Introduction
Welcome to Capri mobile application (the “App”). We respect your privacy, and we are committed to only collecting and using your personal data in compliance with applicable privacy laws and regulations, including the General Data Protection Regulation 2016/679.
This Privacy Policy informs you (hereinafter “User,” “You” or “Your”) of how we collect and process your personal data when you make use of the App, who we share it with, how long we retain it for and your rights as a data subject.
The App is owned and controlled by Vincenzo Bozzaotra, a sole proprietor, in accordance with the laws of Italy (hereinafter the “Company,” “We,” “Us,” or “Our”).
Please read this Privacy Policy carefully before proceeding to use our App. Your continued use of our App will be deemed as your acceptance of this Privacy Policy. If you do not agree with this Privacy Policy, please do not access our App.
The Scope of this Privacy Policy
This Privacy Policy only applies to Users who download and create a User Account for our App or access the website located at www.capri.agency. This Privacy Policy does not extend to your use of any websites or services offered by any third-party.
Data Controller
We are the data controller for all the personal data that we collect from you. You can find out business contact details at the end of this Privacy Policy.
Updates to this Privacy Policy
From time to time, we will amend this Privacy Policy to reflect our new privacy practices and commitment to compliance with local privacy laws and applicable EU directives and regulations. We will post the updated Privacy Policy on this page and notify you of such updates by changing the last updated date on the top. You should review this Privacy Policy regularly to ensure that you are familiar with any changes. You understand and accept that your continued use of the App after the effective date of the update will be deemed as your tacit acceptance of our new Privacy Policy.
Definitions
The following words, wherever used in this Privacy Policy, shall have the meaning as defined in Article 4 of the General Data Protection Regulation 2016/679:
“Data 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; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.”
“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, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”.
“Processing” - means “Any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”.
“Processor” means “a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.”
Personal data we collect and process
Your personal data that we collect includes your:
Full Name;
Email Address;
Phone Number;
Location Data;
Profile Picture; and
User Content
We use your personal data for the following purposes:
User Account
We use your name and your email address to create your User Account and to enable you to log into your User Account securely when using the App.
Legal Basis of Processing
legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We will keep this personal data for as long as your User Account is live. If you terminate your User Account, we will not retain your personal data for longer than necessary for our business, accounting and compliance with the law.
User Profile
We process your username and your profile photo to provide you with a unique user identity on the App and to make it accessible to other App Users. Your User Profile will also be linked with your actions on the App, such as your User Content as well as when you use the in-app chat functionality.
Legal Basis of Processing
legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We will keep your user profile data for the entire duration that your User Account is live on the App. If you terminate your User Account, we will not retain your user profile data for longer than necessary for our business and accounting purposes or if required for compliance with our legal obligations.
User Content
When you upload, create, post or share any of your User Content on the App such as videos, images, ratings and reviews, we will process this data to make it accessible to you and other App Users. Please note that your User Content on the App will be publicly available to other Users. You are advised not to reveal any personal information in any of your User Content that you do not wish to be made publicly available.
Legal Basis of Processing
The legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We will keep your User Content for the entire duration that your User Account is live on the App (unless your User Content is removed from the App due to contravention of our Terms and Conditions). If you terminate your User Account, we may continue to use some of your User Content until such time that you specifically request us to remove it from our App.
Location Data
When you use our App, we require you to permit us to identify your current location (“Location Data”). We use this location data to provide features of our App.
Legal Basis of Processing
The legal basis of our processing is the performance of our contract with you as set out in Article 6(1)(b) of the GDPR.
Data Retention Duration
We will keep your location data for the entire duration that your User Account is live on the App. If you terminate your User Account, we will immediately remove your location data from our database.
Support Requests
When you send us any support requests/enquiries by contacting us via email at [INSERT EMAIL ADDRESS] or by using the in-app contact form. We will collect your name, email address and the content of your message. We process this information to respond to your enquiries/requests and to correspond with you.
Legal Basis of Processing
The legal basis for our processing of this personal data is our legitimate interest as provided in Article 6(1)(f) of the GDPR.
Data Retention Duration
We will keep your Support Request data for a maximum period of six months from the date of last communication. We will remove all your support request data from our records after the lapse of the six month period unless we are required to keep this information on other lawful grounds.
Linked social accounts
Where you link your social media accounts such as Facebook with the App, the Company will request access to your Social Media user ID. The third-party social media platform provider decides the information the Company will be able to access. This personal information is used to enable you to log into your App account with your social account should you choose to do so.
Legal Basis of Processing
The legal basis for processing is your consent as provided in Article 6(1)(a) of GDPR.
