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Privacy policy ex art. 13 GDPR

 

Comehome s.r.l. with registered office in Via Malaga 6, Milan, Italy (hereinafter “Comehome”) cares about your privacy!

This privacy policy has been prepared in Comehome’s style and also pursuant to Article 13 of the EU Regulation 2016/679 (hereafter: “Regulation”) and uploaded to your App Store or Google Play (or whatever third party platform you are using) (hereafter: “Store”) in order to tell you what we do with your data when you host or register for an event via our app (hereafter: “App”).

We may ask you to consent to the processing of your personal data but we will give you all the information you need to make this consent free, express and informed.

All information and data that you enter on the App or that is acquired in the context of the events that you host or participate in (hereinafter referred to as “Services”) will be treated in accordance with the rules and principles of the Regulations and with our philosophy of maximum confidentiality: what happens in Comehome stays in Comehome!

Comehome treats your personal data in accordance with the principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimisation, accuracy, integrity and confidentiality. Especially confidentiality!

 

 

 

 

  1. Controller

The Controller of the processing carried out through the App is Comehome s.r.l., as defined above. We are a company, not an individual, our strength is in the group and for this reason, to have any information regarding the processing of personal data by us, including the list of those responsible for processing data, you can write to the following address: dpo@comehome.fun and our DPO, with our staff, will be happy to give you all the information you need!

  1. The personal data being processed

After you have installed the app on your device, whether you want to organise an event with two swipes on your smartphone or attend a party with a giant tablet, Comehome will process your personal data!

The personal data we process is the data that YOU decide to provide us with. You decide what you want to tell us about yourself, although some data will be absolutely necessary for you to take part in events, for example we need to know your name and location data. We will need to associate you with an online identifier if you want to log in via a social network. When you register for or organise an event we will have access to one or more of your identity details, such as your likes and dislikes! (hereinafter only “Personal Data”).

The Personal Data processed through the App are as follows: personal data, contact data, payment data, data generated by the connection on the App (IP), email address or social profile

a) Data related to your Device

When you press “install” on the Store, you are providing us with explicit consent to install the app on your mobile device (hereafter just “Device”), by doing so we inform you that you are authorising Comehome to read some Personal and Non-Personal Data on your Device that is absolutely necessary to install our wonderful app!

For example, we may read the model of the Device, the version of the operating system and perhaps even the screen resolution.

We cannot deprive ourselves of this information, otherwise we would not be able to make our app work, but if you do not want to provide us with this information, simply uninstall the Comehome app.

When you open the app for the first time we will ask for your consent to share personal data that is not related to the Device.

By giving your consent in the banner when you first open the app, you authorise us to share other Personal Data that is intended to identify your Device (e.g. IDFA) in order to provide you with advertising banners in line with your preferences expressed when using the app. If you have not already done so, if you wish to object to the sharing of this data between the operating system of your Device and the App, you may do so by configuring your Device settings as explained in section 2.e below.

We will ask you for your geographic location so that we can tell you what events and festivals are happening in the city you are in.

This consent to the use of Personal Data is entirely optional but extremely useful to Comehome.

Remember that you can always revoke the sharing of your location from your Device settings and simply provide a physical address, or the city in which you are interested in the Services.

b) Data provided voluntarily by the data subject

When using certain functions of the App, you may process Personal Data of third parties that you send to Comehome. In this case, you are the autonomous data controller, assuming all the obligations and responsibilities of the law. In this regard, you hereby grant Comehome the widest possible indemnity with respect to any dispute, claim, request for compensation for damages from processing, etc., that Comehome may receive from third parties whose Personal Data has been processed through your use of the functions of the App in violation of the applicable data protection regulations. In any case, if you provide or otherwise process the Personal Data of a third party in the use of the App, you hereby guarantee – assuming all related responsibility – that this particular processing hypothesis is based on an appropriate legal basis in accordance with Article 6 of the Regulation, which legitimises the processing of the information in question.

