App Privacy Policy 
 
Giochi Preziosi S.p.A., with registered offices at Via delle Primule, 5, 20815 Cogliate MB – VAT number 05935650969 ("Giochi Preziosi") is committed to protecting the online privacy of the users of the App. This document has been drafted pursuant to art. 13 of EU Regulation 2016/679 and uploaded on third-party platform ("Store") in order to allow you to know well in advance our privacy policy to understand how your personal information is handled when you use our Gormiti application ("App") and, if necessary, to be able to consent to the processing of your personal data in an explicit and informed manner.
In general, any information that you provide to Giochi Preziosi through the App, or that is otherwise collected through the App, in the context of the use of the services offered by Giochi Preziosi (the "Services"), as better defined in Paragraph 3 below, will be processed according to the internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimisation, data quality, integrity and confidentiality.
 
1.       Data Controller 
 
Giochi Preziosi, as identified at the top of the Information Notice, is the Data Controller regarding all the personal data processed through the App.
 
2.       User Data processed 
 
Following the installation of the App, we inform you that Giochi Preziosi will process your personal data, which may consist - also depending on your decisions on how to use the Services - of an online identifier (including nickname) and the PUC code, which is automatically generated by the App, that allows you to be identified or identifiable ( "User Data").
Your User Data may be collected when voluntarily provided by you (e.g. when you create your personal account in order to receive the Services).
 
The User Data processed through the App are:

a.
       Name, contact details and other User Data
·         the nickname you will choose when registering;
·         the country you connect from;
·         the further information which contains personal data  you decide to  communicate with Giochi Preziosi through the contacts details provided in the App;
·         Your Device’s data: by pressing "install" on the Store, you authorize Giochi Preziosi to install the App on your mobile device (hereinafter only "Device"), as well as to read some User Data not on your Device that are essential for the successful installation (e.g. Device model, operating system version, screen resolution, network connection type, language, etc.). Sharing those kind of information is necessary for the installation of the App: you cannot oppose to the processing of these information unless you remove the App from your Device.
Some additional technical data are also displayed: mobile country code (MCC), mobile network code (MNC), name of the mobile operator and whether the operator's network allows VoIP calls. However, these information are not retained by Giochi Preziosi, which does not perform any processing on them other than displayng.
 
b.       Data voluntarily provided by the data subject and data of minors
 
As mentioned in the previous section, you are permitted to provide various types of information to Giochi Preziosi through the App, which may contain not only User Data but also personal data related to other persons.
 
In any situation where you decide to share personal data related to other persons, you will be considered as an independent data controller regarding that personal data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Giochi Preziosi against any complaints, claims or demands for compensation for damages which may arise from the processing of this personal data, brought by the third parties whose information you provide through the App.In any case, if you provide or otherwise process personal data of third parties while using the App, you guarantee – assuming all related liability – that you have these third parties’ consent or on some other appropriate grounds on which you can rely to lawfully give Giochi Preziosi this information.
 
Giochi Preziosi invites you to use the App within the company of a parent, if you are a minor. 
 
If through the ways indicated in the previous paragraphs, you share with Giochi Preziosi User or personal data relating to a minor, you guarantee from now - assuming all related responsibility - that this particular provision of information is based only if and to the extent that consent is given or authorised by the holder of parental authority or the legal representative over the child.
 
 

c.
        Browsing data

 
The App’s operation involves the use of computer systems and software procedures, which collect information about the App’s users as part of their routine operation. While Giochi Preziosi does not collect this information to link it to specific users, but by their very nature could still allow users to be identified, either directly via that information, or by using other information collected. This information includes several parameters related to your operating system and IT environment, including your IP address, the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the App, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the App, as well as to ensure its correct operation and identify any faults and/or abuse of the App. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the App or third parties: save for this last purpose, these data are not retained for more than 14 months.
 
3.       Purpose of processing
 
Giochi Preziosi will use your User Data, collected through the App, for the following purposes:
 
·         to allow you to access the App and register your personal account on the App; to verify your identity and help you in case you lose or forget your login/password details or to provide you with any other Service you request, including password recovery ("Services Providing");
 
·         comply with legal obligations that require Giochi Preziosi to collect and/or further process certain types of User Data ("Compliance");
 
·         prevent or detect any abuse in the use of the App, or any fraudulent activity and therefore allow Giochi Preziosi to protect itself in court ("Abuse/Fraud").
 
