PRIVACY POLICY STATEMENT

1. AIM OF PROCESSING
This Privacy Policy Statement, given to data subjects pursuant to art. 13 of Regulation (EU) 2016/679 and relating to this application available in mobile mode (hereinafter referred to as “App” or “SwaApp”), constitutes an integral part of the App and of the services offered through it, and it applies to the personal data, including special data, defined in art. 9 of the Regulation, supplied by the user of his own free will when signing the licence contract.
In particular, in order to access the services provided by the App, by creating an account, users must be registered with reference to the following personal data: nickname, e-mail, password. When the user installs or uses the App, specific information is collected relating to the device used, the connection and the localisation.
If the user uses integrated third party services when using the App (e.g. payment services), he passes on his personal data directly to the third parties in question, to whom he must refer for the processing of the data conferred. When using the services connected to the App, users may provide further personal data of their own free will, and also upload images and videos. Personal data used will be shared with the other users of the App.
We point out that users must be at least 18 years old to register for the App. Minors must obtain authorisation from their parents or legal guardians. Access by minors to the registration form is not and cannot however be controlled in any way by the Data Controller. Any false statements made by subjects under 18 years of age are presumed to have been made with the authorisation of their parents or their legal guardians, and it is they who are held responsible for any conduct by the minor connected with access to the App, the giving of consent for the purposes indicated or the use of the services. When registering for the App and using the services connected with it, the personal data of third parties may be processed. As an applicant registering for the App and with reference to the personal data of third parties, including those relating to minors, you henceforth warrant – accepting full liability in connection therewith as independent data controller – that this type of processing is based on the prior acquisition – on your part – of authorisation and consent from the third party/ies concerned to the disclosure of the data to Genia Business, fully indemnifying the Data Controller against any complaint, claim or request for compensation of damage caused by the processing that is made by third parties whose personal data have been processed with the use of the App and related services.

2. PURPOSES FOR WHICH DATA ARE USED
GENIA BUSINESS processes personal data supplied via the App:

  1.  for purposes relating to the supply of the services requested (e.g.: to allow you to register and have access to the App; to supply services connected with the App; to upload images and videos, etc.). including all accounting, administrative, logistic and organisational formalities and also to handle the “private area”;
  2. for purposes connected with the drawing up of statistics and scientific research involving aggregated or anonymous data, therefore without allowing the party concerned to be identified;
  3. in order to comply with any obligations laid down by current laws or regulations or by community legislation;
  4. in order to send you material and communications of an informative and promotional nature connected with the activities conducted by Genia Business. We also wish to inform you that you may decide, at any time, to withdraw consent previously given by traditional or automated methods, by simply notifying the Data Controller without any particular formalities, at the following address: privacy@swapappbc.com

3. DATA PROCESSING AND STORAGE PROCEDURES
Personal data are processed mainly in electronic, but also paper form for the period of time strictly necessary to achieve the purposes for which they were collected and in keeping with the provisions of art. 32 of the GDPR 2016/679 by specifically appointed subjects.
Personal details are kept for the prescription periods laid down by the law, whilst personal data contained in the private area and the account itself are erased by the Data Controller automatically one year from the date on which the contractual relationship comes to an end.
The user may eliminate the account at any time, using the App function designed for this purpose, thereby ceasing the processing of the data conferred, which will then be erased from the Data Processor’s servers. In this case, the user must be aware that the data previously shared with other users may continue to be visible and stored by third parties, and that the Data Controller and Data Processor shall not be held in any way liable in connection therewith.

These data, connected with the services provided by this App, are processed locally on the user’s mobile terminal and the servers of the Data Processor, Information Technologies S.r.l., situated in Italy and are entered in the company’s IT system in full compliance with current legislation, including security and confidentiality profiles, and in keeping with the principles of fairness and lawfulness in the processing of data (articles 5, 6, 32 of EU Regulation 2016/679).
The Data Controller does not use any automated decision-making process, as defined in article 22, paragraphs 1 and 4, of EU Regulation no. 2016/679.

