Privacy Policy di VLS Agency
This Application collects some Personal Data of its Users.
Data Controller
VLS AGENCY SRL
25/4 30175 VENEZIA (VE) Italy
PIVA: 04623120278
REA: VE-434267
Owner’s email address: info@vlsagency.com
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Contact Authorisation; Camera Authorisation; Approximate Location Authorisation (continued); Microphone Authorisation; Social Media Account Authorisation; Cookies; Usage Data; email; passwords; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed prior to data collection.
Personal Data may be freely provided by the User or, in case of User Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without any consequences on the availability of the Service or its operation.
Users in doubt as to which Data are mandatory are invited to contact the Data Controller.
The possible use of Cookies – or of other tracking tools – by this Application or by the owners of third party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to communicate or disseminate them, releasing the Owner from any liability towards third parties.
Method and location of data processing
Modalities of treatment
The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Application (administrative, sales, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.
Legal basis for processing
The Controller processes the User’s Personal Data if one of the following conditions is met:
- the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Controller may be allowed to process Personal Data without the User’s consent or any of the other legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
- processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
- processing is necessary for the performance of a legal obligation to which the Controller is subject;
processing is necessary for the performance of a task carried out in the public interest or in the exercise of public authority vested in the Controller; - processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.
However, it is always possible to request the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.
Site
The Data are processed at the Controller’s premises and at any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the country where the User is located. To obtain further information on the location of the processing, the User may refer to the section on the details of the processing of Personal Data.
The User has the right to obtain information on the legal basis for the transfer of Data outside the European Union or to an international organisation of public international law or composed of two or more countries, such as the UN, as well as on the security measures taken by the Controller to protect the Data.
The User can check whether one of the transfers just described takes place by examining the section of this document relating to the details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.
Storage period
Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
- Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Moreover, the Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.
Purposes of Data Processing
The User’s Data are collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), identify any malicious or fraudulent activities, as well as for the following purposes: Permissions to access Personal Data on the User’s device, Statistics, Registration and authentication, Access to accounts on third party services, Registration and authentication provided directly by this Application and Advertising.
To obtain detailed information on the purposes of the processing and the Personal Data processed for each purpose, the User may refer to the section “Personal Data Processing Details”.
Permissions for access to Personal Data on the User's device
Depending on the specific device used by the User, this Application may require certain permissions to access the User Data present on the device itself, as described below.
These permissions must be provided by the User before any information can be processed. Once granted, the permission may be revoked by the User at any time. In order to revoke permissions, the User may use the system settings or contact the Owner at the contact details indicated in this document.
The procedure for checking permissions may vary depending on the device and software used by the user.
Please note that the revocation of one or more permissions may have consequences on the correct functioning of this Application.
If the User grants the permissions indicated below, the related Personal Data may be subject to processing (access, modification or removal) by this Application.
Social media account permission
Used to access the User’s social media accounts such as Facebook and Twitter.
Camera permission
Used to access the camera or capture images and videos from the device.
Contacts permission
Used to access the address book and profiles on the device, allowing you to edit their contents.
Permission Approximate Location (continued)
Used to access the approximate location of the user’s device. This Application may collect, use and share the User’s location in order to provide location-based services.
Microphone Permission
Allows access to and recording of audio through the User’s device.
Details of Personal Data Processing
Personal Data are collected for the following purposes and using the following services:
Information on how to deactivate interest-based advertisements
In addition to any opt-out functionality provided by any of the services listed in this document, Users may take advantage of the information on YourOnlineChoices (EU), The Network Advertising Initiative (US) and Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar services. With these services it is possible to manage the tracking preferences of most advertising tools. The Owner therefore advises Users to use these resources in addition to the information provided herein. AppChoices which helps Users control behavioural advertising on mobile applications.
Users may also disable certain advertising features through their respective device settings, such as device advertising settings for mobile phones or ad settings in general.
Rights of the User
- withdraw consent at any time. The User may revoke the consent to the processing of its Personal
- Data previously expressed. object to the processing of their Data.
- The User may object to the processing of its Data when it is done on a legal basis other than consent.
- Further details on the right to object are set out in the section below. access to their Data. The
- User has the right to obtain information on the Data processed by the Controller, on certain aspects of the processing and to receive a copy of the Data processed. verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected. obtain the restriction of the processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data
- Controller will not process the Data for any purpose other than its preservation. obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of its Data by the Data Controller. receive their Data or have them transferred to another
- Data Controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred without hindrance to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, on a contract to which the User is party or on contractual measures related thereto. Proposing a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details of the right of opposition
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Controller or in pursuit of a legitimate interest of the Controller, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that if their Data are processed for direct marketing purposes, they may object to the processing without giving any reason. To find out whether the Controller processes Data for direct marketing purposes, Users may refer to the respective sections of this document.
How to exercise rights
To exercise their rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month.
User Rights
Legal defence
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory phases of such proceedings to defend against abuses in the use of this Application or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.
Specific disclosures
Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.
System logs and maintenance
For operation and maintenance purposes, this Application and any third party services used by it may collect system logs, i.e. files that record interactions and that may also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.
Responding to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To find out whether any third party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Last Modification: 02/01/2023
