PRIVACY POLICY OF WEBAPPEEL

1. GENERAL INFORMATIONS            

1.1

Webappeel is a society that deals with delivering a subscription service based on the connection to a platform (“…And What If I Were a Midge”) that delivers to the users (in the following “You” or the “User”) the access to the website according to the Terms of Use, to the present Privacy Policy and to any other integrative terms and Conditions that may discipline the use by the User of a specific Subscription plan for “… And what if I were a Midge” (the  “Conditions”). The Service is provided by Webappeel S.r.l., based in Turin (TO) in Legnano Street n. 27 registered on Turin’s Business Register with the number TO – 1286418, having F.C. and VAT N. 12391190019 and having its registered office in Legnano Street n. 27 Turin – Italy (below “Webappeel” or “us”).

1.2

The present privacy policy explains Webappeel’s practices with reference to the collection, storage, use and disclosure of some informations, included personal information of the User related to our provision of the Service to the User. The present privacy policy also involves the people that visit our website or that download and use our application. It helps to inform the User about our processing of the User’s personal information and to ensure to the User that the User’s personal information are treated according to and in accordance with the applicable legislation in matters of data protection when using the Service.

The informative in the case of the Service “... And what if I were a Midge” is even more important because some data that are provided to us are related to a minor and the one that provides them to us – that will have to be exclusively the exerciser of parental responsibility – has to be informed about the use of these data, that will be visualised and used only by that User and will be stored in accordance to the Privacy Policy effective for the protection of the rights of the child.

1.3

The User always have to feel safe when sharing its personal informations with Webappeel. Webappeel has adopted technical and organisational security measures that are fit to grant that the User’s personal information (as well as those of the minor of reference) are, in particular, protected from unauthorised accesses or disclosures, use, modifications, cancellation and loss. If you are not comfortable with the content of the present Privacy Policy, the User can always refrain from using the Service.

2. HOLDER OF THE PROCESSING OF PERSONAL DATA

2.1

Webappeel S.r.l. is the holder of the processing of the User’s personal data managed by Webappeel. You can contact each subject regarding for example the integrity and the confidentiality. Information about how to contact us are available in section 12.2.

3. WHEN AND FROM WHERE WEBAPPEEL COLLECTS PERSONAL DATA?

3.1

Webappeel collects the User’s personal data when:

• the User creates an account on Webappeel and/or uses the Service,
• the User installs and/or uses any application included in the Service,
• the User visits the website,
• the User registers in quality of subscribed to the newsletter of Webappeel,
• the User notifies errors, illegal or inappropriate material or contacts the Customer assistance of Webappeel for any other reason,
• the User links the Service to its Facebook account or to a similar third parties service, for example, to ease the access (login) to the Service, in that case we receive data from the service of that third party,
• the User participate to a survey, included but not limitedly to the questionnaires on Customer satisfaction or to the marketing surveys or answers to a communication from Webappeel, or
• it’s otherwise necessary to manage the relationship between the User and Webappeel.

3.2

Webappeel also collects information via proprietary or third parties cookies and similar tracking technologies (included but not limitedly to beacons, tags and pixels) that may keep track of the activities and choices of the User, for ex. when the User downloads our application, uses the Service or visits our website. This for example is made to ease the login, remember the User’s favourite settings, send to the User customised marketing and measure the profitability of the advertisements. More information on the use of cookies by Webappeel are contained in WebAPPel’s cookies policy on Webappeel’s website.

4. WHICH PERSONAL DATA ARE COLLECTED BY Webappeel?

4.1

When the User creates an account on Webappeel or contacts Webappeel’s Customer service, Webappeel collects the personal information of the User. The basic information of the User that WrbAPPeel collects comprehend the User’s contact information such as the name and/or surname of the User, e-mail address and residential address. Webappeel can also collect data regarding the User’s date of birth, its gender and additional information of contact such as the User’s address. Webappeel also collects the personal information that the User provides about the minor. In this case, the User has to be obligatorily the one exercising parental responsibility for the minor. In this last case, the User will be responsible to have the right to do so.

4.2

When the User uses the Service or any other additional service or product of Webappeel, and visits the website and the app of “… And what if I were a Midge”, Webappeel can also collect information regarding the use (such as the choices of titles and researches), see information (such as visualised contents) and technical data (such as the unique identifier of the platform, the versions of the phone and of the platform, the device’s IP address, language settings, information about the URL, the password (encrypted), the cookies data and the kind of browser). If, when the User registered on Webappeel as a Customer, he registered as a Customer who needs the invoice, Webappeel may also need to collect and handle some of the information that the User provides to the payment service provider of Webappeel to ease this billing.

4.3

If the User chooses to connect the Service to Facebook or to a sfilar third parties service that controls the personal information, Webappeel can collect and handle the data that the User provided via Facebook, or to such other third party, with the permission to share with Webappeel. Webappeel encourages the User to inform about the practices on privacy matters for those third parties.

