PRIVACY POLICY
pursuant to Regulation (EU) No. 679/2016 (“GDPR”)Welcome to the www.therelovution.com Platform (“Platform”).This Privacy Policy provides users with information regarding the processing of personal data collected automatically or voluntarily when accessing and browsing the Platform, as well as when using the services provided therein.Navigation is permitted only to adults and requires prior registration.For questions regarding your account or how to contact customer service, please reach out to our support center at support@id-entity.it. For inquiries about this Privacy Policy or our use of your personal data, cookies, or similar technologies, please contact us via email at privacy@id-entity.it. Please note that for your safety and ours, we may need to authenticate your identity before processing your request.The Platform may contain both affiliated and non-affiliated hyperlinks to websites, web pages, or online services of third parties. By clicking on these links, the user can access multimedia content that, being exclusively under the control of the aforementioned third parties, is beyond the control of Identity s.r.l. and is not governed by this Privacy Policy in any way. Identity therefore advises users to exercise caution when subscribing to services offered by third parties and to carefully read the data processing notices provided by them, over which Identity cannot exert any control or be held responsible.
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1. Data Controller
IDENTITY s.r.l., with registered office in Turin (TO), Corso Francia No. 54, VAT and Tax Code No. 12950850011, certified email: info.identitysrl@pec.it, email: support@id-entity.it (“Identity”).
2. Data Protection Officer
Fabrizio Martini, email address fmartini@spazio88.com, certified email spaziottantottosrl@pec.aruba.it (“DPO”).
3. Types of Personal Data Processed, Purposes of Processing, Legal Bases, and Nature of the Provision of Personal Data"Personal data" means "any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or to one or more factors specific to their physical, physiological, genetic, mental, economic, cultural, or social identity." Identity processes the personal data listed below ("Personal Data").The processing may also concern the "special categories of personal data" referred to in Article 9 of the GDPR, namely "personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, as well as genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a person's sex life or sexual orientation" ("Special Categories of Personal Data"). Specifically, Identity processes the following Special Categories of Personal Data:Information suitable to reveal sexual orientation;Where communicated by the user, information suitable to reveal racial and ethnic origin, as well as religious orientation.In any case, Identity undertakes to collect only information that is adequate, relevant, and limited to what is strictly necessary for the purposes pursued from time to time, ensuring this does not result in a limitation or other violation of the user's rights and freedoms.Browsing DataPersonal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodBrowsing data, such as connection data, IP addresses, domain names, and other parameters related to the browser and operating system used by the user, log data, data regarding installation and configuration licenses, data regarding registrations made, interaction and transaction processes, performance indicators, data regarding browsing flows and page views, use of functions and counts.To enable navigation of the Platform, derive anonymous statistical information on its use, verify its correct operation, and ascertain responsibility in case of computer crimes.Legitimate interest of Identity (Art. 6.1(f) GDPR)No more than 30 (thirty) days and for the period expressly indicated in the Cookie Policy, without prejudice to the possible need for crime ascertainment by the Judicial Authority.The provision of browsing data is necessary to navigate and interact with the Platform. Refusal to provide them would prevent browsing the Platform. The user may freely choose whether to accept cookies and other tracking technologies not strictly necessary for the operation of the Platform. For information on how we process personal data through the use of cookies or similar technologies, please consult the Cookie Policy.Registering on the Platform and Accessing ServicesPersonal Data and Special Categories of Personal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodEmail address, password, date of birth, age, nickname, first and last name, data pertaining to profiles on social networks, information about the user's experience as a creator and about user’s interests in using the Platform as a creator, and any additional data provided to complete the profile.To create and manage the user's personal profile and access features in the reserved area.Execution of the contract (Art. 6.1(b) GDPR) and fulfillment of obligations connected thereto to which Identity is subject (Art. 6.1(c) GDPR); with regard to Special Categories of Personal Data: user's consent (Art. 6.1(a) GDPR)For the entire duration of the relationship and in any case until the rights deriving from the same are time-barred, without prejudice to the fulfillment of retention obligations provided for by law. Personal Data will be deleted 1 year after profile closure, and Special Categories of Personal Data will be deleted upon profile closure.Data processed for customer care purposes will be retained for 2 years from the date of handling the request.
