PRIVACY INFORMATION NOTICE

Privacy Policy of Tako Dojo

Tako Dojo collects some Personal Data from its Users.

Owner and Data Controller

Grifo Multimedia s.r.l. – via Bruno Zaccaro 17/19 – 70126 Bari (Italia)

Owner contact email: dpo.grifomultimedia@grifomultimedia.it

The present APP is addressed to minor users. It should therefore be used only under due parental supervision. To use the APP, parents or those exercising parental rights over the intended minor user should carefully read and accept this document by ticking the box below. For the purposes of data protection law, consent is not valid if it has been granted by children under 14 years of age.

GRIFO MULTIMEDIA S.r.l., with registered offices in Via Bruno Zaccaro no. 17/19 – 70126 Bari, Italy, whose data protection officer (DPO) may be reached at the email address dpo.grifomultimedia@grifomultimedia.it (“Company”) in its capacity as editor of the APP and as data controller, wishes to provide you with information about the use of the APP, and specifically on how personal data of the user are processed, pursuant to art. 13 of Regulation (EU) 2016/679 (“GDPR”) and to Opinion 02/2013 of the WP 29 Working Group on applications for smart devices.

The Company informs that:

– the pharma companies which sponsor the APP do not access and do not process any personal data;

– the use of the APP implies processing of personal data by the Company, specifically:

email address
password (only a checksum is recorded)
ID (assigned after registration)
Date of registration
Status of consents
IP address
score of the games contained in the APP
particular data included in art. 9.1 of the GDPR, that is, data pertaining to the user’s health such as glycaemia levels.

We wish to clarify that data pertaining to the user’s health may be inferred directly (on the basis of any information added in the APP) or indirectly (e.g. from the fact that the user uses an APP dedicated to people suffering from diabetes).

The purposes of the processing are the following:

– use the APP’s functionalities, including the “forgotten password” and data backup functions – the legal basis of the processing is your consent, pursuant to art. 9.2.(a) of the GDPR;

– perform anonymous statistics on the functioning and usage of the APP (art. 6.1.(f) of the GDPR).

Conferring your registration data and consent to their processing are required –without them it is possible to download and install the APP, but not to use it.

Data shall be accessible to IT and administrative staff of the Company authorized to process personal data, as well as third party providers (e.g., providers of IT and cloud computing services) and other entities to which data must be sent to comply with legal obligations. Such entities shall act, as the case may be, as data processors or data controllers of the Company. Data may be transferred outside the EU: in such cases, the transfer shall take place safely, and shall feature adequate measures as sanctioned by the GDPR (e.g. standard contractual clauses approved by the EU commission or selection of data recipients enrolled in programmes for the free movement of data, such as the EU-US “Privacy Shield”).

We wish to clarify that originally anonymised data (or data that are permanently anonymised) and aggregate data are NOT considered as personal data pursuant to the laws on the protection of personal data and by this document. Specifically, aggregate and anonymised data are information recorded by users and grouped in a way that makes it impossible to track down individual users. Such anonymised data, such as those pertaining to the correct use of the APP, frequency of use, updates, etc., report on system crashes may be collected automatically by the Company for statistical purposes and shared- in anonymous format- also with the Companies that sponsor its development.

With the exception of the above, users’ data are not communicated to third parties and are not disseminated.

Data are retained no longer than is necessary for the specified purposes, and in any case no longer than 24 months after the APP has been used for the last time. Data are processed in line with the principle of lawful and fair processing and data minimization, security and confidentiality. As per security measures, the Company has implemented adequate measures as per art. 32 of the GDPR.

Data are processed in anonymous, electronic format. The Company informs you that, by submitting a request to the Data Controller and/or DPO at the above address, it is possible to exercise the rights sanctioned by arts. 15-22 GDPR, including the right to obtain confirmation about whether the Company is processing your personal data or not, verify their content, origin, exactness, request that they are supplemented, updated, rectified, erases, anonymised, frozen (if processed against the law), oppose to the processing of legitimate reasons, withdraw consent (without prejudice for the lawfulness of the processing activities carried out before withdrawal). Furthermore, we require to carefully read the privacy policies of the Stores from which the APP was downloaded (AppStore, Google Play, etc.), as these may perform independent processing operations (e.g. your email address, device data, geolocalisation data, consumption habits, data on your health, etc.) and share such information with third parties, as per the policies implemented by said stores –please see those policies for more information. Please note that such Stores act as independent data controllers for the purposes of the GDPR, and that therefore the Company does not control, and may not be held liable, for the processing operations performed by the Stores.