PRIVACY POLICY STATEMENT
Before you provide us with your personal data, in compliance with the provisions of the General Data Protection Regulation (EU) 2016/679 (hereinafter referred to as the “Regulation” or “GDPR”), of Legislative Decree no. 196 of 30 June 2003, as amended by Legislative Decree no. 101 of 10 August 2018, which aims to protect the fundamental rights and freedoms of individuals, and in particular the right to the protection of personal data, it is important that you read a series of information aimed at ensuring that the processing of your personal data is carried out in compliance with your fundamental rights and freedoms.
TaTaTu S.p.A. (hereinafter referred to as “TaTaTu” or “we”) cares about the protection of your personal data and wishes to offer you the best possible experience so that you can enjoy our service today, as well as in the future. This Privacy Policy (hereinafter referred to as "Policy") describes how we collect, use, store or otherwise process (jointly "processing") the personal data of users of the TaTaTu "Platform" (hereinafter also referred to as "Services").
Introduction
Data controller
Data Protection Officer
Purpose of processing and legal basis
Processing of personal data and methods of processing
Anonymous data processing
Nature of the provision of personal data and consequences of denial
Communication and sharing of personal data
Cookies and other technologies
Minors
Storage periods for personal data
Rights of the data subject
Third-party websites and services
Company events
1.Introduction
The Platform allows users to enjoy multimedia content, such as videos or images, and to interact with Platform content. Users are rewarded with coins (hereinafter "TTU Coins") earned by interacting with content on the Platform. For more details on how our Platform works and to read the terms that govern your use of the Platform, please see our Terms of Use.
2.Data controller
The Data Controller of your personal data is TaTaTu S.p.A. (Tax Code and VAT Number 15653581007), with registered office in Barberini Street 29 – Rome (hereinafter referred to as the “Data Controller”). The Data Controller can be contacted at the following email address: privacy@tatatu.com
3. Data Protection Officer
TaTaTu S.p.A. has appointed a Data Protection Officer, who may be contacted at any time at the following e-mail address [●].
4.Purpose of processing and legal basis
Below, you will find further details about the ways in which we process your personal data.
PURPOSE
LEGAL BASIS
Registration to the Platform and proper provision
of the Services, including:
•management of user profiles and published content
•managing auctions and fulfilling your orders and requests
•the calculation and management of TTU Coins earned by you
•administration of our award program
•enabling you to update, modify and manage your profile and content
•enabling us to communicate with you on the Platform about your use of the Services
•enabling us to carry out any activities necessary or useful for the constant improvement of the Services. The processing carried out for this purpose is necessary for the fulfilment of contractual obligations. The Data Controller has identified the legal basis of the data processing pursuant to Article 6, letter b) of the Regulation.
B) Fulfilment of legal obligations we are subject to. The processing carried out for this purpose is essential for fulfilling legal obligations. The Data Controller has identified the legal basis of the data processing pursuant to Article 6, letter c) of the Regulation.
C)To respond to any request you send us by filling in the contact form. The processing carried out for this purpose is essential for fulfilling contractual obligations. The Data Controller has identified the legal basis of the data processing pursuant to Article 6, letter b) of the Regulation.
D)Sending informative and promotional communications to improve your experience (Direct Marketing).
The processing carried out for these purposes is carried out with your prior, specific and informed consent provided to the Controller individually for each of the purposes listed, pursuant to the provisions of Article 6 letter a) of the Regulation.
In any case, you can always send an e-mail to cancel each individual consent given to privacy@tatatu.com
E) Sending information, promotional communications and personalized suggestions based on your tastes and preferences expressed on the Platform as well as on the activities carried out, content published and used (Direct Profile Marketing).
F) Our partners will send you information, promotions and suggestions that are personalized according to your tastes and preferences expressed on the Platform as well as the activities carried out, content published and used. For more information about the objective described here, please refer to section 8 of this Policy (Profiled Marketing by Third Parties).
G) Troubleshooting, technical assistance and support provided on the Platform, as well as password recovery through double authentication.
The processing carried out for these purposes is necessary for the purposes of pursuing the legitimate interest of the Controller, in accordance with the provisions of Art. 6, letter f) of the Regulation.
