Version of May, 25, 2018
Premise and Definitions
The acceptance of this Policy is a necessary condition for accessing PnP Services, which can not be otherwise provided. The user who even partially does not accept this Policy is obliged not to register on the Platform, to not access it and / or to cancel his profile if previously registered.
- Personal data (also “PD”): any information obtained from PnP on a natural person who is, on the basis of the same information, identified or identifiable;
- Aggregate data: a set of information on individuals or groups of people that does not allow, following specific treatments (so-called Pseudonymisation), to trace the Personal Data of the individuals concerned;
- Interested: person owner of the personal data obtained from PnP which is, on the basis of the same data, identified or identifiable;
- Treatment: any operation or set of operations performed by PnP on personal data or on a set of personal data of the data subjects;
- Data Controller: PlacenPeople Srl, which is responsible for the processing of personal data collected;
- Data Processor: natural or legal person, public authority, service or other body that processes personal data on behalf of PlacenPeople;
- Consent of the interested party: manifestation of free will, specific, informed and unequivocal of the interested party, with which he expresses his consent to the processing of personal data concerning him.
Data Controller is PLACENPEOPLE SRL, with registered office in Viale Meucci 19/c, 70125 Bari (BA), Italy, VAT No. 08125910722, n. rea 605992 (hereinafter “Controller”).
At the time of writing this Policy, the contact details of the Controller, as reported in the “contact” section of the Website and the Apps, are: e-mail email@example.com.
Any variation of these data will be made known to Users promptly, by updating the information contained in the “contacts” section of the Website and the Apps.
For all and / or certain processing operations, PnP may use third-party companies established in EU or non-EU territory. The updated list of data processors and data processors is kept at the Data Controller’s headquarters and will be made known on request by the interested parties.
Object of the Treatment
PlacenPeople may process the personally identifiable and non-sensitive Personal Data of its Users, which have been:
- provided directly by the Users through their insertion on the Platform, ie filling in appropriate text or numeric fields, or selecting items from lists, or by ticking boxes (eg registering with the platform, creating or updating profiles or announcements, communicating with other users or with PlacenPeople, accessing or connecting to the platform through third party sites);
- provided directly by the Users through their insertion in communication or messaging channels indicated as “official” by PlacenPeople in its “contacts” page.
- obtained through the mobile devices of the Users, which transmit information concerning the position, the IP address, the IMEI code and the like. Some devices allow the User to prevent the tracking of their position. This could, however, limit and / or reduce the functionality of the services provided by the Platform;
- generated during the use of the Platform (eg IP address, used software, pageviews, visit time, source and exit URLs);
- generated during the use of the Service, such as for example reservations and presence in activities. With regard, in particular, to payments made on the Platform, such data may be shared by PnP with the Organizers or with the Managers for organizational or commercial purposes; through the privacy settings of profile, the User may at any time request that such data be communicated and viewed by the recipient only in aggregate form, to prevent the identification of the same;
- inserted by other members of the Community, in the process of creating an invitation to registration to be presented to the User. Should the User decide not to proceed with the registration, we will delete such data. If the User decides to proceed with the registration, he / she must approve these data, and from that moment on we will process such data as provided by the User.