Processing the user's purchase and subscription order and fulfillment of the contract.Fulfillment of legal and contractual obligations related to the contract, including those related to administrative, accounting, and tax matters.customer care, anche ai fini della gestione di eventuali richieste o reclamiThe provision of Personal Data and Special Categories of Personal Data is optional; however, failure to provide the data marked as mandatory in the registration form will prevent the user's request to register on the Platform and access the services from being processed.With regard to Special Categories of Personal Data, the user may withdraw the consent given at any time by sending an email to privacy@id-entity.com.The optional and voluntary sending of email messages to the addresses indicated on this Platform entails the acquisition of the sender's email address, as well as any other personal data voluntarily included in the message, which will be used by Identity solely for the purpose of responding to the sender and will not be disseminated in any way.Customer Database and Right to DefensePersonal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodEmail address, nickname, first and last name, banking data.Entry and/or update of customer records.Legitimate interest of Identity (Art. 6.1(f) GDPR)For the entire duration of the relationship and in any case until the rights deriving from the same are time-barred, without prejudice to the fulfillment of retention obligations provided for by law.The provision of Personal Data is necessary for the pursuit of the indicated purposes.MarketingPersonal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodEmail address, first and last name.Soft spam: updating the user on marketing offers related to purchases they have already made.Legitimate interest of Identity (Art. 6.1(f) GDPR)For the entire duration of the subscription to the Platform.Email address, first and last name.Direct marketing: updating the user on marketing offers.User's consent (Art. 6.1(a) GDPR)24 months from the expression of consent and in any case until its revocation.Data related to purchases on the Platform, country of origin, gender, and age, interaction with the Platform. We may also enrich the profile with statistical information that we may lawfully acquire from other sources: for example, in relation to the area of residence (such as demographic information, georeferencing data, etc.) or the electronic devices used to interact with the Platform.Profiling: allowing Identity to send personalized commercial communications to the user based on their profile and purchase and browsing habits, as well as to develop products and services consistent with customer preferences.User's consent (Art. 6.1(a) GDPR)Data related to interactions with the Platform will be retained for 12 months from the date of collection; information related to purchases will be retained for 3 years from the date of each purchaseThe provision of Personal Data is necessary for the pursuit of the indicated purposes. Failure to provide Personal Data will prevent marketing activities.Lack of consent for direct marketing and profiling purposes will prevent these processing activities without prejudice to the pursuit of all other purposes.For direct marketing and profiling purposes, the user may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by modifying preferences within the user area.Billing and PaymentsPersonal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodFirst name, last name, IBAN, payment method (credit/debit card)Payment managementExecution of the contract (Art. 6.1(b) GDPR) and fulfillment of obligations connected thereto to which Identity is subject (Art. 6.1(c) GDPR)For the entire duration of the relationship and in any case until the rights deriving from the same are time-barred, without prejudice to the fulfillment of retention obligations provided for by lawPayments are processed by CCBill. As specified in its privacy policy, CCBill is responsible for data processing when facilitating payment transactions on behalf of and under the direction of a commercial user (e.g., receives instructions on who to pay, how much to pay, when to pay). CCBill is the data controller when it determines the purposes and means of ongoing processing. For more information on CCBill's activities as a data controller, please consult the Privacy Policy of https://ccbill.com/gdpr/.ComplaintsPersonal DataPurpose of ProcessingLegal Basis for ProcessingRetention PeriodFirst name, last name, email address, data contained in the identity document, and any other personal data provided by you when filling out the complaint.Processing and management of complaints.Legitimate interest of Identity (Art. 6.1(f) GDPR)For the period necessary to manage the complaint, without prejudice to compliance with the retention obligations provided for by law.The provision of Personal Data is necessary to pursue the indicated purpose. Failure to provide Personal Data will prevent the submission of a complaint to have content deemed harmful to one’s rights or otherwise contrary to the Terms and Conditions of Use of the Platform removed.4. Methods of ProcessingWithin the scope of the purposes indicated, the processing of Personal Data will be carried out using electronic and automated tools, in compliance with the legal provisions on personal data processing, adopting adequate security measures. The processing of Personal Data is managed by internal personnel at Identity who are specifically authorized, trained, and instructed to ensure adequate security and confidentiality and to avoid risks of loss and/or destruction and unauthorized access.5. Communication and Dissemination of Personal DataPersonal Data will not be disseminated. Within the limits strictly relevant to the purposes, Personal Data may be communicated to:Subjects authorized by law or regulation, such as, by way of example but not limited to, Public and Judicial Authorities;Subjects who, as independent data controllers or data processors under Article 28 of the GDPR, are involved in the processing of Personal Data (such as, by way of example but not limited to, the company in charge of managing and maintaining IT systems, the company that processes payments, legal and tax consultants...).The updated list of data processors can be requested by email at privacy@id-entity.it.6. Rights of the Data SubjectThe rights that the user can exercise in accordance with the GDPR and within the limits provided by Part I, Title I, Chapter III of the Italian Privacy Code (Legislative Decree No. 196/2003) are:Access in the cases provided (Art. 15 GDPR);Rectification of inaccurate Personal Data and integration of incomplete Personal Data (Art. 16 GDPR);Erasure of Personal Data for the reasons provided (Art. 17 GDPR);Restriction of processing for the cases provided (Art. 18 GDPR);Data portability in the cases provided (Art. 20 GDPR);Objection to processing in the cases provided (Art. 21 GDPR).All the rights listed above can be exercised by sending a communication via email to privacy@id-entity.it, certified email, or registered mail to the addresses indicated in point 1).Regarding Special Categories of Personal Data, the user may withdraw consent at any time without prejudice to the lawfulness of processing based on consent before its withdrawal by sending an email to privacy@id-entity.it.Regarding direct marketing and profiling purposes, the user may withdraw consent at any time without prejudice to the lawfulness of processing based on consent before its withdrawal by modifying settings within the reserved area.7. ComplaintIf the user believes that the processing of Personal Data violates the provisions of the GDPR, there is the right to lodge a complaint with the Data Protection Authority (Art. 77 GDPR).8. Transfer of Data AbroadPersonal Data will be processed at the headquarters of Identity and on servers located within the European Union.To provide certain services, Identity may have suppliers located within the European Union, whose servers are within the European Union.However, Personal Data may be subject to transfer to third countries. In such cases, Identity undertakes to ensure that the transfer of Personal Data to these countries takes place in compliance with the GDPR and specifically in the presence of adequate safeguards (adequacy decisions, standard contractual clauses approved by the European Commission, etc.).