The data relating to your images is based on the contractual relationship between you and Comehome, in this sense, once you have given your consent to the use of the images, we may use them to relay posts on social networks or in special marketing campaigns. You may object to this processing of your personal data by revoking your consent to the processing of the image. (see section 8 “Rights of data subjects”).

c) Data processed in the context of interaction with social media and virtual meeting platforms (i.e. Zoom)

In addition to filling in the registration form, if you have a Facebook profile, you can also simply click on the “Login with Facebook” button. In this case, Facebook will automatically send ComeHome some of your Personal Data specified in the “pop-up” window that appears at the time of the request, and there will be no need for you to fill out any further forms.

As far as the possibility of participating in virtual events is concerned, we will not collect any further data, but the Personal Data you send via the platform may be processed by our partners, i.e. those applications such as Zoom or Google Meet that allow Comehomers to see each other virtually. To this end, we have designated the vendors of these platforms as data processors, in order to guarantee Comehomers the utmost confidentiality.

d) SDKs and tracking technologies

SDKs (Software Development Kits) and related technologies are information that applications record and/or read on your devices. Typically, these technologies allow application Controllers to analyse the use of applications in order to avoid malfunctions and improve the user experience. Comehome uses SKDs and related technologies provided by third parties who generally process Personal Data on behalf of Comehome in their capacity as data controllers for the purpose of providing the Services. There may be residual cases in which certain services provided to Comehome by third parties may involve access by such third parties to Personal Data and other information contained on your Device, including for purposes beyond the provision of the Services. With respect to any such further processing, the third parties act as independent data controllers, and for this reason we list below links to the third parties’ privacy policies on the use of your Personal Data, as well as those that Comehome has designated as data controllers:

– Swrve: https://www.swrve.com/company/privacy-policy

– Flurry: http://www.flurry.com/legal-privacy/privacy-policy

– Localytics: https://www.localytics.com/privacy-policy/

– Facebook: https://www.facebook.com/policy.php

– AppFlyer: https://www.appsflyer.com/privacy-policy/

– Google Analytics: https://www.google.com/intl/it_it/analytics/learn/privacy.html

– Splunk: https://www.splunk.com/en_us/legal/privacy/privacy-policy.html

– Plot: https://www.plotprojects.com/privacypolicy/

– InLoco Media: https://www.inlocomedia.com/politica-de-privacidade/

– Ogury: http://www.ogury.co/privacy.html

– Pubnative: https://pubnative.net/privacy-policy/

– AdMob: https://www.google.com/intl/en/policies/privacy/

– Facebook ADV: https://www.facebook.com/policies/ads

If you wish to prevent the operating system of your Device from sharing some of your Personal Data (e.g. IDFAs) with Comehome or with the aforementioned third parties for profiling purposes, you can do so by setting your Device accordingly. In particular, if your Device is iOS, go to “Settings”, then “Privacy”, then “Advertising” and activate the “Restrict data collection” button. On the same page you can also reset your Ad ID. If your device is Android, go to “Google Settings” or “Settings”, scroll down to “Google”, then “Ads” and select “Disable interest-based ads” or “Disable ad customisation”.

  1. Purpose of processing

Now it’s time to tell you why we process your personal data.

First of all, we need your personal data in order to a) Provide you with services! i.e.: 1) the organisation of events; 2) the participation in events; 3) the newsletter service; the legal basis for the processing of Personal Data for this purpose is art. 6.1.b of the Regulation, i.e. these data are necessary to provide you with the services you have requested! You can decide not to provide us with this data but we will not be able to provide you with the service.

We may also need your data to respond to you! or b) to respond to requests for assistance or information that we may receive from you via the “Contact Us” form within the App or by reviewing events; the legal basis for processing Personal Data for this purpose is art. 6.1.b of the Regulations, i.e. this data is necessary to provide you with the services you have requested! You can decide not to provide us with this data but we will not be able to provide you with the service.

Comply with the law! I.e. c) to fulfil any legal, accounting and tax obligations; the processing is necessary to fulfil a legal obligation to which Comehome is subject, according to art. 6.1.c. of the Regulations.

to propose new events to you and to contact you in order to organise new events and to help you organise them; or d) to carry out direct marketing by e-mail for services similar to those you have previously used, unless you object to this by writing to dpo@comehome.fun or subsequently when you receive the relevant e-mail marketing messages; the legal basis for this purpose is Art. 6.1.a. Your consent to this processing is completely optional and, even if you decide not to give it, the use of the services will not be affected. If you wish to object to the processing of your Personal Data for marketing purposes, you may do so at any time by sending a request to dpo@comehome.fun, using the link at the bottom of the email.

