Policy summary
Personal Data processed for the following purposes and using the following services:
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Analytics
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Google Analytics (Universal Analytics) and Google Analytics (Universal Analytics) with anonymized IP
Personal Data: Trackers; Usage Data
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Unity Analytics
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
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Google Analytics 4
Personal Data: number of Users; session statistics; Trackers; Usage Data
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Google Analytics for Firebase (for apps)
Personal Data: device information; number of sessions; operating systems; session duration; Trackers; Usage Data
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Google Analytics Granular location and device data collection
Personal Data: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data
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Google Analytics Demographics and Interests reports
Personal Data: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
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Google Analytics Advertising Reporting Features
Personal Data: Trackers; 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
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Data transfer outside of the UK
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Data transfer outside the EU
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Device permissions for Personal Data access
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Hosting and backend infrastructure
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Firebase Cloud Firestore, Firebase Cloud Functions, Firebase Realtime Database and Firebase Cloud Storage
Personal Data: Usage Data; various types of Data as specified in the privacy policy of the service
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Amazon S3
Personal Data: Usage Data
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Amazon Web Services (AWS), Firebase Hosting and Vuforia
Personal Data: various types of Data as specified in the privacy policy of the service
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iubenda Accessibility Solution
Personal Data: Trackers; Usage Data
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Infrastructure monitoring
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Location-based interactions
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Managing contacts and sending messages
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Managing data collection and online surveys
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Platform services and hosting
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App Store Connect
Personal Data: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data
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Google Play Store
Personal Data: Usage Data
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Registration and authentication
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Firebase Authentication
Personal Data: email address; password; social media accounts
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Adherence to the Google API Services User Data Policy and Limited Use Requirements
Personal Data: various types of Data as specified in the privacy policy of the service
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Google OAuth
Personal Data: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service
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Traffic optimization and distribution
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Amazon CloudFront
Personal Data: browser information; city; country; county; device information; geography/region; IP address; latitude (of city); longitude (of city); metro area; operating systems; state; Usage Data; ZIP/Postal code
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Google Cloud CDN
Personal Data: Usage Data
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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Collection of Personal Information about California consumers aged 13 to 16
We collect Personal Information of consumers between the age of 13 and 16 and won't Sell or Share their Personal Information unless those consumers have opted in.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Collection of Personal Information about California consumers below the age of 13
We collect Personal Information of consumers below the age of 13 and won't Sell or Share their Personal Information unless their parents or guardians have opted in on behalf of those minors.
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Collection of Personal Information about Users aged 13 to 16 in the United States
We collect Personal Information of Users between the age of 13 and 16* and won't Sell their personal data unless those Users have opted in.
*in some states like Delaware and Florida this age limit is raised to 18 years.
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Collection of Personal Information about Users below the age of 13 in the United States
We collect, use, or disclose Personal Information of Users below the age of 13 only if we have obtained verifiable parental consent to do so.
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Equal protection of User Data
This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
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localStorage
localStorage allows this Application to store and access data right in the User's browser with no expiration date.
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Profiling of Users in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota and Montana
We perform automated processing of your Personal Information to evaluate, analyze, or predict personal aspects related to, for example, your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements. Such profiling activity is done in furtherance of decisions that may result in the provision or denial of, for example, financial or lending services, housing, insurance, education enrollment or opportunity, criminal justice, employment opportunities, healthcare services, or access to essential goods or services.
You always have the right to opt out from this kind of profiling activity. To fully exercise this right to opt out you can contact us at any time, using the contact details provided in this document.
To find out more about your rights and how to exercise them, you can consult the“Your privacy rights under US state laws” section of this document.
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Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
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sessionStorage
sessionStorage allows this Application to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
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Transfer of Data outside of Switzerland based on standard data protection clauses
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland, if such transfer is carried out according to standard data protection clauses previously approved, established or recognized by the Federal Data Protection and Information Commissioner.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by Swiss law. For further information, Users are requested to contact the Owner through the contact details provided in this document.
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Transfer of Data outside of Switzerland based on the Users’ consent
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland if Users consent to such transfer.
