2. TYPES OF DATA COLLECTED
2.1 Among the types of Personal Data that the Company collects, by itself or through third parties, there are: Cookies; Usage Data; email address; ZIP/Postal code; city; first name; last name; date of birth; phone number; address; password; country; picture; User ID; geographic position; various types of Data. We may collect this information through various forms and in various places such as Our Platform, including when You access the Platform, when You first register with Us, when You create a transaction, when You contact Us, when You update Your information or when You otherwise interact with Us, by, for example, way of telephone, letter or in person.
2.2 Unless specified otherwise, all Data requested by the Company is mandatory and failure to provide this Data may make it impossible for the Company to provide its services. In cases where the Company 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.
2.3 Users who are uncertain about which Personal Data is mandatory are welcome to contact the Company.
2.5 We process the data collected through cookies either independently or with third party service providers, who analyze the data collected through cookies pursuant to contractual relationships with Us. The processing of such data is done to analyze the pages a User visits on the Platform, which Platforms a User has visited before coming to the Platform, and where a User goes after leaving the Platform. The Usage Information and/or the Personal Information may be combined for marketing and for market research purposes, including internal demographic studies, so that we can optimize our products and Services and customize the Platform for You and for the purpose of providing Our Services
2.6 Users are responsible for any third-party Personal Data obtained, published or shared through the Company and confirm that they have the third party’s consent to provide the Data to the Company.
2.7 In the event You provide Personal Data belonging to a third party, You shall ensure that due consent has been procured from such third party for providing their Personal Information for further sharing and processing by the Company. You shall ensure that such consent is documented and can be provided, if required by the Company. The Company disclaims all liability arising out of any unauthorized sharing or processing of any Personal Information belonging to a third party and You agree to indemnify and hold the User harmless against any third party claims which arise out of such unauthorized sharing and processing of Personal Information belonging to a third party.
3. MODE OF PROCESSING THE DATA
3.1 Methods of processing
3.1.1 The Company takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
3.1.2 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 Company, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the Company (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 Company. The updated list of these parties may be requested from the Company at any time. We aim to protect the Personal Information by i) only sharing and providing access to Personal Information to the minimum extent necessary, subject to appropriate contractual restrictions including confidentiality restrictions where appropriate, and on an anonymized basis wherever possible; (ii) using secure servers to store Personal Information; (iii) verifying the identity of any individual who requests access to Personal Information prior to granting them access to such information; and (iv) using Secure Sockets Layer (SSL) software or other similar encryption technologies to encrypt any payment transactions You make on or via our Platform.
4. LEGAL BASIS OF PROCESSING
4.2 The Company 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 Company 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 Company;
- processing is necessary for the purposes of the legitimate interests pursued by the Company or by a third party.
- In any case, the Company 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.
5. RETENTION TIME
5.1 Personal Data shall be processed and stored for as long as required by the purpose they have been collected for or to comply with applicable laws. Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Company and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Company’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 Company within the relevant sections of this document or by contacting the Company.
5.2 The Company 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 Company 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.
5.3 Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
6. THE PURPOSES OF PROCESSING
6.2 We will communicate with You using the contact information provided in order to respond to any queries that You may have, to provide any information requested regarding the Services or to send marketing and promotional material on our Services. You can choose to opt out of receiving such promotional and marketing communications by sending us an email at [●]. We may also use Your Personal Information to send You information in relation to our Services based on the analysis of the Usage Information collected. We may also send strictly service-related announcements, for instance, if our Services are temporarily suspended for maintenance, we may send You an email, text message, flash notification or telephone call. If You do not wish to receive such alerts, You have the option to unsubscribe from such emails or opt out by sending an email to [●].
6.3 We, our business partners, affiliates or third party service providers may use Personal Information or Usage Information collected in the following ways:
- to operate and improve the Platform and tools associated with the Platform;
- to create aggregated and anonymized information to determine which Platform features are most popular and useful to Users, and for other statistical analyses;
- to customize the content or the Services on the Platform for You, or the communications sent to You through the Platform;
- to provide You the Services;
- to improve our ability to provide You the Services;
- to observe, improve and administer the quality of Services;
- to analyse how the Platform is used, diagnose technical problems;
- to remember the basic information provided by You for effective access;
- to confirm Your identity in order to determine Your eligibility to use the Platform and avail the Services;
- to notify You about any changes to the Platform;
- to transmit, share or transfer the data to a group company or affiliate of Us to enable such group company or Affiliate to provide You with the Services;
- to enable Us to comply with Our legal and regulatory obligations;
- for the purpose of sending administrative notices, Service related alerts and other similar communication with a view to optimizing the efficiency of the Platform;
- to do market research, troubleshooting or project planning,
- to protect against errors, fraud and other criminal activity; and
6.6 We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, store, transfer and disclose Your information (including Personal Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate: (i) to satisfy any applicable law, regulation, governmental requests or legal process; (ii) to protect the safety, rights, property or security of the Company, our Services, the Platform or any third party; (iii) to protect the safety of the public for any reason; (iv) to detect, prevent or otherwise address fraud, security or technical issues; and /or (v) to prevent or stop any activity we consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Such disclosures may be carried out without notice to You.
