PRIVACY POLICY
Version of May, 25, 2018
Premise and Definitions
Notwithstanding what is indicated in the Terms of Use, PlacenPeople is a
web platform that provides its services through the Website
www.placenpeople.com, the web propoerties and blogs connected to it, and through the relevant Apps available for mobile
devices.
This Privacy Policy (hereinafter "Policy")
provides information on how PlacenPeople processes the Personal Data of those
who use the services, in compliance with the provisions of art. 13 D. Lgs.
30.6.2003 n. 196 (hereinafter, "Privacy Code") and by the articles
13-14 of EU Regulation no. 2016/679 (hereinafter, "GDPR").
The acceptance of this Policy is a necessary condition for
accessing PnP Services, which can not be otherwise provided. The user who even
partially does not accept this Policy is obliged not to register on the
Platform, to not access it and / or to cancel his profile if previously
registered.
Pursuant to and for the effects of the same, the
definitions contained in the paragraph "Premise and definitions" of the Terms of Use
apply. In addition, the following definitions apply, regardless of the singular
or plural usage of the terms reported:
·
Personal data (also “PD”): any
information obtained from PnP on a natural person who is, on the basis of the
same information, identified or identifiable;
·
Aggregate data: a set of
information on individuals or groups of people that does not allow, following
specific treatments (so-called Pseudonymisation), to trace the Personal Data of
the individuals concerned;
·
Interested: person owner of
the personal data obtained from PnP which is, on the basis of the same data,
identified or identifiable;
·
Treatment: any operation
or set of operations performed by PnP on personal data or on a set of personal
data of the data subjects;
·
Data Controller: PlacenPeople
Srl, which is responsible for the processing of personal data collected;
·
Data Processor: natural or
legal person, public authority, service or other body that processes personal
data on behalf of PlacenPeople;
·
Consent of the
interested party: manifestation of free will, specific, informed and
unequivocal of the interested party, with which he expresses his consent to the
processing of personal data concerning him.
Data Controller
Data Controller is PLACENPEOPLE SRL, with registered
office in Viale Meucci 19/c, 70125 Bari (BA), Italy, VAT No. 08125910722, n.
rea 605992 (hereinafter "Controller").
At the time of writing this Policy, the contact details of
the Controller, as reported in the "contact" section of the Website
and the Apps, are: e-mail contacts@placenpeople.com.
Any variation of these data will be made known to Users
promptly, by updating the information contained in the "contacts"
section of the Website and the Apps.
Data Processor
For all and / or certain processing operations, PnP may
use third-party companies established in EU or non-EU territory. The updated
list of data processors and data processors is kept at the Data Controller's
headquarters and will be made known on request by the interested parties.
Object of the Treatment
PlacenPeople may process the personally identifiable and
non-sensitive Personal Data of its Users, which have been:
·
provided directly by the Users through their insertion on
the Platform, ie filling in appropriate text or numeric fields, or selecting
items from lists, or by ticking boxes (eg registering with the platform,
creating or updating profiles or announcements, communicating with other users
or with PlacenPeople, accessing or connecting to the platform through third
party sites);
· provided directly by the Users through their insertion in communication or messaging channels indicated as "official" by PlacenPeople in its "contacts" page.
· obtained through the mobile devices of the Users, which transmit information concerning the position, the IP address, the IMEI code and the like. Some devices allow the User to prevent the tracking of their position. This could, however, limit and / or reduce the functionality of the services provided by the Platform;
·
generated during the use of the Platform (eg IP address,
used software, pageviews, visit time, source and exit URLs);
·
generated during the use of the Service, such as for example
reservations and presence in activities. With regard, in particular, to
payments made on the Platform, such data may be shared by PnP with the
Organizers or with the Managers for organizational or commercial purposes; through
the privacy settings of profile, the User may at any time request that such
data be communicated and viewed by the recipient only in aggregate form, to
prevent the identification of the same;
·
inserted by other members of the Community, in the process
of creating an invitation to registration to be presented to the User. Should
the User decide not to proceed with the registration, we will delete such data.