4.       Legal basis and mandatory or optional nature of the processing
 
The legal bases used by Giochi Preziosi to process your personal data, according to the purposes indicated in Section 3 above, are the following:
 
·         Services Provision: the processing for this purpose is necessary in order to provide you with the Services and, therefore, for the performance of the contract with you. It is not mandatory to provide your User Data to Giochi Preziosi for this purpose, however, if you do not, Giochi Preziosi will not be able to provide any Services to you.
·         Compliance: the processing for this purpose is necessary for Giochi Preziosi in order to comply with any legal obligations. When you provide User Data to Giochi Preziosi, it must process them in accordance with the applicable law, which may involve retaining and reporting your User Data to official authorities for compliance with tax, customs or other legal obligations.

·         Abuse/Fraud: information collected for this purpose will be used exclusively to prevent and/or detect any fraudulent activity or abuse in the use of the App and therefore allow Giochi Preziosi to defend itself in court.
 
5.       Recipients of User Data
 
Your User Data may be shared with the following list of subjects ( "Recipients"):
·         subjects who typically act as data processors, i.e.: persons, companies or professional firms providing Giochi Preziosi with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters in relation to the provision of the Services;
·         subjects engaged in order to provide the Services (e.g., hosting providers, e-mail platform providers) and/or to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
·         persons authorized by Giochi Preziosi to process User Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of Giochi Preziosi);
·         companies of the Giochi Preziosi Group for internal administrative purposes;
  • public entities, bodies or authorities to whom your User Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.
 
6.     User Data Transfers
 
Some User Data may be transferred to Recipients outside the European Economic Area. Giochi Preziosi ensures that the processing of User Data by these recipients takes place in accordance with applicable law. Indeed, transfers may be based on an adequacy decision or on Standards Contractual Clauses approved by the European Commission. More information on these transfers is available upon request at Giochi Preziosi by writing to the addresses listed below in Section 8.
 
7.     Retention of User Data
 
User Data processed for the purpose of Services Provision will be held by Giochi Preziosi for the period deemed strictly necessary for such  purpose (e.g. for the management of your account), after which they will be irreversibly anonymised. In any case, as these User Data are processed to provide the Services to you, Giochi Preziosi may continue to store this User Data for a longer period, as may be necessary to protect their autonomous interests related to potential liability related to the provision of the Services.
 
User Data processed for Compliance purposes will be kept by Giochi Preziosi for the period required by specific legal obligations or applicable law.
 
User Data processed in order to prevent Abuse/Fraud will be kept by Giochi Preziosi for the time strictly necessary for the above mentioned purpose and therefore until Giochi Preziosi is required to keep it for legal protection or to communicate such data to the competent Authorities.
 
8.     Rights of the interested party
 
You have the right to ask Giochi Preziosi at any time:
·         access to your User Data, (or a copy of such User Data), as well as further information on the ongoing processing of such personal data;
·         correct or update  your User Data processed by Giochi Preziosi, where it may be inaccurate or incomplete;
·         request erasure of your User Data being processed by Giochi Preziosi 
·         request the restriction of the processing of your User Data processed by Giochi Preziosi;
·         obtain a copy of your User Data in a structured, commonly used and machine-readable format. 
 
You can also exercise your rights by writing to Giochi Preziosi at the following address: privacy@giochipreziosi.it.
In any case, you are always entitled to complain to the competent Supervisory Authority for the protection of Personal data if you believe that the processing of your User Data is unlawful.
 