4.4

Moreover, Webappeel can also collect and handle the personal information that the User provides in public forums on Webappeel’s website or to Webappeel when the User uses Webappeel’s website, the sites of Webappeel on third parties platforms such as application stores, social network sites or links the User’s profile to third parties sites or platforms with its account.

4.5

Webappeel can also collect and handle some personal information related to the eligibility of the User to use the Service to the payment method of the User. In any case, since Webappeel collaborates with third parties payment services providers that operate independently on systems separated from Webappeel, no complete payment data, such as complete credit cards’ numbers, will be stored by Webappeel. Webappeel encourages the User to inform about the practices on privacy matters for those third parties payment providers.

5. HOW LONG ARE THE PERSONAL DATA STORED?

5.1

Webappeel will preserve the User’s personal information as long as it is necessary with regard to the purpose of the respective processing activity.

5.2

This means that all the personal information collected and elaborated for marketing purposes will be stored as long as the User will remain a Subscriber and for twelve (12) months following the cancellation of the User’s subscription unless the User provided to Webappeel the consent to continue processing these data.

5.3

To fulfill our contractual obligations, monitor and document the use of the Gift Cards, we’ll store the personal information that the User provided at registration (such as name and/or Username, e-mail address and/or the phone number and the payment details of the User as well as the minor’s information and its pictures) as long as the User remains a Subscriber, a user of Gift Cards and for a period of twenty-four (24) months from the registration of the User, from the purchase of the Gift Card.

5.4

We’ll store the personal information as long as the User remains a Subscriber.

5.5

When the User contacts Webappeel to receive assistance or for other purposes we’ll store the User’s personal data as long as the problem for which we have been contacted will not be resolved (for ex. problems and requests).

5.6

The User’s personal information are processed for analytical purposes during the period of the User’s subscription.

5.7

Webappeel can store the personal information for a period longer than the times above if required by law or to establish, exercise or defend a right in a lawsuit.

6. WHERE AE THE PERSONAL DATA STORED?

6.1

The User’s personal informations are stored inside of AWS servers located in Germany, the country in which the Contracting Party (as defined in the Terms of Use) considered that greater protection in the "field" where data security is provided.

7. WHY DOES WEBAPPEEL PROCESS THE USER’S PERSONAL INFORMATION?

7.1

Webappeel processes the User’s personal information for various purposes. First of all, Webappeel processes the User’s personal information to manage the Customer relationship with the User and to fulfill its legal obligations. The User’s personal information can be processed also for market and Customers analysis, market research, statistics, activities of business monitoring and business and methodological development of Webappeel to develop and personalise the Service and its functions.

Webappeel also processes the personal information of the minor final user of the Service to insert its particularities in its specific Service which can only be accessed by the User exercising parental responsibility that will have provided them to us with its Username and with its password.

7.2

Webappeel also processes the personal information of the User to provide better and more personalized offers and services. Webappeel processes the User’s personal information also to decrease the risk of sending to the User advertisements or other kinds of irrelevant marketing. The personal information may, for example, be processed, linked, segmented and analysed to provide, through targeted marketing techniques for example via e-mail, information, offers or advices on products and services of Webappeel or its partners, following the preferences, the habits, the needs or the lifestyle of the User. They may also be used as a basis for targeted marketing towards a public that is similar to the existing users of Webappeel. This can for ex. include the treatment of personal information to create to create a personalised public on third parties platforms such as Facebook and Google. Webappeel can also analyse and combine the information about the User to whom Webappeel has access through the Service, the online visits or other User’s registrations (for ex. Facebook or similar social media providers) for the purposes described in the present section.

7.3

In addition to the above, Webappeel processes the User’s personal information to prevent, detect and investigate on possible prohibited or illegal activities, and to enforce our Conditions (for ex. establish if the User is eligible for a Free Trial period or of other offers or marketing campaigns depending on the case).

8. WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA?

8.1

The majority of User’s personal data that Webappeel is processing are processed because it is necessary for Webappeel to execute the Conditions, so as to be able to provide and manage the Service and its features. That is the case in which Webappeel processes for example User’s contact informations like e-mail address and telephone number and informations becoming from the payment service provider.

8.2

Some personal data that Webappeell processes are processed by a balance of interests, such as Webappeel legitimate interest of processing data which is more important than the impact and the risk that the processing of the data could have on the User’s integrity. That is the case in which Webappeel processes User’s personal data for caring purposes (for instance general assistance requests).

8.3

Moreover, some personal data are processed under User’s consent. This becomes when Webappeel processes personal data obtained from User’s Facebook account, for Webappeel and Webappeel partner products and services direct marketing.