If the User decides to proceed with the registration, he / she must approve
these data, and from that moment on we will process such data as provided by
the User.
· sent to PlacenPeople by Users or also by other members of the Community, in ways that make explicit the User's consent to the use of the modality itself (example: in a photo, in which users are posing with the name tag or symbols of PlacenPeople)
Purpose and
Legal basis of the Treatment
Users' Personal Data may be processed by PlacenPeople only
with the consent of the interested parties, which must be provided autonomously
for the various processing purposes set out below. These include, in
particular:
A) Purposes of Service (management of the Platform and the
Service, improvement of the Users' experience), aimed at:
·
allow, upon request of the User, the registration, access
and use of the PnP Platform;
·
send operational and service messages, such as notices
related to reservations, support messages or administrative messages,
reminders, technical communications, updates, safety notices, and other
information requested by the User or made necessary by the Service;
·
make payments, as well as the preparation of documentation
of a fiscal nature;
·
improve the Users' experience within the Community, making
visible information on the expected participation of the MeCs in the proposed
Activities, or participation to activities in the past, as well as organizing activities to benefit the Community, such as
events, awards, experiences and similar. The User can always limit the
visibility of his data within the Community by changing the Privacy settings of
his User Profile (so-called SuperPrivacy option), or communicating this request to PlacenPeople if the user profile is not accessible;
·
allow, only upon prior request by the User, forms of
collaboration between MeC and PnP and give the User access to particular roles,
which allow actions aimed at expanding and improving the functioning of the
PlacenPeople Platform;
·
fulfill the pre-contractual, contractual and tax
obligations deriving from the relationships existing with the User;
·
fulfill the obligations established by law, regulations,
community legislation or an order of the Authority;
·
prevent or detect fraudulent activities or abuses,
increasing trust and security within the Platform, including through surveys
and checks on published materials and on the profiles used, as well as through
controls even on governmental databases;
·
exercise the rights of the Owner, resolve any disputes
with the Users and enforce the rights of the Company towards third parties;
B) Marketing purposes, aimed at:
·
allow subscription to the Newsletter Service (both
registration and unsubscription are freely initiated by the User);
·
conduct analytics, research, advertising and marketing
activities with the aim of improving, managing, protecting and optimizing the
PlacenPeople Platform and activities, as well as the experience of our Users;
·
send promotional and / or commercial communications
regarding information of potential interest to the User. The User may at any
time oppose the further receipt of such communications by changing the Privacy
settings of his Profile;
C) purposes of communication and / or transfer to third
parties of data, for marketing, commercial, statistical or promotional
purposes.
Nature and Revocation of Consent
Consent to Data Processing for Service Purposes is
mandatory for registration to the Platform and for access to PnP Services,
which will not otherwise be provided (so-called Privacy On mode). By registering with the Platform, the User
authorizes PnP to process its Data for the purpose in question by setting its
privacy on the "Privacy On" level. The consent to the Treatment for
the Purpose of Service may always be revoked by the User by simply canceling
their MeC Profile from the PlacenPeople Platform (also obtainable through a specific request).
The consent to the processing of data for the purposes of
marketing and communication or transfer to third parties is, instead, optional
(so-called Free mode). With respect
to these purposes, the User does not provide any consent or confers any data
when registering with the Platform. The User can freely choose the Free mode by
changing the privacy settings of his User Profile, through the appropriate
functionality, or by consenting to PlacenPeople's request. The consent given for the purposes in question may be revoked at
any time by the User itself by further modification of the privacy settings of
their User Profile. In this case, the User will continue to have access to the
Platform and to PnP Services, with the exclusion of commercial and promotional
functions.
