Setai Privacy Policy

1. Introduction
Setai s.r.l. is the Data Owner and Controller, located in via Roma n. 19, 30172 Venezia (VE).

In the present document Setai gives to the User some information about the personal data processing related to the download ad utilization of the application Setai.
Setai App protect the User privacy and his personal data and ensures that the personal data processing respect the applicable law in the matter, in particular the General Data Protection Regulation n. 2016/679, and the Data Protection Act 2018.
Setai strongly encourages the User to read the following privacy policy before downloading and using the application. The present privacy policy is exclusively related to the personal data communicated to the Service by the User or otherwise obtained by the application utilization or collected, used and disclosed by Setai s.r.l., its affiliated companies or third parties which operate with Setai s.r.l. authorization. The present privacy policy regards the personal data processing for every utilization of the Service, online or offline, both through IOs or Android access, and for every content, function or application offered by Setai s.r.l. by the App, the Website, the Social Pages or any other accessory service.
The data collection and utilization as described in the present Privacy Policy is based on the User voluntary consent, on the fulfilment of Setai obligations and on the User legitimate interest.
Setai can develop the existing services or modify the functions of the service. If the modification would impact on the data processing, Setai will modify the Privacy Policy and will inform the User about it. For any question or further information the User can contact Setai at the following link: www.setai.io/contact-us

2. Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of Setai (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

3. Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
• Users have given their consent for one or more specific purposes;
• provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
• processing is necessary for compliance with a legal obligation to which the Owner is subject;
• processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
• processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

4. Place
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
If broader protection standards are applicable, Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

5. Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
Therefore:
• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

6. The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Registration and authentication, Hosting and backend infrastructure, Contacting the User, Device permissions for Personal Data access, Social features, Infrastructure monitoring, Content performance and features testing, Analytics, Access to third-party accounts, User database management and Managing contacts and sending messages.

7. Device permissions for Personal Data access
Depending on the User’s specific device, Setai may request certain permissions that allow it to access the User’s device Data.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User’s device and software.
Please note that the revoking of such permissions might impact the proper functioning of Setai.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e. accessed to, modified or removed) by Setai.
The App Used for accessing the camera or capturing images and video from the device.

8. The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User’s consent, on a contract which the User is part of or on pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.


Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification.

How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as soon as possible.

9. Additional information about Data collection and processing


Device permission

Setai requests to the User the Camera permission.


Login

The User has the possibility to login through Facebook, Google or the User’s private e-mail.
All of these login modes are provided by Firebase Authentication. Firebase Authentication is a registration and authentication service provided by Google LLC. To simplify the registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the information on its platform.
Personal Data processed by the service is the email address.
Place of processing: United States – Privacy Policy


Registration

The User needs to register in order to use the Service. Once the login has been made, he will insert optional information:birth year; lifestyle, gender; activity; dietary preferences; physical exercise; intolerances; allergies; country of the User; city of the User.


Backend

Setai uses Firebase Cloud backend service which works through many geographically distributed servers, making difficult to determined where the personal data are stored. Firebase Cloud Firestore is a backend service provided by Google LLC.
Personal Data processed by Firebase Cloud backend are: Usage Data; various types of Data as specified in the privacy policy of the service. Privacy Policy
Place of processing: United States


Content performance

Setai utilizes Firebase Remote Config to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Setai.
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.
It processes various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.


Analytics

Setai uses Google Analytics which is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Setai, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
The Personal Data processed by Google Analytics are: Cookies; Usage Data.
Place of processing: United States – Privacy Policy

Legal action
The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of Setai or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.


Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, Setai may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.


Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.


Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within Setai and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner.

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