PRIVACY POLICY

01/06/2018

Hello and welcome to the privacy statement (the “Statement”) by Edgar Srl (“Edgar” or “we”), a company under Italian law controlled by Edgar Inc that has developed and owns the web platform published on the website www.edgarsmartconcierge.com (“DG website”), the mobile apps (the “DG Apps”) and the web platform published on the website www.guidemeright.com (“GMR website”), all together defined as the “Platform”.

Due to the nature of the services Edgar supplies, we deal with different user segments. To better understand which parts of this Privacy Policy are more relevant to you, see the following definitions below, which will be used subsequently throughout this document.

  • Host: you have an account on the DG website that you use to customize the App for your Guests.
  • Provider: you have an account on the GMR website you use to propose and sell experiences and services to Guest
  • Guest: you have downloaded, logged in and used the DG App created by the Hosts via the Platform.
  • Visitor: you visited or are randomly browsing the Platform to find out more about our offer but do not have an account on Edgar.

Edgar, via the DG website and the DG Apps, works as a Guest Management tool. It offers the possibility of accommodation operators to equip themselves with a digital concierge app by which their guests can discover and book services at their destination and request extra services to their host, who will manage the interactions with his guests through a dedicated Extranet. The GMR website, on the other hand, operates as an IT matching tool. It is a marketplace for tours, experiences and tourist services through which users can complete transactions independently. The DG website and the App DG, in particular, allow to:

  • (i) Create and customize the app of your own accommodation facility;
  • (ii) Manage interactions with guests through a dedicated Extranet, by sending automatic and non-automatic messages and a Live Chat;
  • (iii) Integrate your own account with other tourist software such as PMS and Channel Manager;
  • (iv) Ask your own host for extra services, through the app;
  • (v) Book tours, experiences and services at your destination directly on the App;
  • (vi) Access a DB of geolocated Points of Interest;
  • (vii) Send to the structure the personal data needed for the bureaucratic declaration to “Alloggiati” Web Portal by using Fast Check-in;
  • (vi) Access the "add on" services made available on the platform from time to time.

The GMR website, in particular, allows to:

  • (i) Register as a Local Friend or Local Provider to offer tours, experiences and services through the platform;
  • (ii) Register as a user (Guest) to get in touch with Local Friends and book tours, experiences and services through the platform;
  • (iii) Create a personal profile to present yourself to the Community;
  • (iv) Promote events on a specific date;
  • (v) Chat directly with other Community members;
  • (vi) Access to touristic information about the main Italian cities.

Through the Platform we collect some information about you, as a Host, Provider, Guest or Visitor (“you” or the ”User”), which is termed “Personal Data”. Personal Data can be generically defined as any information pertaining to identified individuals or individuals who can also be identified through other information - for example, through a number or an identification code - such as: name, surname or title; address; tax code; an image; a recording of an individual's voice; fingerprint; bank data; etc.

This Statement aims to provide you with all the necessary information so that you can become aware of our policy regarding the collection, disclosure and use of your Personal Data, as a User and together with the Terms and Conditions of Use (the “TOS”) constitutes the contract regulating the relations between you and Edgar.

Edgar, where you activate the Platform services through third party services (by way of example only, and not exhaustively: login via Facebook Connect), your Personal Data may be shared by such third parties

This Statement does not apply to services offered by third parties and their information processing methods. We advise you to carefully read the relevant privacy information on the websites of respective third parties in regards to how they will process information and potentially share it with Edgar.

https://www.facebook.com/policy.php

This Statement does not apply, in particular, to the collection and processing of Personal Data made by third parties other than Edgar that perform management functions within the Platform, such as “properties”: spaces reserved for a specific community that adopt the functions of the Platform for the benefit of a smaller group of people (the "Host") autonomously created by them. The Hosts are autonomous and independent of Edgar. Keep in mind, therefore, that these Hosts will be responsible for processing your Personal Data each in relation to the actual processing carried out in relation to participation in the community to which you decide to subscribe. Contractually, each Host is required by Edgar to adopt policies that are compliant with applicable privacy laws and the transferability of the Personal Data acquired and processed by them is prevented. We therefore recommend that you carefully read these privacy statements in order to understand how the information will be processed by these Communities Managers.

This Information is provided in compliance with Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data (the “General Data Protection Regulation”). In the event that you are under 18 years of age (eighteen), or lack capacity, this Statement is addressed to the person responsible for this by the applicable Italian law, which is the only person authorised to grant the relevant express consent.

This information may be supplemented or amended in order to ensure that it is updated with respect to the law and/or adequate in respect to any technical changes made to the Platform and/or to any changes in the purposes or processing methods of the Information.