When collecting Users’ consent, the Owner makes sure to provide all the information that Users need to make an educated decision and to understand the implications and consequences of providing or denying their consent.
Users may withdraw their consent at any time.
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Transfer of Data outside of Switzerland to third countries that guarantee an adequate level of data protection
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland to a destination country, or international organization guaranteeing an adequate level of protection of the Data according to a decision of the Swiss Federal Council.
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Transfer of personal information outside of Brazil based on contracts and other legal means
We can transfer your personal information outside of the Brazilian territory provided that we are able to ensure that any further processing of your personal information will be in compliance with the principles and the rules established by the LGPD, and your rights are safeguarded.
To do so, we may use one of the following legal means:
specific contractual clauses for each given transfer. This means that we will enter into an agreement with the recipient of your personal information to make sure that such transfers meet the requirements explained above. Such an agreement shall be subject to the ANPD’s prior verification;
standard contractual clauses. These clauses set terms and conditions for the transfer of personal information and are adopted by the ANPD;
global corporate clauses. These clauses set terms and conditions for the transfer of personal information within an organisation and, before they come into force, are subject to the ANPD’s prior verification;
seals of approval, certificates and codes of conduct regularly issued by the ANPD. These legal instruments allow us to transfer your personal information provided that we abide by their rules. They are subject to the previous approval of the ANPD.
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Transfer of personal information outside of Brazil based on your consent
We can transfer your personal information outside of the Brazilian territory if you consent to such transfer.
When we ask for your consent, we’ll make sure to provide all the information that you need to make an educated decision and to understand the implications and consequences of providing or denying your consent.
Such information will be given in clear and plain language and in such a way that you’ll be able to clearly distinguish these requests from other consent requests that we may possibly ask.
You may withdraw your consent at any time.
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Transfer of personal information outside of Brazil to countries that guarantee the same protection standards as LGPD
We can transfer your personal information outside of the Brazilian territory, if the destination country, or the international organization which receives the personal information, provides an adequate level of protection of the personal information according to the ANPD.
The ANPD authorizes such transfers whenever it considers that country to possess and provide personal information protection standards comparable to those set forth by the LGPD, having taken into account the following:
the general and sectoral rules of the legislation in force in the country of destination or in the international organization;
the nature of the personal information subject to the transfer;
the compliance with the general principles on the protection of the personal information and on the rights of the individuals as set forth in the LGPD;
the adoption of suitable security measures;
the existence of judicial and institutional guarantees for the respect of personal information protection rights; and
any other pertinent circumstance related to the relevant transfer.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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User identification via a universally unique identifier (UUID)
This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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We do not collect Personal Information about California consumers below the age of 16
We do not knowingly collect Personal Information of California consumers who are below the age of 16 nor do we Sell or Share it.
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We do not collect Personal Information about Users below the age of 13 in the United States
We do not knowingly collect Personal Information of Users who are below the age of 13 nor do we Sell or process their Information for Targeted Advertising purposes.
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“Do Not Track”
Because there is no legal or industry consensus yet on how “Do Not Track” signals should be recognized or honored, this Application does not support “Do Not Track” requests at this time.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
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Owner and Data Controller
JAPAN 812-0011
Fukuoka prefecture FUKUOKA1-23-2, HAKATAEKIMAE, HAKATA-KUPARK FRONT HAKATAEKIMAE 1 CHOME 5F-B
Owner contact email: eryngii.mori@gmail.com
Full policy
Owner and Data Controller
JAPAN 812-0011
Fukuoka prefecture FUKUOKA1-23-2, HAKATAEKIMAE, HAKATA-KUPARK FRONT HAKATAEKIMAE 1 CHOME 5F-B
Owner contact email: eryngii.mori@gmail.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Trackers; Usage Data; number of Users; session statistics; device information; number of sessions; session duration; operating systems; city; browser information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service; various types of Data; Contacts permission; Phone permission; Call permission; personal data collected from a known child; first name; last name; email address; payment info; geographic position; answers to questions; Universally unique identifier (UUID); password; social media accounts; IP address; ZIP/Postal code; state; county; country; latitude (of city); longitude (of city); metro area; geography/region.