In order to ensure the best experience of the User, it is
in any case permitted to limit the Data Processing for Service Purposes to
collection only and, in particular, to exclude sharing of the User's economic
data within the Community (so-called Superprivacy
mode). The User can exercise this option by changing the Privacy settings of
his User Profile or by submitting a request in PlacenPeople. While not preventing access to the Platform, the choice of
the Superprivacy mode could affect the functionality of the same, limiting the
usability of some PnP Services.
Treatment Mode
PlacenPeople processes the Personal Data of Users through
collection, registration, organization, storage, consultation, processing,
modification, selection, extraction, comparison, use, interconnection,
blocking, publication, communication, cancellation and destruction of Personal Data. Data
may be processed either on paper or digital and / or automated.
Communications from Users and directed to PnP or to other
users can be examined by PnP, with the aim of preventing any fraud and abuse,
to verify compliance with applicable rules, to develop the product and the
offer, or even just to improve the service offered. PnP will try to prevent, as
far as possible, that its systems are used in violation of the law; however,
this activity does not imply any systematic control or guarantee on the
communications of the Users.
By using the Platform, User agrees that PlacenPeople, in
its sole discretion, may review, scan, analyze and retain his communications,
either manually or by automated means.
PlacenPeople treats Users' Personal Data only for the time
necessary to fulfill the aforementioned purposes and, in any case, no later
than 10 years from the termination of the relationship.
Access to Data
For the purposes mentioned above, PlacenPleople may make
the Processed Personal Data accessible:
·
to the employees and collaborators of the Data Controller,
or its subsidiaries and associates, and their employees, or to third parties
and PnP suppliers, in their capacity as persons in charge and / or internal
managers of the processing and / or system administrators;
·
to subsidiaries and associates, and to their employees
(for example, for support activities in the study of the feasibility of the
client's project, for technical project management activities, for the storage
of personal data, etc.), or to third parties and suppliers (for example,
providers for the management and maintenance of the website, suppliers,
lenders, professional offices, etc.), which perform outsourcing activities on
behalf of the Data Controller, in their capacity as external data processors.
The subjects in question undertake, in any case, to
process the User Data in accordance with this Privacy Policy, ensuring
compliance with the same obligations, methods and limits imposed on PnP.
Data
Communication
Depending on the nature of the consent given by the
interested party (Privacy On, Free or Superprivacy), PnP can communicate the
User's Personal Data as follows.
In case of consent for the sole purpose of Service
(Privacy On), some parts of the User Profile containing PD can be shared with
other Users within the Platform. Likewise, some parts of the User Profile may
be viewed by other Users on the Platform or in the Ads. Such parts may include,
as in the case of Announcements, information and PDs taken from the profile of
the Creator, as well as information or PDs taken from the profile of other
users (for example the subscribers to such Announcement).
Public User Profiles and Ads pages may be indexed by
search engines and may be publicly disseminated as search results.
When a booking is finalized, some PD of the User,
including for example the full name or the telephone, could be communicated by
PlacenPeople to the Organizer, in order to organize the meeting or to improve
the experience, or to third parties, in order to support organizational
activities or increase its level of security. In any case, PlacenPeople will
not share the telephone number of the Users unless there are previous
agreements to that effect, or a confirmed booking. The details of the MeC for
billing are never shared by PnP with the Organizer.
The mutual evaluation expressed by the MeC and the
Organizer at the end of an Activity, expressed according to one or more
parameters of judgment, could be publicly accessible on the Platform.
In case of consent for Marketing and Communication purposes
or transfer to Third Party (Free), in
addition to the sharing methods above, some parts of the Public User Profiles,
or hosted Announcements, may be viewed and / or shared externally with third
parties, for marketing or commercial purposes.
The sharing of the PD of the Users within the Community
will, instead, be limited in the option for the SuperPrivacy mode.
The User acknowledges and accepts that PlacenPeople may
use, store and communicate PD and content produced by it in order to:
·
respond to any complaints raised against PnP;
·
comply with judicial orders;
·
avoid Users' breach of obligations agreed in the Terms of
Use;
·
protect the rights, property or personal safety of
PlacenPeople, its Users or MeC, or the general public.
