Privacy Policy Statement

As part of its business, DataLysm undertakes, in accordance with the legislation in force in Italy, to respect the privacy of Internet users according to General Data Protection Regulation (“GDPR”)

The entity responsible for the collection and use of the collected data for the purposes described in this Privacy Statement is 3rdPlace

This Privacy Policy Statement outlines the principles and commitments.

Article 1 - DEFINITIONS

"Cookies": means text files sent to the Terminal when it visits a Medium. Cookies are stored on the Terminal's web browser, and can be viewed only by the entity that stored them for or on whose behalf it stored them. Cookies are used to collect and send the Data on the visit to the Medium by the Terminal - for example, number of visits, average time spent, pages viewed, navigation history on the website, content of web tags, and other statistics.

"Partner(s)": means any natural or legal person registering on 3rdPlace, in order to make Collected Data available with Internet users' consent.

"Personal data": information that allows, in any form whatsoever, directly or indirectly, the identification of the individuals to whom it applies, whether the processing is carried out by a natural or legal person.

"Collected Data": means the pseudonymized anonymous information collected by the Partner by means of the Marker from the Terminals visiting the Partner's Medium.

"Medium(Media)": means an Internet content (website, documents, application) that can be accessed and used from any device connected to the Internet: computers, mobile phones, Braille tablets, screen readers, game consoles, etc.

Article 2 - COMMITMENT

The Partners enrolled in 3rdPlace transmit the Collected Data on their own. These Collected Data are anonymous and pseudonymized. These data do not allow identification of users. The Partners enrolled in 3rdPlace undertake to collect the free and informed consent of all Internet users in the collection of data concerning them. In this regard, any Partner has undertaken in particular to indicate to Internet users of its Media that third-party Cookies may be placed on each Terminal, stating the purpose of these Cookies, particularly by 3rdPlace and indicating specifically to the Internet users, how to set their browser to avoid the placement of said Cookies. 3rdPlace uses physical and electronic systems, as well as specific procedures, to ensure the protection of such information, in accordance with its legal obligations.

Article 3 - TYPE OF COLLECTED DATA

The data transferred to 3rdPlace are collected via anonymous Cookies that may in particular consist of data:

If a web user accesses Services from a mobile or other device, 3rdPlace may collect a unique device identifier assigned to that device or other information for this device in order to use the content. This collected data can also be supplemented by information obtained from third parties or submitted by the users.

3rdPlace may also collect anonymous information from Third Parties. Some Partners: publishers of Internet Media or services, media brokers and networks may place their own cookies on a user's computer, unrelated to 3rdPlace, and over which 3rdPlace has no control, access or capacity for action. 3rdPlace does not control these sites and their use of these technologies is governed by the privacy policies of the third parties using such technologies.

For more information about third-party advertising networks that use these technologies, any user can visit http://www.aboutads.info.

To learn more about third party online advertising and to withdraw from this type of advertising, visit the following Web sites:

3rdPlace works with multiple data and advertising partners and clients, and their own technical partners, including but not limited to the following:

Article 4 - PURPOSE OF COLLECTED DATA

The Collected Data are shared between Users of the 3rdPlace Platform, and they can be exchanged on Third-parties platforms.

The Collected Data are intended to improve Internet users' online experience. They are intended in particular to allow the display of targeted advertisements based on the interests of users who are part of the Target Audience.

For example, Cookies allow Advertisers to identify which ads are offered to him and to control the number of times the advertising can be broadcast on a Terminal. In this way, the advertising is more relevant to the user.

The Collected Data can also be used to allow the Publisher of an Internet Medium to design the ergonomics, presentation, and offers its site.

In no event may the Collected Data be reported or used to enable the display of advertisements specifically targeting children under 13 years of age.

Under no circumstances can the Collected Data be used to identify users.

We will only collect the information that we deem necessary for the purposes listed below. As a result, we may not be able to address a request or provide a product or a service if we are missing some of this information.

