- WHAT TYPES OF DATA DO WE COLLECT?
When you use the services related to the MoreGlobe App, you accept that our company collects some data that you release during the registration process in the MoreGlobe APP and some others that are generated when you frame with your camera using the MoreGlobe APP. This page is intended to tell you what data we collect, why and how we use them.
We process two types of data:
⦁ data provided by the user
⦁ data we collect automatically
DATA PROVIDED BY THE USER
When you use the APP, we ask you to provide us with certain data, necessary for making use of our service. These are, for example, the data we ask you for:
⦁ email address and password entered during registration to use the services offered by the MoreGlobe App
THIRD PARTY DATA
If you provide third parties personal data, such as those of your family members or friends, you must be sure that they have been adequately informed and have consented to the processing of their data in the manner described in this policy.
DATA WE COLLECT AUTOMATICALLY
When you frame certain content with the camera via the MoreGlobe App to enjoy the Augmented Reality experience, we collect, automatically and anonymously through encrypted systems, some analytics data among which:
- Type of device used
- GPS position of the device you are using
- Duration and frequency of views
- Bounce rate
- Click on the dedicated link placed on that particular AR content
- HOW WE USE THE COLLECTED DATA
We use the data released by the users during the registration process and those collected automatically to ensure, first of all, the correct use of the service, therefore, to offer an experience really in line with the users’ expectations, finally, to send general notifications about the App updates or push notifications to show you interesting contents, therefore to propose a more personalised service in line with your interests.
2.1 Ensuring the correct use of the service
The email and password that you enter during the registration process are used exclusively to create a call sign account that can be traced back only to that particular user, so that he/she can use all the services offered by the MoreGlobe APP.
2.2 Ensuring an experience that truly meets your expectations
We use your data to ensure your access to and use of the MoreGlobe App, therefore to give you the possibility to live the Augmented Reality experience in a simple and intuitive way.
These treatments are necessary to properly deliver the services of Creatiwa Studio S.r.l.s to users who subscribe. These treatments are based on the legitimate interest of the Controller (see point 4.1) and you can object at any time.
2.3 Send general notifications about the App updates or about content you find interesting
When necessary, we send you push notifications to inform you about the need to update the App when we release new updates in the Android and IOS stores, to continue to enjoy effectively and efficiently the Augmented Reality experience through the MoreGlobe App.
2.4 Offer a more personalised service in line with your interests
We process the data collected during the Augmented Reality framing with the MoreGlobe App to analyse your habits, in order to offer you an ever increasingly personalised service in line with your interests, through push notifications.
- IS THE PROVISION OF DATA COMPULSORY?
The provision of the data requested during the registration process for the creation of the account (email and password) and the consent to the identification of your GPS position during the operations of framing with the Augmented Reality camera is mandatory only for the treatments necessary to provide the services offered by Creatiwa Studio S.r.l.s (any refusal for the purpose of providing the service makes it impossible to use the service itself) through the MoreGlobe App, summarized in this information notice.
- WHO ARE THE SUBJECTS OF THE TREATMENT?
4.1. Data Controller
The data controller is Creatiwa Studio S.r.l.s in the person of its pro-tempore legal representative, with registered office located in Salerno (IT), Via Scavata Case Rosse, SNC, 84131, P.IVA 05675660657 | REA SA – 465001.
The data controller employs data processors to achieve the purposes specified in point 1, and a Data Protection Officer (DPO) to supervise the protection of personal data.
For any request relating to your personal data, please refer to point 4.2 below.
4.2. Data Protection Officer (DPO) and contact information
The designated Data Protection Officer (DPO) pursuant to Art. 37 of the GDPR is Letizia Giugliano.
We remind you that you can contact the DPO at any time and send any question or request related to your personal data and to the respect of your privacy, by writing to: email@example.com.
4.3. Subjects to whom analysis data during AR framing with the MoreGlobe APP’s camera may be communicated
The automatically collected data concerning the User’s activity on a specific Augmented Reality content, enjoyed through the MoreGlobe APP, may be communicated to:
⦁ Companies that carry out functions closely related and instrumental to the operatIvity – also technical – of the services offered by the MoreGlobe App created by Creatiwa Studio S.r.l.s.
