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Tolivi

First Move Made For You

Privacy Policy

This Application collects some Personal Data from its Users.

This document can be printed for reference by using the print command in the settings of any browser.

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 Data Supervisor)
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 statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

POLICY SUMMARY

  • Access to third-party accounts
    • Facebook account access
      Permissions: About Me; Activities; Age range; Email; Photos; Upload Photos
  • Analytics
    • Google Analytics
      Personal Data: Tracker; Usage Data
  • Beta Testing
    • App Center
      Personal Data: Data communicated while using the service; email address; various types of Data as specified in the privacy policy of the service
    • Google Play Beta Testing
      Personal Data: country; device logs; email address; first name; Tracker; Usage Data
  • Contacting the User
    • Phone contact
      Personal Data: phone number
    • Contact form
      Personal Data: city; country; date of birth; email address; first name; phone number
  • Data transfer outside of the UK
    • Data transfer abroad based on consent (UK), Data transfer abroad based on standard contractual clauses (UK), Data transfers according to a UK adequacy regulation and Other legal basis for Data transfer abroad (UK)
      Personal Data: various types of Data
  • Data transfer outside the EU
    • Data transfer abroad based on consent, Data transfer abroad based on standard contractual clauses, Data transfer to countries that guarantee European standards and Other legal basis for Data transfer abroad
      Personal Data: various types of Data
  • Device permissions for Personal Data access
    • Device permissions for Personal Data access
      Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Calendar permission; Call permission; Camera permission; Contacts permission; Microphone permission; Photo Library permission; Precise location permission (non-continuous); Reminders permission
  • Handling payments
    • Apple Pay
      Personal Data: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; various types of Data as specified in the privacy policy of the service
    • Google Pay
      Personal Data: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Tracker; various types of Data as specified in the privacy policy of the service
    • Stripe
      Personal Data: billing address; email address; first name; last name; payment info; purchase history; various types of Data as specified in the privacy policy of the service
  • Hosting and backend infrastructure
    • Microsoft Azure
      Personal Data: various types of Data as specified in the privacy policy of the service
  • Location-based interactions
    • Geolocation and Non-continuous geolocationPersonal Personal Data: geographic position
  • Platform services and hosting
    • Apple App Store and Google Play Store
      Personal Data: Usage Data
  • Registration and authentication provided directly by this Application
    • Direct registration
      Personal Data: city; country; date of birth; email address; first name; gender; last name; physical address; profile picture
  • Social features
    • Public profile
      Personal Data: city; country; date of birth; email address; first name; gender; last name; physical address; profile picture
    • Inviting and suggesting friends
      Personal Data: various types of Data

Further information about Personal Data

  • Social features
    This Application may request access to your address book.
  • 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.
  • Automated decision-making
    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law. Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.

    The rationale behind the automated decision making is:
    • to enable or otherwise improve the decision-making process;
    • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
    • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
    • to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

Consequences of automated decision-making processes for Users and rights of Users subjected to it

As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken. In particular, Users have the right to:

  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

  • Browser Fingerprinting
    Browser Fingerprinting creates an identifier based on a device’s unique combination of characteristics (e.g. IP address, HTTP header, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User’s browsing behaviour across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.
  • CCPA: Collection of personal information about minors
    We do not knowingly collect personal information of consumers who are below the age of 16.
  • Local Storage
    Local Storage allows this Application to store and access data right in the User’s browser with no expiration date.
  • Personal Data collected through sources other than the User
    The Owner of this Application 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.
  • Push notifications based on the User’s geographic location
    This Application 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 this Application).

    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 this Application or all of the apps on the particular device.

    Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    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.
  • Rights for registered California Users under the age of 18
    California’s “Online Eraser” law, part of California’s Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

    If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

    In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner’s servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
  • The Service is intended for adults
    Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.
  • 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.
  • Unique device identification
    This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

Contact information

Full policy

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Tracker; Usage Data; Data communicated while using the service; email address; first name; country; device logs; phone number; date of birth; city; various types of Data; Calendar permission; Contacts permission; Camera permission; Precise location permission (non-continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Microphone permission; Reminders permission; Photo Library permission; Call permission; last name; payment info; purchase history; billing address; shipping address; geographic position; gender; physical address; profile picture; 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 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 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.

