With this document, the Company intends to provide information on why and how Users’ personal data is processed.

The User is asked to check this document regularly, because the Platform is constantly evolving and this document may change along with it. Use of the Platform after changes to this document take effect constitutes acceptance of those changes by the User.

The Company is committed to keeping the Platform a safe place for sharing and managing Users’ personal data. Users are invited to report any anomalies found by contacting the Company so that it can take any necessary measures.

1. Who Is the Data Controller

The Data Controller is the company 3x1010 S.r.l. (hereinafter “Controller”), which determines the methods and purposes of the data processing carried out through the Platform. Our headquarters are located at Corso Castelfidardo, 22 – 10138, Turin at OGR Tech.

The Data Controller can be contacted at privacy@3x1010.it.

2. What Data Are Processed? Why Do We Process Personal Data? And On What Legal Basis?

Through the Platform we collect various data. Some data are voluntarily provided by the User, such as: personal and contact details, all other information that the User decides to upload to the Account (image, bio, etc.), as well as data relating to the use of the Platform’s Services.

Other data are collected automatically during the use of the Platform, such as:

• Technical data: IP address, browser type, information about the device used to connect to the Platform;
• Usage data: pages visited, time spent on the Platform, navigation patterns;
• Geo-referencing data: used to determine events in the User’s area of reference (if the feature is enabled by the User);
• Performance data: information on loading speed, any technical errors;
• Cookies and other tracking tools: small text files installed on the User’s device that are used to perform activities related to the functioning of the Platform (so-called Technical Cookies) or to track the User’s activity. For more information, please refer to the Cookie Policy.

The Controller processes the data for:

1. Contract. To provide and maintain the Platform and the related Services. The legal basis is the contract;
2. Communication with Users. To notify Users about specific activities carried out on the Platform, allowing Users to choose which communication channel to make available;
3. Improvement and Support. To improve the Platform, provide technical support and manage any reports. The legal basis is the contract, as well as legal obligation;
4. Litigation. To manage any disputes with Users. The legal basis is the contract, as well as the legitimate interest in protecting the legal positions of the Controller or third parties;
5. Statistics. To extract anonymous data related to usage, matchmaking trends and any other statistical data regarding the use of the Platform and Services through the use of anonymous data. The legal basis is the legitimate interest of the Controller in collecting anonymous information and using it also for third parties;
6. Feedback. To receive communications related to the use of the Platform and to participate in any surveys or opinion collections related to the use of the Platform or Services. This activity may be carried out by direct request from the Controller or through the use of automated tools. The legal basis is the legitimate interest of the Controller in receiving feedback and informing the User of any issues related to the Platform or Services;
7. Marketing. To send the User commercial communications regarding services or products, including those of third parties and not strictly related to the Platform. The legal basis is the User’s explicit consent;
8. Sharing data with event sponsors or other partners of the Controller for their analysis and marketing purposes. The legal basis is the User’s explicit consent.

3. What Is the Source of the Data?

The data source may be the User themself, when completing the information required by the forms on the Platform or contacting us directly; additionally, some data may be acquired through the device with the User’s authorization. Another source may be social networks used for the Social Connect function to log in to the Platform or link it to update one’s data.

4. Can Minors Use the Platform?

The Platform is reserved for adult Users.

Minors and those exercising parental responsibility or the guardian may contact us to manage account deactivation. The Controller’s policy on the use of false or third-party data is very strict. For more details, please refer to the Terms of Use.

5. How Long Do We Keep Your Personal Data?

The retention period for personal data depends on the purposes for which we process the personal data. We regularly verify the need for the personal data kept and keep track of inspections.

When we process personal data for contractual purposes, we process and retain personal data for as long as necessary to fulfill contractual obligations and until the period required by law or statute of limitations. The same applies to purposes related to Support and Litigation. Feedback is kept for 12 months, as it is strictly aimed at improving the Platform and its evolution. The use of data for marketing purposes will continue for the duration of the subscription or until consent is withdrawn.

6. Who Are the Recipients of the Data?

Users’ personal data are processed by the Company’s internal staff, who act on the basis of specific instructions provided regarding the purposes and methods of processing.

Data may also be communicated to various categories of recipients external to the Company, who act as duly appointed Data Processors or as independent Data Controllers:

IT and Technology Service Providers:

• Cloud service providers for Platform hosting;
• Email service providers for communications to Users;
• Backup and disaster recovery service providers;
• Platform maintenance and technical development service providers.

Professional Service Providers:

• Legal consultants for the management of any disputes;
• Tax and administrative consultants for accounting compliance;
• Audit firms for certification obligations;
• Consulting firms for service improvement.

Authorities and Public Bodies:

• Judicial or administrative authorities, upon request;
• Law enforcement or other public entities, for compliance with legal obligations;
• Public bodies, for compliance with legal obligations.

Other Entities:

• Other Platform Users, limited to the data that the User chooses to share through the Matchmaking process;
• Potential buyers or investors, in the event of extraordinary corporate transactions.

The Company is committed to carefully selecting its partners and service providers, subjecting them to specific confidentiality and data security obligations through appropriate contractual clauses.

To obtain a complete and updated list of Data Processors and other recipients, the User may send a written request using the contacts provided in the “Who Is the Data Controller?” section.

7. Where Is Personal Data Located?

Data is processed within the European Union.

8. What Are Your Rights?

The User may choose not to provide certain personal data. In some cases, failure to provide data makes it impossible to use the Services (for example, when providing registration data), while in other cases it does not cause particular issues (for example, by not giving consent).

You can exercise the rights provided by data protection legislation, including: the right of access, rectification, erasure, portability, restriction of processing, and objection (Chapter III of EU Regulation 2016/679). Such rights may be subject to specific limitations. For any questions, we invite you to contact us.

8.1. Can Minors Use the Platform?

Consent is given freely and may be revoked at any time. Processing carried out before revocation is lawful and is not affected by the revocation of consent.

8.2. Other Remedies

You also have the right to lodge a complaint with the competent Supervisory Authority or to bring judicial proceedings if you consider that the processing is not carried out in accordance with the law.

8.3. How to Exercise Them?

To exercise your rights, you can contact us at privacy@3x1010.it.