Privacy Policy

1. Introduction

1. This information ("Information") is provided pursuant to art. 13 and 14 of EU Regulation 679/2016 of 27 April 2016, concerning the protection of individuals with regards to the processing of personal data, as well as the free circulation of such data ("GDPR"), of Legislative Decree no. 196/2003 and subsequent amendments if and to the extent applicable (the "Privacy Code") to all those who interact with this website (the "Site") created, processed and managed by Starteed Group S.r.l. ("Starteed") and hosted on the platform owned by the latter company, and in particular both to those who use the Site without making any registration, and to those who, at the end of a specific procedure, have registered on the Site and use of the online services provided through it (all without distinction, the "Users" or the individual "User").

2. It is therefore essential, in the interests of the individual User, to read and fully understand the contents of the Information before proceeding with the experience of browsing the Site and before activating the relative services. If necessary, the user can obtain further clarification simply by writing to privacy@starteed.com

3. The personal data supplied in order to use and / or register on, the Site and its related services, as well as the additional information retrieved through it in accordance with paragraph 3 below (the "Data") may be subject to processing in accordance with the applicable legislation in force and in full compliance with the principles of correctness, lawfulness and transparency, and the protection of confidentiality and the rights of Users.

4. The Information relates exclusively to the processing of Data in connection with this Site and not to other websites that may be consulted by Users via links, nor the activity of third-party service providers that may even temporarily come into possession of User Data.

5. Users are free to give or deny consent to the processing, communication and dissemination of the Data according to the methods indicated, however Starteed is obliged to inform that any refusal to consent may result in the impossibility of total or partial disbursement of the services provided through the Website.

6. Since the Data Controller, as subsequently identified, reserves the right to make changes to the Information at any time by giving publicity on the Site, it is advisable to consult this page frequently to verify any changes or updates to the same.

7. Any changes made to the Information over time will be duly published on the Website, where all previous versions will still be available.

2. Data controller

The data controller (the "Data Controller") is Starteed Group Srl, a company incorporated pursuant to Italian law, with its registered office at Via Bligny 5, Turin, VAT number and registration in the Turin Business Register no. 11170160011, in the name of its legal representative.

3. Type of data collected

A. Navigation data

1. The computer systems and software procedures that allow the Site to function acquire some personal data whose transmission is implicit in the use of Internet communication protocols.
2. Although such information is not collected to be associated with identified subjects, by their very nature they could, through processing and association with data held by third parties, allow Users to be identified.
3. This type of data includes the IP addresses or domain names of the computers used by the Users who connect to the Site, the URI (Uniform Resource Identifier) ​​addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numeric code indicating the status of the response given by the server (success, error, etc.) and other parameters relating to the operating system and the users' computer environment.
4. The use of these data has the sole purpose of obtaining completely anonymous statistical information, on the use of the Site and on the correct functioning of the latter and is deleted after their processing.

B. Data provided voluntarily by Users

1. Among the personal data collected independently or through third parties there may be: usage data, telephone number, email address, name, surname, profession, province, state, country, post code, gender, date of birth , city, as well as additional information specifically requested by the payment manager to complete the transaction or in any case necessary to complete the payment.
2. The optional, explicit and voluntary sending of electronic mail to the addresses indicated on the Website entails the subsequent acquisition of the sender's address necessary to respond to requests, as well as any other data included in the communication itself.

4. Cookies

The Site uses "cookies" for the use of its services. By using the Site, you consent to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the user's computer hard disk. There are two macro-categories of cookies: technical cookies and profiling cookies. Technical cookies are necessary for the proper functioning of a website and to allow user navigation; without them, the user may not be able to view the pages correctly or use some services. Profiling cookies are responsible for creating user profiles in order to send advertising messages in line with the preferences shown by the user while browsing. Cookies can also be classified as:

i. the "session" cookies, which are deleted immediately when the browser is closed.
ii. "persistent" cookies, which remain in the browser for a certain period of time. They are used, for example, to recognize the device that connects to a site facilitating authentication operations for the user.
iii. "own" cookies, generated and managed directly by the manager of the website on which the user is browsing.
iv. "third party" cookies, generated and managed by parties other than the website manager on which the user is browsing.
For any further information on the cookies used, refer to the Starteed cookie policy.

5. Purpose of data processing

The Data will be used by Starteed, in full compliance with the GDPR, the Privacy Code and, subject to the consent of the Users provided in the form and in the manner prescribed, for the purposes detailed below.

A. Use of the Site and related services

The single User will confirm, simply by continuing the browsing experience on the Site, or by taking advantage of the services provided through it, that he has read and fully accepted this Information, consenting that his Data may be used for:

i. the execution and management of the Website services, also through third-party services, offered to registered users.
ii. the fulfilment of obligations established by laws, regulations or community regulations, as well as by provisions of the supervisory or public security authorities.
If the individual User does not intend to accept the Information, he must avoid using the services and immediately leave the Site. In addition to the above, the individual User may also, during registration, freely decide whether to expressly express his consent also for the purposes as specified below.

B. Marketing and / or promotional activities by Starteed

In the event that during the registration process on the Site the User decides to put the first check in the appropriate request box, he will expressly declare in this way to fully accept the content of the Information and that his Data may be used for promotional and marketing activities by Starteed, such as sending advertising material, direct sales, and commercial communication.