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, based in Ireland, 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 fulfil 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: Access to third-party accounts, Analytics, Beta Testing, Contacting the User, Data transfer outside of the UK, Data transfer outside the EU, Device permissions for Personal Data access, Handling payments, Hosting and backend infrastructure, Location-based interactions, Platform services and hosting, Registration and authentication provided directly by this Application and Social features.

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:

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.

About Me

Provides access to the ‘About Me’ section of the profile.

Activities

Provides access to the User’s list of activities.

Age range

Provides access to the User’s age range.

Email

Provides access to the User’s primary email address.

Photos

Provides access to the photos the User has uploaded, and photos the User has been tagged in.

Upload Photos

Add or modify user’s photos.

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.

Approximate location permission (continuous)

Used for accessing the User’s approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

Approximate location permission (non-continuous)

Used for accessing the User’s approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for this Application to derive the approximate position of the User on a continuous basis.

Calendar permission

Used for accessing the calendar on the User’s device, including the reading, adding and removing of entries.

Call permission

Used for accessing a host of typical features associated with telephony.

Camera permission

Used for accessing the camera or capturing images and video from the device.

Contacts permission

Used for accessing contacts and profiles on the User’s device, including the changing of entries.

Microphone permission

Allows accessing and recording microphone audio from the User’s device.

Photo Library permission

Allows access to the User’s Photo Library.

Precise location permission (non-continuous)

Used for accessing the User’s precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.

The geographic location of the User is determined in a manner that isn’t continuous. This means that it is impossible for this Application to derive the exact position of the User on a continuous basis.

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:

  • 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: About Me; Activities; Age range; Email; Photos; Upload Photos.
    Place of processing: United States – Privacy Policy.
  • Analytics
    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

    Google Analytics

    Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

    Personal Data processed: Tracker; 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 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.

    App Center (Microsoft Corporation)
    App Center is a beta testing service provided by Microsoft Corporation. This Application may also send push notifications to the User.
    Personal Data processed: Data communicated while using the service; email address; 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 the location this Application is accessed from.
    Personal Data processed: country; device logs; email address; first name; Tracker; Usage Data.
    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
  • Contacting the User

    Phone contact (this Application)
    Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
    Personal Data processed: phone number.

    Contact form (this Application)
    By filling in the contact form with their Data, the User authorizes this Application 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: city; country; date of birth; email address; first name; phone number.
  • Data transfer outside of the UK
    The Owner is allowed to transfer Personal Data collected within the UK to third countries only subject to specific legal requirements (so-called “restricted transfers”). Restricted transfers may take place according to the conditions specified below.
    Users can enquire with the Owner to learn which legal basis applies to which specific service.

    Data transfer abroad based on consent (UK) (this Application)
    If this is the legal basis, Personal Data of Users shall be transferred from the UK to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.

    In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
    Personal Data processed: various types of Data.

    Data transfer abroad based on standard contractual clauses (UK) (this Application)
    If this is the legal basis, the transfer of Personal Data from the UK to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.

    This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation, which are recognized as valid also under UK law. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
    Personal Data processed: various types of Data.

    Data transfers according to a UK adequacy regulation (this Application)
    If this is the legal basis, the transfer of Personal Data from the UK to third countries may take place according to a so called “adequacy regulation” of the UK Government.

    The UK Government adopts adequacy regulations for specific countries or territories whenever such countries or territories guarantee Personal Data protection standards comparable to those set forth by UK data protection legislation. Users can find an updated list of all adequacy regulations on the website of the Information Commissioner’s Office (ICO).
    Personal Data processed: various types of Data.

    Other legal basis for Data transfer abroad (UK) (this Application)
    If no other legal basis applies, Personal Data shall be transferred from the UK 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;
  • the data transferred is sourced from a public register created under UK law;
  • subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.

    In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.

    Personal Data processed: various types of Data.
  • 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 (this Application)
    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 this Application.
    Personal Data processed: various types of Data.

    Data transfer abroad based on standard contractual clauses (this Application)
    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 to countries that guarantee European standards (this Application)
    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.

    Other legal basis for Data transfer abroad (this Application)
    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;
  • subject to further conditions, the Owner has a compelling legitimate interest to perform a one-off transfer of Personal Data.

In such cases, the Owner shall inform the User about the legal bases the transfer is based on via this Application.