Article 5 – LEGAL BASIS OF PROCESSING COLLECTED DATA

We may process data for the above purposes when it is needed for contract performance or to comply with certain legal obligations or for 3rdPlace’ legitimate business interests require it, including for marketing and improving our services, protecting against fraud and other liabilities, ensuring compliance and our ability to assert legal defenses, and guaranteeing the security our networks and systems.

We may disclose collected data to third parties, including our vendors, subcontractors, and processors; and/or business partners for purposes related to those described above, law enforcement or other government officials upon request if we believe such disclosure necessary or appropriate and As we otherwise believe is necessary to protect collected data or property, including the security and integrity of the 3rdPlace Platform.

Article 6 – COMMUNICATION TO THIRD PARTIES AND INTERNATIONAL TRANSFER

3rdPlace may need to share the Collected Data with Third-parties particularly for storing the data necessary for the Platform's operation and the execution of the 3rdPlace mission. The Collected Data can be transferred and stored in a country outside of the European Economic Area ("EEA") for the purpose of data retention and the operation and maintenance of the 3rdPlace platform. These countries may not provide the same level of data protection as that provided by the laws of your country. The transfer of data to countries that do not ensure protection similar to your local law is protected by the standard contractual clauses signed between 3rdPlace and the recipients of the data located in these countries. 3rdPlace will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy Statement. Unfortunately, the transmission of information via the internet is not completely secure. Although 3rdPlace takes all reasonable precautions to protect the Collected Data concerning you, the security of the data transmitted can not be guaranteed and any transmission creates risks. Upon receiving Collected Data about you, 3rdPlace will use strict procedures and security features to try to prevent any unauthorized access. In any event, 3rdPlace limits access to the Collected Data solely to employees whose duties require access to this information in order to provide you with 3rdPlace products and services.

The Collected Data are processed in a confidential manner and are not communicated to any third party without the consent of the user concerned. We may disclose collected data to third parties, including our vendors, subcontractors, and processors; and/or business partners for purposes related to those described above. It is possible, in particular, in special cases, that 3rdPlace may be required by law to disclose the data to investigating authorities. In such cases, the transfer and communication of such data will be take place in accordance with the legislation in force.

Article 7 - HOW TO PREVENT DATA COLLECTION?

Most browsers are initially set to accept cookies, but any Internet user can change the settings so that he will be notified when a cookie has been set or updated, or to block the cookies. You can consult the "Help" menu on your browser for more information.

7.1 From your web browser:

7.2 From 3rdPlace

Please go to this link and look for the "How can I opt out?" section to check for your status and opt in or out of data recording.

Article 8 - DATA RETENTION

Collected Data will be kept for no longer than is necessary for the specific purposes for which the personal data are processed.

Article 9 - RIGHTS AND CHOICES

The GDPR provides you with certain rights regarding your personal data. Any user tracked by 3rdPlace has the right to request:

To exercise these rights, a request must be sent by mail with the user’s personal identifier (GUID) that is recorded in the 3rdPlace cookie, at the following address:

3rdPlace , Foro Buonaparte 71, Milano, ITALY

In all cases, you have a right to file a complaint with a data protection authority in particular in the country of your habitual residence, your place of work or where you consider that your privacy rights have been infringed.

Article 10 - AMENDMENT OF THIS POLICY PRIVACY

3rdPlace may update this Privacy Policy Statement at any time. 3rdPlace will notify you about important changes concerning the processing of personal identification information by posting a notice on this Website. 3rdPlace encourages you to periodically review this Privacy Policy Statement.

Any changes to this document shall take effect immediately after their notification by any means, such as a message posted on the Website's homepage, an email or postal mail. However, changing the purpose of the collection, the use and the disclosure of the Collected Data can be implemented only with your express permission or only to the extent permitted or required by law.

The use of the Website after such changes will be deemed acceptance of such changes, except for a change to the purposes for which the collection is intended, the use or the disclosure of Collected Data. If you no longer wish to be bound by the terms of the amended document, you should immediately discontinue use of any service related to 3rdPlace.