We will inform you of any changes with specific and appropriate individual notices, but we advise you to periodically check this document to stay up to date. Any updated versions, which will bear the date on which the update is carried out, will be promptly published on the Platform and will become effective immediately after publication. In particular, they will be considered fully binding upon you from the date of publication on the Platform if you do not decide to unsubscribe from the Platform.

  • 1. Data Controller, Data Processors and Data Protection Supervisors

    The data controller is Edgar Srl, with registered office in Italy, Z.I. Predda Niedda Str 2 ang Str 1 a Sassari (07100), e-mail: info@edgarsc.com, hereinafter also referred to as “Data Controller”.

    The following persons are responsible for processing (hereinafter referred to as “Operators”) for the purposes of statistical analysis, export, control and supervision to guarantee the smooth operation of the Platform:

    The detailed list of data Processors may be requested by sending a simple written request to the Data Controller at the addresses indicated above.

    Responsible for data protection (“Data Protection Officer”) is:

  • 2. Types of data processed and purpose of the processing

    2.1 Data and browsing activities

    The IT systems and the procedures used to operate the Platform may automatically acquire, during their normal operation, some Personal Data related to your browsing, such as, by way of example, the IP address, the amount of accesses, the duration of browsing, the browser used, the pages viewed, and the date and time at which access took place. Personal data relating to your browsing are collected primarily for the purpose of obtaining non-identifying statistical information about the use of the Platform and to check its correct functioning. Personal Data relating to your browsing may also be processed, after the registration necessary for the use of services accessible through the use of credentials as per Article 2.2, for:

    • (i) Profiling activities, i.e. the study and analysis of your interests and requests for the definition of individual and group profiles, after obtaining your express consent, as resulting from the check of the item "I expressly consent to the processing of Personal Data for the purposes of profiling, highlighted in bold in paragraph (i) of Article 2.1 and (ii) of Article 2.2 of the Edgar Privacy Policy". Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for profiling purposes, by making a simple request to the Controller, without any formalities.

      How can we actually use your Personal Data for this purpose? We may process Personal Data related to your browsing to better understand your interests and preferences, so as to provide you with an experience consistent with these interests and preferences. For example, we may do so to provide you with access to content for which you have shown the most interest, or send you personalised offers or promotions via email and push notifications (as long as you have consented to receive our communications for advertising and commercial purposes), or offer advertising content related to your interests.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices, it is in our legitimate interest to look at your preferences, extrapolated from your browsing, so that you can better customise our offer.

    To carry out these operations, the Platform currently uses: (i) the Google Analytics service, a service of web analytics provided by Google that sends cookies to your device.

  • 2.1.1 Cookies

    Cookies (“Cookies”) are small text strings that are stored on your own device and which record data related to your browsing activity. These data, if the cookies are not disabled, are communicated to the website or the application that installed them each time you return to visit it.

    Types of Cookies:

    • Technical cookies: allow browsing through the website or application and using options or services. For example, they identify the session, limited access to web sections, remember the elements of an order, make the registration request or participation to an event, use the security features while browsing, and store content for audio or video broadcast. It concerns, in other words, all those Cookies necessary to satisfy the specific request that the user has made at that time and which are not used for further purposes.
    • Profiling cookies: they allow a more effective management of the advertising spaces on the website or application and allow the adaptation of advertising for relevance to the user and to prevent the user from viewing advertisements already seen. These cookies therefore perform actual profiling of user behaviour.
    • Third-party cookies: Third-party Cookies are Cookies, used by the website or application manager, but installed on the device of the user by third parties other than the operator of the website or the application. Third-party cookies are, for example, the statistical services of Google Analytics or the advertising service of Google Adsense.
    • The Platform, in particular, uses:

      • (i) Technical cookies (which store your login credentials in order to make it easier to log in) and for which your specific consent is not required;
      • (ii) Profiling Cookies that keep track of the choices you have made in the navigation and use of the Platform services, so as to ensure a personalised and easier use of the services offered by the Platform, for which your specific consent is required and which we notify to the Privacy Guarantor;
      • (iii)Third-party analytical cookies:
      • (iii)(a) concretely adopted with measures that allow you to eliminate the identifying power and not cross checked by the third party, for which your specific consent is not required;
      • (iii)(b) adopted without any measures that eliminate the identifying power, for which your specific consent is required.

      If you require more information about these cookies, and to understand how to reject or delete them, please take a look at the privacy policies listed below, using the addresses provided.

      Below is the list of Cookies used.

