Privacy Policy of With®

Full policy

Owner and Data Controller

Monaco Group Ltd - 78 York Street, London, United Kingdom, W1H 1DP

Owner contact email: hello@monaco-group.co.uk

Types of Data collected

Among the types of Personal Data that With® collects, by itself or through third parties, there are: Cookies; Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data; first name; last name; gender; date of birth; phone number; address; country; county; email address; city; field of activity; username; password; profile picture; social media accounts ; geographic position; device information; geography/region; number of Users ; number of sessions; session duration; In-app purchases; Application opens; Application updates; first launches; operating systems; Data communicated while using the service; device logs; company name; payment data; app information; picture.

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 With®.
Unless specified otherwise, all Data requested by With® is mandatory and failure to provide this Data may make it impossible for With® to provide its services. In cases where With® 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 With® or by the owners of third-party services used by With® 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, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through With® and confirm that they have the third party's consent to provide the Data to the Owner.

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 With® (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.

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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• 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.

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.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

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

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

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: Advertising, Handling payments, Platform services and hosting, Data transfer outside the EU, Access to third-party accounts, Contacting the User, Analytics, Registration and authentication, Remarketing and behavioral targeting, Hosting and backend infrastructure, Managing contacts and sending messages, Social features, Infrastructure monitoring, Content performance and features testing (A/B testing), Location-based interactions, Tag Management, Beta Testing, SPAM protection, Displaying content from external platforms and Commercial affiliation.

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 With®

With® 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 With® 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:

Basic information

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.

Access private data

Access the User's and friends' private data.

Access Requests

Provides read access to the User's friend requests.

Birthday

Provides access to the birthday.

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.

Share

Share items on the User's behalf.

Upload Photos

Add or modify user's photos.

Detailed information on the processing of Personal Data

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

• Access to third-party accounts

  This type of service allows With® 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 (With®)

  This service allows With® to connect with the User's account on the Facebook social network, provided by Facebook, Inc.

  Permissions asked: Access private data; Access Requests; Birthday; Gender; Photos; Share; Upload Photos.

  Place of processing: United States – Privacy Policy.

• 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 With®, 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 With®. 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 the location With® is accessed from.
  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.

  Facebook Audience Network (Facebook, Inc.)

  Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

  With® may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

  Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

  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.

  Facebook Lookalike Audience (Facebook, Inc.)

  Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of With® or engagement with relevant content across the Facebook apps and services.
  On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.

  Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Google Ad Manager

  Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
  This service uses the “DoubleClick” Cookie, which tracks use of With® and User behavior concerning ads, products and services offered.  

  Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Google Ads Similar audiences

  Similar audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of With®.
  On the basis of this Data, personalized ads will be shown to Users suggested by Google Ads Similar audiences.

  Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers 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.

  Google AdSense

  Google AdSense is an advertising service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from. This service uses the “DoubleClick” Cookie, which tracks use of With® 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.

• 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.

  Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.)

  Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on With®. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

  Facebook Analytics for Apps (Facebook, Inc.)

  Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.

  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.

  Google Ads conversion tracking

  Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that connects data from the Google Ads advertising network with actions performed on With®.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Google Analytics

  Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of With®, 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.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  Google Analytics Advertising Reporting Features

  Google Analytics on With® 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.

  Personal Data processed: Cookies; 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; Ireland – Privacy Policy – Opt Out.

  Google Analytics Demographics and Interests reports

  Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for With® (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: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  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 the location With® is accessed from.
  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.

  With® 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 opens; 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.

  Google Analytics with anonymized IP

  Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of With®, 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.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

• Beta Testing

  This type of service makes it possible to manage User access to With®, 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 With® in a personally identifiable form.

  Google Play Beta Testing

  Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  Personal Data processed: Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  TestFlight (Apple Inc.)

  TestFlight is a beta testing service provided by Apple Inc.

  Personal Data processed: app information; Cookies; country; Data communicated while using the service; date of birth; device information; device logs; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data as specified in the privacy policy of the service.

  Place of processing: United States – Privacy Policy.

• Commercial affiliation

  This type of service allows With® to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
  Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with With®.
  For details of which data are collected, please refer to the privacy policy of each service.

  iTunes affiliation (Apple Inc.)

  iTunes affiliation is a commercial affiliation service provided by Apple Inc.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Contacting the User

  Contact form (With®)

  By filling in the contact form with their Data, the User authorizes With® to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data processed: address; city; country; county; date of birth; email address; field of activity; first name; gender; last name; phone number.

  Phone contact (With®)

  Users that provided their phone number might be contacted for commercial or promotional purposes related to With®, as well as for fulfilling support requests.

  Personal Data processed: phone number.

• Content performance and features testing (A/B testing)

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of With®.

  Firebase Remote Config

  Firebase Remote Config is an A/B testing and configuration service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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.

  Google Optimize

  Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, ("Google").

  Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

• Data transfer outside the EU

  The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
  Users can inquire with the Owner to learn which legal basis applies to which specific service.

  Data transfer abroad based on consent (With®)

  If this is the legal basis, 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 With®.

  Personal Data processed: various types of Data.

  Data transfer abroad based on standard contractual clauses (With®)

  If this is the legal basis, 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.

  Personal Data processed: various types of Data.

  Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (With®)

  If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
  In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
  Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.

  Personal Data processed: various types of Data.

  Data transfer to countries that guarantee European standards (With®)

  If this is the legal basis, 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.

  Personal Data processed: various types of Data.

• Displaying content from external platforms

  This type of service allows you to view content hosted on external platforms directly from the pages of With® 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.