4. COMPULSORY/OPTIONAL NATURE OF PROVIDING DATA
With reference to the purpose described under point 2a), consent must be given in order to benefit from the services covered by the contract. If consent is not given or given incorrectly, the service cannot be activated.
With reference to the purpose described under point 2b), even though they may prove useful, the supply of data is optional and failure to provide them will not prejudice the App registration/activation procedure.
With reference to the purpose described under point 2c), it is mandatory and failure to provide data will make it impossible for the Data Controller to meet obligations laid down by current laws or regulations or by community legislation.
With reference to the purpose described under point 2d), the supply of personal data for promotional and/or marketing purposes is optional. Failure to supply data in this case will not prejudice the conclusion of the contract or the activation of the App.

5. DISCLOSURE AND DISSEMINATION
Your personal data may be disclosed to:
1. Persons, companies or professional practices that offer Genia Business s.r.l assistance and consultancy services connected with accounting, administrative, legal, tax and financial matters relating to the supply of the services and the use of the App;
2. Subjects, bodies or authorities to which your personal data must be disclosed by operation of law or under a regulation or by orders given by an authority;
3. Subjects delegated and/or appointed in the manner described in art. 4, no. 10, of EU Regulation 2016/679 by Genia Business to carry out operations strictly linked to the supply of services, or, when necessary, external data processors appointed in accordance with art. 28 of the aforementioned Regulation.
With the exception of the situations described above, the user’s personal data are not disseminated.

6. RIGHTS OF THE DATA SUBJECT
The user may exercise the rights envisaged in EU Regulation 2016/679 in articles 15 to 22 at any time and, more precisely the right to: 
a) request confirmation as to whether or not his personal data exist;
b)  obtain information regarding the purposes for which the data are being processed, the categories of personal data, the recipients or categories of recipient to whom the personal data have been or will be disclosed and, whenever possible, the period for which the data will be stored;
c)  have data rectified or erased;
d)  obtain the restriction of processing;
e)  obtain data portability, that is, the right to receive them from a data controller, in a structured, commonly used and machine-readable format, and to transmit those data to another data controller without hindrance;
f)  object to processing at any time, including processing for direct marketing purposes;
g)  object to an automated decision-making process relating to natural persons, including profiling;
h)  request from the Data Controller access to personal data and rectification or erasure thereof or the restriction of the processing concerning the data subject or to object to their being processed, as well as the right to data portability;
i)   withdraw consent at any moment, without prejudice to the lawfulness of the processing based on the consent given prior to the withdrawal;
j)   lodge a complaint with the Data Protection Authority.
To exercise these rights, you can write to the Data Controller – Genia Business Srl - Via Caduti del Pilastro 8 - 40055 Castenaso (Bologna), Italy – or send an e-mail to:
privacy@swapappbc.com      .

The Data Controller may modify or simply revise this App Privacy Policy Statement, either wholly or partially, also in response to changes in laws or regulations dealing with this subject and safeguarding your rights. Users will be notified of any variations or revisions to the Privacy Policy Statement by e-mail as soon as they are introduced and these will be binding as soon as the notification is received. We therefore invite you to visit this section regularly so that you can familiarise yourself with the most recent, revised version of this Privacy Policy Statement, and keep up-to-date with the information that we collect and the use to which it is put.

7. Data Controller and Data Processor
Once the App has been installed and the user has consulted and benefited from the services provided by it, personal data relating to identified or identifiable natural persons may be processed. Details of the Data Controller and provider of the App are given below:
Genia Business Srl - Via Caduti del Pilastro 8 - 40055 Castenaso (Bologna), Italy - VAT No. 02727491207.

In accordance with art. 28 of the GDPR we indicate as external data processor the company IT – Information Technologies S.r.l., with registered office at Via Ferrarese no. 219/7, 40128 Bologna (Italy), that offers services for the maintenance of the App.
An up-to-date list of other data processors is available from the Data Controller and may be requested by e-mail from the following address privacy@swapappbc.com .

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