      Nome cookie Dominio Descrizione Durata Ulteriori informazioni
      __cfduid .tawk.to Used by the customer care chat 1 year https://www.tawk.to/privacy-policy/
      JSESSIONID, EXTSESSID www.guidemeright.com Keep the user session between the pages of the website session
      __gat, _ga, __utma, __utmb, __utmc, __utmz .guidemeright.com Stores an unique id used to gather statistical data about the user's behavior on the website 2 years https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
      _gid .guidemeright.com Stores an unique id used to gather statistical data about the user's behavior on the website session https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage
      1P_JAR, NID, SSID, HSID, SID, APISID, SAPISID .google.it Third party cookie to store google maps user preferences 10 years https://policies.google.com/technologies/types?hl=en
      CONSENT .google.it Used for the consent of Google services 20 years
      DV .google.it session
      SIDCC .google.it Security cookie used to protect user's data from unauthorized access session https://policies.google.com/technologies/types?hl=en
      vuid .vimeo.com Collect data on which pages the users visit 2 years https://vimeo.com/cookie_policy
      IDE .doubleclick.net used by Google doubleclick to track user's click on ads and measure ads efficacy 2 years https://www.google.it/intl/en/policies/technologies/types/
      __tawkuuid .guidemeright.com third party cookie 6 months https://www.tawk.to/privacy-policy/
      cc_cookie_accept .guidemeright.com used to store the fact that the user accepted the cookie policy 1 year
      cc_cookie_decline .guidemeright.com used to store the fact that the user didn't accepted the cookie policy session
      PYPF .paypalobjects.com used by paypal to recognize the user and minimize the time taken for the login 30 days https://www.paypal.com/it/webapps/mpp/ua/privacy-full
      TawkConnectionTime .guidemeright.com third party cookie session https://www.tawk.to/privacy-policy/
      TawkConnectionTime .guidemeright.com third party cookie session https://www.tawk.to/privacy-policy/
      internationalization .guidemeright.com technical cookie used to store user's preferences about the webisite's language session
      mp_#_mixpanel .guidemeright.com technical cookie used by mixpanel to track the user's behavior for statistical analysis 1 year https://mixpanel.com/legal/privacy-policy/
      _hjIncludedInSample .guidemeright.com technical cookie used by hotjar to track the user's behavior for statistical analysis https://www.hotjar.com/legal/policies/privacy
      ajs_anonymous_id, ajs_group_id, ajs_user_id, mkjs_group_id, mkjs_user_id .mapbox.com technical cookie used by mapbox 6 months https://www.mapbox.com/privacy/
      • (i) Google Analytics (Google Inc.) → Identifying third-party cookies. Google Analytics uses cookies to collect and analyse information on the use behaviour of the Platform. The information collected and processed by Google Analytics allows us to prepare reports regarding the activities carried out on the Platform. We use the Google analysis tool to monitor or collect personal identification and profiling information.

        For more information, please refer to the links below: https://www.google.it/policies/privacy/partners/

        You can selectively disable the action of Google Analytics by installing the opt-out component provided by Google on your browser. We therefore invite you, where you intend to disable the action of Google Analytics, to access the link below: https://tools.google.com/dlpage/gaoptout

      • (ii) Google Adwords & Google Remarketing Cookies (Google Inc.) → Non-identifying third-party cookies The Platform may use Google Adwords and Google Remarketing technology. To help us keep track of sales and other conversions, a Cookie is added to the User's device when the user clicks on an ad. This cookie lasts 30 days and does not collect or monitor information that identifies the User. Users can disable Google conversion monitoring cookies in their Internet browser settings. To learn more about click here
      • (iii) Bing Ads (Microsoft Inc.) → Non-identifying third-party cookies
      • (iv) Facebook Ads (Facebook Inc.) → Non-identifying third-party cookies For more information on Facebook remarketing, you can visit the page https://www.facebook.com/help/1505060059715840

      • The installation of Cookies, which normally occurs automatically with most browsers, can be prevented by simply deactivating, in the functions of your browser, the enabling of cookies.

        For specific and further information about Cookies, click on the link of the browser that you usually use:

        For further information or clarifications, you can contact us by email at: info@edgarsc.com.

        If you decide not to enable Cookies, your experience on the Platform may be limited.

        You can find more information about cookies and how to manage them by consulting the site www.aboutcookies.org or by consulting the provision identification of the simplified procedures for the information and the acquisition of consent for the use of cookies..

  • 2.2 Data processed in relation to the use of services accessible through the use of credentials

    The information we collect from you varies depending on what information/access you require from us. This information may be collected via the DG and GMR Websites, the DG App, through our live chat services (on the Websites), at events/conferences or from direct contact to a member of Information Apss staff (via email/telephone). The information collected may include:

    • Name
    • Surname
    • Email address
    • Phone number
    Some Platform services are reserved for registered Users. To complete the registration process you must provide necessarily, among others, the following Personal Data:
    • Name
    • Surname
    • Email
    • Password
    • Telephone number (only for Hosts and Providers)

    How may we actually use your Personal Data for this purpose?