C. Communication and transfer of data to third parties

In the event that during the registration process on the Site the User decides to put the second check in the appropriate request box for consent, he will expressly declare in this way to fully accept the content of the Information and that his Data may they can also be used for communication and / or transfer of data to third parties, for promotional and marketing activities, with which Starteed from time to time develops or concludes commercial agreements, partnerships, initiatives or common projects.

6. Mode and place of data processing

The Data are processed by automated tools and for the time strictly necessary for the purposes for which they were collected, except as provided for the purposes set out in points 5.A and 5.B.

Specific security measures are constantly observed in order to prevent the loss of data, unlawful or incorrect use, and unauthorized access. Specifically, data security uses:

A. Firewall, that is protection systems that prevent unauthorized access to company information systems.
B. Data encryption, ie. a method to mask data and information during transmission to make them understandable only by the actual intended recipient of the communication.
C. Digital certification.
D. Other electronic or automated means suitable to guarantee the security and confidentiality of the Data, in compliance with the provisions of the GPDR and the Privacy Code.

In particular, all IT security, technical, organizational and procedural security measures will be adopted, as required by the GDPR and the Privacy Code, so that the minimum level of data protection is guaranteed, allowing access only to the persons in charge of processing on behalf of the owner. The information acquired and the methods of processing will be pertinent and the Data will also be managed and protected in environments that allow full access control to them. The updated list of those responsible can always be requested from the Data Controller. The processing operations connected to the online services of the Site take place on the Starteed site. Starteed uses the infrastructure offered by Amazon Web Services, licensed by AWS Ireland Ltd, whose servers are located in Ireland or other countries as specified on the website https://aws.amazon.com, which manages and preserve all or some Data. For further information in this regard, you can contact the Data Controller at the addresses indicated in paragraph 8 below. Personal data is stored and processed through IT systems managed by Starteed or by third party technical service providers. The data is processed exclusively by specifically authorised personnel, including the personnel responsible for carrying out extraordinary maintenance operations. The data will be kept only for the time strictly necessary for the contractual or legal purposes for which the same data have been provided to the Owner and, in any case, not later than ten years from the termination of any relationship with the Owner.

7. Third parties to whom data could be communicated

The Data is communicated to the manager of the crowdfunding or crowd creation campaign, as identified on this Site, or to its appointees, operating in total autonomy as a distinct data controller, for the sole purpose of guaranteeing the correct and effective functioning of the campaign itself and limited to the purpose of this is to provide Users with constant updates on the progress of the campaign as well as to be able to proceed with the sending of any rewards that have been recognized, always within the limits of the purposes and times indicated.

Furthermore, the Data provided by the Users may be communicated by virtue of the purposes described in the preceding paragraph 5 and for the time strictly necessary for the performance of the respective activities, to the third parties indicated below, who also operate in total autonomy as separate data controllers:

a. Companies in charge of auditing and control activities on behalf of Starteed.
b. Employees, consultants and collaborators of Starteed and / or its customers and / or partners in the execution of the activities falling within the corporate purpose.
c. Companies that perform archiving services for documentation relating to relationships with Users.
d. Survey company about the quality of services provided and the level of customer satisfaction.
e. Third party technical service providers.
f. Banking companies and, more generally, payment service management.
g. Subsidiaries or parent companies, or companies connected to Starteed, company or business unit transferees, companies resulting from possible mergers, demergers, or acquisitions.
The list of these third parties will always be updated and accessible upon request to Starteed.
Furthermore, with regard to the sole purposes described in paragraph 5.C, the Data provided by Users may be communicated and / or transferred also to:
a. Subjects with whom Starteed from time to time develops or concludes commercial agreements, partnerships, initiatives or joint projects, such as [..., crowdfunding campaign managers].
b. Subsidiaries or parent companies or companies connected to Starteed, transferees of companies or branches of companies, companies resulting from possible mergers, demergers or acquisitions.

8. Rights of interested parties

At any time, the User may exercise, pursuant to articles 15 to 22 of the GDPR, the right to:

• Request confirmation of the existence or otherwise of personal data.
• Obtain indications about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the storage period.
• Obtain the correction and deletion of data.
• Obtain the treatment limitation.
• Obtain data portability, ie. receiving them from a data controller, in a structured format, commonly used and readable by an automatic device, and transmitting them to another data controller without hindrance.
• Oppose the processing at any time, also in the case of processing for direct marketing purposes.
• Oppose an automated decision-making process relating to natural persons, including profiling.
• Ask the data controller to access personal data and to correct or delete them or limit the processing that concerns them or to oppose their treatment, in addition to the right to data portability.
• Withdraw consent at any time without jeopardising the lawfulness of the processing based on the consent given before the revocation.
• Lodge a complaint with a supervisory authority (Authority for the protection of personal data - www.garanteprivacy.it).
• Any request for the exercise of these rights will be delivered by registered letter or by email to: privacy@starteed.com

9. Changes

This Privacy Policy may be modified to reflect legislative, technological changes, changes in the collection and use of data or to allow us to add new features or services. In the event of changes, we will notify the customer: (i) by announcement published on the main page of the Portal and / or (ii) adopting any other action we deem appropriate. Any changes made will be effective from the time of their publication, and browsing the Site after that time will be considered as acceptance of these changes.

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