6.7 We may share Your information, including Your Personal Information and Usage Information with our parent, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information: (i) to a subsequent Company, co-Company or operator of the Platform or applicable database; or (ii) in connection with a corporate merger, consolidation, restructuring, the sale of substantially all of our membership interests and/or assets or other corporate change, including, during the course of any due diligence process. You will be notified via email and/or through a prominent notice on the Platform of any change in uses of Your Personal Information, as well as any choices You may have regarding Your Personal Information.
6.9 The Platform may contain content that is supplied by a third party, and those third parties may collect Platform usage information and other information when web pages from any online or mobile services are provided to Your browser. In addition, when You are using the Platform, You may be directed to other Platforms that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. These other Platforms may send their own cookies to You, independently collect data or solicit Personal Information and may or may not have their own published privacy policies. When You leave the Platform, we encourage You to read the privacy statements of all third party Platforms before submitting any information to third parties.
6.10 Should you require detailed information on the nature of data processed for a particular purpose, please reach out to us at [●].
7. CHILDREN’S PRIVACY
7.1 Protecting the privacy of young children is especially important. For that reason, We do not knowingly collect or solicit Personal Information from anyone under the age of 13.
7.2 In the event that we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible.
7.3 If You believe that we might have any information from or about a child under 13, please contact us at [●].
8. OPT IN/OPT OUT
8.1 If You wish to specifically opt for receiving non-essential communications such as promotional and marketing-related information regarding the Company, the Platform and the Services, please send the Company an email at [●].
8.2 If you wish to specifically opt out of providing consent for collection or processing of Personal Information, please send the Company an email at [●]. Please note that if you choose to opt out of providing Personal Information or restrict the Company from processing the Personal Information, the Company may not be able to provide the Services or may provide the Services in a limited manner.
9. DATA TRANSFER
9.1 Your Personal Information collected through the Platform may be stored and processed in India or any other country in which We or Our subsidiaries, affiliates or service providers maintain facilities. We may transfer information that We collect about You, including Personal Information, to affiliated entities, or to other third parties across borders and from Your country or jurisdiction to other countries or jurisdictions around the world. If Your Personal Information is transferred to another country, We will ensure that, where those countries are not deemed to have adequate protection, We have signed agreements incorporating the Model Contract Clauses to ensure the adequate protection of Your Personal Information.
10. THE RIGHTS OF USERS
10.1 Users may exercise certain rights regarding their Data processed by the Company. 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 Company, 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 Company 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 Company.
- 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.
- opt out of receiving any promotional or marketing material by clicking on the “Unsubscribe” button or by sending an email to [●]. Please note that if You withdraw Your consent, this will not affect the lawfulness of our use and processing of Your information if such processing is based on another lawful basis other than consent;
- 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 Company or for the purposes of the legitimate interests pursued by the Company, Users may object to such processing by providing a ground related to their particular situation to justify the objection
10.2 Generally, we do not rely on consent as a legal basis for processing Your Personal Information other than in relation to sending third party direct marketing communications to You via email or text message. You have the right to withdraw Your consent to marketing at any time by contacting us at [●].
10.3 Any requests to exercise User rights can be directed to the Company through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Company as early as possible and always within one month.
11. LEGAL ACTION
11.1 The User’s Personal Data may be used for legal purposes by the Company in court or in the stages leading to possible legal action arising from improper use of the Company or the related Services. The User declares to be aware that the Company may be required to reveal personal data upon request of public authorities.
12. ADDITIONAL INFORMATION ABOUT USER’S PERSONAL DATA
13. INFORMATION NOT CONTAINED IN THIS POLICY
13.1 More details concerning the collection or processing of Personal Data may be requested from the Company at any time. Please see the contact information at the beginning of this document.
14. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
14.1 The Company does not support “Do Not Track” requests.
14.2 To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
15.2 Should the changes affect processing activities performed on the basis of the User’s consent, the Company shall collect new consent from the User, where required.