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Privacy Policy & Data Protection

This Application collects some Personal Data of its Users.

Personal data collected for the following purposes and using the following services:

**Access to accounts on third-party services**

Access to Facebook account
Permissions: Access to private data; Access to activities; Access to friends lists; Access to requests
Access to Twitter account
Personal Data: Various types of Data as specified in the privacy policy of the service
Commenting on content
Facebook Comments Personal Data: Cookies; Usage Data

**Contacting the User**

Contact via phone
Personal Data: phone number
Contact form
Personal Data: ZIP code; city; Tax code; surname; email; name; phone number; VAT number
Social features - Public profile
Personal Data: city; surname; date of birth; email; image; address; country; name; phone number; province

**Payment management**
2Checkout Personal Data: Various types of Data as specified in the privacy policy of the service

**Interaction with social networks and external platforms**
Facebook Like button and social widgets, PayPal button and widgets, Google+ +1 button and social widgets Personal Data: Cookies; Usage Data

**Data Controller**

Andrea Radice
ROOTS Srl
Via Generale Gustavo Fara, 3 - 20124 Milan
VAT No. 12111900960 - Dest. Code M5UXCR1 - REA MI - 2641132

**Types of Data collected**

Among the Personal Data collected by this Application, either independently or through third parties, there are: Cookies; Usage Data; phone number; name; surname; VAT number; email; ZIP code; city; Tax code; address; date of birth; country; province; image.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific explanatory texts displayed before the data is collected.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless specified otherwise, all Data requested by this Application is mandatory. If the User refuses to provide it, this Application may be unable to provide the Service. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without any consequences on the availability or functioning of the Service. Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.

**Legal basis of processing**

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User's consent or another legal basis specified below until the User objects ("opt-out") to such processing. This is not, however, applicable if the processing of Personal Data is subject to European data protection law;

processing is necessary for the performance of a contract with the User and/or for pre-contractual measures;

processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;

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

In any case, the User is entitled to request the Data Controller to clarify the legal basis of each processing operation and in particular to specify whether the processing operation is based on the law, provided for by a contract, or necessary to conclude a contract.

**Location**

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.

The User's Personal Data may be transferred to a country other than the one in which the User is located. For more information on the location of the processing, the User can refer to the section containing details on the processing of Personal Data. The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data. The User can check if one of the above-mentioned transfers takes place by examining the section of this document relating to the details of the processing of Personal Data or by contacting the Data Controller using the contact details provided at the beginning.

**Storage period**

The Data is processed and stored for the time required by the purposes for which it was collected. Therefore:

Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until such contract has been fully performed.

Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Data Controller within the relevant sections of this document or by contacting the Data Controller.

When processing is based on the User's consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the storage period, the Personal Data will be deleted. Therefore, upon expiration of this period, the right of access, deletion, rectification, and the right to data portability cannot be exercised.

**Purposes of processing**

The User's Data is collected to allow the Data Controller to provide its Services, as well as for the following purposes: Access to accounts on third-party services, Payment management, Commenting on content, Contacting the User, Social features, and Interaction with social networks and external platforms.

For more detailed information on the purposes of processing and the Personal Data specifically relevant to each purpose, the User can refer to the relevant sections of this document.

**Facebook permissions requested by this site**

This site may request some Facebook permissions allowing it to perform actions with the User's Facebook account and to collect information, including Personal Data, from it. This service allows this site to connect with the User's account on the Facebook social network, provided by Facebook Inc.

For more information about the following permissions, refer to the Facebook permissions documentation and Facebook's privacy policy.

The requested permissions are as follows:

Basic information

Basic information about the User registered on Facebook, which normally includes the following Data: id, name, image, gender, and localization language, and in some cases Facebook "Friends". If the User has made additional Data publicly available, these will be available as well.

Access to private data
Allows access to the User's private data and friends.
Access to activities
Provides access to the User's activity list.
Access to friends lists
Provides access to lists of friends the User has created.
Access to requests
Provides read access to the User's friend requests.

**Details on the processing of Personal Data**

Personal Data is collected for the following purposes and using the following services:

**Access to accounts on third-party services**

This type of service allows this site to retrieve data from your accounts on third-party services and perform actions with them.
These services are not activated automatically but require the express permission of the User.

**Contacting the User**

Contact via phone
Users who have provided their phone number may be contacted for commercial or promotional purposes related to this site, as well as to fulfill support requests.


Contact form
By filling in the contact form with their Data, the User authorizes this site to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form's header.

**Social features**

Public profile
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain the User's interactions with this site.

**Payment management**

Payment management services allow this site to process payments by credit card, bank transfer, or other means. The data used for payment is acquired directly by the payment service provider requested without being processed in any way by this site.
Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or notifications regarding payment.

**Interaction with social networks and external platforms**

This type of service allows interaction with social networks or other external platforms directly from the pages of this site.
The interaction and information obtained through this site are always subject to the User's privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

**Facebook Like button and social widgets (Facebook, Inc.)**
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.

**PayPal button and widgets (PayPal Inc.)**
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

**Google+ +1 button and social widgets (Google LLC)**
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google LLC.

**Additional information about Data collection and processing**

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

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

System logs and maintenance
For operation and maintenance purposes, this 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.

Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.

How "Do Not Track" requests are handled
This 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.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

If the changes affect processing activities performed on the basis of the User's consent, the Data Controller shall collect new consent from the User, where required.

**Definitions and legal references**

Personal Data (or Data)
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.

Usage Data
Information collected automatically through this 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 this 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
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

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

Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)
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 this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application
The means by which the Personal Data of the User is collected and processed.

Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.

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

Cookies
Small sets of data stored in the User's device.

Legal information
This privacy statement 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.

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