Policy summary
Personal Data processed for the following purposes and using the following services:
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Access to third-party accounts
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Advertising
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AdMob
Personal Data: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
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Google AdSense
Personal Data: Cookies; Usage Data
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Analytics
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Google Analytics for Firebase
Personal Data: Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data
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AWStats and MixPanel
Personal Data: Cookies; Usage Data
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Beta Testing
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TestFlight
Personal Data: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; various types of Data as specified in the privacy policy of the service
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Google Play Beta Testing
Personal Data: country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; username; various types of Data as specified in the privacy policy of the service
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Data transfer outside the EU
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Device permissions for Personal Data access
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Displaying content from external platforms
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Hosting and backend infrastructure
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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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Registration and authentication
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Remarketing and behavioral targeting
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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 follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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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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Push notifications
This Application may send push notifications to the User.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.
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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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Owner and Data Controller
GetMegaFlip SRL, 196G / 2, Utvin, Timis, Romania
Owner contact email: privacy@ctrlbody.com
Full policy
Owner and Data Controller
GetMegaFlip SRL, 196G / 2, Utvin, Timis, Romania
Owner contact email: privacy@ctrlbody.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application updates; first launches; operating systems; email address; first name; last name; country; gender; date of birth; city; various types of Data; Calendar permission; Camera permission; Reminders permission; Health Data read permission; movement activity; body measurements & indexes; food related activity ; geographic position; Data communicated while using the service; app information; device logs; username.
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.
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, Access to third-party accounts, Registration and authentication, Remarketing and behavioral targeting, Advertising, Hosting and backend infrastructure, Contacting the User, Data transfer outside the EU, Device permissions for Personal Data access, Displaying content from external platforms, Handling activity data, Handling payments, Infrastructure monitoring, Location-based interactions, Managing contacts and sending messages, Social features, SPAM protection, Tag Management and Beta Testing.
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”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Birthday
Provides access to the birthday.
Current City
Provides access to the User's current location.
Email
Provides access to the User's primary email address.
Fitness Actions
Shows the User's workout with the app.
Gender
Provides access to the User's gender.
Photos
Provides access to the photos the User has uploaded, and photos the User has been tagged in.
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.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Camera permission
Used for accessing the camera or capturing images and video from the device.
Health Data read permission
Allows reading the User’s health Data.
Reminders permission
Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.
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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Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Birthday; Current City; Email; Fitness Actions; Gender; Photos.
Place of processing: United States – Privacy Policy.
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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.
AdMob
AdMob is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy.
Google AdSense
Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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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 for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
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: Application updates; Cookies; device information; first launches; geography/region; In-app purchases; number of sessions; number of Users ; operating systems; session duration; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
AWStats (this Application)
AWStats is an analytics software used by this Application to analyze Data directly without the help of third parties.
The User can disable the collection of this statistical information by turning off JavaScript in their web browser. However, this action may negatively affect the User's navigation experience on this Application as well as other applications.
Personal Data processed: Cookies; Usage Data.
MixPanel (MixPanel)
MixPanel is an analytics service provided by Mixpanel Inc.
Personal Data processed: Cookies; Usage Data.
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.
TestFlight (Apple Inc.)
TestFlight is a beta testing service provided by Apple Inc.
Personal Data processed: app information; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Play Beta Testing
Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; username; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Contacting the User
Mailing list or newsletter (this Application)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: city; country; date of birth; email address; first name; gender; last name.
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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: Calendar permission; Camera permission; Health Data read permission; Reminders permission.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Spotify widget (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: Sweden – Privacy Policy.
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Handling activity data
This type of service allows the Owner to use the activity data collected by your device in order for this Application to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings.
Depending on what is described below, third parties may be involved in the activity tracking.
Most devices allow for the User to control which Data is accessed or stored.
Apple HealthKit (Apple Inc.)
HealthKit is an activity data handling service provided by Apple Inc. that enables the Owner to access or store activity data.
Personal Data processed: body measurements & indexes; date of birth; food related activity ; gender; movement activity.
Place of processing: United States – Privacy Policy.
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Handling payments
Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
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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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 of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
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: Germany – 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
Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Location-based interactions
Non-continuous 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.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
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
Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. 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: United States – Privacy Policy; Ireland – Privacy Policy.
GetResponse (Implix Sp. z o.o.)
GetResponse is an email address management and message sending service provided by Implix Sp. z o.o.
Personal Data processed: email address; first name; last name; username.
Place of processing: Poland – 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.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google OAuth
Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Social features
Firebase Dynamic Links
Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within this Application.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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SPAM protection
This type of service analyzes the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic 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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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – 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 follow the instructions provided by
YourOnlineChoices (EU),
the Network Advertising Initiative (US) and
the Digital Advertising Alliance (US),
DAAC (Canada),
DDAI (Japan)
or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document.
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.
Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Further information about the processing of Personal Data
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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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Push notifications
This Application may send push notifications to the User.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.
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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.
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
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions 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.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.
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 privacy policy relates solely to this Application, if not stated otherwise within this document.