The Data Controller may, in any case, communicate User
Data to Supervisory Bodies, Judicial Authorities and to all other subjects to
whom the communication is mandatory by law. PlacenPeople commits itself, within
the limits of the commercially reasonable, to inform Users about requests
received from the authorities that involve their data, unless this is not permitted
by law or by the authorities' request, or to the judgment of PnP it is possible
to identify another impeding cause.
Aggregated Data and non-personal data may be used by
PlacenPeople for any purpose.
Social Plug-in
The PnP platform may use third-party social plug-ins (eg
the "like" button on facebook). With the use of these functions, the
User may send information to third parties. Any information on the processing
of data carried out by these third-party companies is contained in the Privacy
Policy of the companies in question, to which reference is made in full, with
full and total exclusion of any liability of PnP.
In addition, the MeC may link its PlacenPeople Profile to
third-party social networking sites (hereafter: "Socials"). In this
case:
·
some information on Socials may be available on the
PlacenPeople profile, or vice-versa;
·
some information on Socials may be available on
PlacenPeople announcements, or vice-versa
·
the User's contacts on these Social networks may view
information relating to the User's activities on the Platform, while
PlacenPeople users may view information related to the User's contacts on these
Socials.
Such information coming from the Socials will be subject
to the settings of such third party websites, and will be processed by
PlacenPeople for the reasons set out in the paragraph "Purpose and Legal
basis of the Treatment" of this policy.
Data Transfer
Users' Personal Data will be stored on Server sites within
the European Union or foreign countries, as long as they are hosted by GDPR compliant hosting companies. Any further information on this point can be requested to PlacenPeople.
Rights of the data owner
Data owners residing in the EU have the right to exercise,
at any time, the rights referred to in Articles 7 et
seq. of the Privacy Code and articles 15 et seq. GDPR, and in particular the right to obtain from PnP:
•
confirmation that a data processing is currently in
progress concerning him and, in this case, to obtain access to these data and
to this privacy note;
•
updating, rectification or integration of inaccurate
personal data concerning him;
•
the cancellation of personal data concerning him if: a)
they are no longer necessary with respect to the purposes for which they were
collected or otherwise processed; b) the interested party revokes the consent
on which the treatment is based and if there is no other legal basis; c) the
interested party opposes the processing and there is no legitimate overriding
reason to proceed with the same; d) personal data have been processed
unlawfully; e) personal data must be deleted to fulfill a legal obligation
under Union or Member State law to which the data controller is subject;
•
a limitation of Data Processing if: a) the data subject
disputes the accuracy of personal data, for the period necessary for the data
controller to verify the accuracy of such personal data; b) the processing is
illegal; c) personal data are necessary for the interested party to ascertain,
exercise or defend a right in court; d) the interested party has opposed the
processing of personal data for the purpose of sending advertising or direct
sales material or for carrying out market research or commercial communication,
through the use of automated call systems without intervention an operator by
e-mail and / or through traditional marketing methods by telephone and / or
paper mail;
•
the attestation that the above operations have been
brought to the attention, also with regard to their content, of those to whom
the data had been communicated or disseminated, except in the case in which
this fulfillment proves impossible or involves a use of means manifestly
disproportionate to the protected right;
•
the personal data concerning him / her provided to a data
controller in a structured format, commonly used and readable by automatic
device and to transmit this data to another data controller without impediments
by the data controller who supplied them. In exercising its rights in relation
to the portability of data pursuant to paragraph 1, the data subject shall have
the right to obtain direct transmission of personal data from one controller to
another, if technically feasible;
The User also has the right to object, in whole or in
part, a) to the processing of data for purposes relevant to the purpose of
collection, where there are legitimate reasons; b) to the processing of data
for direct marketing purposes and using automated methods. This opposition
extends to traditional commercial communications, but the faculty for the
interested party to exercise the right of partial opposition remains
unaffected. Therefore, the interested party can decide to receive only
communications using traditional methods or only automated communications or
none of the two types of communication.
