Privacy Policy of com.rellowteam.kakebo2

This Application collects some Personal Data of its Users.

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Owner and Data Controller

RellowTeam

Via del Poetto, 36

09126 Cagliari

Owner contact email: rellowteam@gmail.com

Types of data collected

Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies; Usage data; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the Data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.

Unless otherwise specified, all the Data requested by this Application are mandatory and failure to provide them may make it impossible for this Application to provide its services. In cases where this Application expressly indicates that some Data are not mandatory, Users are free not to communicate such Data without consequences for the availability or operation of the Service.

Users uncertain about which Personal Data are mandatory are invited to contact the Data Controller.

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 requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.

Users are responsible for the Personal Data of third parties obtained, published or shared through this Application and confirm that they have the consent of the interested party to provide the Data to the Owner.

Mode and place of data processing

Methods of processing

The Data Controller adopts the appropriate security measures aimed at preventing unauthorized access, disclosure, modification or unauthorized destruction of the Data.

Data processing is carried out using IT tools and / or enabled IT tools, according to organizational methods and with methods strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third parties, interested technical service providers, couriers) may have access to the Data. postal services, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of these subjects may be requested from the Data Controller at any time.

Legal basis of the processing

The Data Controller may process Personal Data relating to Users if one of the following conditions is met:

● Users have given their consent for one or more specific purposes. Note: in some legislations the Data Controller may be authorized 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. However, this does not apply if the processing of Personal Data is subject to European data protection legislation;

● the provision of Data is necessary for the execution of a contract with the User and / or for any pre-contractual obligations of the same;

● the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

● the processing is connected to a task carried out in the public interest or in the exercise of public powers conferred on the Data Controller;

● the processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party.

In any case, the Data Controller will be happy to help clarify the specific legal basis applicable to the processing, and in particular whether the provision of Personal Data is a legal or contractual obligation, or a necessary requirement to enter into a contract.

Place

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located.

Depending on the User's location, data transfers may involve the transfer of the User's Data to a country other than your own. To find out more about the place of processing of such transferred Data, Users can consult the section containing details on the processing of Personal Data.

Users also have the right to know the legal basis of data transfers to a country outside the European Union or to any international organization of public international law or consisting of two or more countries, such as the UN, and on the measures security adopted by the Data Controller to safeguard their Data.

If this transfer occurs, Users can learn more by checking the relevant sections of this document or inquire with the Data Controller using the information provided in the contact section.

Retention time

Personal Data will be processed and stored for the time required by the purpose for which they were collected.

Therefore:

● Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be kept until the complete execution of this contract.

● The Personal Data collected for the purposes of legitimate interest of the Data Controller will be kept for the time necessary to fulfill these purposes. Users can find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

The Data Controller may be allowed to keep Personal Data for a longer period if the User has given consent to such processing, provided that such consent is not revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period whenever this is necessary for the fulfillment of a legal obligation or by order of an authority.

After the retention period, the Personal Data will be deleted. Therefore, at the expiry of the retention period, the right of access, cancellation, rectification and the right to data portability cannot be exercised.

The purposes of the processing

The User Data is collected to allow the Owner to provide its Service, comply with legal obligations, respond to executive requests, protect its rights and interests (or those of its Users or third parties), detect any malicious activities or fraudulent, as well as the following: Device permissions for access to Personal Data, Analysis, Registration and authentication, Access to third party accounts, Registration and authentication provided directly by this Application and Advertising.

For specific information on the Personal Data used for each purpose, the User can refer to the section "Detailed information on the processing of Personal Data".

Device permissions for access to personal data

Depending on the User's specific device, this Application may require 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 they can access their information. Once the authorization has been granted, it can be revoked by the User at any time. To revoke these permissions, Users can refer to the device settings or contact the Owner for support at the contact details provided in this document.

The exact procedure for checking app permissions may depend on the User's device and software.

Please note that revoking these permissions may affect the proper functioning of this Application.

