Types of Data we collect

The Owner does not provide a list of the categories of Personal Data collected.

Complete information regarding each category of Personal Data collected is provided in the sections of this privacy policy dedicated to that purpose or through specific explanatory texts displayed before the Data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when this Application is used.

Unless otherwise stated, all Data requested by this Application is mandatory, and failure to provide it may make it impossible for this Application to provide its Services. Where this Application specifically indicates that certain Data is not mandatory, Users are free not to provide such Data without this affecting the availability or operation of the Service.

Users who are unsure about which Data is mandatory may contact the Owner.

The use of Cookies, or other tracking tools, by this Application or by the owners of third-party services used by this Application is intended to provide the Service requested by the User, in addition to any other purposes described in this document and in the Cookie Policy.

The User is responsible for any third-party Personal Data obtained, published or shared through this Application.

Methods and place of processing the Data collected

Methods of processing

The Owner shall process Users’ Data appropriately and shall adopt suitable security measures to prevent unauthorized access, disclosure, alteration or destruction of the Data.

Data processing shall be carried out using computers and/or IT-enabled tools, following organizational procedures and methods strictly related to the stated purposes. In addition to the Owner, in certain cases the Data may be accessible to specific categories of authorized persons involved in the operation of this Application, including administration, sales, marketing, legal and system administration personnel, or external contractors that provide services to the Owner, such as third-party technical service providers, courier companies, hosting providers, IT companies and communications agencies. Where necessary, these parties shall be appointed by the Owner as Data Processors. An up-to-date list of such parties may be requested from the Owner at any time.

Place

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

Depending on the Users’ location, Data transfers may involve transferring Users’ Data to a country other than their own. For further information about the place of processing of transferred Data, Users may refer to the section containing details about the processing of Personal Data.

Retention period

Unless otherwise stated in this document, Personal Data shall be processed and retained for as long as necessary for the purpose for which it was collected and may be retained for longer where required by a relevant legal obligation or on the basis of the Users’ consent.

Cookie Policy

This Application uses Trackers. For further information, Users may consult the Cookie Policy.

Further information for Users in the European Union

Legal basis for processing

The Owner may process the User’s Personal Data where one of the following conditions applies:

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

In any event, the Owner is available to clarify the specific legal bases that apply to the processing and, in particular, whether the provision of Personal Data is a contractual or statutory requirement or a requirement necessary to enter into a contract.

Further information about retention periods

Unless otherwise stated in this document, Personal Data shall be processed and retained for as long as necessary for the purpose for which it was collected and may be retained for longer where required by a relevant legal obligation or on the basis of the Users’ consent.

Therefore:

• Personal Data collected for the performance of a contract between the Owner and the User shall be retained until that contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained for as long as necessary to fulfil those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner.
• The Owner may retain Personal Data for an additional period where the User has consented to such processing, for as long as that consent remains valid. Furthermore, the Owner may be required to retain Personal Data for an additional period whenever this is necessary to comply with a legal obligation or an order from an authority.

Once the retention period has expired, the Personal Data shall be deleted. Therefore, the rights of access, erasure, rectification and data portability cannot be exercised after the retention period has expired.

Users’ rights under 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 the processing of their Data. Users have the right to object to the processing of their Data where the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to know whether their Data is being processed by the Owner, obtain information about certain aspects of the processing, and receive a copy of the Data being processed.
• Verify and request rectification. Users have the right to verify the accuracy of their Data and request that it be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In such cases, the Owner shall process the Data only for storage purposes.
• Have their Personal Data erased or otherwise removed. Users have the right to obtain the erasure of their Data by 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, where technically feasible, to have it transmitted to another controller without hindrance.
• Lodge a complaint. Users have the right to lodge a complaint with the competent data protection authority.

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

Information about the right to object to processing

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

Users should be aware, however, that where their Personal Data is processed for direct marketing purposes, they may 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 may no longer be processed for those purposes. To find out whether Users’ Personal Data is being processed by the Owner for direct marketing purposes, Users should consult the relevant sections of this document.

How to exercise these rights

Any request to exercise the User’s rights may be submitted to the Owner using the contact details provided in this document. These requests are free of charge, and the Owner shall respond as soon as possible and always within one month, providing Users with the information required by law. The Owner shall communicate any rectification or erasure of Personal Data or restriction of processing to each recipient, where applicable, to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner shall inform them about those recipients.

Additional information about Data collection and processing

Legal defence

The User’s Personal Data may be used for the Owner’s legal defence before a court or in judicial proceedings prior to possible legal action arising from the improper use of this Application or the related Services.

The User acknowledges that the Owner may be required by public authorities to disclose Personal Data.

Additional information about the 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 specific Services or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance purposes, this Application and any third-party services used by it may collect system logs, meaning files that record interactions with this Application and may contain Personal Data, such as the User’s IP address.

Information not contained in this privacy policy

Additional information regarding the collection and processing of Personal Data may be requested from the Owner at any time. The relevant contact information is provided at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to amend this privacy policy at any time by notifying Users through this page and, where possible, through this Application and/or, where technically and legally feasible, by notifying Users directly, provided that the Owner has the necessary contact information for this purpose. Users are strongly encouraged to review this page frequently, referring to the date of the latest revision stated at the top of the page.

Where changes affect processing activities carried out on the basis of the User’s consent, the Owner shall obtain the User’s new consent where required.