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Information concerning the Processing of Personal Data
pursuant to art. 13 Legislative Decree of 30 June 2003, n. 196
and EU General Data Protection Regulation 2016/679 (“GDPR”)

 

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Privacy

WHAT TYPES OF DATA WE COLLECT?

When you use our services, you accept that our company collects some of your personal data. This page is intended to tell you what data we collect, why and how we use it.

We treat two types of data:

• data provided by the user
• data that we collect automatically

DATA PROVIDED BY THE USER

Registration
When you register, we ask you to provide us with some data that you need to take advantage of our service.

These are the data we ask you:

• profile name
• email address
• password
• city ​​or municipality of reference

You can also choose to provide us with the following information:

• picture profile
• personal phrase
• date of birth
• sex
• telephone number

Third party data

If you provide personal data of third parties, such as those of your family or friends, you must be sure that these subjects have been adequately informed and have consented to the related processing in the manner described by this statement.

Data of minors 16 years

If you are under the age of 16, you can not provide us with any personal data and you can not register on wall:in, and in any case we do not assume any responsibility for any false statements that you provide. Should we notice the existence of untruthful declarations, we will proceed with the immediate cancellation of any personal data acquired.

DATA THAT WE COLLECT AUTOMATICALLY

We collect the following data using the services you use:

• technical data: eg IP address, browser type, information on your computer and/or device, data on the current (approximate) position of the instrument you are using;
• data collected using cookies or similar technologies: for more information, please visit the “Cookies” section.

 

1. HOW DO WE USE THE COLLECTED DATA?

We use the data collected to offer you our service every day, to inform you about our business activities or to offer you a more personalized service in line with your interests.

1.1 To guarantee you access to our services and improve their provision

We use your information to guarantee you access to our services and their provision, including:

• registration and creation of a personal profile
• publication of events
• use the “add to favorites” and “add to private wall” features
• communications related to the provision of the service
• review of events, moderation or removal of content, prevention of fraud
• activities of an administrative, financial or accounting nature, such as those relating to purchases of paid services and possible recovery of credit

These treatments are necessary to supply correctly wall:in services in respect of users who join.

We also use your data to improve and implement the service, through the following treatments:

• detection of your current position (approximate) to facilitate the use of some features of the service, such as viewing events close to you
• communications relating to services similar to those used by you
• market research, optional surveys and surveys of the degree of user satisfaction

These treatments are based on the legitimate interest of the Data Controller (see point 3.1) and you can object at any time.

1.2 To inform you about our business activities

We use the data collected, if you have expressly provided your consent, to inform you about promotional activities that may interest you.

In particular we use them for:

• communicate promotional, commercial and advertising activities on events, initiatives or partnerships of wall:in, by e-mail, sending SMS or push notifications
• carry out analysis and reporting activities related to promotional communication systems, such as the detection of the number of open emails, clicks made on links within the communication, the type of device used to read the communication and the relative operating system or the list of unsubscriptions to the newsletter.

1.3. To offer you a personalized service

We process the data collected, if you have expressly provided your consent, to analyze your habits or consumption choices in order to propose an increasingly personalized service and in line with your interests and to improve our commercial offer. These analyzes are not in any case related to an automated decision-making process.

 

2. IS THE DATA CONFERENCE MANDATORY?

The provision of personal data is mandatory only for the processing necessary for the provision of services offered by wall:in (any refusal for the purpose of providing the service makes it impossible to use the service) within the website www.wallinapp.com and related mobile and desktop applications.

 

3. WHO ARE THE SUBJECTS OF THE TREATMENT?

3.1. Data controller

The data controller is wall:in S.r.l. in person of its legal representative pro-tempore, with registered office located in Genoa (IT), Piazza della Vittoria, 15/30, C.F. 02475170995

The data controller uses data controllers to achieve the purposes specified in point 1 and a Data Protection Officer (DPO) to monitor the protection of personal data.

For each request related to your personal data, compare the following point 3.2.

3.2. Data Protection Officer (DPO) and contact information

The person in charge of data protection (Data Protection Officer) pursuant to art. 37 of the GDPR is Mr. Gabriele Bricola.

We remind you that you can contact the DPO at any time and send any question or request regarding your personal data and respect your privacy by writing to support@wallinapp.com and inserting the subject “Privacy – Data Protection Officer”.

3.3. Subjects to whom personal data may be disclosed

The data collected as part of the provision of the service may be communicated to:

• companies that perform functions strictly connected and instrumental to the operations – even technical – of the services of wall:in, such as suppliers that provide services for the review and verification of announcements, suppliers of direct marketing services and customer care, companies which provide archiving, administrative, payment and invoicing services
• bodies and administrative and judicial authorities by virtue of legal obligations

Your personal data may be transferred outside the European Union to be processed by some of our service providers. In this case, we make sure that this transfer takes place in compliance with current legislation and that an adequate level of personal data protection is guaranteed based on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules.

