privacy Policy of

In order to receive information about your Personal Data, the
purposes and the parties the Data is shared with, contact the Owner.

Owner and Data Controlle

Types of Data collected

The owner does not provide a list of Personal Data types collected.

Complete details on each type of Personal Data collected are provided
in the dedicated sections of this privacy policy or by specific
explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage
Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is
mandatory and failure to provide this Data may make it impossible for
this Application to provide its services. In cases where this
Application specifically states that some Data is not mandatory, Users
are free not to communicate this Data without consequences to the
availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or
by the owners of third-party services used by this Application serves
the purpose of providing the Service required by the User, in addition
to any other purposes described in the present document and in the
Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained,
published or shared through this Application 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
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.

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.


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.


  • 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 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.

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
  • 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 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) 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

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

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy
at any time by giving notice to 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

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.