Updated 01/07/2024

MARKER MYSTERY TOUR APPLICATION PRIVACY POLICY

In Italy, the protection of personal data is governed by the General Data Protection Regulation of 27 April 2016, better known as GDPR, and Legislative Decree No. 196/2003.

CHRONES. SRL (hereinafter referred to as “we”) a limited liability company (SRL) innovative start-up P.IVA IT08822590728 with registered office in Via Mons. Santeramo n. 23, 76121 – Barletta (BT) and share capital of 10,000 euros.

As Data Controller, we undertake to protect the data of our users (hereinafter ‘you’) that we process for the purposes of our activity. For this reason, we undertake to comply with the principles and rules applicable to the protection of personal data.

To this end, this policy explains how we collect and process your personal data (hereinafter ‘Data’) as a result of your use of the ‘Marker Mystery Tour’ application.

1. Type of data processed

As part of our data collection for the provision of the Service, we process the following Data in particular: surname, first name, e-mail address, mobile phone number, gender, nationality. All requested information is considered essential for the provision of our Service.

When you use the application, we also process Data such as: identification, connection and location.

•          Identification data (e-mail address, surname, first name, telephone number, gender and nationality): This data is used to create your user account. When registering, you will be asked to define a password and information known only to you, useful for operations such as password recovery. This information will be used to identify you when you access the “Marker Mystery Tour” application.
•         Data relating to your mobile device and your use of the application: in order to improve our services, we collect data relating to your device (make, model, operating system version, screen orientation, available RAM memory, available disk space) and your activity on the application and website, such as traffic/connection data (IP address, connection data, cookies, trackers, audience measurement). This data is used internally for statistical purposes to improve the quality of our services.
•        Geolocation data: The user will be asked for their consent to collect and process location data. Geolocation data can be used its at any time in the background or only when the application is open. In particular, the geolocation function allows users to find markers (the images to be scanned useful for the progress and use of the Service within the Application) owned by one or more participants closest to their location, to receive information and notifications, to be guided to the markers of their choice, to know how far they are from a marker.

This data may also be used to display geolocation-targeted advertising on your device. You can revoke your consent to the collection of geolocation data at any time by accessing your device settings.

The application may also require certain logins, such as:

• ·       Camera access

You will be asked to access the camera if you use the Scan function (a function that allows you to scan markers using your phone).

We collect your Data directly when you provide it to us, on the basis of consent. Your Data may also be disclosed to us indirectly by our partners, on the legal basis of the contracts binding us to these service providers or, where applicable, on the basis of legitimate interest.

There is no fully automated decision-making process based on your Personal Data.

2. Who is affected by the processing of Data?

Your Data may be processed (i) if you are our user or (ii) as a potential customer.

2.1.          If you are a registered user

Your Data may be processed when you:

• you create an account on the Mobile Application;
• you subscribe to our Newsletter;
• you visit our websites that may use cookies;
• register for a live event organised by us (…, etc.);
• you interact with us, especially through social networks.

For this processing, we rely on your consent. It should be noted that the sending of canvassing via SMS/e-mail responds to our legitimate interest in relation to products or services similar to those for which your data was collected. If you wish to object to this processing, please consult the section ‘How to exercise your rights’.

Finally, your Data may be processed when you exercise your rights over your Data or to enable us to comply with our legal obligations.

For such processing operations, we rely on your consent.

Finally, your Data may be processed when you exercise your rights over your Data or to enable us to fulfil our legal obligations.

Please note: you may be required to provide the data of a third party. In this case, please ensure that you have their consent and you must inform us as soon as this person decides to withdraw it.

2.2 If you are a registered user with a Performer account

For performer accounts, in addition to the general cases of processing of registered user data as described above, there are additional specific situations in which data may be processed. These include, but are not limited to:

• • Geolocation: For the purposes of performing performer activities, we may collect and process geolocation data to enable performers to view the location of other performers, in addition to being displayed in the first instance via a special button on the main page of the Application. This may include displaying the relative geographic location of other registered users as part of their activities on the platform.
  • Performance Analysis: We may process performer data to conduct analysis on their performance and offer personalised recommendations to improve their work experience on the platform.