    Generally, we may need to use the above Personal Data, such as your email address, to set up and manage your account (for example, to send you password reminders or yearunce changes to your account details).

    What is the legal basis that allows us to process your Personal Data in this way?

    We will ask for your consent before processing your Personal Data in this way. The processing of your Personal Data is necessary to set up and manage your account. The provision of any other Personal Data required as part of the registration procedure, unless explicitly indicated as mandatory, is optional and granted entirely at your will. The Personal Data provided for the use of the services accessible through the use of credentials, together with the data communicated to us by third parties that you used to register with the Platform, may also be processed for:

    • (i) Sending communications for advertising and commercial purposes, as well as for direct sales by Edgar also referring to third party products and services, avoiding the communication of your data to such subjects. Subject to the obtaining of express consent, as resulting from the checking of the item "I expressly consent to the processing of Personal Data for the purpose of sending advertising and commercial purposes generally highlighted in bold in paragraph (i) of Article 2.2 of the Edgar Privacy Policy",your Personal Data may be used by Edgar for the purpose of sending advertising and commercial communications (marketing) and/or direct sale of products or services of its own or third parties, by e-mail, fax, telephone and any other communication technology remotely, including social media, possibly taking into account the indications you decide to provide us with by freely answering questions that will enable us to be more familiar with your requests and interests.. Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for marketing and/or direct sales purposes, by making a simple request to the Controller, without any formalities.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to send informational and advertising material, including of third parties; send commercial communications, including interactive ones; carry out direct sales or placement of products or services; or for all lawful purposes of a commercial nature.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices in this regard, it is in our legitimate interest to be able to use the Personal Data for sending commercial communications, for the purpose: (i) of offering you the services of the Platform completely free of charge; and at the same time (ii) of making Edgar economically sustainable. We are, in fact, a startup that offers services free of charge, compensating for this gratuity with the monetisation resulting from:

      • The promotion of our PRO service
      • The promotion of Host with which we make "revenue shares" on internal transactions such as registration fees or other forms of payment within the community
      • Discounts and offers on which models of "affiliate marketing" are developed
      • Sponsored initiatives in which business partners support Edgar to promote initiatives, products, opportunities and content

      (ii) Profiling activities, i.e. the study and analysis of your interests and requests for the definition of individual and group profiles, subject to your prior express consent, as resulting from the check of the box "I expressly consent to the processing of Personal Data for the purposes of profiling, highlighted in bold in paragraph (i) of Article 2.1 and (ii) of Article 2.2 of the Edgar Privacy Policy". Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even in the event of consent, you will still have the right to object, in whole or in part, to the processing of your Personal Data for profiling purposes, by making a simple request to the Controller, without any formalities.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to better understand your interests and preferences, so as to provide you with an experience consistent with these interests and preferences. For example, we may do so to provide you with access to content for which you have shown the most interest, or improve and customize the Platform service, or send you personalised offers or promotions via email (as long as you have consented to receive our communications for advertising and commercial purposes), or offer advertising content related to your interests. This includes, for example, adapting our advertising to ensure that certain advertisements are visible when the public is particularly interested in watching them.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is in line with your choices, it is in our legitimate interest to look at your preferences, extrapolated from your browsing, so that you can better customise our offer.

      Additional information gathered by the Guest that use the App DG:: we can also gather information related to your device (Hardware model and version of the operating system), to your navigation (usage of the App, like the page visited but always anonymously), or to uor localization (anonymously) in order to identify and solve potential technical issues, to measure the interest generated by the contents and to provide you the most appropriate touristic information, like ordering them depending on their proximity.


      (iii) Communication of data to third parties for the sending of advertising and commercial messages (marketing) and direct sales by such third parties.. Upon obtaining your express consent, as resulting from the check of the entry "I expressly authorize that my Personal Data be communicated to [community name] for the purposes highlighted in bold in paragraph (iii) of Article 2.2 of the Edgar Privacy Policy", your personal data may be used by Edgar to communicate them to the community (as specified in point 3) for the purpose of sending advertising and commercial communications (marketing) and/or direct sale by said third parties, by e-mail, fax, telephone and any other remote communication technology, including social media. Consent to the processing of this data is optional and any refusal to permit processing will not make it impossible to use the services of the Platform. Even where consent has been given, you will still have the right to object, in the future, in whole or in part, to the communication of your Personal Data to third parties, making a simple request to the Owner, without any formalities.