Furthermore, the User has in any case the right to raise a complaint with the Guarantor Authority.
How to exercise
rights
The User may, at any time and compatibly with temporary
technical difficulties, review, update, correct or delete the PDs present in
his own MeC Profile, or even completely eliminate this profile, through the
appropriate functionalities present on the internal pages of the PnP Platform.
In addition, the User can exercise his rights by sending a
request with registered letter to PLACENPEOPLE SRL, at its registered office,
as indicated in the "contacts" section of the Site and the Apps, or alternatively by communicating this request through an official contact channel (the channels considered official are defined in the "contacts" section of the Site).
PnP carries out the operations or provides the requested
information without undue delay and, in any case, within a period of 30 days
from receipt of the request. This deadline may be extended for up to two
months, if necessary, taking into account the complexity and the number of
requests. The data controller informs the User of such extension, and of the
reasons for the delay, within one month from receipt of the request. If the
interested party submits the request by electronic means, the information is
provided, where possible, by electronic means, unless otherwise indicated by
the interested party.
The operations and information in question are carried out
and / or provided to the User for free. However, if the requests of the
interested party are found to be unfounded or excessive, in particular due to
their repetitive nature, PnP may at its discretion:
a) charge a reasonable service fee and, in any case, not
more than € 15.00, taking into account the administrative costs incurred to
provide the information or communication or take the required action;
b) refuse to satisfy the request.
If it has reasonable doubts about the identity of the
person who submits the request for information, PnP can always request further
to confirm the identity of the person concerned.
Extraordinary
operations
Should PlacenPeople undertake or be involved in any
merger, acquisition, reorganization, transfer of business or bankruptcy or
insolvency proceedings, it may sell, transfer or share some or all of the
assets of the Company, including the PD of the users contained in the Platform.
In such cases, the User will be informed before his personal data are
transferred and subjected to a different Privacy Policy, as well as put in a
position to provide autonomous consent to such variation.
Additional
features
1. Invitation service
The Platform offers the possibility for the User to send
an invitation to their contacts to register in the Community, specifying the
name and email address of the recipient. This service provides that the
recipient can see who the sender of the invitation is. Placenpeople will
proceed to a single submission for each request, and will not store data
related to that recipient in its databases. If the MeC that sends the
invitation covers a coordination role within the community, it will have the
possibility to send invitations to specific roles (for example, to become an
organizer); in this case the recipient will be able to view the sender's
contact details, such as name, e-mail, mobile phone number or other PD.
2. Pre-registration
The Platform offers the possibility to some categories of
user to start the registration for new MeCs, specifying the recipient's email
and other information in their possession. This registration will not be
confirmed except by the recipient, who will be able to correct / integrate the
data entered, and to which it is however up to accept the Terms of Use in order
to proceed with the actual registration.
3. Operational messaging
The Platform offers a notification service via e-mail or
cellular communications regarding the user (such as confirming reservations,
receiving feedback, etc.). PlacenPeople strongly recommends to pay attention to
such communications. However, the user who does not wish to receive such
communications can forward them to the junk mail box or delete his own MeC
profile.
4. Profile management service
PlacenPeople can offer a profile management service at the
request of the user and for a fee. This service is provided according to
specific regulations. The user who wishes to make use of this service must
expressly authorize PlacenPeople, by means of a written document or voice
recording, to carry out on its behalf operations on the profile itself, in
accordance with the provisions of the regulation.
Changes to this
Privacy Policy
PlacenPeople reserves the right to change this Privacy
Policy at its discretion, at any time and without notice. In case of updating,
the User will always be invited to give a new acceptance of the Privacy Policy.
In case of non-acceptance, the User's access to the Platform will remain
precluded.
The Policy will always be present on the Website during
the normal operation of the Platform, and accessible to users. The "Last
Updated Date" at the beginning of this Privacy Policy will be valid for
its entry into force.