The purpose of this document (hereinafter “Privacy Policy”) is to inform Users with regard to
personal data, considered as any information that allows the identification of a natural person
(hereinafter “Personal Data”), collected from the website and from the application
www.aptagram.com (hereinafter, the Application).
The Data Controller, as identified below, may amend or simply update, wholly or in part, this
Privacy Policy informing the Users about the changes. The amendments or updates shall be binding
as soon as they are published on the Application. Therefore, the User is invited to read the
Privacy Policy at every access to the Application.
If the User does not accept any amendments to the Privacy Policy, the User must terminate the use
of the Application and he may ask the Data Controller to remove his Personal Data.
1. Personal Data collected by the Application
The Data Controller shall collect the following categories of Personal Data:
1.1. Voluntary contents and information provided by the User
- Contact information and contents: Personal Data that the User voluntarily provides to the
Application during use, such as personal details, contact information, login credentials to
services and / or products provided, interests and preferences, personal interests and
preferences and any other personal contents, etc.
- Sensitive data: Personal Data revealing racial or ethnic origin, political opinions, religious
or philosophical beliefs, or trade union membership, and the processing of genetic data,
biometric data for the purpose of uniquely identifying a natural person, data concerning
health or data concerning the sex life or sexual orientation of a natural person.
- Personal Data from social media: Users may share with the Application the data they have
provided to social media. The User can monitor Personal Data, which the Application may have
access to 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 authorising the
Data Controller to have his Personal Data access, the User gives his consent to the
acquisition, processing and retention in accordance with the Privacy Policy.
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.
1.2. 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: Personal 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 Personal Data concerning User’s location, which
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.
1.3. Personal Data collected through cookies or similar technologies
Cookies, or any type of persistent cookies and systems for tracking Users, are not used for the
communication of personal information. Therefore, Users’ Personal Data is not collected through
the use of such technologies. 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 and legal obligations as well as for the following purposes:
- Registration and authentication of the User: to allow the User to register in the Application
for access and identification.
- Support and contact with the User: to answer User’s requests and provide help in case of
issues.
- Comment and feedback: to allow the User to post reviews and comments.
- Interaction through live chat: to allow the User to interact via live chat.
- Login through external platforms’ accounts: to allow the User to log into the Application
using external platforms’ accounts (e.g. Google, Facebook).
- EXTERNAL management of payments via credit card, bank transfer or other means: to manage
Users’ payments through external platforms that collect payment data without allowing the
owner of the Application to access it.
- Technical monitoring of the infrastructure for maintenance, fixing and improvement of
performance: to identify and solve technical issues and improve performance.
- Statistic only with anonymous Data: to analyse statistics based on aggregated data or data
that does not allow to identify the User.
- Monitoring, analysis and tracking of the User behavior: to monitor and analyse how the User
behaves in the Application.
- Users’ profiling: to group and analyse in an automated way the characteristics and the
behaviours of the User and provide personalised services and messages.
- User’s experience personalisation: to modify the Application and adapt it to the User’s
needs.
- Sending of e-mails or newsletter and handling of mailing list: to contact the User using
e-mails containing commercial and promotional information concerning the Application.
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
support@aptagram.com.
4. Legal basis for the processing
User’s Personal Data is processed on the following legal basis:
- User’s 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
- Processing is necessary for the purposes of the vital interest pursued by the Data Controller
or by a third party
It is always possible to ask the Data Controller to clarify the legal basis of each processing at
the following mailing address support@aptagram.com.
5. Place
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 support@aptagram.com or at the
following mailing address Via Germania n.7 int.12, 35010 Vigonza (PD), Italia.
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
Personal Data will be stored for the time necessary to perform the purposes for which they have
been collected.
In particular, Personal Data will be stored for the whole duration of the agreement, to fulfil the
inherent and consequent obligations, for the compliance with law provisions and for defensive
purposes.
When the Processing of Personal Data is based on the User consent, the Data Controller may store
Personal Data until the withdrawal of such consent.
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 or stored in a form that shall not allow the identification of
the User within 30 days from the end of the storage period. At the expiration of such period, the
right to access, rectify, erase and of portability of Personal Data can not be exercised.
8. Automated individual decision-making
All collected Data shall not be subject to automated individual decision-making, including
profiling, which may produce legal effects concerning the User or may significantly affect the
User.
9. Rights of the User
The Users may exercise specific 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.
10. Data Controller
- The Data Controller is Aptagram srl
- Registered office in Via Germania, n.7 int.12 35010 Vigonza (PD)
- Tax Code/VAT Code: 05610900283
- E-mail simone.simionato@aptagram.com
- Certified e-mail aptagram@pec.it
- Phone +39-049-859-7926