Privacy Policy

of this Application

Owner and Data Controller

Samuele Mancuso

Via Caio Duilio 25B – Catanzaro (CZ) 88100, Italy

Owner contact email: work.s.mancuso95@gmail.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: Usage Data; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); approximate device location (where applicable and only if granted by the User); device information; application diagnostics and crash data; preferences and settings; and any vehicle-related information voluntarily entered by the User into the Application (such as make, model, registration year, odometer readings, fuel consumption, maintenance logs, photographs and notes).

This vehicle-related content is treated as User-generated content and is stored, by default, locally on the User's device. Where iCloud sync is enabled by the User through the device settings, such content may also be stored within the User's personal iCloud account, which is operated by Apple Inc. and to which the Owner has no access.

Complete details on each category 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.

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.

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

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligations or based on the Users' consent.

Therefore:

•   Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.

•   Personal Data collected for the purposes of the Owner's legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

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

The 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:

•   Providing the core functions of the Application: storing and displaying the User's vehicles, fuel refills, maintenance logs and reminders;

•   Sending local push notifications to remind the User of upcoming or overdue maintenance procedures;

•   Improving the Application through anonymous usage analytics and crash reporting;

•   Hosting and backend infrastructure where applicable;

•   Managing User-initiated communications with the Owner;

•   Complying with applicable laws.

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".

Detailed information on the processing of Personal Data

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

Application data storage

The Application stores User-generated content (vehicle profiles, refuel records, maintenance entries, photos, notes and similar) locally on the User's device. Where the User enables iCloud synchronization through the device's system settings, this content is additionally stored in the User's personal iCloud account managed by Apple Inc. The Owner does not have access to the content stored in the User's iCloud account.

Personal Data processed: vehicle data, fuel logs, maintenance records, photos and any other content voluntarily entered by the User.

Place of processing: User's device; where iCloud sync is enabled, Apple's data centers (see Apple's privacy policy at https://www.apple.com/legal/privacy/).

Notifications (push and local)

This Application may ask the User for permission to send local notifications, in order to remind the User of upcoming or overdue maintenance procedures. Notifications are scheduled and delivered locally on the device and do not, by themselves, transmit content to the Owner.

Personal Data processed: notification permission status; reminder schedules created by the User.

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 in an aggregated and anonymized manner. Analytics tools, where used, are configured to collect Usage Data without identifying the individual User.

Personal Data processed: Usage Data; device information; app interaction events; approximate region (derived from IP).

Place of processing: as determined by the relevant analytics provider; see provider documentation for transfer mechanisms.

Crash reporting and diagnostics

This Application may collect crash logs and diagnostic information when the App unexpectedly terminates or behaves unexpectedly, to identify and resolve bugs. Where Apple's standard crash reporting service is used (Xcode/TestFlight/App Store Connect), the User may opt in or out via the device's privacy settings ("Share with App Developers").

Personal Data processed: device model; OS version; stack traces; technical diagnostic identifiers.

Place of processing: Apple Inc., United States.

Contacting the User

When the User contacts the Owner via email or any contact method made available, the Owner processes the contact details and the content of the message in order to reply.

Personal Data processed: email address; first name; last name; the content of the User's message.

Place of processing: Italy and any other location where the email service provider is located.

Cookie Policy

This Application is a native mobile application and does not use HTTP cookies in the manner of a website. However, similar local storage technologies (such as application caches, the iOS keychain, UserDefaults and CoreData/SwiftData on-device databases) may be used to store information necessary to the operation of the Service, such as User preferences, session tokens or cached data.

Where third-party SDKs (e.g., analytics or crash reporting) make use of identifiers stored locally on the device, those identifiers are subject to Apple's App Tracking Transparency framework and the User is asked for consent before any cross-app tracking can occur.

The rights of Users based on the General Data Protection Regulation (GDPR)

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

In particular, Users have the right to do the following, to the extent permitted by law:

•   Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.

•   Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.

•   Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.

•   Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.

•   Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.

•   Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.

•   Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.

•   Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform them about those recipients.