Under no circumstances do we transfer or sell personal data to third parties.

 

4. HOW TO REVOKE (OPT-OUT) THE CONSENT TO THE USE OF COOKIES?

4.1. Access to personal data from your private area and revocation of consent (opt-out)

You can, at any time, view your personal data in your private area. Enter the Settings of the App and click on the “Profile” section.

Remember that you can unsubscribe at any time the consent you provided by requesting the deletion of your account at support@wallinapp.com from the e-mail box with which you registered in wall:in and specifying in the subject of the email “Request deleting account wall:in”, or by deleting your account within the app in the Settings menu.

4.2. Export and cancellation of the processing of personal data

To export your personal data (takeout) or request the cancellation you can send a request to the email address support@wallinapp.com from the email box with which you registered in wall:in and specifying in the subject of the email “Request for export and/or deletion of the personal data of the account wall:in”.

Your personal data will be exported within 30 days or, in case the export becomes particularly complex, within three months.

The cancellation will be made within the foreseen technical times and in accordance with the retention period specified in the following point 5.

4.3. Exercise your rights

Any natural person who uses our services can:

• obtain from the owner, at any time, information about the existence of their personal data, the origin of the same, the purposes and methods of treatment and, if present, to obtain access to personal data and information referred to in Article 15 of the GDPR
• request the updating, rectification, integration, deletion, limitation of data processing if one of the conditions provided for in Article 18 of the GDPR occurs, the transformation into anonymous form or blocking of personal data, processed in violation by law, including those that do not need to be kept for the purposes for which the data were collected and/or subsequently processed
• oppose, in whole or in part, for legitimate reasons, to the processing of data, even if pertinent to the purpose of collection and processing of personal data provided for commercial information purposes or sending advertising material or direct selling or for the fulfillment of market research or commercial communication. Each user also has the right to withdraw the consent at any time without prejudice to the lawfulness of the treatment based on the consent given before the revocation
• receive personal data, provided knowingly and actively or through the use of the service, in a structured format, commonly used and readable by automatic device, and transmit them to another data controller without impediments
• propose a complaint to the Italian Data Protection Authority

We remind you that for any question or request concerning your personal data and the respect of your privacy you can write to the dedicated address support@wallinapp.com.

 

5. HOW AND FOR HOW LONG YOUR DATA WILL BE PRESERVED?

The retention of personal data will take place in paper and/or electronic/IT format and for the time strictly necessary to fulfill the purposes referred to in point 1, in compliance with your privacy and current regulations.

In the case of active users, announcements and user-generated content will be retained for 36 months for reasons of security, prevention and moderation of content and/or conduct contrary to the conditions of the service and the editorial rules of wall:in order to ensure a better quality of the same also in collaboration with the Authorities.

For purposes of analysis directed to the development and improvement of the service, the personal data of the user may be subject to the same retention period.

For direct marketing and profiling purposes we keep your data for a maximum period equal to that foreseen by the applicable legislation (respectively equal to 24 and 12 months).

Invoices, accounting documents and transaction data are stored for 11 years under the law (including tax obligations).

In the case of the exercise of the right to be forgotten through the request for explicit cancellation of personal data processed by the owner, we remind you that such data will be kept, in a protected form and with restricted access, only for purposes of ascertainment and repression of crimes, no more than 12 months from the date of the request and will subsequently be securely deleted or anonymised irreversibly.

Finally, we remind you that for the same purposes, the data relating to electronic traffic, excluding the contents of communications, will be kept for a period of no more than 6 years from the date of communication, pursuant to art. 24 of the Law n. 167/2017, which implemented the EU Directive 2017/541 on anti-terrorism.

 

6. HOW DO WE ASSURE THE PROTECTION OF YOUR DATA?

The data are collected by the subjects indicated in point 3, according to the indications of the relevant legislation, with particular regard to the security measures provided by the GDPR (Article 32) for their processing by means of computerized, manual and automated tools and with strictly related logic to the purposes indicated in point 1 and in any case so as to guarantee the security and confidentiality of the data.

In compliance with applicable regulations, a system of anti-spam verification on the communication between users is active. The data entered may be verified for the sole purpose of identifying illegal activities or contents that do not comply with the General Conditions of the Service, but will not be processed or communicated for commercial or promotional purposes.