      How may we actually use your Personal Data for this purpose? If you have expressly consented that the Personal Data be communicated to [community name] for sending advertising and commercial messages (marketing) and direct sale by such third parties, your Personal Data may be transmitted to our business partners so that they can send you offers on their products or services, by e-mail, fax, telephone and any other remote communication technology, including social media. Keep in mind, however, that our business partners are responsible for the processing of data each in relation to their privacy policy.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is consistent with your choices in this regard, it is in our legitimate interest to be able to communicate the Personal Data to our commercial partners, for the purpose of: (i) offering you the services of the Platform completely free of charge; and at the same time (ii) for making Edgar economically sustainable. In fact, we are a startup that offers services free of charge, compensating for this gratuity with the monetisation of Personal Data collected, through communication to our business partners.


      (iv) Any additional purpose necessarily related to the execution of the Platform's services, as illustrated in the TOSs.

      How may we actually use your Personal Data for this purpose? We may need to use your Personal Data, if necessary, to fulfil our contractual obligations to you, for example when you have requested access to the Platform services.

      What is the legal basis that allows us to process your Personal Data in this way? If you have requested the performance of the services of the Platform, as explained in TOS, processing your Personal Data is necessary to fulfil our contractual obligations towards you.

      (v) Any additional purpose that necessarily allows us to comply with the requirements of the law regarding the protection of personal data.

      How may we actually use your Personal Data for this purpose?

      In some cases we may need to process Personal Data to comply with current legislation. For example, you may no longer wish to be contacted by us. For this reason, we keep the list of your preferences ("suppression list") so as not to contact you, if you asked us not to do so. To this end, we may need to process certain personal data.

      What is the legal basis that allows us to process your Personal Data in this way? It is our right to process your Personal Data to comply with current legislation. It is our right to process your Personal Data, for example, to maintain the "suppression list" and not to contact you if you asked us not to do so.

    • 2.2.1 Register of Objections

      The registration of your telephone numbers (the “Telephone Numbers”) in the Register of Objections allows you to cancel and withdraw any consent for telephone contacts that may have previously been granted to third parties for commercial purposes. Any consents granted after registration in the register are excluded from automatic revocation.

      In order to give effect to your rights:

      1. we provide evidence of the fact that we consult the Register of Objections on a monthly basis and update the contact lists accordingly;
      2. we will give you periodic quarterly communication via email of the subjects to whom the Telephone Numbers will be transferred;
      3. we have set up a privileged channel with our third-party business partners so that it is possible for us to report any entry in the Register of Objections made after the transfer of your Personal Data.

    • 2.3 Personal Data which you provide to us voluntarily

      The Personal Data that you provide to us voluntarily and freely on the basis of your autonomous impulse (for example sending e-mails to the e-mail addresses indicated on the Platform for the purpose of obtaining information), will be acquired by us and processed by the Data Controller. In particular, in addition to your e-mail address, necessary to reply to you, any other personal data to which the electronic communication refers or in any case contained in the e-mail message will be acquired. Such Personal Data, if different from those, possibly already in our possession and subject to explicit consent in regards to processing, as per Article 2.2, will not in any way be disclosed or communicated to third parties with respect to the owner's organisation, nor will they be used to define the profiles or personality of the data subject or for direct or indirect commercial or advertising purposes and, in any case, will be kept exclusively for the purposes of the storage of correspondence. Specifically, these are the information you might provide us voluntarily:

      1. As a Guest of the GMR website:
        1. Anagraphic and contact information
      2. As a Provider of the GMR website
        1. Anagraphic and contact information
        2. Copy of your Identification Document
        3. Copy of your Professional certification (potential)
      3. As a Guest on the App DG:
        1. Anagraphic and contact information
        2. Copy of your Identification Document
      4. As a Host:
        1. Bureaucratic and billing information
        2. Customer contact information

    • 2.4 Billing Information

      If you purchase a product from Criton we will seek additional information in order to process the transaction per the contract you have agreed to. We will seek additional information such as: (i) Card Holders postal address (for payment processing; (ii) Bank card information (in order to process the payment). Your card information will be stored securely by Stripe or Paypal on our behalf while you are a contracted customer, we can charge your card as per your wishes but we do not have access to your full card details.. You can cancel your card payments via Stripe or Paypal at any time, this may impact on the services we provide you, including the removal of your app(s) from publication.


    • 2.5 Tag and beacon

      If you complete an Action on our sites such as a form submission to send a request, to download content or sign up for a Free Trial, you will be added to AgileCRM, our CRM system, and the other tools needed to safety transfer your information. The data we capture enables us to offer the best user experience by tailoring communications to your preferences and interests. In order to do this a tracking tag will be added to all emails issued to you via AgileCRM. These tags enable us to analyse how you interact with our communications. You can opt- out of our email communications at any time.


