Data Controller

Types of Data Collected

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or by specific information notices displayed prior to the collection of the data.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically while using this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to provide them, this Application may be unable to provide the Service. In cases where this Application specifically states that certain Data are optional, Users are free not to communicate such Data without any consequences on the availability or the functioning of the Service.
Users who have doubts about which Data are mandatory are encouraged to contact the Data Controller.
Any use of Cookies — or other tracking tools — by this Application or by the owners of third-party services used by this Application, unless otherwise stated, is for the purpose of providing the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for third-party Personal Data obtained, published, or shared through this Application and warrants that they have the right to communicate or disseminate them, holding the Data Controller harmless from any liability towards third parties.

METHODS AND PLACE OF PROCESSING THE DATA COLLECTED

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Processing is carried out using computer and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to other parties involved in the operation of this Application (administrative, sales, marketing, legal, system administration staff) or to external parties (such as third-party technical service providers, postal carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Data Controller. The updated list of Data Processors may always be requested from the Data Controller.

Legal Basis of Processing

The Data Controller may process Personal Data relating to the User if one of the following 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 (“opt-out”) to such processing. This, however, does not apply when the processing of Personal Data is subject to European data protection legislation;
• processing is necessary for the performance of a contract with the User and/or for any pre-contractual measures;
• 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, it is always possible to request that the Data Controller clarify the specific legal basis that applies to each processing operation and, in particular, to specify whether the processing is based on statutory law, provided for by a contract, or necessary to enter into a contract.

Place

The Data are 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 the one in which the User is located. For information on the place of processing, Users can refer to the section concerning details on the processing of Personal Data.

The User has the right to obtain information regarding the legal basis for transfers of 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 adopted by the Data Controller to safeguard the Data.

The User can verify whether any of the above-mentioned transfers takes place by examining the relevant sections of this document concerning the processing of Personal Data or by asking the Data Controller using the contact details indicated at the beginning.

Retention Period

Data are processed and stored for as long as required by the purposes for which they were collected.

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 purposes related to the legitimate interests of the Data Controller shall be retained until such interests have been fulfilled. Users may obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, upon expiry of that period, the rights of access, erasure, rectification, and data portability can no longer be exercised.

Users’ Rights

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

In particular, the User has the right to:

• withdraw consent at any time. The User may withdraw consent previously given for the processing of their Personal Data.
• object to the processing of their Data. The User may object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details on the right to object are provided below.
• access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing, and to receive a copy of the Data processed.
• verify and seek rectification. The User may verify the accuracy of their Data and request their update or correction.
• restrict the processing of their Data. Under certain circumstances, the User may request the restriction of the processing of their Data. In this case, the Data Controller will not process the Data for any purpose other than their storage.
• obtain the erasure or removal of their Personal Data. Under certain circumstances, the User may request the erasure of their Data by the Data Controller.
• receive their Data and have them transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have them transmitted without hindrance to another controller. This provision applies when the Data are processed by automated means and the processing is based on the User’s consent, on a contract to which the User is party, or on pre-contractual obligations thereof.
• lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.

Details about the right to object

Where Personal Data are processed for a public interest, in the exercise of official authority vested in the Data Controller, or for the purposes of the legitimate interests pursued by the Data Controller, Users may object to such processing on grounds related to their particular situation.

Users are reminded that, where their Personal Data are processed for direct marketing purposes, they may object to that processing at any time without providing any justification. To find out whether the Data Controller processes Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

To exercise their rights, Users may send a request to the contact details of the Data Controller indicated in this document. Requests are free of charge and will be processed by the Data Controller as soon as possible and, in any case, within one month.

FURTHER INFORMATION ABOUT PROCESSING

Defense in court

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 declares to be aware that the Data Controller may be required to reveal Personal 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 regarding 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, i.e., files that record interactions and may also contain Personal Data, such as the User’s IP address.

Information not contained in this policy

More details concerning the processing of Personal Data may be requested from the Data Controller at any time using the contact details.

“Do Not Track” requests

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 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 notifying Users on this page and, if possible, within this Application and, where technically and legally feasible, by sending a notice to Users via any contact information available to the Data Controller. Please consult this page regularly, referring to the date of the last modification indicated below.

Where changes affect processing activities whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.