Introduction

This Privacy Policy describes the information we process to run the Picturize Service as described in our Terms and Conditions. Whenever you use Picturize, you agree to this Privacy Policy.

Definitions and legal references

Application means the Picturize app and the Picturize Service, by which the Personal Data of the User is collected and processed.

Cookie means Trackers consisting of small sets of Data stored in the User's browser.

Data Controller (or Controller) means the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of the Application. 

Data Processor means the natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Subject means the natural person to whom the Personal Data refers.

European Union (or EU) means all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

GDPR means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (General Data Protection Regulation).

Personal Data (or Data) means any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Service means the service provided by the Application.

Tracker means any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Usage Data means information collected automatically through the Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use the Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User means the individual using the Application who, unless otherwise specified, coincides with the Data Subject.

Types of Data collected

Among the types of personal Data that the we collect, by ourselves or through third parties, there are Cookies and Usage Data. Complete details on each type of personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using the Application.

Unless specified otherwise, all Data requested by the Application is mandatory and failure to provide the Data may make it impossible for the Application to provide its Services. In cases where the Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Application.

Mode and place of processing the Data

A) Methods of processing

We take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the personal Data. The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. The Data may be accessible to certain types of persons in charge, involved with the operation of the Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data processors. 

B) Legal basis of processing

We may process personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes. Under some legislations we may be allowed to process personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of personal Data is subject to European Data protection law;

• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

• Processing is necessary for compliance with a legal obligation to which we are subject to;

• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in us;

• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party.

C) Place

The Data is processed at our operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, Data transfers may involve transferring the User's Data to a country other than their own. 

D) Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. We may be allowed to retain personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, we may be obliged to retain personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to Data portability cannot be enforced after expiration of the retention period.

The purposes of processing

The Data concerning the User is collected to allow us to provide our service, comply with any legal obligations, respond to enforcement requests, protect our rights and interests (or those of our Users or third parties), detect any malicious or fraudulent activity.

In addition, personal Data is collected for the following purposes and using the following services:

• Analytics: We keep the right to monitor and analyze web traffic and to keep track of the User’s behavior when using the Application.

• Hosting and backend infrastructure: To run the Application, we have to host and store certain personal Data of the User.

• Social features: We may use certain personal Data of the User to implement social features, such as getting connected with other Users.

• Push notifications: We may send push notifications to the User, however, the User may in most cases opt-out of receiving push notifications by visiting the device settings, such as the notification settings for mobile phones, and then change those settings for this Application, some or all of the apps on the particular device. Users must be aware that disabling push notifications may negatively affect the utility of the Application.

The rights of the User

Under the GDPR and other national legislation, the User may have the right to access, rectify, port and erase its Data. The User may also have the right to object to and restrict certain processing of its Data. 

Details about the right to object to processing

Where Personal Data are processed in the public interest, in the exercise of official authority vested in us or for the protection of our legitimate interests, users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. 

How to exercise the Users’ rights

Any requests to exercise Users’ rights can be directed by e-mail to: contact@picturize.app.

Additional information about Data collection and processing

A) Legal action

The User's Personal Data may be used for legal purposes by us in court or in the stages leading to possible legal action arising from improper use of the Application or the related Services. The User declares to be aware that we may be required to reveal personal Data upon request of public authorities.

B) Additional information about User's Personal Data

In addition to the information contained in this privacy policy, the Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

C) System logs and maintenance

For operation and maintenance purposes, the Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

D) How “Do Not Track” requests are handled

The Application does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

E) Changes to this privacy policy

We reserve the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within the Application. It is strongly recommended to check this page frequently, referring to the date of the last modification listed at the bottom. Should the changes affect processing activities performed on the basis of the User’s consent, we will collect new consent from the User, where required.

Legal information

This privacy policy has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy relates solely to this Application, if not stated otherwise within this document.

Date: 3 January 2022