    • 2.6 Geolocation

      The possible acquisition of data on your location will only be possible with your express consent expressed during the use of the Platform. Subject to your consent, we may use this data to provide you with services and/or advertisements available in your geographical area, based on the permissions you have given and based on the settings of your device. You can disable the geolocation function at any time, either from your personal account on the Platform or from your device settings. For more information on how to disable this service on your device, we suggest contacting the manufacturer of your device.

      How may we actually use your Personal Data for this purpose? We may process Personal Data to provide you with an experience that is more targeted to your local area. For example, we can do this by providing you with access to personalised content or promotions by geographical area.

      What is the legal basis that allows us to process your Personal Data in this way? Provided that you have given your consent and that this is consistent with your choices, it is in our legitimate interest to look at your local area, so as to better customise our offer.


    • 2.7 Social Network

      We allow you or we will allow you to register and/or use our services using the account of some of the major social networks (purely by way of example and not exhaustively: Facebook). By choosing to use these services to register with the Platform, or to take advantage of our social services, you authorise us to collect your Personal Authentication Data to these social networks (e.g. your username, your login credentials - in encrypted mode -, your profile image, the country you have indicated as your residence, your hometown, your date of birth, the images and the network of your contacts, as well as all the other information that you can make available on, or through, your accounts and your activity on social networks). The Personal Data to which we have access varies depending on your privacy settings and the related consent on the aforementioned social networks. If you decide to connect the account managed by one of the above social networks to your account on the Platform - by authorising access to your Personal Data - you authorise us to acquire, process and possibly communicate the Personal Data present on these social networks, in accordance with current information and for all the specific related purposes.

      We remind you that we do not store or will not store the password of your Facebook account. If you wish to use the social features of the Platform, we warn you that we will use your username and your profile image (if you decide not to authorise the processing of some of these Personal Data, you can change these preferences directly on your personal account on the Platform).


    • 2.8 Protection of Personal Data

      We carefully protect the information in our possession related to EDGAR or our users from unauthorised access, alteration, disclosure or destruction. Specifically:

      • We provide encrypted access to our services using SSL;
      • Browsing in EDGAR solutions uses a secure channel;
      • We review our practices of collecting, processing and storing information, including physical security measures, to protect against unauthorised system access;
      • The data is saved on an architecture that allows it to be backed up daily and in the case of transfer, with prior consent, the sensitive data is encrypted with AES, MD5 or SHA2 algorithms;
      • We restrict access to EDGAR databases and systems to EDGAR’s employees and subcontractors who need them for the performance of their duties and are subject to strict contractual confidentiality obligations whose non-compliance may lead to disciplinary action or termination of contract. However, take note that the use of an open and public telematic system such as the Internet for the transmission of information increases the standard risks of any remote service.


    • 3. Categories of subjects to whom the Personal Data may be communicated and scope of data dissemination

      Unless otherwise specified in relation to the individual purposes of the processing as specified above, the Personal Data collected may be disclosed to - or otherwise communicated to - persons in charge and/or responsible (including external) of the processing, in relation to the skills and functions of each, in order to meet the aforementioned purposes or to implement specific regulatory and/or contractual obligations.

      Your personal data may also be brought to the attention of the following subjects or of the following categories of subjects, to the extent that this is necessary for the fulfilment of regulatory and/or contractual obligations:

      1. The Apps developed by Edgar are associated with an entity that provides services to the users of the App DG. This entity can be a Hotel, Apartment or another that has built and published an App with the platform. By accepting Edgar terms of use and privacy policy, you are consenting to these entities having access to the user data only in the context of the services provided by these entities through the respective App, and the personal data of the users aren’t sold to third parties or used for Marketing purposes without your consent. The personal data of the users are deleted or anonymised after the guest’s check-out or after the data expiration period applied by Edgar (see Data retention period). We may share anonymised information, that is, information that doesn’t contain personally identifiable information, publicly and with our partners, including information to show trends in relation to the general use of our services
      2. Providers that you book through the Platform, only in order to facilitate the meeting between the parties for the providing of the service;
      3. with the services we use to build the Guest solution: the Platform is built using third-party services for software development, software hosting, component access, frameworks, and service access APIs.The entities that we use for this purpose are identified here and don’t have access to users’ personal data or authorization to access them:
        • Amazon - Solution development and hosting support;
        • Google - Solution development and hosting support;
        • Apple - Support for iOS Apps hosting;
        • Crashlytics - Solution development support;
        • Twilio - Support for sms and VoIP calls, not having access to the identification of the users who make the calls;
      4. our authorized employees and/or collaborators who provide assistance and consulting services in the areas of administration, product, legal advice, Customer Service and IT systems, as well as the personnel in charge of maintaining our network and our hardware and software equipment;
      5. our third party service providers who process personal data on our behalf and under our direction for the above purposes acting as data processors, such as those providing the Company with IT and hosting services, call centers and customer support, services analytical and administrative, etc.;
      6. payment service providers and financial institutions (e.g. for chargeback, fraud detection and preventive purposes) acting as independent data controllers;
      7. the social platforms with which we have a commercial collaboration, if it is expressly requested by the User and/or the Customer (e.g. when using methods of identification through social media);
      8. the competent authorities, if it is prescribed by the regulations in force;
      9. the competent authorities and third-party authorities empowered by law, when this is necessary in order to enforce our terms of use and to protect and defend our rights or our property or the rights and property of third parties;
      10. third parties who receive data (e.g. business consultants, professionals in the service provisioning of adequate audit in fiscal matter (“due diligence”) or that estimate the value and capabilities of the business) if necessary in relation to sales of our business or its assets (eventuality in which the data will be communicated to our consultants and consultants of any potential buyer and they will be transferred to the new owners).