If the User grants one of the permissions listed below, the respective Personal Data may be processed (i.e. consulted, modified or removed) by this Application.

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 your account data on a third party service and perform actions with it. These services are not activated automatically, but require explicit authorization from the User. Advertising

● Analysis

● Device permissions for accessing personal data

● Registration and authentication

● Registration and authentication provided directly by this Application

Users' rights

Users can exercise certain rights in relation to their data processed by the owner.

In particular, Users have the right to:

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

● Oppose the 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 know if the Data is processed by the Data Controller, to obtain information on some aspects of the processing and to obtain a copy of the Data being processed.

● Check and ask for rectification. Users have the right to verify the accuracy of their data and request its updating or correction.

● Restrict the processing of their data. Users have the right, in certain circumstances, to limit the processing of their data. In this case, the owner will not process their data for any purpose other than their conservation.

● Have your Personal Data deleted or otherwise removed. Users have the right, in certain circumstances, to obtain the cancellation of their Data by the Owner.

● Receive your data and have it transferred to another owner. Users have the right to receive their data in a structured format, commonly used and readable by an automatic device and, if technically feasible, to have them transmitted to another owner without hindrance. This provision applies provided that the Data are processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party or on pre-contractual obligations of the same.

● File a complaint. Users have the right to lodge a complaint with the competent data protection authority.

Details on the right to object to the processing

Where Personal Data are processed for a public interest, in the exercise of an official authority vested with the Data Controller or for the purposes of the legitimate interest pursued by the Data Controller, Users may oppose such processing by providing a reason connected to their particular situation to justify the 'objection.

The User must know that, however, if his Personal Data are processed for direct marketing purposes, he can object to such processing at any time without providing any justification. To find out if the Data Controller processes Personal Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise these rights

Any requests to exercise the User's rights can be addressed to the Data Controller using the contact details provided in this document. These requests can be exercised free of charge and will be processed by the Data Controller as quickly as possible and always within one month.

Learn more about data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Data Controller in court or in the preparatory stages for possible legal actions deriving from the improper use of this Application or the related Services.

The User declares to be aware that the Data Controller may be required to disclose personal data upon request of the public authorities.

Learn more about your personal data

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

System logs and maintenance

For operational and maintenance purposes, this Application and any third party services may collect files that record the interaction with this Application (System Logs) using other Personal Data (such as the IP address) for this purpose.

Information not contained in this policy

More details regarding the collection or processing of Personal Data may be requested from the Data Controller 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 if some of the third party services used honor "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 Users on this page and possibly within this Application and / or - as far as technically and legally feasible - by sending a communication to Users through any contact details available to the owner. We strongly recommend that you check this page often, referring to the date of the last modification indicated at the bottom.

If the changes concern processing activities carried out on the basis of the User's consent, the Data Controller will collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable constitutes personal data.

Usage data

Information collected automatically through this Application (or third party services used in this Application), which may include: the IP addresses or domain names of the computers used by the Users who use this Application, the URI (Uniform Resource Identifier) ​​addresses, the time of the request, the method used to forward the request to the server, the size of the file received in response, the numeric code indicating the status of the server response (success, error, etc.), the country of origin, the characteristics of the browser and the operating system used by the User, the various time details per visit (e.g. the time spent on each page of the Application) and the details on the path followed within the Application with particular reference to the sequence of pages visited, and others parameters relating to the operating system of the device 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 Processor)

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

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of the processing of Personal Data, including the security measures relating to the operation and use of this Application . The Data Controller, unless otherwise specified, is the owner of this Application.

This application

The ways in which the User's Personal Data are collected and processed.

Service

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

European Union (or EU)

Unless otherwise specified, all references to the European Union made within this document include all current member states of 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 means any technology - eg. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allow tracking of Users, for example by accessing or storing information on the User's device.

Legal information

This privacy statement has been drawn up on the basis of the provisions of multiple legislations, including art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

Unless otherwise specified, this privacy statement only concerns this Application.

Last update: 03 June 2021

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