Drawn up pursuant to art. 13 of European Regulation 2016/679 (GDPR)
Version 1.0
Personal data provided by the Data Subject will be processed by Wallife S.p.a (hereinafter “Wallife”) in compliance with the legislation in force on the protection of personal data and with the principles of fairness, lawfulness, transparency and protection of confidentiality set out therein.
The Controller of data processing for the use of the application and the related services provided is Wallife S.p.a, with registered office in Rome, via Vittorio Veneto no. 116, postcode 00187, VAT no. 15766131005.
The Data Subject may contact the Controller at the above postal address or at the following email addresses: info@wallife.com and the certified email address wallife@legalmail.it.
The legal basis for the processing carried out by Wallife, for the purpose of using the application and performing the related services, is the performance of the contract to which the data subject is a party. Further legal bases are set out below.
The personal data collected by the Controller are those provided by the data subject and, depending on the services concerned, by way of example:
The location data we collect, as well as the storage time, depend on your device and your account settings. For example, you can enable or disable your device location from the application (“Settings”).
Identity and contact data relating to your user profile: first name, last name, date of birth, tax code.
For example the date of purchase, the price of the product and information on the type of assistance you requested.
Through the App we process geolocation data to allow the user to benefit from the services and features offered by Wallife. Such data include:
By means of this document Wallife informs the Data Subject that the methods of collection will comply with the GDPR and that, with particular regard to sensor data, and specifically to recording and transmission, these vary according to the operating system installed on the device (iOS/Android) and to the activities detected. The data collected on the device in the manner indicated are, after anonymisation, sent to Wallife, encoded in binary format over an encrypted connection (TLS), and saved on a dedicated server for the time necessary for the Processing and for the subsequent retention within the terms of the law.
Where the data subject’s data are not collected from the Data Subject directly but from third parties (e.g. a collective insurance policy), Wallife, as Data Controller, provides the data subject with all the information set out in this notice, containing its own details and those of the data processor, where appointed, the legal basis, the manner in which the processing is carried out and the purposes for which it is performed.
Wallife informs the data subject of the source from which the personal data originate and, where applicable, whether the data come from publicly accessible sources.
Where the data subject’s data are collected from third parties, the user always has the right to request the correction of their data should these have been communicated by third parties or collected by Wallife inaccurately.
Wallife, as controller, processes personal data with the aid of IT and/or electronic tools and, in any case, in compliance with every precautionary measure guaranteeing their security and confidentiality for the time necessary to perform the service requested by the data subject or required by the purposes of the contract and of the processing described in this notice. The data subject may at any time request the interruption of processing and/or the erasure of the data processed, consistently with the performance of the services and within the limits of the exercise of rights as established by the GDPR.
The processing of the personal data provided will be carried out by persons expressly designated by the Controller through specific appointments, who process the data as processors or as expressly authorised persons. In addition to the Controller and the persons it appoints, data may also be accessed by authorised persons involved in the management of the Wallife website (administrative, commercial, marketing, legal staff, system administrators) or by external parties (technical service suppliers, providers, etc.).
Personal data are processed at the operating offices of the Controller, of the processor or in any other place where the parties involved in the processing are located, including States belonging to the European Union.
Data are retained by Wallife for the time necessary to carry out the activities constituting the purposes for which they were collected.
At any time, consistently with the performance of the services, the data subject has the right to ask Wallife to interrupt the processing and erase their data. It being understood that such data must in any case be retained by Wallife for the time necessary to fulfil legal and regulatory obligations or the provisions issued by sector supervisory and control Authorities.
At the end of the retention period the data provided will be erased both from the databases of Wallife S.p.a and from any paper records, if any.
The processing of data will be aimed at carrying out the activities listed below:
Use of the application made available to the Data Subject and performance of the activity of supplying the services contractually agreed by the parties (identified legal basis: performance of a contract or pre-contractual measures).
Carrying out, where specifically provided for and subject to the express and freely given consent of the data subject, direct marketing activities, such as sending advertising material and communications of an informative and/or promotional nature by email, SMS or MMS in relation to products or services supplied and/or promoted by Wallife or by its commercial partners (identified legal basis: the optional consent of the Data Subject).
Carrying out, where expressly provided for and subject to express and freely given consent, individual or aggregate profiling activities and market research aimed, for example, at analysing consumption habits and choices, producing statistics on them or assessing the level of satisfaction with the products and services offered (identified legal basis in the case of individual profiling: the optional consent of the data subject).
The persons to whom the personal data processed by Wallife and by the appointed Processors refer may at any time exercise the rights granted to them under the GDPR and national legislation and, specifically, they may:
Obtain access to their personal data, request their rectification or erasure, or the restriction of processing. They also have the right to object to the processing, as well as the right to request its portability. Furthermore, at any time, they may withdraw the consent given, it being specified that the withdrawal of consent does not affect the lawfulness of the processing carried out up to the withdrawal.
In such cases requests must be sent to Wallife S.p.A., with registered office in Via Vittorio Veneto, 116 – 00187 Rome – VAT no.: 15766131005.
The data subject may also lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei dati personali), following the instructions provided by that Authority on its official website.
The Wallife website and the application to be downloaded on the user’s device use cookies, that is tracking tools which, where consent is given by the data subject, allow the Controller to collect and save information on the User’s device while the User is using the application or the website.
The Data Controller may transmit to third parties the data of the data subject collected in order to fulfil legal obligations to which Wallife is subject, both for supervisory and control and for tax purposes, and any other obligation incumbent upon it, including towards public security authorities (e.g. requests made by the Data Protection Authority, the Revenue Agency or any other requesting Authority).
Furthermore, should services supplied by third parties be provided within the application, those third parties will be required, independently of the purposes described by Wallife, to adequately inform the data subject about their own processing on the basis of the services they offer.
Wallife has appointed a Data Protection Officer (“DPO”) who may be contacted at the following addresses:
Via Vittorio Veneto, 116 – 00187 Rome, Italy
Email: dpo@wallife.com