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Privacy Policy

  

   Owner and Data Controller   


   Types of Data collected   

     Among the types of Personal Data that this Application collects, by itself or through third parties, there are:       Trackers; Usage Data; first name; last name; gender; phone number; email address; ZIP/Postal code.     

Complete details on each type of Personal Data collected are  provided in the dedicated sections of this privacy policy or by specific  explanation texts displayed prior to the Data collection.
Personal  Data may be freely provided by the User, or, in case of Usage Data,  collected automatically when using this Application.
Unless specified  otherwise, all Data requested by this Application is mandatory and  failure to provide this Data may make it impossible for this Application  to provide its services. In cases where this Application specifically  states that some Data is not mandatory, Users are free not to  communicate this Data without consequences to the availability or the  functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any  use of Cookies – or of other tracking tools — by this Application or by  the owners of third-party services used by this Application serves the  purpose of providing the Service required by the User, in addition to  any other purposes described in the present document.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.


Mode and place of processing the Data

   Methods of processing   

The Owner takes appropriate security measures to prevent  unauthorized access, disclosure, modification, or unauthorized  destruction of the Data.
The Data processing is carried out using  computers and/or IT enabled tools, following organizational procedures  and modes strictly related to the purposes indicated. In addition to the  Owner, in some cases, the Data may be accessible to certain types of  persons in charge, involved with the operation of this Application  (administration, sales, marketing, legal, system administration) or  external parties (such as third-party technical service providers, mail  carriers, hosting providers, IT companies, communications agencies)  appointed, if necessary, as Data Processors by the Owner. The updated  list of these parties may be requested from the Owner at any time.

   Place   

The Data is processed at the Owner's operating offices and in any  other places where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve  transferring the User's Data to a country other than their own. To find  out more about the place of processing of such transferred Data, Users  can check the section containing details about the processing of  Personal Data.

   Retention time   

Unless specified otherwise in this document, Personal Data shall be  processed and stored for as long as required by the purpose they have  been collected for and may be retained for longer due to applicable  legal obligation or based on the Users’ consent.


The purposes of processing

       The Data concerning the User is collected to allow the Owner to  provide its Service, comply with its legal obligations, respond to  enforcement requests, protect its rights and interests (or those of its  Users or third parties), detect any malicious or fraudulent activity, as  well as the following:         Analytics and Contacting the User.       

For specific information about the Personal Data used for each  purpose, the User may refer to the section “Detailed information on the  processing of Personal Data”.


Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  •                 Analytics               
     
  •                 Contacting the User               
     

   Further Information for Users       

 Legal basis of processing 

The Owner may process Personal Data relating to Users if one of the following applies:

  • Users have given their consent for one or more specific purposes.
  • provision of Data is necessary for the performance of an agreement  with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is carried out in the public  interest or in the exercise of official authority vested in the Owner;
  • processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal  basis that applies to the processing, and in particular whether the  provision of Personal Data is a statutory or contractual requirement, or  a requirement necessary to enter into a contract. 

 Further information about retention time 

Unless specified otherwise in this document, Personal Data shall be  processed and stored for as long as required by the purpose they have  been collected for and may be retained for longer due to applicable  legal obligation or based on the Users’ consent.

Therefore:

  • Personal Data collected for purposes related to the performance of  a contract between the Owner and the User shall be retained until such  contract has been fully performed.
  • Personal Data collected for the purposes of the Owner’s legitimate  interests shall be retained as long as needed to fulfill such purposes.  Users may find specific information regarding the legitimate interests  pursued by the Owner within the relevant sections of  this document or  by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period  whenever the User has given consent to such processing, as long as such  consent is not withdrawn. Furthermore, the Owner may be obliged to  retain Personal Data for a longer period whenever required to fulfil a  legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted.  Therefore, the right of access, the right to erasure, the right to  rectification and the right to data portability cannot be enforced after  expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

  • Withdraw their consent at any time. Users have  the right to withdraw consent where they have previously given their  consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have  the right to object to the processing of their Data if the processing is  carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn  if Data is being processed by the Owner, obtain disclosure regarding  certain aspects of the processing and obtain a copy of the Data  undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have  the right to restrict the processing of their Data. In this case, the  Owner will not process their Data for any purpose other than storing it. 
  • Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly  used and machine readable format and, if technically feasible, to have  it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

 Users are also entitled to learn about the legal basis for Data  transfers abroad including to any international organization governed by  public international law or set up by two or more countries, such as  the UN, and about the security measures taken by the Owner to safeguard  their Data. 

 Details about the right to object to processing 

Where Personal Data is processed for a public interest, in  the exercise of an official authority vested in the Owner or for the  purposes of the legitimate interests pursued by the Owner, Users may  object to such processing by providing a ground related to their  particular situation to justify the objection.

Users must know that, however, should their Personal Data be  processed for direct marketing purposes, they can object to that  processing at any time, free of charge and without providing any  justification. Where the User objects to processing for direct marketing  purposes, the Personal Data will no longer be processed for such  purposes. To learn whether the Owner is processing Personal Data for  direct marketing purposes, Users may refer to the relevant sections of  this document. 

 How to exercise these rights 

Any requests to exercise User rights can be directed to the Owner  through the contact details provided in this document. Such requests are  free of charge and will be answered by the Owner as early as possible  and always within one month, providing Users with the information  required by law. Any rectification or erasure of Personal Data or  restriction of processing will be communicated by the Owner to each  recipient, if any, to whom the Personal Data has been disclosed unless  this proves impossible or involves disproportionate effort. At the  Users’ request, the Owner will inform them about those recipients.


Additional information about Data collection and processing

   Legal action   

The User's Personal Data may be used for legal purposes by the  Owner in Court or in the stages leading to possible legal action arising  from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

   Additional information about User's Personal Data   

In addition to the information contained in this privacy policy,  this Application may provide the User with additional and contextual  information concerning particular Services or the collection and  processing of Personal Data upon request.

   System logs and maintenance   

For operation and maintenance purposes, this Application and any  third-party services may collect files that record interaction with this  Application (System logs) or use other Personal Data (such as the IP  Address) for this purpose.

   Information not contained in this policy   

More details concerning the collection or processing of Personal  Data may be requested from the Owner at any time. Please see the contact  information at the beginning of this document.

   Changes to this privacy policy   

The Owner reserves the right to make changes to this privacy policy  at any time by notifying its Users on this page and possibly within  this Application and/or - as far as technically and legally feasible -  sending a notice to Users via any contact information available to the  Owner. It is strongly recommended to check this page often, referring to  the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis  of the User’s consent, the Owner shall collect new consent from the  User, where required.

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