Privacy Policy

Pursuant to Legislative Decree 196/2003 and Regulation (EU) 2016/679 (hereinafter referred to as the “Regulation”), this page describes the methods of processing personal data of users who use the application of Wacebo Europe Srl.

This policy applies to the information and personal data we collect during the provision of the service offered through the portal you are browsing.

Data Controller

The Data Controller is Wacebo Europe Srl, with registered office at Via G. Bonelli n. 40 – 00127 Rome (RM), (Email: [email protected], PEC: [email protected], Tel.: +39 0698383431).

Source and Type of Data

Wacebo Europe Srl collects personal data from the User, voluntarily provided at the time of:

a) registration on the Wacebo Europe Srl application. Such data may include, by way of example and not limitation: name, surname, email, telephone number, gender, year of birth.

b) sending a message using the “contact us” feature. Sending messages involves the processing of the sender’s contact details, necessary to provide a response, as well as any personal data included in the communication. This process is always optional, explicit, and voluntary. The data provided will be used with IT and electronic tools solely for the purpose of providing the requested service and, for that reason, will be stored only for the period in which the service remains active.

Purpose of Data Processing

1) Personal data collected by Wacebo Europe Srl are processed to allow registration on and use of the application;

2) to respond to any contact requests;

3) to send informational or commercial promotional communications (e.g., event invitations, communications regarding new services, promotional offers). Such processing may be carried out automatically via email and may take place as long as the data subject has not withdrawn consent to the use of their data.

4) Finally, the data will be used to manage and monitor risks, prevent possible fraud, manage potential disputes, and take legal action when necessary.

Legal Basis for Processing

With reference to the purposes indicated in the previous paragraph, the legal basis for such processing is, in relation to:

1) and 2) the performance of a contract to which the data subject is a party or the implementation of pre-contractual measures taken at the data subject’s request;

3) the express consent of the data subject for the specific purpose;

4) the need to pursue the legitimate interests of the Data Controller (in particular with regard to fraud prevention).

Data Recipients

The personal data processed by the Data Controller are not disclosed, meaning they are not made known to unspecified subjects in any possible form, including making them available or simply consultable.

However, they may be communicated to employees working under the authority of the Controller or to persons authorized to process the data. Processing by such subjects will take into account their roles and job responsibilities, their respective competences, and will be carried out in compliance with the instructions given by the Controller. Wacebo Europe Srl has appointed third-party service providers as external Data Processors, who are provided only with the personal data necessary to deliver their services and are not permitted to use or disclose the personal data of the data subjects for any other purposes without prior authorization.

Data Processing Methods

Wacebo Europe Srl adopts data processing methods in line with the security requirements set forth by the “Code regarding the protection of personal data” (Legislative Decree 196/2003) and the European Regulation 2016/679 (GDPR). Wacebo Europe Srl has implemented an information security program that includes IT, administrative, technological, and physical controls designed to reasonably safeguard the User’s personal data, including encryption technology in accordance with industry standards.

Data Retention

User data will be retained only for the time necessary to ensure the proper provision of the offered services. In the event of service termination at the User’s initiative, the related data will be retained for no longer than three months, subject to any specific legal obligations for public security purposes. Furthermore, if a user provides the Controller with personal data that are not requested or not necessary for the provision of the requested service, Wacebo Europe Srl cannot be considered the Controller of such data and will delete them as soon as possible.

Rights Regarding Personal Data

With regard to the personal data subject to processing under this policy, the data subject has the right, at any time, to:

• request from the Controller access to their personal data and related information (Art. 15 of the GDPR); rectification of inaccurate data or completion of incomplete data (Art. 16 of the GDPR); erasure of personal data concerning them (when one of the conditions set out in Art. 17, para. 1 of the GDPR applies, and in compliance with the exceptions in para. 3 of the same Article); restriction of processing (in the cases provided for by Art. 18, para. 1 of the GDPR);
• request and obtain from the Controller — in cases where the legal basis for processing is consent and the processing is carried out by automated means — their personal data in a structured, commonly used, and machine-readable format, also for the purpose of transmitting such data to another controller (so-called right to data portability — Art. 20 of the GDPR);
• object at any time to the processing of their personal data on grounds relating to their particular situation (Art. 21 of the GDPR);
• withdraw consent at any time, limited to cases where processing is based on their consent for one or more specific purposes. Processing based on consent and carried out before withdrawal remains lawful (Art. 7, para. 3 of the GDPR);

Requests may be submitted by contacting the Controller via PEC at [email protected], by email at [email protected], or by registered letter to Via G. Bonelli n. 40 – 00127 Rome (RM).

Third-Party Privacy Policies

Through the platform, content and links to external sites may be provided, to which you may be redirected for various purposes. Moreover, the use of services provided by third parties may require you to provide them or others with your personal data for purposes not directly related to the execution of the service. The services mentioned in the app may have privacy policies different from ours. We therefore encourage you to review the privacy policies of such services before providing them with personal information. Wacebo Europe Srl is responsible only for what is expressly stated in this policy.

Refusal to Provide Data

Refusal to provide the data necessary for registration on the Wacebo Europe Srl application will prevent successful completion of the operation. Additional data indicated in the section “Source and Type of Data” that are not mandatory for registration are provided on a voluntary basis; however, if the data subject decides not to provide them, Wacebo Europe Srl may not be able to offer certain services.

Automated Decision-Making Processes

The Controller does not perform processing operations involving automated decision-making processes on personal data of individuals, except for those who request to receive informational or promotional communications.