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.
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 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.
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.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Managing contacts and sending messages, Hosting and backend infrastructure, Advertising, Beta Testing, Data transfer outside of the UK, Data transfer outside the EU, Device permissions for Personal Data access, Handling payments, Infrastructure monitoring, Location-based interactions, Managing data collection and online surveys, Platform services and hosting, Registration and authentication and Traffic optimization and distribution.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Call permission
Used for accessing a host of typical features associated with telephony.
Contacts permission
Used for accessing contacts and profiles on the User's device, including the changing of entries.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Unity Ads (Unity Technologies ApS)
Unity Ads is an advertising service provided by Unity Technologies ApS.
Personal Data processed: Trackers; Usage Data.
Place of processing: Denmark – Privacy Policy.
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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.
Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics) with anonymized IP (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Unity Analytics (Unity Technologies ApS)
Unity Analytics is an analytics service provided by Unity Technologies ApS.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Denmark – Privacy Policy.
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Google Analytics for Firebase (for apps) (Google LLC)
Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google LLC.
In order to understand Google's use of Data, consult Google's partner policy.
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner.
This Application uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.
Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: device information; number of sessions; operating systems; session duration; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google Analytics Granular location and device data collection (Google LLC)
Google Analytics on this Application has granular data collection activated which collects location and device data on a per-region basis. It allows the Owner to create and analyze User reports that rely on those metrics.
Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google Analytics Demographics and Interests reports (Google LLC)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
In order to understand Google's use of Data, consult their partner policy and their Business Data page.
Personal Data processed: Trackers; 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: United States – Privacy Policy – Opt Out.
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Beta Testing
This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.
Google Play Beta Testing (Google LLC)
Google Play Beta Testing is a beta testing service provided by Google LLC.
Personal Data processed: Data communicated while using the service; device information; Usage Data.
Place of processing: United States – Privacy Policy.
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Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Call permission; Contacts permission; Phone permission.
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Handling payments
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Google Pay (Google LLC)
Google Pay is a payment service provided by Google LLC, which allows users to make online payments using their Google credentials.
Personal Data processed: email address; first name; last name; payment info; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Hosting and backend infrastructure
This type of service 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 services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Firebase Cloud Firestore (Google LLC)
Firebase Cloud Firestore is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Japan – Privacy Policy.
Amazon S3 (Amazon Web Services, Inc.)
Amazon S3 is a cloud storage service provided by Amazon Web Services, Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Cloud Functions (Google LLC)
Firebase Cloud Functions is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Hosting (Google LLC)
Firebase Hosting is a hosting service provided by Google LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Realtime Database (Google LLC)
Firebase Realtime Database is a hosting and backend service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Firebase Cloud Storage (Google LLC)
Firebase Cloud Storage is a hosting service provided by Google LLC.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
iubenda Accessibility Solution (iubenda srl)
iubenda Accessibility Solution is a service that helps websites to comply with accessibility standards and is provided by iubenda srl.
Personal Data processed: Trackers; Usage Data.
Place of processing: Italy – Privacy Policy.
Vuforia (PTC, Inc)
Vuforia is a hosting and backend service provided by PTC, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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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.
Firebase Performance Monitoring (Google LLC)
Firebase Performance Monitoring is a monitoring service provided by Google LLC.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Geolocation (this Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Personal Data processed: geographic position.
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Managing contacts and sending messages
This type of service 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.
Firebase Notifications (Google LLC)
Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Japan – Privacy Policy.
Firebase Cloud Messaging (Google LLC)
Firebase Cloud Messaging is a message sending service provided by Google LLC. Firebase Cloud Messaging allows the Owner to send messages and notifications to Users across platforms such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or specific topics or User segments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Japan – Privacy Policy.
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Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Customerly Survey (Customerly Ltd.)
Customerly Survey is a survey builder and data collection platform provided by Customerly Ltd.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Google Forms (Google LLC)
Google Forms is a form builder and data collection platform provided by Google LLC.
Personal Data processed: answers to questions; email address; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
App Store Connect (Apple Inc.)
