1. WHAT AND WHOM DOES THIS PRIVACY POLICY COVER?

The Company is the data controller of the personal data (e.g. information that identifies a specific person, such as a full name or e-mail address) that we collect from and about you through the Company’s Services, which is processed in accordance with the terms of this Privacy Policy.

This Privacy Policy, together with our Cookies Policy, applies to all users, including those who use the Company’s Services without having registered or subscribed to any Company Service, and those who have registered or subscribed to a Company Service. As set out in our Terms of Use, the Company’s Services are intended for a general audience, are not directed at children and do not knowingly collect personal data from children under 16 years of age.

2. WHAT TYPE OF PERSONAL DATA DO WE COLLECT ABOUT YOU?

The Company collects (1) registration data, when you register or when you register for a Company Service, (2) public data and posts that are shared through the Company’s Services, (3) data that you have allowed social media to share with the Company, (4) activity data when you access and interact with a Company service. Specifically, the Company collects the following types of data from and about you:

Registration data, that is, the information you submit in order to register for a Company Service, for example to create an account, post comments, receive a newsletter or take part in a competition. Registration information may include, for example, your first name, surname, e-mail address, gender, country, postcode and date of birth.
Public data and posts consisting of comments or content that you post on the Company’s Services and your personal data that accompany such posts or content, which may include your pseudonym, username, comments, likes, status, profile information and photograph. Public information and posts are always public, which means that they are available to everyone and may appear in the search results of external search engines.
Data from social media. If you access or log in to a Company Service through a social media service, or link a Company service to a social media service, the data we collect may also include your user ID and/or the username associated with that social media service, the information or content that you have allowed the social media service to share with us, as well as your profile photograph, e-mail address or friends lists, and the personal data that you have made public in connection with that social media service. When you access the Company’s Services through social media services, or when you link a Company Service with social media services, you authorise the Company to collect, store and use the relevant personal data and content in accordance with this Privacy Policy.
Activity data. When you access and interact with the Company’s Services, we may collect specific information about those visits. For example, in order to enable your connection to the Company’s Services, our servers receive and record information about your computer, device and browser, possibly including your IP address, browser type and other software or hardware information. If you access the Company’s services from a mobile or other device, we may collect a unique device identifier assigned to that device, geolocation data or other transaction details for that device. We may also collect cookies and other tracking technologies (such as browser cookies, pixels, beacons and Adobe Flash technology commonly called “Flash cookies”). These technologies may be used to collect and store information about your use of the Company’s Services, such as the pages you have visited, the videos and other content you have viewed, the search queries you have submitted and the advertisements you have seen. For more information, please refer to our Cookies Policy.
Information from other sources. We may supplement the information we collect with information from other sources, such as publicly available information about your online and offline activity from social media services and commercially available sources.

We do not collect:

Financial information from a payment service provider: in some cases, we may use an unaffiliated payment service to enable you to purchase a product or make payments (“Payment Service”). If you wish to purchase a product or make a payment through a Payment Service, you will be directed to a Payment Service website. Any information you provide to a Payment Service will be subject to the privacy policy of the Payment Service and not to this Privacy Policy. We have no control over, and are not responsible for, any use by the Payment Service of information collected through any Payment Service.
Sensitive information: we ask that you do not send us, and do not disclose, sensitive personal data (such as social security numbers, information relating to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) on or through the Company’s Services or otherwise.

Linked services
Finally, the Company’s Services may also link to websites, including social media websites, operated by non-affiliated companies, and may provide advertisements or offer content, functionality, games, newsletters, competitions or applications developed and maintained by non-affiliated companies. The Company is not responsible for the privacy practices of non-affiliated companies, and as soon as you leave the Company’s Services or click on an advertisement you should check the applicable Privacy Policy of the other service.

Functionality cookies
These cookies “remember” your preferences as you browse our site, so that we can suggest suitable products based on your needs. With these cookies you enjoy a personalised version, which makes it much easier to find what you are looking for.

3. HOW DO WE USE YOUR PERSONAL DATA?

We use the personal data that we collect from and in relation to you in order to:

  • Provide you with the Company’s Services and Features,
  • Measure, analyse and improve those Services and Features of the Company,
  • Improve your experience through the Company’s Services (both online and offline) by providing content that you may find relevant and interesting,
  • Enable you to comment on content and to take part in online games, competitions or reward programmes,
  • Provide you with customer service and answer your questions,
  • Protect the rights of the Company and of others. For example, there may be cases in which the Company may use your personal data, including cases where the Company believes, in good faith, that such processing is necessary for: (i) the protection, enforcement or defence of the legal rights, security or property of the Company, of the Company’s affiliates or of their employees, agents, contractors, licensors and suppliers (including the enforcement of our agreements and terms of use), (ii) the protection of the safety, privacy and security of users of the Company’s Services or of citizens, (iii) the protection of the Company, as well as other third parties involved, such as the Company’s suppliers, from fraud or for risk management purposes,
  • Comply with applicable laws or legal processes and/or respond to requests from competent government authorities.
  • Complete a corporate transaction such as a proposed or actual reorganisation, merger, sale, joint venture, assignment, transfer or other disposal of all or part of the business, assets or stock of the business (including in any bankruptcy or similar proceedings). For example, if the Company is involved in a merger or transfer of all or a substantial part of its business, the Company may disclose and transfer your personal data to the party or parties involved in the transaction as part of that transaction,
  • Enable the social transaction function – if you log in or link a social media service account with the Company’s Services, we may share your username, photograph and likes, as well as your activities and comments, with other users of the Company’s Services and with your friends who are associated with your social media service. We may also share the same personal data with the social media service provider,
  • Send you (via e-mail, SMS, telephone, chat and social media), with your prior consent, offers, promotions and other commercial communications relating to the Company’s Services.
  • Send you, with your prior consent, commercial communications tailored to your interests and needs through the communication methods referred to in point (j) above.

We may use anonymous data or data that no longer identify you personally, even indirectly (e.g. statistics) for any purpose or share them with third parties.

4. ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

The processing of your personal data for the purposes :
Of Section 3, points (a) to (f) of this Privacy Policy is necessary for the provision of the requested services and is therefore mandatory, because otherwise the services could not be provided, of Section 3, point (g) of this Privacy Policy is required in accordance with applicable laws and is therefore also mandatory.

Of Section 3, point (h) of this Privacy Policy is carried out on the basis of the legitimate interest of the Company and of its counterparties in conducting such economic activities. That interest is adequately balanced against your own interest, given that the data processing is carried out within the strictly necessary limits for the conduct of such economic activities. This data processing activity is not mandatory and you may object at any time as described in Section 11 of this Privacy Policy.

By contrast, the processing of your personal data for the remaining purposes :
Of Section 3, point (i) is at your discretion, but without your consent it is impossible to link a social media service account with the Company’s Service, which means that you will have to log in to the Company’s Service using a different mechanism,

Of Section 3, points (j) and (k) is at your discretion, but without your consent it is impossible for the Company and/or third parties to provide you with general commercial communications of the Company and services/products or communications from third parties based on your interests and needs, and to provide you with services under the same name. You may withdraw your consent at any time with regard to the processing of your personal data for the purposes of Section 3, points (i) to (k), by sending a notification to the e-mail address described in Section 11 below.

5. HOW DO WE PROCESS YOUR PERSONAL DATA?

Your personal data are processed by both electronic and non-automated means and are protected by appropriate security measures, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of the processing, as well as the varying likelihood and severity of the risk to the rights and freedoms of individuals. Specifically, the Company uses appropriate administrative, technical, personnel and physical measures designed to protect the personal data in its possession against loss, theft and unauthorised use, disclosure or alteration.

6. WHO CAN ACCESS YOUR PERSONAL DATA?

The Company may share your personal data for the purposes of Section 3 above with the following categories of recipients located within the European Union or outside the European Union, in accordance with and within the limits of the provisions of Section 7 below:

Third-party service providers who are entrusted with processing activities and, where required by applicable laws, are duly appointed as processors (e.g. cloud service providers, other group organisations, service providers who serve or support the Company’s Service and therefore, by way of example and without limitation, companies providing IT services, experts, consultants and lawyers – companies arising from possible mergers, demergers or other transformations, and
Affiliated companies in their capacity as data controllers or data processors.
Competent authorities for the purposes of compliance with applicable laws.
The data processors appointed by the company include IT service providers.
You may request from the Company a full list of the data processors that have been appointed, at the address stated in Section 11 of this Privacy Policy.

7. ARE YOUR PERSONAL DATA TRANSFERRED ABROAD?

Data may be transferred to countries within and outside the European Economic Area and in particular to America. The European Commission recognises that certain countries outside the EEA provide an adequate level of data protection in accordance with EEA standards. The full list of these countries is available at

http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm.

For transfers from the EEA to countries that are not considered safe by the European Commission, we have put in place appropriate and suitable safeguards designed to protect your personal data and to transfer your personal data in accordance with applicable data protection laws, such as standard contractual clauses approved by the European Commission in accordance with Articles 45 and 46 of Regulation (EU) 2016/679 on data protection (the “personal data protection regulation”). You have the right to request a copy of the above measures and further information about your personal data by contacting the Company at the address stated in Section 11 of this Privacy Policy.

8. WHAT ARE YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA?

You have the right, at any time, to:

obtain confirmation as to whether your personal data exist and be informed of their content and origin, verify their accuracy and request their correction, updating or amendment,
request the erasure, anonymisation or restriction of processing of your personal data that were processed in breach of applicable law,
object to the processing, in all cases, of your personal data on legitimate grounds.