Personal Data processed: various types of Data.

  • 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: Approximate location permission (continuous); Approximate location permission (non-continuous); Calendar permission; Call permission; Camera permission; Contacts permission; Microphone permission; Photo Library permission; Precise location permission (non-continuous); Reminders permission.
  • Handling payments
    Unless otherwise specified, this Application processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Application isn’t involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

    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: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy.

    Google Pay
    Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on the location this Application is accessed from, which allows users to make online payments using their Google credentials.
    Personal Data processed: billing address; email address; first name; last name; payment info; phone number; purchase history; shipping address; Tracker; various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

    Stripe
    Stripe is a payment service provided by Stripe Inc, Stripe Technology Europe Ltd or by Stripe Payments Ltd, depending on the location this Application is accessed from.
    Personal Data processed: billing address; email address; first name; last name; payment info; purchase history; various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy; Ireland – Privacy Policy; United Kingdom – Privacy Policy.
  • Hosting and backend infrastructure
    This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
    Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Microsoft Azure (Microsoft Corporation)
    Microsoft Azure is a hosting service provided by Microsoft Corporation.
    Personal Data processed: various types of Data as specified in the privacy policy of the service.
    Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; South Africa – Privacy Policy; Australia – Privacy Policy; Switzerland – Privacy Policy; Germany – Privacy Policy; United Kingdom – Privacy Policy; France – Privacy Policy; Canada – Privacy Policy; Netherlands – Privacy Policy; Ireland – Privacy Policy.
  • Location-based interactions
    Geolocation (this Application)
    This Application may collect, use, and share User location Data in order to provide location-based services. Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
    Personal Data processed: geographic position.

    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 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.
  • Platform services and hosting
    These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the
    Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data. Some of these services work through geographically
    distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Apple App Store (Apple Inc.)
    This Application 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 this Application. 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
    This Application 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 this Application 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 provided directly by this Application
    By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

    Direct registration (this Application)
    The User registers by filling out the registration form and providing the Personal Data directly to this Application.
    Personal Data processed: city; country; date of birth; email address; first name; gender; last name; physical address; profile picture.
  • Social features
    Public profile (this Application)
    Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users’ interactions with this Application.
    Personal Data processed: date of birth; email address; first name; gender; geographic position; last name; picture.

    Inviting and suggesting friends (this Application)
    This Application may use the Personal Data provided to allow Users to invite their friends – for example through the address book, if access has been provided – and to suggest friends or connections inside it.
    Personal Data processed: various types of Data.

    Further information about Personal Data
  • Access the address book
    This Application may request access to your address book.
  • 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.
  • Automated decision-making
    Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User’s Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law. Automated decisions are made by technological means –
    mostly based on algorithms subject to predefined criteria – which may also be provided by third parties. The rationale behind the automated decision making is:
  • to enable or otherwise improve the decision-making process;
  • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
  • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
  • to reduce the risk of User’s failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

    Consequences of automated decision-making processes for Users and rights of Users subjected to it
    As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken. In particular, Users have the right to:
  • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
  • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
  • request and obtain from the Owner human intervention on such processing.

    To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
  • Browser Fingerprinting
    Browser Fingerprinting creates an identifier based on a device’s unique combination of characteristics (e.g. IP address, HTTP header, browser properties etc.), that allows to distinguish the User from other Users, thereby enabling to track the User’s browsing behaviour across the web. Browser Fingerprinting does not have an expiration date and cannot be deleted.
  • Local Storage
    Local Storage allows this Application to store and access data right in the User’s browser with no expiration date.
  • Personal Data collected through sources other than the User
    The Owner of this Application 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.
  • Push notifications based on the User’s geographic location
    This Application 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 this Application.
  • Push notifications for direct marketing
  • Push notifications for direct marketing
    This Application 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 this Application).

    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 this Application or all of the apps on the particular device.

    Users must be aware that disabling push notifications may negatively affect the utility of this Application.

    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.
  • Rights for registered California Users under the age of 18

    California’s “Online Eraser” law, part of California’s Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.

    If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.

    In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner’s servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
  • The Service is intended for adults
    Users declare themselves to be adult according to their applicable legislation. Minors may not use this Application.
  • 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.
  • Unique device identification
    This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users’ preferences.

    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 isprocessing 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 honour 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 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.