3. Who will receive your Data?

We ensure that the persons who access your Data are authorised and subject to a duty of confidentiality.

These recipients may be the authorised personnel of the departments responsible for managing user relations and support functions (communication, administrative and financial, legal and compliance, general services, security, technical and logistical services, IT systems, etc.). Your rights (rectification, cancellation, etc.) may be exercised by writing to: mmt.support@chrones.eu.

For further information on the use of geolocation data by this company, please consult the privacy policy.

Your data are generally processed within the European Union. We ensure the implementation of adequate safeguards for the protection and security of your Data.

We may also be required to disclose your Data in response to requests from public authorities, in particular to meet national security, anti-fraud or law enforcement requirements. In these cases, we are not responsible for the conditions under which the staff of these authorities process your Data.

4. How long will your data be stored?

Your data is processed in accordance with the following retention rules:

At the end of these retention periods, we may archive your Data, in particular to comply with legal and judicial deadlines. Your Data is then deleted or made anonymous, with the specification that these operations are irreversible and that we are not able to restore it afterwards.

5. Our security and confidentiality commitments

We are committed to ensuring the confidentiality and security of your data. Appropriate organisational and technical security measures are taken to protect your data from unauthorised access, loss, alteration or disclosure to unauthorised third parties. The implementation of such measures may require the involvement of third parties selected by us, especially to conduct vulnerability checks or intrusion tests. These measures are regularly reviewed and updated as necessary.

We are committed to considering data protection principles from the design stage. For instance, we may pseudonymise or anonymise your data when possible or necessary.

We also encourage you to be careful and protect your devices (smartphones, tablets) from unauthorised access.

We advise you to select a password:

• • • Complex, i.e. containing several types of characters (lower case, upper case, numbers, special characters);
    • That does not reveal personal information about you, your preferences or habits;
    • Unique for each account.

6. How to exercise your rights?

To ensure control over the use of your data by us, you have the right to:

• • • • Access your data and receive it in an understandable format.
      • Be informed about how we use your data, as set out in this document.
      • Obtain confirmation of the processing of data relating to you and, where appropriate, request a copy, it being understood that we reserve the right to charge you for any additional copies.
      • Obtain the rectification of any data in your possession that is inaccurate, obsolete or incomplete.
      • Withdraw your consent or, where the processing is based on our legitimate interests, object to the processing of your data on grounds relating to your particular situation.
      • Object to the processing of your data on grounds relating to your particular situation
      • Request the restriction of the processing of your Data. This right only applies under certain conditions (challenge the accuracy of your Data, doubt the lawfulness of the processing, exercise your legal rights).
      • Exercise your right to the portability of your data. This right only applies under certain cumulative conditions (you yourself have communicated your Data to us via our online service and for purposes based solely on your consent or the performance of a contract).
      • Request deletion of your Data. This right only applies under certain conditions (revocation of the consent on which the processing is based, your Data is no longer necessary in relation to the initial purposes of the processing, objection to the processing of your Data, doubt as to the lawfulness of the processing.
      • Formulate specific and general post-mortem instructions on the storage and communication of your Data. In the absence of such instructions, your heirs may send us any request.

In general, to exercise your rights, you can:

– access your account;
– send us your request, enclosing a copy of your identity document;

• • • • by e-mail: mmt.support@chrones.eu
      • by post: Via Mons. Santeramo n. 23, Barletta BT 76121

If there is any doubt about the applicant’s identity, further proof of identity may be requested.

We will provide you with answers to your questions as soon as possible and in compliance with our legal obligations.

You have the right to lodge a complaint with the supervisory authority (Garante della Privacy).

7. Contacts

You can contact our Data Protection Officer at the following address

• • • • by e-mail: mmt.support@chrones.eu
      • by post: Via Mons. Santeramo n. 23, Barletta BT 76121

This policy may be subject to updates if necessary.