1. Personal Data collected by the Application
The Data Controller shall collect the following categories of Personal Data:
A. Voluntary contents and information provided by the User Contact information and contents: for example biographical data, e-mail address or postal address or other contact details, security information used for authentication and account access, personal interests and preferences and any other personal contents, etc.
Personal Data from Social Media: the Users may share Data they have communicated to social media with the Application. The User can monitor Personal Data which the Application may have access to when granting access to his social media accounts and through the privacy settings of the relevant social media website. By way of connecting accounts managed by social media to the
Application and by way of authorizing his Personal Data access, the User gives his consent to the acquisition, processing and
If the User does not communicate Personal Data, for which there is a legal or contractual obligation, will be impossible to the Data
Controller to provide, in whole or in part, its services. It will be impossible also in case that Personal Data is necessary requirement for the use of the service or for the contract conclusion.
The User who communicates to the Data Controller third parties Personal Data, is directly and exclusively liable for their origin,
collection, processing, communication or disclosure.
B. Data and contents automatically acquired while using the Application
Technical Data: the computer system and the software procedures functional to this Application may acquire, in the course of
their ordinary activity, any Personal Data whose communication is implicit in the use of internet communication protocols. Such
information is not collected to be associated with identified Users, however, those Data, due to its nature, may identify Users in the
Processing and through the association with Data held by third parties. This category includes IP addresses or domain names used
by Users who connect to the Application, addresses of Uniform Resource Identifier (URI) of the requested resources, time of the
request, method used submitting the request to the server, size of the file obtained, etc.
Usage Data: Data may be collected relating to the use of the Application by the User, such as the pages visited, the actions
performed, the features and services used by the User.
Geolocation Data: the Application may collect location Data, which may be accurate or inaccurate. The precise location Data may
consist in GNSS Data (Global Navigation Satellite System, such as GPS), as well as in Data which identify the nearest repeater, Wi-Fi hotspots and bluetooth, communicated when you enable products or features based on the location.
C. Personal Data collected through cookies or similar technologies
Personal Data of the Users are not acquired by the Application using these technologies.
Cookies, or any type of persistent cookies and systems for tracking the Users, are not used for the communication of personal
information. The use of session cookies (which are not permanently stored on the computer of the User and disappear with the
termination of the browser) is strictly limited to the transmission of session identification Data (composed by random numbers
generated by the server) necessary to allow a safe and efficient exploration of the Application. Session cookies used in this Application prevent to use other technologies, which may compromise the privacy of Users while browsing on internet and do not allow the acquisition of Personal Data identifying the User.
2. Purposes of the processing
Collected Personal Data may be used for the performance of contractual and pre-contractual obligations, legal obligations and for the following purposes:
internal handling of payments through credit card, bank transfer or any other tool (using Paypal, Stripe, Braintree, etc.) to sign as “ visited “ the points of interests where user has been and listened to the audio/ video content
3. Personal Data processing methods
The Processing of Personal Data is performed with paper, IT and/or digital tools, with methods of organizations and with logics strictly related to the indicated purposes.
In certain cases, subjects other than the Data Controller who are involved in the organization of the Data Controller (such as personnel management, sales personnel, system administrators employees, etc.) or who are not (as IT companies, service providers, postal couriers, hosting providers, etc.) may access to Personal Data. These subjects, will be appointed, where necessary, as Data Processors by the Data Controller and will have access to Users Personal Data whenever required, and shall be contractually obliged to keep it confidential.
The updated list of Data Processors may be requested via email at the email address firstname.lastname@example.org.
4. Legal basis for the processing
The Data Controller processes Personal Data regarding the User whether one of the following applies: the User has given consent for one or more specific purposes;
Processing is necessary for the performance of a contract with the User and/or for the performance of pre-contractual measures;
Processing is necessary to comply with a legal obligation to which the Data Controller is subject;
Processing is necessary for the performance of a task carried out in the public interest or for the exercise of public authority vested in the Data Controller;
Processing is necessary for the purposes of the legitimate interest pursued by the Data Controller or by a third party.
It is always possible to ask the Data Controller to clarify the concrete legal basis of each processing.
Personal Data are processed in the operative offices of the Data Controller and in any other place in which the parties involved in the Data
processing are located. For further information, you may contact the Data Controller at the following email address email@example.com.
6. Security of processing
The Data Processing is performed through adequate methods and tools to ensure the Personal Data security and confidentiality, as the Data Controller has implemented appropriate technical and organizational measures which guarantee, in a provable way, that the Processing complies with the applicable law.
7. Period of storage of Data
The Data Controller will store Personal Data for the necessary time to perform the purposes connected with the performance of the
agreement in force between the Data Controller and the User and Data shall not be stored beyond the duration of years 1 after the end of the relationship with the User. In any case Data could be stored within the limitation term prescribed by the current regulations.
When the Processing of Personal Data is necessary for the purposes of the legitimate interests pursued by the Data Controller, Personal Data shall be stored until the performance of the relevant interest.
When the Processing of Personal Data is based on the User consent, the Data Controller may store Personal Data until the withdrawal of the User.
Personal Data may be stored for a longer period of time in order to perform a legal obligation or public Authority order.
All Personal Data shall be deleted at the end of the period of storage. At the expiration of such period, the rights of Data access,
rectification, erasure and portability must not be exercised.
8. Automated individual decision-making
The Application uses automated individual decision-making to verify a fair usage of the app, which may produce legal effects concerning the User or significantly affect the User and that operates in accordance with the following criteria:
The application is for personal usage , it’s forbidden every reselling to third parties. To avoid no fair usage, an algorithm, based on occurrency of audio listening of a point of interest is implemented:
1.if during a month the app verifies that for 5 times the user listens the same audiocontent of a point of interest while staying near the point , the user will be blocked;
2. if during a year the app verifies that for 15 times the user listens the same audiocontent of a point of interest while staying near the point , the user will be blocked;
It will be possible to contact by mail the holder ITGUIDESAPP@GMAIL.COM to verify how to manage the blocking.
9. Rights of the User
The Users may exercise specifc rights with respect to Personal Data processed by the Data Controller. In particular, the User has the right to:
withdraw its consent at any time;
object the Processing of its Data;
access its Data;
monitor and request the rectification of Data;
obtain a restriction of Processing;
obtain the erasure or remotion of its Personal Data;
receive its Data or obtain the transfer to a different Data Controller;
lodge a complaint before the supervisory authority for the protection of personal data or start legal proceedings.
In order to exercise their rights, the Users may send a request to the contact information of the Data Controller indicated in this
document. These requests are free of charge and performed by the Data Controller in the shortest possible time, in any case no later than 30 days.