Further information for Users in the United Kingdom

This section applies to Users in the United Kingdom and supplements – or where in conflict, replaces – the information provided elsewhere in this privacy policy. Following the United Kingdom's withdrawal from the European Union, the General Data Protection Regulation has been incorporated into UK domestic law as the "UK GDPR" and is applied alongside the Data Protection Act 2018.

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

•   Users have given their consent for one or more specific purposes;

•   provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

•   processing is necessary for compliance with a legal obligation to which the Owner is subject;

•   processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;

•   processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Rights of Users under the UK GDPR

Users in the United Kingdom enjoy substantially the same rights as Users in the European Union (right of access, rectification, erasure, restriction, portability, objection, withdrawal of consent, automated decision-making safeguards). Users may also lodge a complaint with the Information Commissioner's Office (ICO) at https://ico.org.uk.

Further information for Users in Switzerland

This section applies to Users in Switzerland, and for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details concerning the categories of Data processed, the purposes of processing, the categories of recipients of personal data, if any, the retention period and other information about Personal Data can be found in the section titled "Detailed information on the processing of Personal Data" within this document.

Rights of Users under the Swiss Federal Act on Data Protection

Users may exercise certain rights regarding their Data within the limits of the law, including the following:

•   right of access to Personal Data;

•   right to object to the processing of their Personal Data (which also allows Users to demand restriction of the processing of Personal Data, its erasure or destruction, the prohibition of disclosure of Personal Data to third parties);

•   right to receive their Personal Data and to transmit it to another controller (data portability);

•   right to ask for incorrect Personal Data to be rectified.

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible, providing Users with the information required by law.

Further information for Users in Brazil

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "we", "us", "our").

This section applies to all Users in Brazil ("you", "yours"), pursuant to the "Lei Geral de Proteção de Dados" (the "LGPD"), and for such Users, it supersedes any other possibly divergent or conflicting information contained in this privacy policy.

Grounds on which we process your personal information

We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:

•   your consent to the relevant processing activities;

•   compliance with a legal or regulatory obligation that lies with us;

•   the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;

•   studies conducted by research entities, preferably carried out on anonymized personal information;

•   the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;

•   the exercising of our rights in judicial, administrative or arbitration procedures;

•   protection or physical safety of yourself or a third party;

•   the protection of health – in procedures carried out by health entities or professionals;

•   our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and

•   credit protection.

Your privacy rights as a Brazilian User, how to file a request and our response to your requests

You have the right to:

•   obtain confirmation of the existence of processing activities on your personal information;

•   access your personal information;

•   have incomplete, inaccurate or outdated personal information rectified;

•   obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;

•   obtain information about the possibility to provide or deny our consent and the consequences thereof;

•   obtain information about the third parties with whom we share your personal information;

•   be granted, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;

•   obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;

•   withdraw your consent at any time;

•   file a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;

•   oppose processing activities in cases where the processing is not carried out in compliance with the provisions of the law;

•   request clear and adequate information regarding the criteria and procedures used for an automated decision; and

•   request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests.

You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.

How to file your request

You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.

How and when we will respond to your request

We will strive to promptly respond to your requests.

In any case, should it be impossible for us to do so, we'll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so.

In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you'd like your personal information to be delivered in electronic or printed form. You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we'll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets.

Transfer of personal information outside of Brazil permitted by the law

We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:

•   when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by international law;

•   when the transfer is necessary to protect your life or physical security or those of a third party;

•   when the transfer is authorized by the ANPD;

•   when the transfer results from a commitment undertaken in an international cooperation agreement;

•   when the transfer is necessary for the execution of a public policy or legal attribution of public service;

•   when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.

Further information for Users in Canada

This section applies to Users resident in Canada and supplements – or where in conflict, replaces – the information provided elsewhere in this privacy policy. Personal Information of Users in Canada is processed in accordance with the Personal Information Protection and Electronic Documents Act ("PIPEDA") and, where applicable, with provincial privacy legislation including Quebec's Act respecting the protection of personal information in the private sector ("Law 25").

Rights of Users in Canada

Users in Canada have the right to:

•   be informed of the existence, use and disclosure of their Personal Information;

•   access their Personal Information held by the Owner and to challenge its accuracy and completeness;

•   withdraw their consent at any time, subject to legal or contractual restrictions and reasonable notice;

•   file a complaint with the Office of the Privacy Commissioner of Canada (https://www.priv.gc.ca) or, where applicable, with the relevant provincial authority (such as the Commission d'accès à l'information du Québec).