⦁ Institutions and administrative and judicial authorities by virtue of legal obligations
⦁ If a specific Augmented Reality content (photo, audio track, video, 3D), available through the MoreGlobe App, is the result of a commercial agreement between a Client (Company or Freelancer) and Creatiwa, the automatically collected data (c.f.r. art.1) may be transferred to them in aggregate non-identifiable form, relating to your activity on that specific Augmented Reality content. In this case, we ensure that this transfer is done in compliance with current legislation and that an adequate level of protection of personal data is guaranteed, by relying on an adequacy decision, on standard clauses defined by the European Commission or on Binding Corporate Rules.
As we do not collect any sensitive information about users’ personal identity, we do not, under any circumstances, transfer or sell any personal information to third parties.
- HOW CAN YOU GET INFORMATION ABOUT THE DATA, MODIFY THEM, DELETE THEM OR GET A COPY?
5.1. Access to personal data
You may, at any time, ask to see your personal data in our possession by sending an email to firstname.lastname@example.org.
5.2. Exporting and deleting your personal data
To export your personal data (takeout) or request their deletion, you can send a request to email@example.com.
Your data will be exported within 30 days or, if the takeout is particularly complex, within three months.
Deletion will be carried out within the expected technical time and in accordance with the retention period specified in point 5 below.
5.3. Exercise of your rights
Any natural person using our service can:
⦁ obtain from the controller, at any time, information about the existence of their personal data, their origin, their purposes and methods of processing and, if any, obtain access to personal data and information referred to in Article 15 of the GDPR
⦁ reques the updating, rectification, integration, deletion, limitation of the processing of data, if one of the conditions set out in Article 18 of the GDPR applies, the transformation into an anonymous form or the blocking of personal data processed in violation of the law, including data whose storage is not necessary in relation to the purposes for which the data were collected and/or subsequently processed
⦁ oppose, in whole or in part, for legitimate reasons, the processing of data, even if pertinent to the purpose of collection and the processing of personal data for purposes of commercial information or sending advertising materials or direct selling or for carrying out market research or commercial communication. Every user has also the right to revoke the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation.
⦁ to receive his/her personal data, consciously and actively provided or through the use of the service, in a structured, commonly used and machine-readable format, and to transmit them to another data controller without hindrance
⦁ to lodge a complaint with 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 firstname.lastname@example.org
- HOW AND FOR HOW LONG WILL YOUR DATA BE STORED?
Personal data will be stored on paper and/or electronically/informatically for the time strictly necessary to fulfil the purposes set out in point 1, in compliance with your privacy and current regulations.
For profiling purposes we will 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 retained for 11 years in accordance with the law (including tax obligations).
If you exercise your right to be forgotten, by requesting the express deletion of personal data processed by the data controller, we remind you that such data will be stored, in a protected form and with limited access, solely for the purpose of investigating and prosecuting criminal offences, for a period not exceeding 12 months from the date of the request and will then be securely deleted or irreversibly anonymised.
Finally, we remind you that for the same purposes, data relating to telematic traffic, excluding in any case the contents of communications, will be kept for a period not exceeding 6 years from the date of communication, pursuant to Article 24 of Law n. 167/2017, which implemented EU Directive 2017/541 on anti-terrorism.
- HOW DO WE ENSURE THE PROTECTION OF YOUR DATA?
The data are collected by the persons indicated in point 4, according to the indications of the relevant legislation, with particular regard to the security measures provided by the GDPR (art. 32) for their processing by computerised, manual and automated tools and with logics strictly related to the purposes indicated in point 1 and, in any case, in such a way as to guarantee the security and confidentiality of the data themselves.
This information notice may be subject to change. If substantial changes are made to the use of user related data by the Data Controller, the latter will notify the user by publishing them as clearly as possible on its pages or by alternative or similar means.