H) Preventing threats to the integrity, availability and confidentiality of your personal data, combating spam or other malware and, in general, detecting, preventing and mitigating security risks (Information security)
I)Fraud prevention and, more broadly, the prevention of access to the Services provided by the Platform by persons who may compromise its security (Fraud prevention)
5. Processing of Personal data processed and method of processing
The processing of your personal data shall be carried out electronically or automatically and transmitted through telematic networks. The Data Controller adopts adequate technical and organizational measures to guarantee an appropriate level of security with regard to the type of data processed.
Below, you will find more details about the personal data being processed.
Registration to the Platform and Correct Provision of Services
Necessary Optional
Data provided by you First name, last name and e-mail address for the purpose of registration and verification of your account.
Furthermore, if you decide to participate in auctions or to use the TTU Coins you have earned to win prizes, we will ask you to provide us with your address and mobile phone number so that we can arrange for delivery of the goods you have won. Additional personal data you provide us with in order to enrich and personalize your user profile, content you upload, and share, likes and dislikes expressed through "likes" or comments on your own content, that of other users or in blogs and forums.
ii. To respond to any request you send us by filling in the contact form.
Necessary Optional
The data you provide Contact information, name, surname and other relevant information you choose to provide when describing the problem, you are experiencing
N/A
iii. Marketing and profiling
With specific regard to the processing of personal data for marketing and profiling purposes, both direct and third party, the provision of your personal data is totally optional and processing is subject to your prior specific and informed consent to the processing of your personal data for each of the purposes listed in paragraph 4, points D, E and F.
In any case, you can always send an e-mail to cancel each individual consent given privacy@tatatu.com
Marketing Profiling
Data provided by you Contact information, name, surname, further personal data provided by you to enhance your user profile. Contact information, name, surname, further personal data provided by you to enhance your user profile.
Data collected and processed by the Platform
N/A Content uploaded, shared and enjoyed by you, likes and dislikes expressed by means of "likes" or comments on your own content, that of other users or in blogs and forums.
The details of your TTU Coins purchases and auctions in which you have participated.
Information about how you use our Services, types of content you view or interact with, features you use, actions you take on the Platform, people or accounts you interact with, and the time, frequency and duration of your activities on the Platform.
iv. Information security & Fraud prevention
When using the Platform, we may automatically collect certain information as further detailed in the table below.
What personal data do we collect?
Why do we collect this personal data?
Details of your transactions with TTU Coins to and from your account. We collect this information to enable you to use our services securely and to protect you from fraud, as well as to provide you with technical or issue-related support that you are currently experiencing. Furthermore, the processing of this information enables us to prevent access to the Services provided by the Platform by persons who may compromise the security of the Services, to prevent threats to the integrity, availability and confidentiality of your personal data, to combat spam or other malware and, in general, to detect, prevent and mitigate security risks.
Technical information (such as: response times of Platform pages, download errors, duration of visits to certain Platform pages, information about your interaction with certain Platform pages, such as scrolling, clicking, etc.).
Your IP address and details of your mobile phone's operating system.
v. Interactions with other social media platforms
When you interact with us or post content about us on third party social media platforms, such as Facebook, Twitter or Google+, we may collect certain personal data and information about that interaction.
The personal data that may be collected depends entirely on the settings you define on these additional social media platforms and the general terms and conditions and data protection policies of these platforms.
The personal data we may collect may include, for example, your profile picture, gender, username, user ID, age group, language, country, list of friends or followers.
We may also allow you to post certain information from these platforms to your TaTaTu profile and allow you to access the Services using your third-party social media account, in which case, you will be expressly asked to consent to our accessing and collecting certain information from your social media profile according to the specific policies of that platform.
Please note that this privacy policy does not refer to any processing of personal data by third-party social media platforms. TaTaTU has no control over or responsibility for the processing of personal data that may be carried out by third parties on their social media platforms. For more information on processing by third parties, please refer to the privacy policy of the individual social media platforms.