 

7. FURTHER INFORMATION

7.1. Surveys

We may ask you, during navigation, the availability to participate in targeted surveys in order to know your opinion and the degree of satisfaction with regard to the services provided. These surveys can be carried out directly on wall:in or through the help of other platforms.

Within the surveys it will be possible, optionally, to provide an e-mail address in order to receive news and information on the services of wall:in.

We remind you that participation in surveys is completely optional and that you can always oppose this treatment.

7.2. Position

When you use wall:in applications and services with active location tracking, we may collect and process information about your current (approximate) location. This data is processed anonymously, in a format that does not allow the user to be personally identified and used for the sole purpose of facilitating the use of some position-based service features. You can activate/deactivate location services at any time by accessing your browser and/or device settings as follows:

Safari

• Desktop
  • go to “Preferences”> “Websites”> “Location” and remove wall:in from the list

• Mobile
  • go to “Preferences”> “Privacy”> “Location” and disable the location for Safari

Chrome

• Desktop
  • open Chrome chrome://settings/content/location and remove wall:in from the list

• Mobile
  • open Chrome and select “Site Settings”> “Location” and remove wall:in from the list 

Firefox

• Desktop e mobile
  • open Firefox and go to about: preferences#privacy, search for “Permission”> “Location”> “Settings” and remove wall:in from the list

Internet Explorer

• Desktop
  • open Internet Explorer, click on the “gear” icon and select “Internet Options” in the privacy panel, under the Position item, click on the “Delete Sites” button

7.3. Search engine

The information related to the ads posted on wall:in will be visible in the searches made in the internal search engine and could be made available to third party search engines as it is allowed to index the contents by third party engines. In the event that the page about the ad has already been removed from wall:in, it is possible that the cached copy will remain in the search results for a few days. The search results are not managed by wall:in, but the user can report the removal of the page and request the update of the cached copy directly to the third party search engine.

 

8. CAN THE INFORMATION ON THE PRIVACY CAN BE CHANGES IN TIME?

This information may be subject to change. If substantial changes are made to the use of data on the user by the Owner, the latter will notify the user by publishing them with the maximum evidence on their pages or through alternative or similar means.

 

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Cookie

Cookies and similar technologies

1. WHAT ARE COOKIES?

Cookies are small text files that the sites visited by users send to their terminals or devices, where they are stored to be transmitted again to the same sites during subsequent visits. Cookies (and/or similar technologies such as SDK technologies for the mobile world) can be stored permanently (persistent cookies) on your device or have a variable duration; they can in fact be deleted by closing the browser or having a limited duration to the single session (session cookies). Cookies can be installed from wall:in (first-party cookies) or from other websites (third-party cookies).

Cookies are used for different purposes as better specified in the next point 2 of this page.

For profiling activities, personal data collected through cookies are processed for a maximum period of 12 months from the moment in which consent to treatment is given. Below you will find all the information about cookies installed through the wall:in site and/or related applications and the necessary instructions on how to manage your preferences regarding them.

We remind you that our platform supports the browsers and/or applications identified below for the purposes of proper service delivery. For best results we recommend that you download the latest version of your browser and/or app.

We remind you that wall:in can not guarantee the correct functioning of the service and the effectiveness of the indications contained in this information for previous versions of browsers and/or unsupported apps.

1.1. Desktop site browser

• Chrome version 49.0 or later
• Firefox version 52.0 or later
• Internet Explorer version 11 or later
• Edge
• Safari version 8 or later

1.2. Mobile website browser

• iOS 7.1 or later (iPhone 4 or later): Safari
• Android 4.1 or later: Chrome 28.0 or later, Samsung Browser 3.3 or later, Android browser
• Windows Phone 8.1 or later: IEMobile

1.3. Browser for tablet devices

• Ipad: Safari
• Android: Android Browser

1.4. App

• IOS 6.1.0 or later
• Android 3.2.0 or later

 

2. WHICH COOKIES ARE ON WALL:IN?

2.1. First-party cookies and related purposes

The main purposes of cookies installed by wall:in are:

(i) techniques, cookies are used for purposes related to the provision of the service and to allow or improve navigation on the wall:in or store the searches. These cookies are essential to ensure that our platform is working properly.

(ii) analytical, cookies are used to collect statistical information on the use of the service by users (e.g. number of visitors, pages visited, …). We use these cookies to analyze traffic on our pages anonymously, without storing personal data.

2.2. Third-party cookies and related purposes

The main purposes of cookies installed by third parties are:

(i) analytical: to collect statistical information on the use of the service by users (e.g. number of visitors, pages visited, …). These cookies are used to analyze the traffic on our pages anonymously, without storing personal data.