Giochi Preziosi S.p.A., with registered offices at Via delle Primule, 5, 20815 Cogliate MB – VAT number 05935650969 ("Giochi Preziosi") is committed to protecting the online privacy of the users of the App. This document has been drafted pursuant to art. 13 of EU Regulation 2016/679 and uploaded on third-party platform ("Store") in order to allow you to know well in advance our privacy policy to understand how your personal information is handled when you use our Gormiti application ("App") and, if necessary, to be able to consent to the processing of your personal data in an explicit and informed manner.
In general, any information that you provide to Giochi Preziosi through the App, or that is otherwise collected through the App, in the context of the use of the services offered by Giochi Preziosi (the "Services"), as better defined in Paragraph 3 below, will be processed according to the internationally recognized principles of lawfulness, correctness, transparency, purpose limitation and storage, data minimisation, data quality, integrity and confidentiality.
 
1.       Data Controller 
 
Giochi Preziosi, as identified at the top of the Information Notice, is the Data Controller regarding all the personal data processed through the App.
 
2.       User Data processed 
 
Following the installation of the App, we inform you that Giochi Preziosi will process your personal data, which may consist - also depending on your decisions on how to use the Services - of an online identifier (including nickname) and the PUC code, which is automatically generated by the App, that allows you to be identified or identifiable ( "User Data").
Your User Data may be collected when voluntarily provided by you (e.g. when you create your personal account in order to receive the Services).
 
The User Data processed through the App are:

a.
       Name, contact details and other User Data
·         the nickname you will choose when registering;
·         the country you connect from;
·         the further information which contains personal data  you decide to  communicate with Giochi Preziosi through the contacts details provided in the App;
·         Your Device’s data: by pressing "install" on the Store, you authorize Giochi Preziosi to install the App on your mobile device (hereinafter only "Device"), as well as to read some User Data not on your Device that are essential for the successful installation (e.g. Device model, operating system version, screen resolution, network connection type, language, etc.). Sharing those kind of information is necessary for the installation of the App: you cannot oppose to the processing of these information unless you remove the App from your Device.
Some additional technical data are also displayed: mobile country code (MCC), mobile network code (MNC), name of the mobile operator and whether the operator's network allows VoIP calls. However, these information are not retained by Giochi Preziosi, which does not perform any processing on them other than displayng.
 
b.       Data voluntarily provided by the data subject and data of minors
 
As mentioned in the previous section, you are permitted to provide various types of information to Giochi Preziosi through the App, which may contain not only User Data but also personal data related to other persons.
 
In any situation where you decide to share personal data related to other persons, you will be considered as an independent data controller regarding that personal data and must assume all inherent legal obligations and responsibilities. This means, among other things, that you must fully indemnify Giochi Preziosi against any complaints, claims or demands for compensation for damages which may arise from the processing of this personal data, brought by the third parties whose information you provide through the App.In any case, if you provide or otherwise process personal data of third parties while using the App, you guarantee – assuming all related liability – that you have these third parties’ consent or on some other appropriate grounds on which you can rely to lawfully give Giochi Preziosi this information.
 
Giochi Preziosi invites you to use the App within the company of a parent, if you are a minor. 
 
If through the ways indicated in the previous paragraphs, you share with Giochi Preziosi User or personal data relating to a minor, you guarantee from now - assuming all related responsibility - that this particular provision of information is based only if and to the extent that consent is given or authorised by the holder of parental authority or the legal representative over the child.
 
 

c.
        Browsing data

 
The App’s operation involves the use of computer systems and software procedures, which collect information about the App’s users as part of their routine operation. While Giochi Preziosi does not collect this information to link it to specific users, but by their very nature could still allow users to be identified, either directly via that information, or by using other information collected. This information includes several parameters related to your operating system and IT environment, including your IP address, the domain names of your computer, the URI (Uniform Resource Identifier) addresses of resources you request on the App, the time of requests made, the method used to submit requests to the server, the dimensions of the file obtained in response to a request, the numerical code indicating the status of the response sent by the server (successful, error, etc.), and so on. These data are used to compile statistical information on the use of the App, as well as to ensure its correct operation and identify any faults and/or abuse of the App. The data could be used to ascertain responsibility in the event of hypothetical computer crimes against the App or third parties: save for this last purpose, these data are not retained for more than 14 months.
 
