PRIVACY POLICY OF NON-PROFIT ASSOCIATION FOR SOCIAL DEVELOPMENT "LEZIONI DI BACIO"

This informational note has been prepared by the Non-Profit Association for Social Development "LEZIONI DI BACIO", Tax Code: 90172850274, headquartered on Via Torino 56H, Mirano, Italy pursuant to Article 13 of Italian Legislative Decree No. 196 of 30 June 2003, containing the Policy for safeguarding Personal Information (hereinafter ”Privacy Code“ for short).
This document will allow you to learn about our privacy policy and to understand how your personal information is handled when using our services by using the VIRALKISS® IT platform (henceforth also referred to as the “platform” for short) which consists primarily of an APP for mobile devices (hereinafter “APP” for short) and to enable you to grant your expressed and informed consent to process your personal information in those areas of the APP that require you to provide personal information.
The information and data provided by you, or otherwise acquired during registration for the various services offered through the APP, shall be processed in accordance with the provisions of the Privacy Policy (the full text is available on the website of the Data Protection Authority www.garanteprivacy.it), Guideline no. 2, dated 17 May 2001, issued by the European Commission, and confidentiality obligations underlying the activities of the Non-Profit Association for Social Development "LEZIONI DI BACIO" (hereinafter LEZIONI DI BACIO for the sake of brevity).
Personal data processing shall mean any action or set of actions, also performed without the aid of electronic instruments, concerning the collection, recording, organisation, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, communication, dissemination, deletion and destruction of data, even if not recorded in a database.
According to Privacy Code regulations, any processing performed by LEZIONI DI BACIO shall be characterised by propriety, lawfulness and transparency, and the protection of your privacy and your rights.

PURPOSE OF DATA PROCESSING:
The data processing we intend is aimed to enable the delivery of services requested by the user through registration and the creation of his/her Account or by communication via contact form, including collection, storage and processing of data for the purposes of setting up and subsequently managing the technical and administrative aspects of the relationship (and the Account created by the user) related to the provision of services and executing communications related to developing the established relationship. The data will also be processed to fulfill legal, accounting and tax obligations.
Personal data may also be processed for the purpose of enabling navigation and browsing within the APP.
Keep in mind that certain initiatives are implemented with the cooperation of other parties and that those same parties, as far as they are concerned, operate as independent data controllers (if you consented to data sharing through the PRIVACY DISCLAIMER) and must abide by the terms set forth by the Privacy Code.
Additionally, we wish to point out that processing purposes also means the collection, storage and processing of your data to perform statistical analyses in anonymous and/or aggregate form, with the possibility of identifying the user to check the quality of the services offered. Lastly, data may be processed – only when the user has expressly granted specific consent through the PRIVACY DISCLAIMER – for initiatives consistent with the pursuit of the social purposes of LEZIONI DI BACIO by the owners of the VIRALKISS® platform.

PROCESSING METHOD:
Electronic or otherwise automatic tools will predominantly handle your personal data.

COMMUNICATION AND DISSEMINATION OF PERSONAL DATA:
Your personal generic data may be disclosed to:
1.Individuals, companies or professional offices that provide assistance and advice to LEZIONI DI BACIO on accounting, administration, legal, tax and financial matters relating to the provision of Services;
2.Persons, entities or authorities who require the communication of your personal information as mandated by law or by order of the authorities;
3.Persons delegated and/or mandated by LEZIONI DI BACIO to perform activities strictly related to service provision and technical maintenance (including maintenance of network equipment and electronic communications networks) of the APP;
Additionally, the persons or categories of persons to whom personal information may be communicated or who are entitled to knowledge of said information as Data Processors (if appointed) or Representatives include: the LEZIONI DI BACIO staff in charge of managing administrative and/or technical aspects of the services, and IT managers for the platform through which services are provided.

