Privacy Policy of IMPASTO 48

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.


Policy summary


Personal Data processed for the following purposes and using the following services:

Beta Testing

TestFlight

Personal Data: device information; Usage Data

Contacting the User

Contact form and Mailing list or newsletter

Personal Data: email address; first name; last name; phone number

Phone contact

Personal Data: phone number

Social features

Inviting and suggesting friends

Personal Data: various types of Data

Managing contacts and sending messages

MailUp

Personal Data: email address

ActiveCampaign Text Message and SMS Marketing

Personal Data: email address; phone number; Usage Data

Mailchimp

Personal Data: email address; Trackers; Usage Data

User database management

ActiveCampaign

Personal Data: email address; Trackers; various types of Data as specified in the privacy policy of the service

Handling activity data

Activity data tracked by your device

Personal Data: general activity data

Handling payments

PayPal

Personal Data: various types of Data as specified in the privacy policy of the service

Satispay

Personal Data: Trackers

Managing data collection and online surveys

Data provided via online forms, managed directly

Personal Data: city; date of birth; email address; first name; last name; phone number; Trackers

Interaction with external social networks and platforms

PayPal Button and Widgets

Personal Data: Trackers; Usage Data

Location-based interactions

Non-continuous geolocation

Personal Data: coarse location; geographic position

Device permissions for Personal Data access

Device permissions for Personal Data access

Personal Data: Approximate location permission (non-continuous); Camera permission; Phone permission; Social media accounts permission; Storage permission

Registration and authentication

Sign in with Apple

Personal Data: email address; password

Facebook Oauth

Personal Data: Trackers; Usage Data

Direct registration and profiling

Personal Data: date of birth; email address; first name; last name; password; phone number; Trackers; Usage Data; various types of Data

Registration and authentication provided directly by this Application

Direct registration

Personal Data: date of birth; email address; first name; last name; password; phone number; Trackers; Usage Data

Analytics

Analytics collected directly

Personal Data: Trackers; Usage Data


Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), Network Advertising Initiative (US) and Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document. The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.


Further information about the processing of Personal Data


Platform services and Hosting: WordPress or others

App Widget on websites owned by the Owner of this Privacy Policy

Velocissimo software for customer database management

All contacts obtained through registration within the application are stored in the databases of the Velocissimo software. The Owner of this Privacy Policy is responsible for how the infrastructure is used to process such data.

Replio hosting and Velocissimo software

The data of this application are stored on Replio servers owned by Webapp Srl. The data collected by this Application and its contents are accessible through the backend of the Velocissimo CMS software.

Prepaid cards (Velocissimo software)

Users may use the credit accumulated on their Fidelity Card to pay for the desired service. Please note that Fidelity Cards and the related data stored on Webapp servers are under the responsibility of the Owner of this Privacy Policy.

Unique device identification

This Application may track Users by storing a unique identifier of their device, for statistical purposes or to keep Users' preferences.

Push notifications

This Application may send push notifications to the User.


Contact information


Owner and Data Controller

SARO 2022 SRLS (IMPASTO 48)
VIALE ALESSANDRINO 150

00172 Roma

Contact information
lucadallarosa76@gmail.com


Full policy


Owner and Data Controller

SARO 2022 SRLS (IMPASTO 48)
VIALE ALESSANDRINO 150

00172 Roma

Contact information: lucadallarosa76@gmail.com


Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: first name; last name; phone number; email address; Trackers; Usage Data; Camera permission; Approximate location permission (non-continuous); Phone permission; Storage permission; Social media accounts permission; device information; various types of Data; date of birth; city; general activity data; geographic position; coarse location; password.

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.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.


Mode and place of processing the Data


Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organisational 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.


Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.


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: Contacting the User, Managing contacts and sending messages, Handling payments, Interaction with external social networks and platforms, Device permissions for Personal Data access, Analytics, Beta Testing, Social features, User database management, Managing data collection and online surveys, Handling activity data, Location-based interactions, Registration and authentication and Registration and authentication provided directly by this Application.

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'.


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 dependant 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.


Social media accounts permission

Used for accessing the User's social media account profiles, such as Facebook and Twitter.


Camera permission

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


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.


Storage permission

Used for accessing shared external storage, including the reading and adding of any items.


Phone permission

Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the 'phone state', which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.


Detailed information on the processing of Personal Data

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

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.

TestFlight (Apple Inc.)

TestFlight is a beta testing service provided by Apple Inc.

Personal Data processed: device information; Usage Data.

Place of processing: United States – Privacy Policy

Social features

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.

User database management

This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Application. Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

ActiveCampaign (ActiveCampaign, Inc.)

ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.

Personal Data processed: email address; Trackers; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy

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.

PayPal (PayPal Inc.)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy

Satispay (Satispay Europe S.A.)