- sent to PlacenPeople by Users or also by other members of the Community, in ways that make explicit the User’s consent to the use of the modality itself (example: in a photo, in which users are posing with the name tag or symbols of PlacenPeople)
Purpose and Legal basis of the Treatment
Users’ Personal Data may be processed by PlacenPeople only with the consent of the interested parties, which must be provided autonomously for the various processing purposes set out below. These include, in particular:
- A) Purposes of Service (management of the Platform and the Service, improvement of the Users’ experience), aimed at:
- allow, upon request of the User, the registration, access and use of the PnP Platform;
- send operational and service messages, such as notices related to reservations, support messages or administrative messages, reminders, technical communications, updates, safety notices, and other information requested by the User or made necessary by the Service;
- make payments, as well as the preparation of documentation of a fiscal nature;
- improve the Users’ experience within the Community, making visible information on the expected participation of the MeCs in the proposed Activities, or participation to activities in the past, as well as organizing activities to benefit the Community, such as events, awards, experiences and similar. The User can always limit the visibility of his data within the Community by changing the Privacy settings of his User Profile (so-called SuperPrivacy option), or communicating this request to PlacenPeople if the user profile is not accessible;
- allow, only upon prior request by the User, forms of collaboration between MeC and PnP and give the User access to particular roles, which allow actions aimed at expanding and improving the functioning of the PlacenPeople Platform;
- fulfill the pre-contractual, contractual and tax obligations deriving from the relationships existing with the User;
- fulfill the obligations established by law, regulations, community legislation or an order of the Authority;
- prevent or detect fraudulent activities or abuses, increasing trust and security within the Platform, including through surveys and checks on published materials and on the profiles used, as well as through controls even on governmental databases;
- exercise the rights of the Owner, resolve any disputes with the Users and enforce the rights of the Company towards third parties;
- B) Marketing purposes, aimed at:
- allow subscription to the Newsletter Service (both registration and unsubscription are freely initiated by the User);
- conduct analytics, research, advertising and marketing activities with the aim of improving, managing, protecting and optimizing the PlacenPeople Platform and activities, as well as the experience of our Users;
- send promotional and / or commercial communications regarding information of potential interest to the User. The User may at any time oppose the further receipt of such communications by changing the Privacy settings of his Profile;
- C) purposes of communication and / or transfer to third parties of data, for marketing, commercial, statistical or promotional purposes.
Nature and Revocation of Consent
Consent to Data Processing for Service Purposes is mandatory for registration to the Platform and for access to PnP Services, which will not otherwise be provided (so-called Privacy On mode). By registering with the Platform, the User authorizes PnP to process its Data for the purpose in question by setting its privacy on the “Privacy On” level. The consent to the Treatment for the Purpose of Service may always be revoked by the User by simply canceling their MeC Profile from the PlacenPeople Platform (also obtainable through a specific request).
The consent to the processing of data for the purposes of marketing and communication or transfer to third parties is, instead, optional (so-called Free mode). With respect to these purposes, the User does not provide any consent or confers any data when registering with the Platform. The User can freely choose the Free mode by changing the privacy settings of his User Profile, through the appropriate functionality, or by consenting to PlacenPeople’s request. The consent given for the purposes in question may be revoked at any time by the User itself by further modification of the privacy settings of their User Profile. In this case, the User will continue to have access to the Platform and to PnP Services, with the exclusion of commercial and promotional functions.
In order to ensure the best experience of the User, it is in any case permitted to limit the Data Processing for Service Purposes to collection only and, in particular, to exclude sharing of the User’s economic data within the Community (so-called Superprivacy mode). The User can exercise this option by changing the Privacy settings of his User Profile or by submitting a request in PlacenPeople. While not preventing access to the Platform, the choice of the Superprivacy mode could affect the functionality of the same, limiting the usability of some PnP Services.
PlacenPeople processes the Personal Data of Users through collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, blocking, publication, communication, cancellation and destruction of Personal Data. Data may be processed either on paper or digital and / or automated.
Communications from Users and directed to PnP or to other users can be examined by PnP, with the aim of preventing any fraud and abuse, to verify compliance with applicable rules, to develop the product and the offer, or even just to improve the service offered. PnP will try to prevent, as far as possible, that its systems are used in violation of the law; however, this activity does not imply any systematic control or guarantee on the communications of the Users.
By using the Platform, User agrees that PlacenPeople, in its sole discretion, may review, scan, analyze and retain his communications, either manually or by automated means.
PlacenPeople treats Users’ Personal Data only for the time necessary to fulfill the aforementioned purposes and, in any case, no later than 10 years from the termination of the relationship.
Access to Data
For the purposes mentioned above, PlacenPleople may make the Processed Personal Data accessible:
- to the employees and collaborators of the Data Controller, or its subsidiaries and associates, and their employees, or to third parties and PnP suppliers, in their capacity as persons in charge and / or internal managers of the processing and / or system administrators;
- to subsidiaries and associates, and to their employees (for example, for support activities in the study of the feasibility of the client’s project, for technical project management activities, for the storage of personal data, etc.), or to third parties and suppliers (for example, providers for the management and maintenance of the website, suppliers, lenders, professional offices, etc.), which perform outsourcing activities on behalf of the Data Controller, in their capacity as external data processors.