3.       Purpose of processing
 
Giochi Preziosi will use your User Data, collected through the App, for the following purposes:
 
·         to allow you to access the App and register your personal account on the App; to verify your identity and help you in case you lose or forget your login/password details or to provide you with any other Service you request, including password recovery ("Services Providing");
 
·         comply with legal obligations that require Giochi Preziosi to collect and/or further process certain types of User Data ("Compliance");
 
·         prevent or detect any abuse in the use of the App, or any fraudulent activity and therefore allow Giochi Preziosi to protect itself in court ("Abuse/Fraud").
 
4.       Legal basis and mandatory or optional nature of the processing
 
The legal bases used by Giochi Preziosi to process your personal data, according to the purposes indicated in Section 3 above, are the following:
 
·         Services Provision: the processing for this purpose is necessary in order to provide you with the Services and, therefore, for the performance of the contract with you. It is not mandatory to provide your User Data to Giochi Preziosi for this purpose, however, if you do not, Giochi Preziosi will not be able to provide any Services to you.
·         Compliance: the processing for this purpose is necessary for Giochi Preziosi in order to comply with any legal obligations. When you provide User Data to Giochi Preziosi, it must process them in accordance with the applicable law, which may involve retaining and reporting your User Data to official authorities for compliance with tax, customs or other legal obligations.

·         Abuse/Fraud: information collected for this purpose will be used exclusively to prevent and/or detect any fraudulent activity or abuse in the use of the App and therefore allow Giochi Preziosi to defend itself in court.
 
5.       Recipients of User Data
 
Your User Data may be shared with the following list of subjects ( "Recipients"):
·         subjects who typically act as data processors, i.e.: persons, companies or professional firms providing Giochi Preziosi with advice and consultancy regarding accounting, administrative, legal, tax, financial and debt collection matters in relation to the provision of the Services;
·         subjects engaged in order to provide the Services (e.g., hosting providers, e-mail platform providers) and/or to perform technical maintenance (including maintenance of network equipment and electronic communications networks);
·         persons authorized by Giochi Preziosi to process User Data necessary to carry out activities strictly related to the provision of the Services, who are committed to confidentiality or have an adequate legal obligation of confidentiality (e.g. employees of Giochi Preziosi);
·         companies of the Giochi Preziosi Group for internal administrative purposes;
  • public entities, bodies or authorities to whom your User Data may be disclosed, in accordance with the applicable law or binding orders of those entities, bodies or authorities.
 
6.     User Data Transfers
 
Some User Data may be transferred to Recipients outside the European Economic Area. Giochi Preziosi ensures that the processing of User Data by these recipients takes place in accordance with applicable law. Indeed, transfers may be based on an adequacy decision or on Standards Contractual Clauses approved by the European Commission. More information on these transfers is available upon request at Giochi Preziosi by writing to the addresses listed below in Section 8.
 
7.     Retention of User Data
 
User Data processed for the purpose of Services Provision will be held by Giochi Preziosi for the period deemed strictly necessary for such  purpose (e.g. for the management of your account), after which they will be irreversibly anonymised. In any case, as these User Data are processed to provide the Services to you, Giochi Preziosi may continue to store this User Data for a longer period, as may be necessary to protect their autonomous interests related to potential liability related to the provision of the Services.
 
User Data processed for Compliance purposes will be kept by Giochi Preziosi for the period required by specific legal obligations or applicable law.
 
User Data processed in order to prevent Abuse/Fraud will be kept by Giochi Preziosi for the time strictly necessary for the above mentioned purpose and therefore until Giochi Preziosi is required to keep it for legal protection or to communicate such data to the competent Authorities.
 
8.     Rights of the interested party
 
You have the right to ask Giochi Preziosi at any time:
·         access to your User Data, (or a copy of such User Data), as well as further information on the ongoing processing of such personal data;
·         correct or update  your User Data processed by Giochi Preziosi, where it may be inaccurate or incomplete;
·         request erasure of your User Data being processed by Giochi Preziosi 
·         request the restriction of the processing of your User Data processed by Giochi Preziosi;
·         obtain a copy of your User Data in a structured, commonly used and machine-readable format. 
 
You can also exercise your rights by writing to Giochi Preziosi at the following address: privacy@giochipreziosi.it.
In any case, you are always entitled to complain to the competent Supervisory Authority for the protection of Personal data if you believe that the processing of your User Data is unlawful.
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