Data Retention Duration
We will retain your Social Login information for as long as your user account is live on our App. We will purge this social account data from our records six months after your account is terminated.
Notwithstanding anything to the contrary, if required, we may process your personal data for compliance with applicable law.
Third-Party Services
Firebase Push Notifications
We make use of Google Firebase push notifications on our App. These messages are sent from our Application through Firebase Service. Push notifications are automatically permitted on Android devices; however, if you wish to disable push notification, you can easily deactivate them by changing your device settings. To learn more about Firebase privacy practices, please visit https://firebase.google.com/support/privacy/ and Google’s privacy policy at https://policies.google.com/privacy?hl=it.
Google Maps
Our App uses the Google Maps map service operated by Google Inc. The Google Maps service. You understand and accept that when you make use of our App, your IP address will be processed by Google Inc, on our behalf to provide their location services to us. To learn more about Google’s privacy policy, please visit https://policies.google.com/privacy?hl=it.
Disclosing your personal data
We do not sell or rent your personal data to any third party. We may disclose your personal data as described hereunder:
Email distribution Tools
We will use third-party email distribution tools to send emails to you as and when required. Your name and email address will be stored on these email distribution tools.
App Users
When you create a User Account, your User Profile is published on the App, and when you post any User Content on the App, all such content will be publicly visible to other App Users. You understand that the Company will not be responsible for any unauthorised use of such personal data by any third-party.
Company Employees
Your personal data will be shared with our Company employees on a need to know basis to enable them to deliver our App on behalf of the Company.
Merger or Acquisition
In the future, if we undergo a merger or acquisition, your personal data, such as your name, email address, and phone number, will form part of our business assets and may be transferred to the new entity. Please note that any transfer of your personal data as a result of a commercial transaction will not negatively impact your privacy rights as specified in this Privacy policy.
Compliance Obligations
We may be required to disclose your personal data to local and international government authorities, law enforcement bodies, courts of law or other government agencies as and when required for compliance with our legal and regulatory obligations, for asserting or defending our rights and interests.
Third-Party Service Providers
We may disclose your personal data to our Service Providers who assist us with the maintenance and development of our App.
Third-party website links
Our App contains links to third-party Websites that are not owned or operated by us. Should you decide to click on any such third party links, you will be directed to such third party Website. These third-party websites have their own Terms and Conditions and Privacy Policy. We encourage our Users to review the third-party website Terms and Privacy Policy prior to using their Website or acquiring any services offered by them.
We cannot be held responsible for any content made available by these third-party websites or their practices.
Transfer of data
Your Personal Data may be transferred to and maintained on computers located in jurisdictions where the data protection laws may be less stringent than those in your current state. If you are located in the European Economic Area, and you create a User Account, please note that we will transfer your personal data, to the United States as well as other parts of the world and process it there. Our current processors are complying with the EU-Swiss and EU-US Privacy Shield Frameworks to ensure that your personal data receives the same data protection that you enjoy in your EEA member state.
Your Data Rights
Your rights relating to your personal data that we hold are as follows:
Right to access your personal data
As a data subject in the European Union, you may ask us to provide you with a copy of all your personal data that we have for you.
Right to rectification
You have the right to rectification of any incorrect or incomplete information. You can exercise your right by logging into your User Account and editing the relevant information; alternatively, you can also contact us at the contact information provided at the bottom of this Privacy Policy with your rectification request.
Right to data portability
You shall have the right to receive the personal data concerning you, which was provided to us in a structured, commonly used, and machine-readable format.
Right to withdraw consent
have the right to withdraw your consent from receiving any direct marketing material from us by clicking the “unsubscribe” button at the bottom of our marketing email or alternatively by contacting us with your request.
Complaints
You also have the right to complain to:
Garante per la protezione dei dati personali
Piazza di Monte Citorio, 121
00186 Roma
e-mail: garante@garanteprivacy.it
For more information, please contact your local data protection authority in the European Economic Area (EEA).
Storage and Security
The security of your personal data is important to us, and we are committed to maintaining the confidentiality of the information you provide us. We take all reasonable and commercially viable measures to protect your personal data. However, you acknowledge that no method of transmission over the Internet or method of electronic storage is completely secure, therefore, we cannot guarantee its absolute security.
Child Privacy
We do not knowingly collect any personal information from children who are under the age of eighteen. If you become aware of any information to suggest that a child has provided his/her personal information to us, please immediately contact us. We will investigate the matter and take appropriate action.
Contact Us
If you have any questions, comments, or enquiries regarding this Privacy Policy or our Privacy Practices, please contact us at the contact information provided hereunder:
Email: [INSERT EMAIL ADDRESS].
Business Address: [INSERT BUSINESS ADDRESS HERE]