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Data and Privacy

To receive information about Personal Data, the purposes, and the parties with whom it is shared, please contact the Owner.

Owner and Data Controller

Types of Data Collected

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

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 the 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 specifies that some Data is not mandatory, Users are free not to communicate this Data without consequences on the availability or functioning of the Service.
Users who have doubts about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or 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 requested by the User, in addition to any other purposes described in this document and in the Cookie Policy, if available.

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 processing of Data 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, 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 of Processing

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 location of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention Time

Unless otherwise specified in this document, Personal Data is processed and stored for as long as required for the purposes for which it was collected and may be stored for a longer period to comply with a legal obligation or upon the User’s consent.

This document informs Users about the technologies that allow this Application to achieve the purposes described below. These technologies enable the Owner to access and store information (using a Cookie, for example) or use resources (by running a script, for example) on a User’s device when the User interacts with this Application.

For the sake of simplicity, all these technologies are defined as “Trackers” in this document unless there is a reason to differentiate them.
For example, although Cookies can be used both on web and mobile browsers, it would be inaccurate to talk about Cookies in the context of mobile applications as they are browser-based trackers. Therefore, in this document, the term Cookies is only used when specifically referring to that particular type of Tracker.

Some of the purposes for which Trackers are used may require the User’s consent. When consent is given, it can be freely withdrawn at any time by following the instructions provided in this document.

This Application only uses Trackers managed directly by the Owner (so-called “first-party” Trackers).
The lifespan and expiration dates of first-party Cookies and other similar Trackers may vary depending on the defined lifespan by the Owner. Some may expire at the end of the User’s browsing session.

Activities strictly necessary for the operation of this Application and the provision of the Service

This Application uses so-called “technical” Cookies and other similar Trackers to carry out activities strictly necessary for the operation or provision of the Service.

How to Manage Preferences and Give or Withdraw Consent

There are various ways to manage preferences related to Trackers and to give or withdraw consent, if applicable:

Users can manage Tracker preferences directly in their device settings, for example by preventing the use or storage of Trackers.

Additionally, whenever the use of Trackers is based on consent, Users can give or withdraw this consent by setting their preferences within the cookie notice, or by updating these preferences accordingly using the appropriate privacy consent preferences widget, if available.

It is also possible, through corresponding browser or device features, to delete previously stored Trackers, including those used to remember the User’s initial consent preferences.

Other Trackers in the browser’s local memory can be cleared by deleting the browsing history.

Accessing Tracker Settings

Users can, for example, find information on how to manage Cookies in the most commonly used browsers at the following addresses:

Users can also manage certain categories of Trackers used in mobile applications by disabling the appropriate device settings, such as mobile device advertising settings or general tracking settings (Users can open the device settings and search for the appropriate setting).

Consequences of Refusing to Use Trackers

The User is free to decide whether to allow the use of Trackers. However, it should be noted that Trackers allow this Application to provide Users with a better experience and advanced features (in accordance with the purposes described in this document). Therefore, if the User decides to block the use of Trackers, it may be possible that the Owner cannot provide the related features.

Owner and Data Controller

Given the objective complexity surrounding tracking technologies, Users are encouraged to contact the Owner if they wish to receive further information on the use of these technologies by this Application.

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 or for any pre-contractual obligations thereof;
  • Processing is necessary to comply 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 be happy 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.

Additional Information on Data Retention

Unless otherwise specified in this document, Personal Data is processed and stored for as long as required for the purpose for which it was collected, and may be stored for longer periods due to a legal obligation applicable or on the basis of the User’s 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 can 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 of access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.

User Rights under the General Data Protection Regulation (GDPR)

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

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, 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.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users also have the right to know 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, as well as the security measures taken by the Owner to safeguard their Data.

Information 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 if their Personal Data is 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. Any rectification or erasure of Personal Data or restriction of processing shall be communicated by the Owner to each recipient to whom the Personal Data has been disclosed, unless this proves impossible or involves a disproportionate effort. Users can request information about these recipients from the Owner.

Additional Information on Data Processing and Collection

Legal Action

User 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.
Users are 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.

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 for this purpose other Personal Data (such as IP Address).

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 or – as far as technically and legally feasible – by 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.

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