OPTIONAL OR MANDATORY CONSENT:
The provision of data is compulsory for all that relates to the activation of services (registration, technical maintenance of the account, etc), which are not commercial in nature and for the offering of standard services. FAILURE TO PROVIDE PERSONAL DATA MAKES IT IMPOSSIBLE TO ACTIVATE SERVICES, INCLUDING REGISTRATION.
Conversely, it is ENTIRELY OPTIONAL AND NOT MANDATORY to provide consent to the processing of personal information for the development of ad-hoc initiatives consistent with the pursuit of the social purposes of LEZIONI DI BACIO carried out by VIRALKISS®. FAILURE TO PROVIDE THIS SEPARATE DATA PROCESSING CONSENT SHALL NOT PREVENT THE USER FROM REGISTERING FOR THE APP AND USING STANDARD SERVICES, AS THE ONLY CONSEQUENCE IS THE INABILITY TO ENJOY AND PARTICIPATE IN SAID INITIATIVES.
If you should decide not to give your separate consent to data processing for conducting ad-hoc initiatives that are consistent with the pursuit of the social purposes of the LEZIONI DI BACIO, such refusal shall have NO CONSEQUENCE WHATSOEVER.

PROCESSING OF SENSITIVE DATA:
We hereby inform you that we do not intend to handle sensitive user data, i.e. data aimed at revealing race or ethnic origin, philosophical, political, religious beliefs or trade union affiliation, membership in political, philosophical, religious or trade union groups, or information that may reveal sexual habits and health conditions.

DATA CONTROLLER AND DATA PROCESSING ASSOCIATES:
The identifying information of the Controller for data processing, as provided by her, is as follows: Dr. Sabrina Chinellato, resident on Via Settembrini 6, Spinea, 30038, Venice, Italy.

DATA STORAGE AND SECURITY MEASURES:
Data shall be stored for the time period defined by applicable Italian law and on servers located at the servers used by APP LEZIONI DI BACIO and powered by ReeVo Cloud Center 2, via Caldera 21, Milan, Italy (info@reevo.it).
In any case, storage of your data will exclusively cover the time period necessary to pursue the aforementioned purposes equal to the duration of the service relationship between you and the Data Controller. Should you cancel your account and stop using the services, your information will be deleted, unless needed for contractual, administrative, tax, accounting, or legal obligations following your cancellation in using the service. As soon as these obligations are satisfied, your data will be deleted.
We also wish to inform you that such data will be collected, processed and stored pursuant to the provisions of Articles 31 et seq. of the Privacy Code and Technical Specifications – Annex B to the Code – relating to security measures.
The database can be accessed only by authorised persons using methods that guarantee protection and confidentiality, thanks to the adopted security measures in place for the prevention of data loss, illegal or incorrect use of data and unauthorised access.
Each associate or supplier receives specific instructions concerning the handling of data as well as instructions that processors are bound to follow in order to avoid disciplinary and/or legal action.

ARTICLE 7 (RIGHT TO ACCESS PERSONAL DATA AND OTHER RIGHTS):
You may contact the Data Controller at any time, without formal obligations or by using the form preset by Data Protection Authority (available for free at www.garanteprivacy.it) to assert your rights as set forth by Article 7 of the Code, which we have reported below translated in English language for your convenience:

ARTICLE 7 OF ITALIAN LEGISLATIVE DECREE NO. 196, DATED 30 JUNE 2003:
1. The data subject shall have the right to obtain confirmation as to whether or not personal data concerning him exist, regardless of their being already recorded, and communication of such data in an intelligible form.
2. A data subject shall have the right to be informed:
•Of the source of the personal data;
•Of the purposes and methods of the processing;
•Of the logic applied to the processing, if the latter is carried out with the help of electronic means;
•Of the identification data concerning data controller, data processors and the representative designated as per Article 5, paragraph 2;
•Of the entities or categories of entity to whom or which the personal data may be communicated and who or which may get to know said data in their capacity as designated representative(s) in the State’s territory, data processor(s) or person(s) in charge of the processing.
3. A data subject shall have the right to obtain:
•Updating, rectification or, where interested therein, integration of the data;
•Erasure, anonymization or blocking of data that have been processed unlawfully, including data whose retention is unnecessary for the purposes for which they have been collected or subsequently processed;
•Certification to the effect that the operations as per letters a) and b) have been notified, as also related to their contents, to the entities to whom or which the data were communicated or disseminated, unless this requirement proves impossible or involves a manifestly disproportionate effort compared with the right that is to be protected.
4. A data subject shall have the right to object, in whole or in part:
•On legitimate grounds, to the processing of personal data concerning him/her, even though they are relevant to the purpose of the collection;
•To the processing of personal data concerning him/her, where it is carried out for the purpose of sending advertising materials or direct selling or else for the performance of market or commercial communication surveys.

The Association "LEZIONI DI BACIO" for VIRALKISS® 2016
English