Quebec residents additionally enjoy the right to data portability and the right to be informed of any automated processing used to render a decision affecting them, in accordance with Law 25.

Cross-border transfers

Users in Canada acknowledge that their Personal Information may be transferred to, processed and stored outside of Canada, including in the European Union and the United States, where the Owner and its service providers operate. The Owner takes appropriate measures to ensure that Personal Information transferred internationally is protected to a standard comparable to that required under Canadian privacy legislation.

Further information for Users in Australia

This section applies to Users resident in Australia and supplements the information provided elsewhere in this privacy policy. Personal Information of Users in Australia is handled in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles ("APPs").

Users may request access to, or correction of, their Personal Information by contacting the Owner using the details provided in this document. Users who believe that the Owner has breached an Australian Privacy Principle may lodge a complaint with the Office of the Australian Information Commissioner (https://www.oaic.gov.au). The Owner will respond to any such complaint within a reasonable time, generally within 30 days.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as "we", "us", "our").

The information contained in this section applies to all Users ("you", "your", "yours") who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana. For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

Notice at collection

The Notice at collection in this section provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

To know more about your rights you can refer to the "Your privacy rights under US state laws" section of this privacy policy. For more details on the collection of Personal Information, please read the section "Detailed information on the processing of Personal Data" of this privacy policy.

We won't process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your Personal Information when you submit requests via any forms in this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

•   the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;

•   the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;

•   the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;

•   the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;

•   the right to opt out from the Sale of your Personal Information;

•   the right to non-discrimination. We will not discriminate against you for exercising your privacy rights.

Additional rights for Users residing in California

In addition to the rights listed above, as a User residing in California, you have:

•   the right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;

•   the right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above, as a User residing in these states, you have:

•   the right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;

•   the right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland, Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data.

Note that in some states like Minnesota, you have the following specific rights connected to profiling:

•   the right to question the results of the profiling;

•   the right to be informed of the reason that the profiling resulted in the decision; if feasible;

•   the right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;

•   the right to review personal data used in the profiling;

•   if inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data.

Additional rights for Users residing in Utah and Iowa

In addition to the rights listed above, as a User residing in Utah and Iowa, you have:

•   the right to opt out of the processing of your Personal Information for Targeted Advertising;

•   the right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link, where provided, on this Application.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as the Global Privacy Control ("GPC"), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Further information for Users in other regions

Where this Application is made available to Users in jurisdictions not specifically addressed in the previous sections, the Owner is committed to processing Personal Data in accordance with the principles of fairness, lawfulness, transparency, purpose limitation, data minimization, accuracy and security set forth in the General Data Protection Regulation.

In particular, the Owner endeavors to honor – within the limits of applicable law – the rights of access, rectification, erasure, restriction, portability and objection in respect of all Users, regardless of their place of residence.

Users who reside in jurisdictions with their own data-protection legislation (including but not limited to the United Kingdom, Japan, South Korea, India, Singapore, South Africa, Mexico and Argentina) may exercise the rights granted under their applicable local law by contacting the Owner using the details provided in this document.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

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 "Do Not Track" requests, please read their privacy policies.

Children

This Application is not intended for use by children under the age of 13 (or other equivalent minimum age depending on jurisdiction). The Owner does not knowingly collect Personal Data from children. If the Owner becomes aware that Personal Data has been collected from a child without verifiable parental consent, the Owner will take steps to delete such information.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User's consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

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.

Sensitive Personal Information

Sensitive Personal Information means all Personal Information that is not publicly available and which reveals information considered as sensitive under applicable privacy legislation.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable US state privacy legislation. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set forth by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy legislation. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set forth by the California privacy legislation, does not constitute Sharing of your Personal Information.

Targeted Advertising

Targeted Advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer's activities over time and across nonaffiliated websites or online applications to predict such consumer's preferences or interests, as defined by the applicable US state privacy legislation.

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.

Legal information

This privacy policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (GDPR).

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: 6 May 2026