This Privacy Policy (“Privacy Policy”) applies to the processing of personal data of users (“user” or “you”) of the Devv 30 mobile application (“app”) by Matteo Giardino (“we” or “us”), in accordance with Regulation (EU) 2016/679 – General Data Protection Regulation (“GDPR”), the Italian Legislative Decree 196/2003 (as amended), and other applicable local laws, as amended or replaced (jointly, “Applicable Privacy Laws”).
If you are a California resident, please see Section 11 (Additional Information for California Consumers) below.
The Data Controller is Matteo Giardino, based in Turin (Italy), VAT 12623180010. For any requests regarding the processing of your personal data, please email us at [email protected].
Our Data Protection Officer can be contacted by sending an email to [email protected] for any requests relating to the processing of your personal data or this Privacy Policy.
We process the following categories of personal data, for the purposes and on the legal bases indicated below. Please note that not all of the below information may be deemed personal data in your jurisdiction in all cases.
| Purpose | Legal Basis | Categories of Processed Data |
|---|---|---|
| a. To enable you to use the app and to provide you with its functionalities, including to: | ||
| • Create and track your fitness plans and activities | ||
| • Show information about the app and your progress | ||
| • Create an account and authenticate your access to your account | The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of the GDPR). | Identification and contact information (such as first and last name, and email address), identifiers and internet and network activity information (such as IP address, device model, device type, OS version, device language, device name, country set in the device settings, information about your interactions with the app, and unique identifiers), and other information necessary to enable you to use the app (such as gender, age, weight, height, fitness level, dietary preferences, and food history). |
| The app requires your permission to access your microphone recordings and your photo and video library when you use the app to activate voice command and to enable you to share your achievements on your social media accounts. However, we do not collect or have access to such data. | ||
| If you create an account or login with your Facebook, Google or Apple account, we will also receive the following information: first and last name, e-mail address. | ||
| b. To improve our products and services (for example, by conducting user surveys and research activities, assessing user satisfaction, assessing the effectiveness of the service provided, evaluating and improving the design of the app, measuring the traffic and performance of the app). | The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to improve our products and services. | |
| As for the collection of personal data by means of analytics tracking technologies, please see Section 12 (In-app Tracking Technologies). | Identification and contact information you provide us (such as name, age, social media handle, or email address, when requested) and information collected or generated in-app, also by means of analytics tracking technologies (for example, information about your interactions with the app, inferences we generate and other related information about your usage of the app). | |
| c. To ensure the quality of the services by analyzing, preventing or correcting failures and bugs, illicit use or misuse of the services. | The legal basis for the processing is our legitimate interest (art. 6(1)(f) of the GDPR) to ensure the quality and the smooth functioning of the service. | Identifiers, internet and network activity information (such as IP address), inferences we generate and other related information about your usage of the app. |
| d. To comply with our legal obligations, including requests from public authorities. | The legal basis for the processing is compliance with legal obligations to which we are subject (art. 6(1)(c) of the GDPR). | |
| Where the requirements provided by the applicable law (such as data protection laws) grant us some discretionary assessments in order to fully comply with it, we may rely on our legitimate interest (art. 6(1)(f) of the GDPR) to carry out processing activities for this purpose in order to demonstrate our compliance. | Any information which may be required by law or under the instructions of public authorities. | |
| e. To process and respond to customer support communications and to requests for information you may raise with us. | The legal basis for the processing is the performance of our contractual relationship (art. 6(1)(b) of GDPR). | Identification and contact information you provide us (such as first and last name, email address) and the content of your communication or request. |
| f. To establish, exercise or defend our rights and those of our employees, and to carry out corporate transactions or operations (for example, in case of bankruptcy, merger, acquisition, reorganization, sale of assets or assignments, and due diligence related to any such transactions). | The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR) to establish, exercise or defend our rights and to carry out corporate transactions or operations. | Any information necessary to ensure the performance of these purposes. |
| g. To analyze your usage information, including your preferences, interests and behaviors when you use our products and services to: | ||
| • Conduct surveys, statistical analysis or other research activities to improve our products and services | ||
| • Maintain, optimize, and develop new features | ||
| • Advertise our products and services towards more creators like you and reach out to inactive users with our ads | ||
| • Measure the effectiveness of our campaigns and make our advertising more relevant | The legal basis for the processing is our legitimate interest (art. 6(1)(f) of GDPR). | |
| The collection of personal data by means of profiling and third-party analytics tracking technologies is based on your consent (art. 122 of Italian Privacy Code). For more details, please see Section 12 (In-app Tracking Technologies). | Your identification and contact information (such as name, age or email address, when requested), identifiers and Internet and network activity information that we collect (such as IP address), information about your interactions with the app, and other related information about your usage of the app collected by means of in-app profiling tracking technologies. | |
| h. To send you information and marketing communications about our products and services such as tips, offers, and newsletters through emails and push notifications. | The legal basis for the processing is your consent (art. 6(1)(a) of GDPR). | |
| Where your consent is not required, for example, where we use your email for the purpose of sending you information about products and services related to or similar to the app, the legal basis is our legitimate interest (art. 6(1)(f) of GDPR). | Identification and contact information you provide us (such as name, e-mail address), identifiers and Internet and network activity information that we collect, and information we may receive from third-party advertising networks and platforms (such as unique identifiers). |
Personal data may be processed by both automated and non-automated means, and may be stored at our premises and on our service providers’ servers. We adopt technical and organizational measures designed to prevent the loss, improper use and alteration of your personal data. In some cases, we may also adopt data encryption and pseudonymization measures. However, transmissions over the Internet are never 100% secure, and you should not provide any personal data if you want to avoid any risk.
Personal data processed for the purposes referred to in Section 2.a), 2.b), 2.e), 2.g) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than three (3) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
Personal data processed for the purposes referred to in Section 2.c) will be kept for a period not exceeding the one necessary for the said purposes and, in each case, for no more than one (1) year from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
Personal data processed for the purposes referred to in Section 2.d), will be kept up to five (5) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
Personal data processed for the purposes referred to in 2.f) will be kept up to ten (10) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
Personal data processed for the purposes referred to in Section 2.h) will be kept up to two (2) years from the date of your last interaction with the app or from the date of the expiration of your subscription unless you access the app after then. In this case, the retention period will start from the date of your last interaction with the app.
At the end of these specified periods, unless any legal obligations require a longer data retention, the processed personal data will be either deleted or anonymized.
It is mandatory for you to provide your personal data for the purposes referred to in Sections 2.a), 2.d), and 2.e). If you do not provide the personal data, you will not be able to enjoy the app’s services and features. When you create an account or login with your Facebook, Google or Apple account, and later decide to withdraw the permission given to share your personal data with us through your social login, the withdrawal of your permission will not affect the data already shared with us or your authentication method. If you want to withdraw your permission to log you in with your social login or delete personal data already shared with us, see Section 7 (Your Rights).