Types of Data collected
Among the types of Personal Data that this Application collects,
by itself or through third parties, there are:
phone number; Cookies; Usage Data; unique device identifiers for
advertising (Google Advertiser ID or IDFA, for example); geographic
position.
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 and in the Cookie
Policy, if available.
Users are responsible for any third-party Personal Data obtained,
published or shared through this Application and confirm that they have
the third party's consent to provide the Data to the Owner.
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.
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. Note: Under some legislations the Owner may be allowed to
process Personal Data until the User objects to such processing
(“opt-out”), without having to rely on consent or any other of the
following legal bases. This, however, does not apply, whenever the
processing of Personal Data is subject to European data protection law;
- 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.
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.
Users are also entitled to learn about the legal basis of Data
transfers to a country outside the European Union or 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.
If any such transfer takes place, Users can find out more by checking
the relevant sections of this document or inquire with the Owner using
the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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 do so
for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted.
Therefore, the right to 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 purposes of processing
The Data concerning the User is collected to allow the Owner to
provide its Services, as well as for the following purposes:
Managing contacts and sending messages, Analytics,
Infrastructure monitoring, Handling payments, Registration and
authentication and Hosting and backend infrastructure.
Users can find further detailed information about such purposes
of processing and about the specific Personal Data used for each purpose
in the respective sections of this document.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
-
Analytics
The services contained in this section enable the
Owner to monitor and analyze web traffic and can be used to keep track
of User behavior.
MixPanel (MixPanel)
MixPanel is an analytics service provided by Mixpanel Inc.
Personal Data collected:
Cookies; Usage Data.
Place of processing:
US
–
Privacy Policy – Opt Out.
-
Handling payments
Payment processing services enable this
Application to process payments by credit card, bank transfer or other
means. To ensure greater security, this Application shares only the
information necessary to execute the transaction with the financial
intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to
the User, such as emails containing invoices or notifications concerning
the payment.
Google Pay (Google)
Google Pay is a payment service provided by
Google LLC or by Google Ireland Limited, depending on the location this
Application is accessed from, which allows users to make online payments
using their Google credentials.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
US
–
Privacy Policy.
Privacy Shield participant.
-
Hosting and backend infrastructure
This type of services has the purpose of hosting
data and files that enable this Application to run and be distributed as
well as to provide a ready-made infrastructure to run specific features
or parts of this Application.
Some of these services work through geographically distributed servers,
making it difficult to determine the actual location where the Personal
Data are stored.
Amazon Web Services (AWS) (Amazon)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
See the Amazon privacy policy
–
Privacy Policy.
Privacy Shield participant.
Linode (Linode, LLC.)
Linode is a hosting service provided by Linode, LLC.
Personal Data collected:
various types of Data as specified in the privacy policy of the service.
Place of processing:
US
–
Privacy Policy.
-
Infrastructure monitoring
This type of service allows this Application to
monitor the use and behavior of its components so its performance,
operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and
mode of implementation of these services, whose function is to filter
the activities of this Application.
Crashlytics (Google Inc.)
Crashlytics is a monitoring service provided by
Google LLC or by Google Ireland Limited, depending on the location this
Application is accessed from.
Personal Data collected:
geographic position; unique device identifiers
for advertising (Google Advertiser ID or IDFA, for example); various
types of Data as specified in the privacy policy of the service.
Place of processing:
US
–
Privacy Policy.
-
Managing contacts and sending messages
This type of services makes it possible to manage a
database of email contacts, phone contacts or any other contact
information to communicate with the User.
These services may also collect data concerning the date and time when
the message was viewed by the User, as well as when the User interacted
with it, such as by clicking on links included in the message.
Twilio (Twilio, Inc.)
Twilio is a phone numbers management and communication service provided by Twilio, Inc.
Personal Data collected:
phone number.
Place of processing:
US
–
Privacy Policy.
-
Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide
registration and authentication services. In this case, this Application
will be able to access some Data, stored by these third party services,
for registration or identification purposes.
Direct registration (This Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data collected:
phone number.
Further information about Personal Data
-
TapJoy
Personal Data: Various types of Data as specified in the privacy policy of the service.
-
Hipmob
Personal Data: Various types of Data as specified in the privacy policy of the service.
-
Papertrail
Personal Data: Various types of Data as
specified in the privacy policy of the service. The Data may include
phone number, ip address and Data related to any HTTP request.
-
Push notifications
This Application may send push notifications to the User.
-
Access the address book
This Application may request access to your address book.
-
Selling goods and services online
The Personal Data collected are used to
provide the User with services or to sell goods, including payment and
possible delivery.
The Personal Data collected to complete the payment may include the
credit card, the bank account used for the transfer, or any other means
of payment envisaged. The kind of Data collected by this Application
depends on the payment system used.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
- 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. Further details are provided in
the dedicated section below.
- 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, under certain circumstances, 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, under certain circumstances, 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. This
provision is applicable provided that the Data is processed by automated
means and that the processing is based on the User's consent, on a
contract which the User is part of or on pre-contractual obligations
thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
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 without providing any justification. 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. These requests
can be exercised free of charge and will be addressed by the Owner as
early as possible and always within one month.
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) 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.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To
determine whether any of the third-party services it uses honor the “Do
Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy
at any time by giving notice to 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.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection
with other information — including a personal identification number —
allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application
(or third-party services employed in this Application), which can
include: the IP addresses or domain names of the computers utilized by
the Users who use this Application, the URI addresses (Uniform Resource
Identifier), the time of the request, the method utilized to submit the
request to the server, the size of the file received in response, the
numerical code indicating the status of the server's answer (successful
outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilized by the User, the various time
details per visit (e.g., the time spent on each page within the
Application) and the details about the path followed within the
Application with special reference to the sequence of pages visited, and
other parameters about the device operating system and/or the User's IT
environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other
body which processes Personal Data on behalf of the Controller, as
described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other
body which, alone or jointly with others, determines the purposes and
means of the processing of Personal Data, including the security
measures concerning the operation and use of this Application. The Data
Controller, unless otherwise specified, is the Owner of this
Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this
document to the European Union include all current member states to the
European Union and the European Economic Area.
Cookies
Small piece of data stored in the User's device.
Legal information
This privacy statement has been prepared based on provisions of
multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679
(General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document.