipment
Information such as number and age of residents (when needed to propose automation scenarios)

These data may be stored:

Locally on the Installer’s tablet, and/or
On the URMET cloud (for backup/archiving, up to 20 MB per Project)
(From Article 4.1)

3.3 Equipment Configuration Data

At the end of a Project, configuration data are stored inside the device installed at the Customer’s residence.
After the Project is closed, the Customer becomes the sole holder of these data.
(Article 4.1)

4. Purposes of Processing

URMET processes personal data for the following purposes:

Creating and managing the Installer Area
Providing access to and operation of the UP2PRO Application
Ensuring the installation, configuration, and setup of Home Automation Equipment
Allowing Project data backup, archiving, and generation of reports
Proposing suggested Home Automation Scenarios based on data entered
Ensuring security, maintenance, and proper operation of the Application
Communicating essential information (account activation, credentials modification, changes to terms, etc.)

(Articles 3, 4, 6, 11)

5. Legal Basis

The processing is based on:

Performance of a contract: access to and use of the UP2PRO Application
Compliance with legal obligations: identity verification in case of fraud, rights of data subjects
Legitimate interest: ensuring functionality, security, backup, integrity of services
Consent: where required (e.g., if the Installer collects Customer data directly)

(Article 11)

6. Data Sharing

URMET may share data with:

6.1 Hosting Provider

The UP2PRO Application is hosted by: OVH SAS
2 rue Kellermann, 59100 Roubaix, France
(From CGU preamble)

6.2 Customers

At Project closure, all configuration data become accessible to the Customer and may be further modified by them.
Installers lose access unless explicitly granted a temporary right.
(Article 4.1)

6.3 Authorities

URMET may modify credentials or share information if required by an authority.
(Article 3.2)

URMET does not use the data for commercial exploitation unrelated to the Services.

7. Data Storage and Retention

Project data backed up to the URMET cloud are stored for archiving purposes.
Local data stored on the Installer’s tablet remain exclusively under the Installer’s responsibility. URMET is not liable for data loss or alteration.
Account information is retained while the Installer Area remains active.
In case of termination, retention follows legal obligations and operational needs.
(Article 4.1, 8)

8. Security Measures

URMET implements appropriate measures to:

Ensure secure access to the Application
Prevent fraudulent use of credentials
Protect against viruses, malicious content, or operational disruptions
(Articles 3.2, 4.2)

Installers are responsible for:

Protecting their login credentials
Ensuring safe use of their devices
Ensuring content uploaded is safe and lawful

9. Rights of Data Subjects

URMET ensures the rights of Installers’ employees or agents whose data it processes, including:

Right of access
Right to rectification
Right to erasure (“right to be forgotten”)
Right to object
Right to restrict processing
Right to data portability
Right not to be subject to automated decision-making
Right to define post‑mortem instructions
Right to lodge a complaint with CNIL (France)

(Article 11.1)

The Installer undertakes to inform Data Subjects of URMET’s Privacy Policy:
https://up.yokiscloud.fr/privacy/en/

10. Installer’s Responsibilities as a Separate Data Controller

For personal data collected directly from Customers (e.g., resident information, photos, plans), the Installer is solely responsible for:

Informing Customers
Ensuring compliance with GDPR and the French LIL (“Loi Informatique & Libertés”)
Informing Customers that their data may be transmitted to URMET
(Article 11.2)

URMET bears no responsibility for Customer-related data handled improperly by the Installer.

11. International Transfers

Data hosted by OVH are stored within the EU (France).
URMET operates within the EU and does not transfer data outside the EU unless legally justified and protected.

12. Changes to this Privacy Policy

URMET may update this Privacy Policy and will inform Installers of any relevant modifications, in accordance with the CGU.