Privacy Policy

Dear User,

Genia Business Srl (hereinafter referred to as "Genia Business" or "Holder"), as a Holder of the Treatment pursuant to Legislative Decree no. No.196/2003 and subsequent amendments - Personal Data Protection Code (hereafter "Privacy Code") - Considers the privacy and protection of personal data as one of the main objectives of your business. We therefore invite you before communicating any personal data to the Holder to read this privacy policy carefully as it contains important information about your privacy, personal data protection, and security measures taken to ensure confidentiality in full compliance with applicable law. This Privacy Policy also includes:

  1. it is meant for this application available in mobile mode (hereinafter referred to as "App" or "SwapApp") that is managed by the Holder;
  2. it is an integrated part of the App and the services offered through it;
  3. it is also to be understood as disclosure information made pursuant to art. 13 of the Privacy Code to those who interact with the services of this App;
  4. it conforms to Recommendation no. 2/2001 on minimum requirements for online data collection in the European Union, adopted on 17 May 2001 by the Working Party “Article 29”.

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The Holder informs you that the processing of her personal data will be based on the principles of fairness, lawfulness, transparency and the protection of your privacy and rights. Your personal information will therefore be processed in accordance with the laws and regulations of the Privacy Code as well as those provided by EU law.

INDEX
Below we provide the index of this Privacy Disclosure so that you can easily find information regarding the processing of your personal data that interests you.
1. HOLDER AND RESPONSIBLE FOR PERSONAL DATA PROCESSING
2. PERSONAL DATA SUBJECT TO TREATMENT
3. FINALITY OF THE TREATMENT AND OBLIGATORY OR OPTIONAL NATURE OF THE PROVIDED DATA
4. TREATMENT, SAFETY AND DATA PROCESSING PROCEDURES
5. COMMUNICATION AND DISTRIBUTION
6. RIGHTS OF THE INTERESTED PARTIES
7. TERMINATION OF TREATMENT
8. MODIFICATIONS OF THE PRIVACY DISCLOSURE
9. CONTACTS

1. HOLDER AND RESPONSIBLE FOR PERSONAL DATA PROCESSING

Following the installation of the App, the consultation and the use of the services that it provides, personal data relating to identified or identifiable individuals can be processed. The identification details of the Holder and App Manager are as follows:
Genia Business Srl - Via Caduti del Pilastro 8 - 40055 Castenaso (Bologna) - P.IVA 02727491207.

In accordance with art. 13, com. 1 letter F) and 30 of the Privacy Code, we indicate as responsible of personal data processing IT - Information Technologies Srl, headquartered in Via Ferrarese n.219/7, Bologna (40128 - BO), which provides maintenance services for the App. An updated list of any additional treatment managers is available from the Holder and may be requested by e-mail at the following email address privacy@swapappbc.com.
Your personal data may be brought to the attention of employees or collaborators of the responsible of data or of the Holder, belonging to the categories of administrative, commercial, legal, accounting or IT administrator, depending on the processing and all the activities related to the supply of app services and their use. These subjects, acting under the direct authority of  the responsible of data or of the Holder, are appointed as persons in in charge of data processing pursuant to art. 29 and 30 of the Privacy Code and receive appropriate operating instructions, to which they must comply.

2. PERSONAL DATA SUBJECT TO TREATMENT

To access the services provided by the App, by creating an account, it is mandatory to register users through the following personal data: first name, last name, email, password.
When the user installs or uses the App, the latest collects specific information about the device, connection, and localization. If you use third-party services using the App (for example, payment services), you will provide your personal information directly to third parties to which you will need to refer for the processing of your data.
While using the services associated to the App, users may voluntarily provide additional personal information, as well as upload images and videos. The personal data used to create your business card will be shared with other users of the App.
Regarding the registration to the App, we underline that this can only be completed by peopleover 18 years of age. Parental or guardian's permission is required for minors. However, the access of minors to registration forms is not and can not in any way be controlled by the Holder. Any unusual statements by minors of  18 imply the consent of the parents or their tutors, assuming responsibility for any child's behavior when accessing the App, giving consent to the purposes indicated and the fruition of services.

When registering to the App and to the services associated to the App, personal data may be processed by third parties. As an applicant to the registration to the App and with reference to the personal data of third parties, including those of minors, you accept - assuming any related liability as an autonomous Holder - that such special treatment is based on the prior acquisition – from you – of the authorization and consent of the third party to the disclosure of the data to Genia Business, giving the broadest possible indemnity for any contestation or claim for damages from such treatment that it would reach the Holder from third parties whose personal data have been processed through the use of the App and its services.

3. FINALITY OF THE TREATMENT AND OBLIGATORY OR OPTIONAL NATURE OF THE PROVIDED DATA

The data you provide through the App will be processed by the Holder for the following purposes:

1. the purpose of delivering the required services (eg registering and accessing the App, delivering services connected to the App, uploading images and videos, etc.).