To know how many people attend the events that we help you to organise or e) to carry out studies, research, market statistics; to send you advertising material, information, commercial information or surveys to improve the App (“customer satisfaction”) by e-mail or text message, and/or through the use of the telephone with operator and/or through the official Comehome pages on social networks;

We may also ask you to update your data or provide consent again, this will be done on the basis of our legitimate interest (art. 6.1.f GDPR) in accordance with the principle of data accuracy. Personal data will also be processed as necessary for the sole legitimate interests of Comehome, including our interests in providing an innovative, personalised, secure and rewarding service to our users, unless such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require the protection of personal data. During such processing activities we may suggest you as a user, processing only data relating to your user name and the events in which you participate.

In the event that you wish to become a Host (user who can host events), your data may be shared with persons authorised to process it in accordance with Article 29 GDPR, so-called Ambassodor, i.e. users of Comehome who have become Hosts before you, who will accompany you in your first steps. These users have been instructed by Comehome to respect the principles of the Regulation.

  1. Recipients of Personal Data

We may need to share your Personal Data for the purposes you have read in section 3.

We may share your data with persons, companies or professional firms that provide assistance and consultancy to Comehome and in accounting, administrative, legal, tax, financial and debt collection matters relating to the provision of the Services; i.e. lawyers, accountants and in general the professionals Comehome needs to comply with the law!

We may share your information with entities that are useful for the provision of the Services (e.g. hosting providers or email platform providers).

We may share your information with persons, entities or authorities to whom we are required to disclose your Personal Information by law or order.

Finally, we may share your data with persons whom Comehome authorises to process Personal Data in order to allow Comehome to carry out activities strictly related to the provision of the Services, who have committed themselves to confidentiality or have an adequate legal obligation of confidentiality.

  1. Transfers of Personal Data

Comehome does not transfer Personal Data outside of the European Union.

  1. Data Retention

The Personal Data processed for the purposes set out in section 3(a-b) will be retained for the time strictly necessary to fulfil these purposes. In any event, since the processing is carried out for the provision of Services, Comehome will process the Personal Data for the period of time permitted by Italian law for the protection of its interests (Article 2946 of the Civil Code and subsequent amendments).

Personal Data processed for the purposes set out in section 3(c) will be retained for as long as required by the specific obligation or applicable law.

For the purposes set out in section 3(d-e), your Personal Data will be processed until you withdraw your consent. However, Comehome may retain your Personal Data for as long as permitted by Italian law to protect its interests (Art. 2947(1)(3) of the Italian Civil Code). Further information regarding the data retention period and the criteria used to determine this period may be requested by writing to the DPO at the following address: dpo@comehome.fun

  1. Rights of data subjects

As a European citizen, and more importantly, as a Comehomer, you can exercise your rights!

You can request the right of access to your Personal Data, as established by art. 15 of the Regulation, and we will give you all the data you have provided us with in an intelligible format.

You can also request the rectification and erasure of your Personal Data, as set out in Articles 16 and 17 of the Regulation, or you can object to the processing of your Personal Data. You can also ask us to restrict the processing of your Personal Data as provided for by article 18 of the Regulation.

You may also request that we provide your data in an interoperable format, as set out in Article 20 of the Regulation.

Requests should be made in writing to our DPO and to the following address: dpo@comehome.fun

In any case, you always have the right to lodge a complaint with the competent supervisory authority (Garante per la Protezione dei Dati Personali), pursuant to article 77 of the Regulation, if you believe that the processing of your Personal Data is contrary to the legislation in force.

  1. Changes

This Privacy Policy is in force from 1 March 2021 and is subsequently modified whenever Comehome endeavours to provide new services. Comehome reserves the right to modify or simply update the content, in part or in full, including due to changes in applicable legislation. Comehome will inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the App. Comehome therefore invites you to visit this section regularly in order to be aware of the most recent and updated version of the privacy policy, so that you are always up-to-date on the data collected and the use made of it by Comehome.