Satispay is a payment service provided by Satispay Europe S.A. which allows Users to make online payments.

Personal Data processed: Trackers.

Place of processing: Luxembourg – Privacy Policy

Interaction with external social networks and platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Application. The interaction and information obtained through this Application are always subject to the User's privacy settings for each social network. This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it. It is recommended to log out from the respective services in order to make sure that the processed data on this Application isn't being connected back to the User's profile.

PayPal Button and Widgets (PayPal Inc.)

The PayPal Button and Widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

Personal Data processed: Trackers; Usage Data.

Place of processing: See the PayPal privacy policy – Privacy Policy

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 (non-continuous); Camera permission; Phone permission; Social media accounts permission; Storage permission.

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: date of birth; email address; first name; last name; password; phone number; Trackers; Usage Data.

Contacting the User

Contact form (this Application)

By completing the contact form with their information, the User authorises this Application to use these details to respond to the inquiries (like quotes, and any other requests).

Personal Data processed: email address; first name; last name; phone number.

Mailing list or newsletter (this Application)

By registering on the mailing list or for the newsletter, the User's email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

Personal Data processed: email address; first name; last name; phone number.

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.

Managing contacts and sending messages

This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User. These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

MailUp (TeamSystem S.p.A.)

MailUp is an email address management and message sending service provided by TeamSystem S.p.A.

Personal Data processed: email address.

Place of processing: Italy – Privacy Policy

ActiveCampaign Text Message and SMS Marketing (ActiveCampaign, Inc.)

ActiveCampaign Text Message and SMS Marketing is an email address management and message sending service provided by ActiveCampaign, Inc.

Personal Data processed: email address; phone number; Usage Data.

Place of processing: United States – Privacy Policy

Mailchimp (Intuit Inc.)

Mailchimp is an email address management and message sending service provided by Intuit Inc.

Personal Data processed: email address; Trackers; Usage Data.

Place of processing: United States – Privacy Policy

Handling activity data

This type of service allows the Owner to use the activity or biometric data collected by your device in order for this Application to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the surroundings. Depending on what is described below, third parties may be involved in the activity tracking. Most devices allow for the User to control which Data is accessed or stored.

Activity data tracked by your device (this Application)

This Application uses some activity data tracked by your device to operate or to provide specific features.

Personal Data processed: general activity data.

Managing data collection and online surveys

This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users. The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.

Data provided via online forms, managed directly (this Application)

This Application makes use of online forms that can be used to collect Data about Users.

Personal Data processed: city; date of birth; email address; first name; last name; phone number; Trackers.

Location-based interactions

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 authorisation has been 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: coarse location; geographic position.

Registration and authentication

By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes. Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.

Sign in with Apple (Apple Inc.)

Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.

Personal Data processed: email address; password.

Place of processing: United States – Privacy Policy

Facebook Oauth (Meta Platforms, Inc.)

Facebook Oauth is a registration and authentication service provided by Meta Platforms, Inc. and is connected to the Facebook social network.

Personal Data processed: Trackers; Usage Data.

Place of processing: United States – Opt out.

Direct registration and profiling (this Application)

By registering or authenticating directly through this Application, Users allow this Application to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.

Personal Data processed: date of birth; email address; first name; last name; password; phone number; Trackers; Usage Data; various types of Data.

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.

Analytics collected directly (this Application)

This Application uses an internal analytics system that does not involve third parties.

Personal Data processed: Trackers; Usage Data.


Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may follow the instructions provided by YourOnlineChoices (EU), Network Advertising Initiative (US) and Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives. Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The Owner thus recommends that Users make use of these resources in addition to the information provided in this document. The Digital Advertising Alliance offers an application called AppChoices that helps Users to control interest-based advertising on mobile apps.

Users may also opt out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.



Further information about the processing of Personal Data

Platform services and Hosting: WordPress or others

App Widget on websites owned by the Owner of this Privacy Policy

Replio hosting and Velocissimo software

The data of this application are stored on Replio servers owned by Webapp Srl. The data collected by this Application and its contents are accessible through the backend of the Velocissimo CMS software.

Unique device identification

This Application may track Users by storing a unique identifier of their device, for statistical purposes or to keep Users' preferences.

Velocissimo software for customer database management

All contacts obtained through registration within the application are stored in the databases of the Velocissimo software. The Owner of this Privacy Policy is responsible for how the infrastructure is used to process such data.

Prepaid cards (Velocissimo software)

Users may use the credit accumulated on their Fidelity Card to pay for the desired service. Please note that Fidelity Cards and the related data stored on Webapp servers are under the responsibility of the Owner of this Privacy Policy.

Push notifications

This Application may send push notifications to the User.


Further Information for Users


Legal basis of processing

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

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.


Further information about retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore:

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

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

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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.


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.


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.


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.


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)

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 utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised 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.

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