  Instagram widget (Instagram, Inc.)

  Instagram is an image visualization service provided by Instagram, Inc. that allows With® to incorporate content of this kind on its pages.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy.

• Handling payments

  Unless otherwise specified, With® 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. With® 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.

  Android Pay

  Android Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, 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; Ireland – Privacy Policy.

  Google Pay

  Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, which allows users to make online payments using their Google credentials.

  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.

  Payments processed via the Apple App Store (Apple Inc.)

  With® uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.

  Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

  Personal Data processed: payment data.

  Place of processing: United States – Privacy Policy.

  Payments processed via the Google Play Store

  With® uses a payment service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that allows the Owner to offer the purchase of the app itself or in-app purchases.

  Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.

  Personal Data processed: payment data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

• Hosting and backend infrastructure

  This type of service has the purpose of hosting Data and files that enable With® to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of With®.

  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

  Firebase Cloud Firestore is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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; Ireland – Privacy Policy.

  Firebase Cloud Functions

  Firebase Cloud Functions is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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; Ireland – Privacy Policy.

  Firebase Cloud Storage

  Firebase Cloud Storage is a hosting service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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; Ireland – Privacy Policy.

  Firebase Hosting

  Firebase Hosting is a hosting service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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.

  Firebase Realtime Database

  Firebase Realtime Database is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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; Ireland – Privacy Policy.

  Google App Engine (Google LLC)

  Google App Engine 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; United Kingdom – Privacy Policy; Germany – Privacy Policy.

  Google Cloud Storage (Google LLC)

  Google Cloud Storage 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; United Kingdom – Privacy Policy.

  SiteGround Hosting (SiteGround Hosting Ltd.)

  SiteGround Hosting is a hosting service provided by SiteGround Hosting Ltd.

  Personal Data processed: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.

  Place of processing: United Kingdom – Privacy Policy.

• Infrastructure monitoring

  This type of service allows With® 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 With®.

  Firebase Performance Monitoring

  Firebase Performance Monitoring is a monitoring service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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.

• Location-based interactions

  Geolocation (With®)

  With® 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 With®.

  Personal Data processed: geographic position.

• 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 Cloud Messaging

  Firebase Cloud Messaging is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from. 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: United States – Privacy Policy; Ireland – Privacy Policy.

  Firebase Notifications

  Firebase Notifications is a message sending service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from. 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.

  Mailchimp (The Rocket Science Group LLC)

  Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.

  Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data.

  Place of processing: United States – Privacy Policy.

• Platform services and hosting

  These services have the purpose of hosting and running key components of With®, therefore allowing the provision of With® 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.

  Apple App Store (Apple Inc.)

  With® is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

  By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of With®. 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.

  Google Play Store

  With® is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.

  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; Ireland – Privacy Policy.

• Registration and authentication

  By registering or authenticating, Users allow With® 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, With® 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.

  Firebase Authentication

  Firebase Authentication is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from. 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; first name; last name; password; phone number; profile picture; social media accounts ; username.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  Google OAuth

  Google OAuth is a registration and authentication service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, 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.

  Instagram Authentication (Instagram, Inc.)

  Instagram Authentication is a registration and authentication service provided by Instagram, Inc. and is connected to the Instagram 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.

• Remarketing and behavioral targeting

  This type of service allows With® and its partners to inform, optimize and serve advertising based on past use of With® 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 Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of With® with the Facebook advertising network.

  Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.

  Personal Data processed: Cookies; email address.

  Place of processing: United States – Privacy Policy – Opt Out.

  Facebook Remarketing (Facebook, Inc.)

  Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of With® with the Facebook advertising network.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out.

  Google Ad Manager Audience Extension

  Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that tracks the visitors of With® and allows selected advertising partners to display targeted ads across the web to them.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy – Opt Out; Ireland – 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 the location With® is accessed from, that connects the activity of With® 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.

• Social features

  Firebase Dynamic Links

  Firebase Dynamic Links is a social feature provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from. 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 With®.

  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.

  Firebase Invites

  Firebase Invites is a social feature provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from, that enables Users to share With®. The sharing may contain referral codes, or content from within With® and may be done via email or SMS. Sharing is tracked with Google Analytics for Firebase, which informs the Owner that the User has opened or installed With® via invite.

  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.

  Public profile (With®)

  Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with With®.

  Personal Data processed: first name; gender; picture; username.

• SPAM protection

  This type of service analyzes the traffic of With®, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.

  Google reCAPTCHA

  Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on the location With® is accessed from.
  The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

  Personal Data processed: Cookies; Usage Data.

  Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

• Tag Management

  This type of service helps the Owner to manage the tags or scripts needed on With® 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 the location With® is accessed from.

  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

• 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 With® only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use With®.

• Push notifications for direct marketing

  With® may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by With®).

  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 changing those settings for With® or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of With®.

  Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

• Push notifications based on the User's geographic location

  With® may use the User's geographic location to send push notifications for 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 changing those settings for some or all of the apps on the particular device.

  Users must be aware that disabling push notifications may negatively affect the utility of With®.

• Push notifications

  With® 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 With®, some or all of the apps on the particular device.
  Users must be aware that disabling push notifications may negatively affect the utility of With®.

• Personal Data collected through sources other than the User

  The Owner of With® may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
  Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

The rights of Users

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

In particular, Users have the right to do the following:

• 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. Further details are provided in the dedicated section below.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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 without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

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 With® 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, With® 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, With® and any third-party services may collect files that record interaction with With® (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

With® does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

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 With® 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.