Third parties: Google Analytics, Google, Firebase, Google AdMob, Google AdSense, Google AdWords, Google Maps, Google Play Console, Google Plus, Apple Developer, OneSignal, WordPress, Campaign Monitor, Facebook, Instagram, Twitter, WhatsApp, Pinterest, Vhosting, AppAnnie

(ii) performance: through these cookies it is possible to develop and implement the service, improving your browsing experience and therefore the use of the same.

Third parties: Google Analytics, Google, Firebase, Google AdMob, Google AdSense, Google AdWords, Google Maps, Google Play Console, Google Plus, Apple Developer, OneSignal, WordPress, Campaign Monitor, Facebook, Instagram, Twitter, WhatsApp, Pinterest, Vhosting, AppAnnie

(iii) di profilazione:

• marketing: we analyze your online actions so that you can provide, through third-party partners, content and commercial offers in line with your interests, also based on your previous browsing experience. This information is managed separately from the identification data held by wall:in.

Third parties: Google Analytics, Google, Firebase, Google AdMob, Google AdSense, Google AdWords, Google Maps, Google Play Console, Google Plus, Apple Developer, OneSignal, WordPress, Campaign Monitor, Facebook, Instagram, Twitter, WhatsApp, Pinterest, Vhosting, AppAnnie

• personalized advertising: through these cookies we show you advertisements according to your preferences, habits or consumption choices.

Third parties: Google Analytics, Google, Firebase, Google AdMob, Google AdSense, Google AdWords, Google Maps, Google Play Console, Google Plus, Apple Developer, OneSignal, WordPress, Campaign Monitor, Facebook, Instagram, Twitter, WhatsApp, Pinterest, Vhosting, AppAnnie

Furthermore, cookies specially designed for “social networks” could be activated. They allow the user to interact via social networks (share function, Facebook, Twitter, WhatsApp, Telegram, Pinterest, Google Plus, Instagram and similar). When a page contains this command, a direct connection is established with the selected social network.

wall:in, in addition to cookies, to improve the service and navigation or for profiling activities, could allow the use of similar technologies on your mobile devices such as tools by Google Analytics, Google, Firebase, Google AdMob, Google AdSense, Google AdWords, Google Maps, Google Play Console, Google Plus, Apple Developer, OneSignal, WordPress, Campaign Monitor, Facebook, Instagram, Twitter, WhatsApp, Pinterest, Vhosting, AppAnnie

The use of these technologies is governed by the privacy policies of these companies and not by the privacy policy of wall:in.

 

3. HOW IS THE CONSENT (OPT-IN) PROVIDED FOR THE USE OF COOKIES?

The consent to the use of profiling cookies is provided by the user through the following methods: closing the banner containing the brief information, scrolling the page hosting the banner or clicking any of its elements and can be revoked at any time.

All technical cookies do not require consent, so they are installed automatically as a result of access to the site or service.

 

4. HOW TO REVOKE (OPT-OUT) THE CONSENT TO THE USE OF COOKIES?

Cookies can be completely disabled by the browser using the appropriate function provided in most browsers.

It is good to know, however, that by deactivating cookies some of the features of wall:in may not be usable.

Here are the links to the information of the main browsers for more information on the deactivation of cookies: Chrome, Firefox, Internet Explorer, Safari, Edge.

To disable the performance and third-party profiling cookies individually, visit the information provided by the third parties indicated in paragraph 2 of this cookie policy.

With reference to profiling cookies aimed at offering you personalized advertising, we inform you that, if you exercise the opt-out, you will continue in any case to receive generic advertising.

To opt out and deactivate personalized advertisements by changing the settings of your mobile devices, follow the instructions below:

4.1. Android

1. on your device open the app “Google Settings”
2. scroll down and select “Google”
3. select “Announcements”
4. select “Disable interest-based ads” or “Disable ad personalization”

4.2. iOS

IOS devices use the Apple Advertising Identifier. For more information on limiting ad tracking with this identifier, visit the “Settings on your device” app or visit the page https://support.apple.com/it-it/HT205223.

 

5. ADDITIONAL INFORMATION ABOUT COOKIES AND HOW TO EXERCISE OPT-OUT

The Youonlinechoice and Networkadvertising.org platforms offer the possibility to refuse or accept the cookies of many digital advertising professionals.

We recommend you to use these platforms to manage the revocation of consent to the use of cookies.

To find out more about targeted advertising, you can consult the following pages:

• European Interactive Digital Advertising Alliance (EIDAA)
• Network Advertising Initiative (NAI)
• Interactive Advertising Bureau (IAB)

 

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Last updated on 24 May 2018