8.4

So far as the processing is used with the consent as a judicial bases, it is optional for the User to give the consent and he can withdraw his consent in every moment, entirely or partially.

9. SAFETY AND INTEGRITY OF PERSONAL DATA

9.1

Safety, integrity and confidentiality of User’s personal data is very important for us. We have implemented tecnique, administratives and physical safety measures which are conceived to protect User’s personal data particularly from unauthorized accesses or disclosures, use, changes, cancelations and losses. Occasionally, we review our safety procedures to value the need to implement new measures or to make technical updates to existing procedures. We remind you that, despite our best efforts, few safety maeasures are impenetrable, and therefore we ask you to immediately inform us if you might encounter any suspect activity in the Service.

10. TO WHOM WEBAPPEEL DIVULGES USER’S PERSONAL DATA?

10.1

Webappeel could divulge User’s Personal Data to suppliers or other people to fulfill the contracts with the User or to fulfill the contracts with the suppliers or otherwise according to established purposes established in the present privacy policy. This could happen when we give informations for example to the User’s bank to prove compliance and to solve misunderstandings and so on.

10.2

Webappeel could also disclose User’s personal data to other people to send advertising and personalised marketing to the User, in order to decrease the risk to send to the User advertising or other types of useless marketing, to measure the success and the extension of our digital marketing and for other promotional purposes. That is the case in which Webappeel uses re-marketing functionalities and impressions, interests and demographical reports in Google Analytics, uploads a custom audience on for instance Facebook and Google and when we inform our business partners, as far as Facebook and Google, that a type of marketing creates a new specific client or a number of new Clients according to the case.

10.3

Webappeel could also disclose personal data to firms which process personal data for us, like ours IT system suppliers, Customer service companies and affiliates. So far as personal data might be disclose to those firms who process data for Webappeel, Webappeel will subscribe contracts for data process with those firms in order to insure a high level of security for User’s personal data.

10.4

If necessary, personal data could be disclose in order to comply with legal duties or requests from judicial authorities or agencies, in order to protect Webappeel legal interests or to detect, prevent or investigate cases of fraud or other technical or safety questions.

11. CHANGES TI PRIVACY POLICY

11.1

This privacy policy can be occasionally reviewed. So far as Webappeel should realize any relevant change to the privacy policy, she will inform the User by mail, SMS or by the Service before changes become actual. Furthermore, the most recent privacy policy will be published on Webappeel website. If any change would request the User’s consent, Webappeel will ask the User the new consent. We invite the User to frequently check the privacy policy in order to stay informed on our privacy policy.

12. YOUR RIGHTS ACCORDING TO UE/SEE LAW

12.1

If the User is inside UE/SEE, or if his personal data are processed by a Webappeel entity inside UE/SEE, User has the following rights (in addiction to withdraw his consent):

• Accesso right User can ask if we have or not his personal data and ask information on which personal data we have and how we process them.
• Right of rectification: we are obliged to rectificate wrong personal data, or to integrate incomplete personal data, following to a specific request.
• Right to cancellation (right to be forgotten): in some circumstances we are obliged to delete User’s personal data following to a specific request.
• Right to limitation of treatment: in some circumstances we are obliged to limit our User’s personal data use according to a specific request. In those cases, we can only use personal data per some purposes according to law.
• Right to data portability: in some circumstances, the User could have the right to receive personal data in a structured format, for a common use and readable by an automatic device and he could have the right to send his personal data to another entity.
• Right to object: In some circumstances, User can deny his personal data use. In that case, we could be obliged to stop his personal data use. Like when personal data are used for marketing and profiling purposes.

12.2

Some of the above mentioned rights can be used only in particular situations, like right of data portability, which can be used only when the process is done according to a contractual requirement or a consent and if the process is done with automated tools, or the right of data cancellation, which can be used only when data are processed based on a balance of interests or a consent. In case of questions on how Webappeel processes User’s personal data, if you want to use your right or you need more informations about your rights, do not hesitate to contact us at the following references:

• Email address: privacy@webappeel.com
• Postal address: Torino (TO) Via Legnano n.27

12.3

If you do not wish Webappeel to process your personal data for marketing purposes, we kindly ask you to communicate it to Webappeel. Furthermore and for each sent newsletter, you will be informed of the possibility to give up receiving olther newsletter. Concerning “push” notifications (in case of mobile devices and tablets) you can give up receiving those notifications by going to “setting” of you device and by clicking on “Notifications", and modifying those setting per some or all you device apps. Concerning cookie, your choices for giving up are described in Webappeel cookie’s information.

12.4

You have also the right to file a compliant to the supervisory  authority if you think that your personal data have been processed in contrast with the applicable data protection legislation. If you are resident in, or your job is in, or the alleged data protection legislation violation has been done in Italy, you can file your compliant to the Italian protection data Autohority.

Webappeel S.r.l.