privacy policy

owner and data controller

types of data collected

any details provided by the users are kept confidential. 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 website.


unless specified otherwise, all data requested by this website is mandatory and failure to provide this data may make it impossible for this application to provide its services. in cases where this website 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 website or by the owners of third-party services used by this website serves the purpose of providing the service required by the user, in addition to any other purposes described in the present document and in the cookie policy, if available. users are responsible for any third-party personal data obtained, published or shared through this website and confirm that they have the third party's consent to provide the data to the owner.

mode and place of processing the data

methods of processing


the owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the data.
 the data processing is carried out using computers and/or IT enabled tools, following organizational 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 website (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.

legal basis of processing

the owner may process personal data relating to users if one of the following applies:

  • users have given their consent for one or more specific purposes.

    • note: under some legislations the owner may be allowed to process personal data until the user objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases.

  • provision of data is necessary for the performance of an agreement with the user and/or for any pre-contractual obligations thereof;

  • processing is necessary for compliance with a legal obligation to which the owner is subject;

  • processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the owner;

  • processing is necessary for the purposes of the legitimate interests pursued by the owner or by a third party.


in any case, the owner will gladly help 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.

retention time

personal data shall be processed and stored for as long as required by the purpose they have been collected for:

  • personal data collected for purposes related to the performance of a contract between the owner and the user shall be retained until such contract has been fully performed.

  • personal data collected for the purposes of the owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. users may find specific information regarding the legitimate interests pursued by the owner within the relevant sections of this document or by contacting the owner.


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 do so for the performance of a legal obligation or upon order of an authority.



once the retention period expires, personal data shall be deleted. therefore, the right to 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

users may exercise certain rights regarding their data processed by the owner:

  • withdraw their consent at any time: users have the right to withdraw consent where they have previously given their consent to the processing of their personal data.

  • object to processing of their data: users have the right to object to the processing of their data if the processing is carried out on a legal basis other than consent. further details are provided in the dedicated section below.

  • access their data: users have the right to learn if data is being processed by the owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing.

  • verify and seek rectification: users have the right to verify the accuracy of their data and ask for it to be updated or corrected.

  • restrict the processing of their data: users have the right, under certain circumstances, to restrict the processing of their data. in this case, the owner will not process their data for any purpose other than storing it.

  • have their personal data deleted or otherwise removed: users have the right, under certain circumstances, to obtain the erasure of their data from the owner.

  • receive their data and have it transferred to another controller: users have the right to receive their data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. this provision is applicable provided that the data is processed by automated means and that the processing is based on the user's consent, on a contract which the user is part of or on pre-contractual obligations thereof.

  • lodge a complaint: users have the right to bring a claim before their competent data protection authority.

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.