Types of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, are: name, surname, and email address.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed prior to the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data without any consequence on the availability of the Service or its operation. Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller. The possible use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, 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.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate them, freeing the Data Controller from any liability to third parties.

Methods and Location of Data Processing

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal 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 Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) may have access to the Data, appointed, if necessary, as Data Processors by the Data Controller. An updated list of these parties may be requested from the Data Controller at any time.

Legal Basis of Processing

The Data Controller processes Personal Data relating to the User if one of the following conditions applies:

• The User has given consent for one or more specific purposes. Note: In some jurisdictions, the Data Controller may be allowed to process Personal Data without the User’s consent or another legal basis specified below, until the User objects to such processing (“opt-out”), without having to rely on consent or another legal basis below, as long as the processing is governed by European data protection law;
• Processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations thereof;
• Processing is necessary for compliance with a legal obligation to which the Data Controller is subject;
• Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
• Processing is necessary for the purposes of the legitimate interests pursued by the Data Controller or by a third party.

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

Location

The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Data Controller. The User’s Personal Data may be transferred to a country other than their own. To find out more about the location of processing, Users can refer to the section containing details about the processing of Personal Data.

The User is entitled to obtain information regarding the legal basis for transferring Data outside the European Union or to an international organization governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the beginning.

Retention Period

The Data is processed and stored for as long as required by the purposes they have been collected for. Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Data Controller’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 Data Controller within the relevant sections of this document or by contacting the Data Controller.
• Where processing is based on consent, the Data Controller may retain Personal Data longer until such consent is withdrawn. Furthermore, the Data Controller 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 upon expiration of the retention period.

Details on Personal Data Processing

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

Contacting the User

User Rights Users can exercise certain rights regarding their Data processed by the Data Controller.

In particular, the User has the right to:

• Withdraw consent at any time. Users can withdraw consent previously given for the processing of their Personal Data.
• Object to the processing of their Data. Users may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided in the section below.
• Access their Data. Users have the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and receive a copy of the processed Data.
• Verify and request rectification. Users can verify the accuracy of their Data and request its update or correction.
• Obtain the limitation of processing. When certain conditions are met, Users may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
• Obtain the erasure or removal of their Personal Data. When certain conditions are met, Users may request the erasure of their Data by the Data Controller.
• Receive their Data or 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. This provision is applicable when the Data is processed by automated means and the processing is based on the User’s consent, on a contract of which the User is a party, or on contractual measures related to it.
• Lodge a complaint. Users may lodge a complaint with the competent data protection authority or take legal action.

Details on the Right to Object

When Personal Data is processed in the public interest, in the exercise of public authority vested in the Data Controller, or for the legitimate interests pursued by the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that if their Data is processed for direct marketing purposes, they can object to that processing without providing any justification. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to Exercise User Rights

To exercise User rights, Users can make a request to the contact details of the Data Controller provided in this document. Requests are free of charge and processed by the Data Controller as soon as possible, in any case within one month.

Further Information on Processing

Legal Defense

The User’s Personal Data may be used by the Data Controller in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services by the User. The User acknowledges that the Data Controller may be required to disclose the Data upon request of public authorities.

Specific Information

Upon the User’s request, 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 operation and maintenance purposes, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information Not Contained in This Policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Response to “Do Not Track” requests

This Application does not support “Do Not Track” requests. To determine whether any third-party services used support them, Users are encouraged to consult the respective privacy policies.

Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if possible, within this Application, as well as by informing Users via their contact information held by the Data Controller. Users are therefore advised to check this page regularly, referring to the date of the last modification indicated at the bottom.

If the changes affect processing activities based on consent, the Data Controller shall collect new consent from the User, if required.