You may send your request to the address stated in Section 11 below. In your request, include your e-mail address, name, address and telephone number and clearly specify the information you wish to access, change, update, remove or delete. We remind you that, even after the cancellation of your account, or if you ask us to delete your personal data, copies of certain information from your account may remain visible in certain cases such as, for example, where you have shared information on social media or other services or, for example, where the retention of such copies is necessary for the purposes of compliance with legal obligations or for the purposes of legal defence. Due to the nature of caching technology, your account may not be immediately inaccessible to others. We may also retain backup information about your account on our servers for a period of time after the cancellation or your request for deletion, for the purposes of compliance with applicable legislation.

We also give you several choices about the use and disclosure of your personal data for marketing purposes. You may withdraw your consent with regard to:

Receiving electronic communications from us. If you no longer wish to receive marketing-related e-mails from us, you can opt out of receiving marketing-related e-mails either by following the unsubscribe instructions in our communications or simply by changing your preferences in your user profile settings if you are a registered user, or through the consent management tool available on our website, if you are not a registered user. You may also send a request to the address stated in Section 11 of the Privacy Policy. In any event, the Company may continue to send you administrative communications about the provision of the Company’s Services.
Sharing your personal information with the Company’s affiliates or with business partners for their own marketing purposes. If you prefer that we do not share your personal information on an ongoing basis with the Company’s affiliates and/or with business partners for their direct marketing purposes, you can opt out of such sharing either simply by changing your preferences in your user profile settings, if you are a registered user, or through the consent management tool available on our website, if you are not a registered user, or by sending a request to the address in Section 11 of the Privacy Policy.

In all of the above cases, we may contact you and ask you for further information, which is necessary for the proper handling of your request. In addition, the additional rights described in Section 9 below apply from 25 May 2018.

9. WHAT APPLIES FROM 25 MAY 2018?

From 25 May 2018, the General Data Protection Regulation (GDPR) has entered into force and the following provisions apply:

Retention periods that apply to your personal data

We will retain your data only for the period necessary to fulfil the purposes for which the data were collected, as described in this Privacy Policy. In any event, the following retention periods will apply with regard to the processing of your personal data for the purposes stated below:

Data collected for the purposes stated in Section 3, points (a) to (h) of this Privacy Policy are retained for the duration of the provision of the Company’s Service, plus the duration of the limitation period under the legislation in force from time to time, after the end of the Company’s Service. Data collected for the purposes of Section 3, point (i) of this Privacy Policy are retained for the period required for you to log in to the Company’s Service through a social network, and
Data collected for the purposes of Section 3, point (j) are kept in a form that permits identification of data subjects for no longer than is necessary for the purposes of the processing of the personal data; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, in accordance with Article 89(1) of the General Data Protection Regulation (GDPR) and subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”)
Data collected for the purposes of Section 3, point (k) are kept in a form that permits identification of data subjects for no longer than is necessary for the purposes of the processing of the personal data; personal data may be stored for longer periods insofar as the personal data will be processed solely for archiving purposes in the public interest, for scientific or historical research purposes or for statistical purposes, in accordance with Article 89(1) of the General Data Protection Regulation (GDPR) and subject to implementation of the appropriate technical and organisational measures required by this Regulation in order to safeguard the rights and freedoms of the data subject (“storage limitation”)
At the end of the retention period, your personal data will be cancelled, anonymised or aggregated.

Additional rights

In addition to the rights stated in Section 8 of this Privacy Policy and following the application of the Personal Data Protection Regulation, you will also have the right, at any time, to:

Request that the Company restrict the processing of your Personal Data where:
You contest the accuracy of the personal data, until we take the necessary steps to correct or verify their accuracy,
The processing is unlawful, but you do not want us to delete your personal data,
We no longer need your personal data for the purposes of the processing, but you need them for the establishment, exercise or defence of legal claims, or
You have objected to the processing on grounds of legitimate interests pending verification as to whether the Company has compelling legitimate grounds to continue the processing.
Object to the processing of your personal data,
Request the erasure of your personal data without undue delay,
Receive an electronic copy of your personal data, if you wish to transfer the personal data you have provided to us, either to yourself or to another provider (“data portability”), where the personal data are processed by automated means and the processing is either (i) based on your consent or (ii) necessary for the performance of the Company’s Service, and
Lodge a complaint with the competent data protection supervisory authority.

10. UPDATES TO THIS PRIVACY POLICY

The Company may amend or update this Privacy Policy for any reason (including, by way of example, changes to applicable law and to interpretations, decisions, opinions and orders relating to that applicable law.) Refer to the Effective Date at the top of this Privacy Policy to see when it was last revised. Any changes to this Privacy Policy will be notified in advance by publishing the revised Privacy Policy on the Company’s Services. Where we make material changes to this Privacy Policy that change the nature of the processing or expand our rights with regard to the use of the personal data we have already collected from you, we will notify you and give you a choice regarding the future use of such personal data, as may be required by applicable legislation.