      Your Personal Data may then be communicated to companies, which Edgar may contact for the implementation of operations necessary for the performance of the provisions you have received and for the provision of the services requested.

      With your express consent, your Personal Data may be transferred to third-party companies of our commercial partners for their processing for commercial and advertising purposes. These third-party companies will act as independent data controllers, taking all responsibility for the content of their advertising and compliance with the law on the processing of personal data, appointing any data controllers, in the event that they outsource the processing of your data. The commercial communications that may be sent to you via the web, post, e-mail, telephone (sms, mms, telemarketing) may concern the following product categories, concerning processing by third-party companies belonging to the following sectors:

      1. Communications: communications and technology products and services, etc.;
      2. The financial and banking sector: financial entities, insurances, investment, social security, etc.;
      3. Leisure Time: pay TV, editorials, tourism, sports, collecting, photography, pastime, games, transport, navigation, tourism (hotels, tour operators, travel agencies, airlines, etc.), aerospace, publishing, gardening, hobbies, raffles, competitions, collectibles, photography, entertainment, communication and entertainment, art, music, etc.;
      4. Distribution and trade: electronics, information technology, image and sound, fashion, accessories, clothing, textiles, bazaars, cosmetics and sanitary, chemical, pharmaceutical and bio-technology, agro-food, supermarkets, beverages, office equipment, furniture, etc.;
      5. Automotive: products and services related to cars, industrial vehicles, cycles and motorcycles, trucks, mechanics and metallurgy, etc.;
      6. Energy and water: products related to electricity, hydrocarbons, gas, water and utility, etc.;
      7. NGOs and associations: products and services related to non-profit organisations, foundations, etc.;
      8. Education, training, education, university, etc.;
      9. Communication and services: advertising, marketing, events, consulting, advertising, PR agencies, advertising agencies, media centres, telecommunications, market research, etc.;
      10. Ecology and environment;
      11. Building, civil engineering and real estate products/services: construction, decoration, home, design, real estate agencies, etc.;
      12. Exhibitions and events, etc.;
      13. Information technology, Internet, e-commerce sites, etc.;
      14. Casino with Italian administrative license (aams), etc.;
      15. Political communications.

      As of now, we would like to point out that your Personal Data communicated to third-party companies may be used by such third-party companies as provided for in their respective independent statements. In some cases these third-party companies, as independent data controllers, may prefer to contact you directly to inform you in detail about how they will process your Personal Data, what opportunities they have in store for you and how to exercise your rights in this regard. These third-party companies may retain the data communicated for the purpose of sending advertising and commercial communications (marketing) and/or direct sales, by e-mail, fax, telephone and any other remote communication technology, without prejudice to your right to oppose the processing for these purposes at any time, by making a simple request without any formalities to the relevant data controller.

      The disclosure of your Personal Data to these third-party companies is based on contracts between us and these third-party companies, for which that an updated list of such third-party companies is always available on this page.

      In communicating your Personal Data to such third-party companies we will always take care to process your Personal Data according to the principles of lawfulness and fairness, respecting the security parameters required by law.

      None of your Personal Data will be subject to voluntary disclosure where not expressly authorised by you.


    • 4. Processing Method

      The Personal Data held for the purposes set out above is processed by us, in a lawful and correct manner, by the prevalent use of automated or semi-automated tools.


    • 5. Optional provision of data, consent and consequences of refusal

      Except in the cases in which the acquisition of Personal Data is deemed necessary for the purposes of using the services you have requested, the provision of any other Personal Data is entirely optional.

      Failure to provide consent for profiling activities, such as the study and analysis of your interests and requests for the determination of individual and group profiles referred to in Point 2.2 (ii) will not have any detrimental consequences for you, but your experience on the Platform may be limited, by virtue of the fact that it will be impossible for the members of the communities to which you belong to discover the skills and interests you are interested in making available and we will no longer be able to personalise the contents shown in the platform and in the notifications (that includes status shares, events, projects, job offers and any high content) in line with your interests and skills.


