PRIVACY POLICY IN ACCORDANCE WITH EU REGULATION N. 2016/679

This section contains information relating to the management methods of Insology Studio S.r.l. with reference to the processing of user data of the doitsquare.com app. This information is also valid for the purposes of art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of art. 13 of EU Regulation no. 2016/679, concerning the protection of natural persons with regard to the processing of personal data as well as the free circulation of such data, for subjects who interact with doitsquare.com. The information refers exclusively to the doitsquare.com app and not to other apps or websites that may be consulted by the user via links contained therein. The purpose of this document is to provide information on the methods, timing and nature of the information that the data controller must provide to users when registering on doitsquare.com, regardless of the purpose of the connection itself, according to Italian and European legislation. The information may undergo changes due to the introduction of new regulations in this regard, the user is therefore invited to periodically check this page. If the user is under the age of sixteen, pursuant to art. 8, ch. 1 EU regulation 2016/679, he will have to legitimize his consent through the authorization of his parents or guardians.

II- DATA PROCESSING

Data owner

The data controller is the natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data. It also takes care of the security profiles. With regard to this App, the data controller is Insology Studio S.r.l. and for any clarification or exercise of the user's rights, he can contact you at the following email address [email protected].

Responsible for data processing

The data controller is the natural or legal person, public authority, service or other body which processes personal data on behalf of the data controller. Pursuant to article 28 of EU Regulation no. 2016/679, upon appointment of the data owner, the data controller of the doitsquare.com app is INSOLOGY STUDIO SRL, with registered office in Casciago (VA), Via Vasche n. 2, (VAT number: 03618840122), in the person of the legal representative pro tempore Mattia Marchiorato.

Place of data processing

Il trattamento dei dati generato dall’utilizzo di doitsquare.com avviene presso la sede operativa della società sita in Casciago (VA), Via Vasche 2 - cap 21020.

III- DATA PROCESSED

1. Data processing method and source

Like all Apps, doitsquare.com also makes use of log files in which information collected in an automated manner is kept during user visits. The information collected could be the following: - Internet protocol (IP) address; - Parameters of the device used; - Name of the internet service provider (ISP); - Date and time of visit; The aforementioned information is test rate in an automated form and collected in an exclusively aggregated form in order to verify the correct functioning of the site and for security reasons. This information will be tested according to the legitimate interests of the owner. For security purposes (anti-spam filters, firewalls, virus detection) the automatically recorded data may possibly also include personal data such as the IP address, which could be used, in accordance with applicable laws, in order to block attempts to damage to the app itself or to cause damage to other users or harmful or criminal activities. These data are never used for the identification or profiling of the user, but only for the purpose of protecting the app and its users, this information will be used on the basis of the legitimate interests of the owner. By registering with the app, the user expressly accepts this privacy policy and, in particular, agrees that the contents inserted are freely disclosed to third parties for the purposes indicated. The data received (user's personal data, user's contact details...) will be used exclusively for the provision of the requested service and only for the time necessary for the provision of the service. The information that users of the site will deem to make public through the services and tools made available to them, are provided by the user knowingly and voluntarily, exempting this site from any liability regarding any violations of the law. It is up to the user to verify that they have permission to enter personal data of third parties or content protected by national and international standards.

2. Purpose of data processing

The data collected by the site during its operation are used exclusively for the purposes indicated above, or in order to allow the user to use the services offered by doitsquare.com and kept for the time strictly necessary to carry out the specified activities and, in any case , no later than 2 years. If the user gives consent, newsletters or text messages may be sent to the same with communications relating to promotional initiatives. The data used for security purposes (blocking attempts to damage the site) are kept for the time strictly necessary to achieve the previously indicated purpose.

3. Data provided by the user

We receive or collect personal data, as detailed, when we provide our services, including when you access, download, install the App, or use our services. We may use this personal data to provide services you request as a contractual necessity, to operate, provide, improve, customize, support and market our services based on our legitimate interests, or to comply with a legal obligation to which we may be subject . If you do not want us to collect and process your personal data, you may not be able to use the services. All the data provided by the user (personal data of the user, contact details of the user...) will be used in order to allow the user to use the services offered by doitsquare.com. The optional, explicit and voluntary sending of e-mails to the addresses indicated on this site involves the subsequent acquisition of the sender's address, necessary to respond to requests, as well as any other personal data included in the message.