6. Anonymous data processing
Anonymous data is information that is altered by means of a computer technique in such a way that it cannot be linked to an identified or identifiable natural person. As a result, the Regulation does not apply to the processing of such anonymous information.
We may use anonymous or combined data for various purposes, such as to better understand the needs and behaviors of our user base, improve our Platform and Services, conduct business intelligence and marketing activities, and detect security threats.
Please note that, with the sole exception of this section, none of the other provisions of this notice applies to anonymous and/or combined data.
7.Nature of the provision of personal data and consequences of a refusal to provide them
The provision of your personal data indicated as compulsory is essential for the pursuit of the purposes set out in paragraph 4, sub-paragraphs (A), (B) and (C).
Failure to provide the aforementioned personal data or the provision of incorrect data shall make it impossible for you to use the service.
Otherwise, the provision of your personal data for the pursuit of the purposes described in sub-paragraphs D), E) and F) of paragraph 4 of this information notice is optional and your refusal will make it impossible for the Data Controller to pursue the aforementioned purposes but will not, in any way, affect your ability to use our Services.
8.Communication and distribution of personal data
Your personal data shall be processed by authorized personnel and by subjects appointed as Data Processors pursuant to Article 28 of the GDPR, in order to carry out the processing activities necessary to pursue the aims detailed in paragraph 4 of this notice. The Data Processors are direct collaborators of TaTaTu and a list thereof is updated on an ongoing basis and is available upon request by sending a request to the following email address: privacy@tatatu.com.
Additionally, if you decide to consent to your personal data being processed for the purposes of third-party profiled marketing (paragraph 4, sub-paragraph F) of this notice), we hereby inform you that some of your personal data will be shared with our third-party partners (hereinafter "platform partners").
Indeed, as described during the registration process, TaTaTu works with several platform partners so that they can better reach users with more relevant ads and content, based on their visits, activities and interactions on our Platform. What makes us different from other social media platforms, however, is that our users earn rewards for sharing their activity and interactive data with platform partners (see our Terms of Use for information on how to earn TTU Coins).
Please note that the list of our platform partners is constantly updated and is available on request by sending an email to privacy@tatatu.com
In view of the above, if you explicitly consent to the processing of your personal data for third-party profiled marketing, we will share certain personal data with our platform partners. You can find more details about personal data processed for third-party profiled marketing purposes in paragraph 5, point iii. of this Policy.
In any case, it is important for you to remember that your consent to the above-mentioned purposes and, therefore, to the disclosure of your personal data to our platform partners for third-party profiled marketing purposes, is entirely optional. If you choose not to give us your consent, this will not affect your ability to use our Services.
In addition, you may withdraw your consent to the above-mentioned purpose, at any time, by sending an e-mail to privacy@tatatu.com
We hereby inform you that your personal data is processed within the territory of the European Union. Moreover, if necessary, for technical or operational reasons, we reserve the right to transfer your personal data to third countries outside the European Union, subject to the existence of a “decision of adequacy” or on the basis of adequate guarantees, or in the cases specifically provided for by the Regulation.
Under no conditions, shall your data be disclosed.
9. Cookies and other technologies
In order to allow you to display more relevant advertisements on our website [insert website], to manage our advertising on third party sites, mobile apps and online services, and to measure and improve our advertisements and marketing efforts, we may work with third party partners, independent advertising companies, channel partners, measurement services and advertising networks (hereinafter collectively referred to as “advertising companies”). These advertising companies may use cookies, pixel tags and other tools to collect IP address, device ID, ad ID and other identifiers, as well as information about your browsing and activities on our Platform and various third-party sites. These advertising companies may use this information to provide you with more relevant advertisements and content and to evaluate the success thereof.
For more information on the processing of your personal data collected by means of cookies and similar technologies, please consult our Cookie Policy in which you can also find more specific and detailed information regarding the advertising companies with which we collaborate.
For more information on online advertising and on how to opt out of interest-based advertising, please visit the following websites:
-Canada: www.youradchoices.ca
- EU: www.youronlinechoices.eu
- USA: www.aboutads.info
Equally, you can check your browsing options and deactivate monitoring on the Platform by changing the settings on your device:
-Apple: http://support.apple.com/kb/HT4228
-Android: http://www.google.com/policies/technologies/ads/
-Windows: http://choice.microsoft.com/en-US/opt-out
Please note that deactivating monitoring on the Platform does not mean that you will not receive advertising while using our Platform. More information is provided at the above links.