    • 6. Duration of the preservation of your personal data

      In accordance with applicable legislation on the protection of personal data, your Personal Data is stored for the period of time strictly necessary for the fulfilment of our obligations and for achieving the purposes for which it was collected. When we no longer need to use your Personal Data, we will remove it from our systems and records and/or take appropriate steps to anonymise it so as to prevent you from being identified (except where we need to keep this data in order to comply with our regulatory obligations).

      If you have given us consent for the processing of your Personal Data for profiling and/or direct advertising purposes in the absence of your explicit new consent to be expressed near the approach of the following specific deadlines, we will delete your Personal Data processed for profiling purposes within 12 months of registration, while if it is processed for direct advertising purposes, then within 24 months of registration.


    • 7. Rights of the data subject

      You have the right to request details about the Personal Data we process, and to revoke your consent to its processing, to correct or delete it and not to be contacted if you have not requested this.

      1. The right to access your Personal Data

        You can request access to your Personal Data by contacting us through the contact details at the foot of the page. The file containing your Personal Data is usually made available within 10 days. It will however be made available no later than 30 days. On occasion, we may be in the position of not being able to consent to access to your Personal Data (for example, if access unreasonably damages someone else's privacy or endangers someone's security). In this case we will provide you with a formal and explicit explanation of the reason for this impossibility. In some cases, we may also charge you an administrative fee to provide access to your Personal Data. Any fees will be reasonable and before we provide access to your Personal Data we will notify you to obtain your consent. If you request a copy of your Personal Data using electronic means, such as email, we will provide you with a copy of your data in electronic format, unless you request otherwise.

      2. The right to modification or cancellation/deletion of your Personal Data

        If you have an account, you can access this account to modify or delete your Personal Data. If you have trouble updating or deleting your data, you can still send an email with your request to info@edgarsc.com and we will solve the problem as soon as possible.

        In the case of exercising the right to be forgotten, we will inform our business partners and any other parties to whom the Personal Data has been communicated of your request.

      3. The right to object to the processing of your Personal Data

        You have the right to ask us to stop processing your Personal Data, even if such processing is necessary for our legitimate interests (for example, when processing is necessary for the commercial purposes we intend to achieve), including for the data we use to send you personalised offers, product recommendations and similar communications. You also have the right to ask us to stop processing your Personal Data for direct advertising purposes. However, we will only send you advertising communications if you have given us your prior express consent. Should you change your mind, you can easily unsubscribe from our advertisements at any time by following the instructions included in them. If you have given your consent to receive offers from our business partners, they are responsible for your rights, including the right to opt-out of receipt of their offers. However, you can opt-out of receiving such offers from third parties at any time by logging into your account and changing your settings. If you have already agreed to receive such offers, your Personal Data will cease to be transmitted to our business partners from the day your request is processed.

      4. The right to have your Personal Data transmitted to another organization (so-called. Portability of Personal Data)

        In regards to the processing of your Personal Data on the basis of your consent or for the performance of a contract, you have the right to request that we provide you with the data concerning you and held by us in a structured format, commonly used and legible, as well, where technically possible, to transmit this data directly to another organisation.

      5. Complaints

        If you believe that the applicable law on the protection of personal data has been breached, you have the right to file a complaint to the Local Data Protection Authority of the European Economic Area (“EEA”).

        The local authority for the protection of personal data will be different depending on the country in which you are located. In the annex to the Privacy Policy, you can find a list of the local authorities concerned with the protection of personal data in the countries of the EEA in which we operate.

        You can exercise the rights mentioned above at any time, by sending us a simple request via e-mail.

      Physical location of Personal Data

      Your Personal Data is stored in the European Economic Area ("AEE"). Specifically, your Personal Data is stored on an Amazon Web Service and/or Google Cloud server machine, located respectively in Ireland and in the Netherlands. The Data may in any case be transferred and stored in a location outside the EEA where these countries are deemed by the European Commission capable of guaranteeing an adequate level of protection. Your personal data may also be processed by staff working outside the EEA, that works for us or for one of our service providers. We will make all reasonable efforts to ensure that your Personal Data is processed in a secure and consistent manner with the Privacy Policy and applicable personal data protection laws, including, if applicable, by adhering to European standard contract terms (or equivalent measures) with legal entities outside the EEA in receipt of personal data.


    • 9. How can we be contacted?

      If you have any questions or concerns about how we process your Personal Data, or you wish to stop the processing or would like to request a copy of this data, please contact us at info@edgarsc.com. Include your reply address when you write to us.