4. Transfer of data abroad.

Personal data may be transferred to countries of the European Union and to third countries with respect to the European Union as long as this is necessary, in compliance with the provisions of European legislation on the transfer of personal data to third countries or international organizations ( articles 44 - 47 and 49 GDPR).

IV- USER RIGHTS

The art. 13 co. 2 of the EU Regulation of 2016/679 lists the user's rights. This privacy policy, therefore, informs the user about the existence: – the right of the interested party to ask the owner for access to personal data (Article 15 of the EU Regulation), their updating (Article 7, paragraph 3, letter a of Legislative Decree 196/2003), rectification (art. 16 EU Regulation), the integration (art. 7, co. 3 lett. a Legislative Decree 196/2003), the limitation of the treatment that concern him (art. 18 EU Regulation) or to oppose, for reasons legitimate, to their treatment (art. 21 EU Regulation), in addition to the right to data portability (art. 20 EU Regulation); – the right to request cancellation (art. 17 EU Regulation), transformation into anonymous form or blocking of data processed in violation of the law, including data whose retention is not necessary in relation to the purposes for which the data are been collected or subsequently processed (art. 7 co. 3, letter b of Legislative Decree 196/2003); – the right to obtain the attestation that the updating, rectification, data integration, cancellation, data blocking, transformation operations have been brought to the attention, also with regard to their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right (art. 7 co. 3, letter c of Legislative Decree 196/2003). Requests can be sent to the data controller at his aforementioned email address (without formalities) or by using the model provided by the Guarantor for the protection of personal data. If the treatment is based on the art. 6 paragraph 1 letter a – express consent to use – or on art. 9 paragraph 2 letter a – express consent to the use of genetic, biometric, health-related data revealing religious, philosophical beliefs or union membership, revealing racial or ethnic origin, political opinions – the user has the right to revoke the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation. Likewise, in the event of a violation of the law, the user has the right to lodge a complaint with the Guarantor for the Protection of Personal Data, as the authority responsible for monitoring data processing in the Italian State. For a more in-depth examination of your rights, see articles 15 et seq. Of the EU Regulation 2016/679 and the art. 7 of Legislative Decree 196/2003.

V - FULFILLMENTS

The holder notifies the Guarantor of the processing of personal data which he intends to proceed, only if the processing concerns: – genetic, biometric data or data indicating the geographical position of persons or objects via an electronic communications network; – data suitable for revealing the state of health and sexual life, processed for the purpose of assisted procreation, provision of health services via telematics relating to databases or the supply of goods, epidemiological surveys, detection of mental, infectious and diffusive diseases , seropositivity, organ and tissue transplantation and monitoring of health expenditure; – data suitable for revealing sexual life or the psychic sphere, processed by non-profit associations, bodies and organizations, even if not recognized, of a political, philosophical, religious or trade union nature; – data processed with the aid of electronic tools aimed at defining the profile or personality of the interested party or at analyzing consumption habits and choices or at monitoring the use of electronic communication services with the exclusion of processing that is technically essential to provide the services same to users; – sensitive data recorded in databases for personnel selection purposes on behalf of third parties as well as sensitive data used for opinion polls, market research and other sample research; – data recorded in special databases managed with electronic tools and relating to the risk of economic solvency, the financial situation, the correct fulfillment of obligations, illicit or fraudulent conduct.

VI – SECURITY OF THE DATA PROVIDED

This app processes user data in a lawful and correct manner, adopting the appropriate security measures to prevent unauthorized access, disclosure, modification or unauthorized destruction of data. The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the owner, in some cases, categories of persons involved in the organization of the site (administrative, marketing, commercial, legal, system administrators) or external subjects such as (such as third party technical service providers, postal couriers) may have access to the data , hosting providers, IT companies, communication agencies).

VII – CHANGES TO THIS DOCUMENT

This document, published in the legal notes of the doitsquare.com app, constitutes its privacy policy. It may be subject to changes or updates. In the case of significant changes and updates, these will be reported with specific notifications to users. However, previous versions of the document will be available on this page.

The document was updated on 08/02/2023 to comply with the relevant regulatory provisions and in particular with EU Regulation 2016/679.