10. Minors
The Platform is not intended for users under the age of 14, and we do not knowingly collect personal data from individuals under the age of 14. Nevertheless, despite TaTaTu's efforts to monitor and prevent the registration of such users, it is not possible to guarantee that there will be no registered users under the age of 14.
If a user, under the age of 14, has provided personal information without the prior consent of the person exercising parental responsibility, the latter is asked to request the deletion of the data provided by the child, at any time, by sending an e-mail to the following address: privacy@tatatu.com
11. Storage periods for personal data
Your personal data will be kept for the period of time strictly necessary for the pursuit of the purposes described in paragraph 4 of this policy, without prejudice to any further legally required storage period.
In particular, in relation to the: •purposes referred to in sub-paragraph A), paragraph 4 of this policy, your personal data will be kept for as long as is necessary for the proper provision of the Services or until you delete your account. If you do not access your account on the Platform for a continuous period of more than 24 months, the Controller will delete your profile; purposes referred to in sub-paragraph C), paragraph 4 of this information notice, the Data Controller will keep your personal data for the time strictly necessary to respond to the request you have made by filling in the contact form; - purposes referred to in sub-paragraphs D), and E) paragraph 4 of this policy, the Controller will store your personal data for direct marketing purposes for no longer than 24 (twenty-four) months and for profiled direct marketing purposes for no longer than 12 (twelve) months, both starting from the time of collection. Such data will then be securely erased or irreversibly anonymized: purposes referred to in sub-paragraph F) paragraph 4 of this policy, for more information on how long our platform partners may keep your personal data, please refer to their privacy policy. The list of our platform partners is constantly updated and is available on request by sending a communication to the e-mail address privacy@tatatu.com
•the purposes referred to in sub-paragraphs G) H) and I), paragraph 4 of this notice, personal data will be stored in accordance with the applicable regulations for a period of time not exceeding that necessary to achieve the purposes for which they are processed.
In any case, TaTaTu, will take care to use the data for the purposes referred to in paragraph 4 for a period of time consistent with your interest in the initiatives of the Owner.
12. Rights of the data subject
Pursuant to Articles 15, 16, 17, 18, 20 and 21 of Regulation (EU) 2016/679, the Data Controller hereby also informs you that – in cases where the applicable conditions are met – you may exercise the following rights:
•access to personal data;
•the rectification of personal data;
•the deletion of personal data, in the cases provided for by the GDPR;
•the limitation of processing of the personal data, subject to the conditions provided for by the Regulation;
•the portability of personal data;
•opposition to the processing of personal data.
Moreover, you have the right to lodge a complaint with the Italian Data Protection Authority.
Your requests to exercise the aforementioned rights must be sent to the following email address: privacy@tatatu.com
Third-party websites and services
While using the Platform, you may come across links to third-party websites and services. This Privacy Policy does not refer to or cover any processing of personal data carried out by such third parties. TaTaTu has no control or responsibility for the processing of personal data carried out by third parties through their websites and/or services. For more information on the processing carried out by third parties, please refer to their privacy policy.
Company events
If TaTaTu is taken over by, or merges with, another company, transfers some or all of its assets to a third party, or in the event of bankruptcy or dissolution of the business, your personal information may be transferred to an acquiring company or third party, including in anticipation of or in connection with the prior due diligence required for such business transactions, subject to the limitations and safeguards of applicable law. In any event, you will be promptly informed of any corporate events so that you can decide whether to proceed with the closure of your profile or to continue using the Services.
Last update: 10/09/2023
We are constantly striving to improve the level of protection of your personal data and respect for your privacy, and we may amend, supplement or update this privacy policy from time to time. We will notify you of any changes to the privacy policy via pop-ups on the Platform and, in any event, you may at any time consult the policy in the privacy section of the Platform to ensure that you are kept up-to-date on all processing activities and our compliance with applicable data protection legislation.