This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage this Application on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of this Application.
App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy.
Google Play Store (Google LLC)
This Application is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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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.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Firebase Authentication (Google LLC)
Firebase Authentication is a registration and authentication service provided by Google LLC.
To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; password; social media accounts.
Place of processing: United States – Privacy Policy.
Adherence to the Google API Services User Data Policy and Limited Use Requirements (this Application)
This Application‘s use or transfer to other apps of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Google OAuth (Google LLC)
Google OAuth is a registration and authentication service provided by Google LLC and is connected to the Google network.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Traffic optimization and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Amazon CloudFront (Amazon Web Services, Inc.)
Amazon CloudFront is a traffic optimization and distribution service provided by Amazon Web Services, Inc.
Personal Data processed: browser information; city; country; county; device information; geography/region; IP address; latitude (of city); longitude (of city); metro area; operating systems; state; Usage Data; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Google Cloud CDN (Google LLC)
Google Cloud CDN is a traffic optimization and distribution service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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Push notifications
This Application may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Application.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Equal protection of User Data
This Application shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
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localStorage
localStorage allows this Application to store and access data right in the User's browser with no expiration date.
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Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
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sessionStorage
sessionStorage allows this Application to store and access data right in the User's browser. Data in sessionStorage is deleted automatically when the session ends (in other words, when the browser tab is closed).
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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User identification via a universally unique identifier (UUID)
This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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“Do Not Track”
Because there is no legal or industry consensus yet on how “Do Not Track” signals should be recognized or honored, this Application does not support “Do Not Track” requests at this time.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Cookie Policy
This Application uses Trackers. To learn more, Users may consult the Cookie Policy.
This section applies to all Users in the European Union, according to the General Data Protection Regulation (the “GDPR”), and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
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 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.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ 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 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 fulfil 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 expiration of the retention period.
The rights of Users based on 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 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 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 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 are also entitled to learn about the legal basis for Data transfers abroad including 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.
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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the condition for Data transfer, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Other legal basis for Data transfer abroad
If no other condition for Data transfer applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under the law of the country that the data originates from;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the condition the transfer is based on via this Application.
Data transfer abroad based on standard contractual clauses
If this is the condition for Data transfer, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer to countries that guarantee European standards
If this is the condition for Data transfer, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Transfer of Personal Data outside of the United Kingdom
Other legal basis for Data transfer abroad (UK)
If no other condition for Data transfer applies, Personal Data shall be transferred from the UK to third countries only if at least one of the following is met:
the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
the transfer is necessary for important reasons of public interest;
the transfer is necessary for establishment, exercise or defence of legal claims;
the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent;
the data transferred is sourced from a public register created under UK law;
subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.
In such cases, the Owner shall inform the User about the condition the transfer is based on via this Application.
Data transfer abroad based on standard contractual clauses (UK)
If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfers according to a UK adequacy regulation
If this is the condition for Data transfer, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.
The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).
Data transfer abroad based on consent (UK)
If this is the condition for Data transfer, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Transfer of Personal Data outside of Switzerland
Transfer of Data outside of Switzerland based on standard data protection clauses
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland, if such transfer is carried out according to standard data protection clauses previously approved, established or recognized by the Federal Data Protection and Information Commissioner.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by Swiss law. For further information, Users are requested to contact the Owner through the contact details provided in this document.
Transfer of Data outside of Switzerland based on the Users’ consent
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland if Users consent to such transfer.
When collecting Users’ consent, the Owner makes sure to provide all the information that Users need to make an educated decision and to understand the implications and consequences of providing or denying their consent.
Users may withdraw their consent at any time.
Transfer of Data outside of Switzerland to third countries that guarantee an adequate level of data protection
If this is the condition for Data transfer, Personal Data can be transferred outside of Switzerland to a destination country, or international organization guaranteeing an adequate level of protection of the Data according to a decision of the Swiss Federal Council.
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) or use other Personal Data (such as the IP Address) for this purpose.
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 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 Processor)
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.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This policy relates solely to this Application, if not stated otherwise within this document.