The provision of your data for the aforementioned purpose 1 is optional, but failing to provide it may render impossible the provision of the required services.

According to art. 24 comm. 1 letter b) of the Privacy Code we do not require consent to the processing of your personal data common for these purposes as necessary to fulfill the obligations arising from a contract of which the subject is part of and/or to fulfill, before the conclusion of the contract, to the specific requests of the person concerned;

2. statistical purposes and scientific research on aggregated or anonymous data, without the possibility of identifying the person concerned.

Treatments on aggregated or anonymous data do not include the application of the Privacy Code;

3. fulfill any obligations under applicable laws, regulation or UE legislation.

The disclosure of your data for the aforementioned purpose 3. is compulsory, failing to provide it would not allow the Holder to comply with the obligations laid down by law, regulation orUE legislation.

According to art. 24 comm. 1, letter a) of the Privacy Code you do not need declare your consent to the processing of your personal data for these purposes;

4. sending material and promotions inherent to the activities of Genia Business. In accordance with the provisions of the Guarantor Authority for the Protection of Personal Data "Guidelines on Promotional Activity and Contrasting Spam - July 4, 2013 [2542348]", in the case of giving the consent to the receipt of information, material and communications regarding the activities of the Holder, we inform you that such activities can be exercised, as foreseen by the current discipline, by means of paper mail, telephone contact by operator ("traditional mode"), e-mail, sending sms, fax and use of social network ("automated modes"). We also inform you that at any time you may decide to revoke the previously granted consent for traditional or automated chanels by communicating it to the Holder without any formalities, writing to: privacy@swapappbc.com.

The disclodure of your data for the above-mentioned purpose 4. is optional and requires your prior consent. Failure to grant your consent to such processing may affect access to the App and the use of the services offered by the App.

4. TREATMENT, SAFETY AND DATA PROCESSING PROCEDURES

Your personal data is handled by the Holder - or by third parties carefully selected for their reliability and competence, appointed responsibles for the treatment - limited to the achievement from the Holder of the above stated purposes, mainly with automated tools and possibly even in paperwork, for the time strictly necessary to achieve the goals for which they were collected.
Specific security measures are observed to prevent data loss, misuse or incorrect use and unauthorized access in full compliance with Art. 31 and following the Privacy Code and the Technical Specifications - Annex B to the Privacy Code - regarding minimum security measures.
The data treatment associated with the services of this App is performed locally on the mobile terminal of the user and at the servers of Information Technologies S.r.l, located in Italy.

5. COMMUNICATION AND DISTRIBUTION

Your personal information may be communicated to:
1. persons, companies or professional firms providing assistance and advice to Genia Business s.r.l in accounting, administrative, legal, tax and financial matters relating to the provision of services and the use of the App;
2. persons, entities or authorities to whom the disclosure of your personal data is compulsory under statutory provisions or regulations or orders of the authorities;
3. entities and/or agents delegated by Genia Business to carry out activities strictly related to providing services, duly appointed in charge of data treatment pursuant to art. 30 of the Privacy Code, or, where necessary, appointed persons responsible for data treatment pursuant to art. 29 of the Privacy Code;
4. Upon obtaining your consent, the Holder reserves the right to perform treatments that integrate the disclodure of your personal data to third parties for purposes other than those referred to in paragraph 3.

6. RIGHTS OF THE INTERESTED PARTIES

Subjects to whom personal data are refered have the right at any time to obtain confirmation of the existence or not of the same data and to know its content and source, to verify its accuracy or to request its integration or updating, or rectification (Article 7 Privacy Code).
Under the same article you have the right to request the cancellation, transformation into anonymous form or the blocking of the data processed in violation of the law, and to oppose in any case, for legitimate reasons, to its treatment.
To exercise these rights, you can write to the Holder - Genia Business Srl - Via Caduti del Pilastro 8 - 40055 Castenaso (Bologna)- or send an email to: privacy@swapappbc.com.

7. TERMINATION OF TREATMENT

You will be able to delete the account at any time by using the App function, resulting in the cessation of the processing of the data being transferred, which will be deleted from the Data Manager's servers. In such a case, the user must be aware that previously shared data with other users may remain visible and preserved by third parties, without any liability of the Holder and App manager.

8. MODIFICATIONS OF THE PRIVACY DISCLOSURE

The Holder may modify or simply update this Privacy Policy of the App, in whole or in part, also due to variations in laws and regulations that govern this matter and protect your rights. Such changes and updates to the Privacy Statement will be notified to users via e-mail as soon as they are introduced and will be binding as soon as you receive such communication. We therefore invite you to visit this section regularly to be aware of the latest and up-to-dated version of our Privacy Policy so that you can be always up to date on the information we collect and on the use we make.

9. CONTACTS

If you wish to receive any information on your data processing by the Holder you can send an email to privacy@geniabusiness.com.

SwapApp by Genia Business Srl
Via Caduti del Pilastro 8 - 40055 Castenaso (BO)
info@swapappbc.com
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