Depending on the nature of the consent given by the interested party (Privacy On, Free or Superprivacy), PnP can communicate the User’s Personal Data as follows.
In case of consent for the sole purpose of Service (Privacy On), some parts of the User Profile containing PD can be shared with other Users within the Platform. Likewise, some parts of the User Profile may be viewed by other Users on the Platform or in the Ads. Such parts may include, as in the case of Announcements, information and PDs taken from the profile of the Creator, as well as information or PDs taken from the profile of other users (for example the subscribers to such Announcement).
Public User Profiles and Ads pages may be indexed by search engines and may be publicly disseminated as search results.
When a booking is finalized, some PD of the User, including for example the full name or the telephone, could be communicated by PlacenPeople to the Organizer, in order to organize the meeting or to improve the experience, or to third parties, in order to support organizational activities or increase its level of security. In any case, PlacenPeople will not share the telephone number of the Users unless there are previous agreements to that effect, or a confirmed booking. The details of the MeC for billing are never shared by PnP with the Organizer.
The mutual evaluation expressed by the MeC and the Organizer at the end of an Activity, expressed according to one or more parameters of judgment, could be publicly accessible on the Platform.
In case of consent for Marketing and Communication purposes or transfer to Third Party (Free), in addition to the sharing methods above, some parts of the Public User Profiles, or hosted Announcements, may be viewed and / or shared externally with third parties, for marketing or commercial purposes.
The sharing of the PD of the Users within the Community will, instead, be limited in the option for the SuperPrivacy mode.
The User acknowledges and accepts that PlacenPeople may use, store and communicate PD and content produced by it in order to:
- respond to any complaints raised against PnP;
- comply with judicial orders;
- protect the rights, property or personal safety of PlacenPeople, its Users or MeC, or the general public.
The Data Controller may, in any case, communicate User Data to Supervisory Bodies, Judicial Authorities and to all other subjects to whom the communication is mandatory by law. PlacenPeople commits itself, within the limits of the commercially reasonable, to inform Users about requests received from the authorities that involve their data, unless this is not permitted by law or by the authorities’ request, or to the judgment of PnP it is possible to identify another impeding cause.
Aggregated Data and non-personal data may be used by PlacenPeople for any purpose.
Use of images, photos or videos
PlacenPeople bases its Service on the creation of a community, which is also one of the declared objectives of PlacenPeople and known by the user at the time of registration. Provided that the images relating to Community Users are acquired in ways that demonstrate full awareness and acceptance of the acquisition itself (for example, being “posing” with a sign bearing the name or registered symbols of PlacenPeople), the public use of these elements has the purpose of making the community manifest and is therefore to be considered as a Service Purpose; therefore the User is hereby informed that in the “privacy on” and “privacy free” mode the images, photos and videos acquired in the mentioned way may be published on the internet or elsewhere. The User has the right to opt for the “superprivacy” mode to oppose such publication, or to request the deletion of such materials to PlacenPeople at any time. With the booking request, made by the User for any activity on his own behalf and on behalf of other members of a group, not registered in PlacenPeople, the User takes responsibility for certifying to PlacenPeople that the contents of this policy are known to these members, and that the publication of the aforementioned material is permitted, except for any explicit refusal to be sent to PlacenPeople through any “official” communication channel (i.e. among those indicated as such in the “contacts” section of the site).
In addition, the MeC may link its PlacenPeople Profile to third-party social networking sites (hereafter: “Socials”). In this case:
- some information on Socials may be available on the PlacenPeople profile, or vice-versa;
- some information on Socials may be available on PlacenPeople announcements, or vice-versa
- the User’s contacts on these Social networks may view information relating to the User’s activities on the Platform, while PlacenPeople users may view information related to the User’s contacts on these Socials.
Such information coming from the Socials will be subject to the settings of such third party websites, and will be processed by PlacenPeople for the reasons set out in the paragraph “Purpose and Legal basis of the Treatment” of this policy.
Users’ Personal Data will be stored on Server sites within the European Union or foreign countries, as long as they are hosted by GDPR compliant hosting companies. Any further information on this point can be requested to PlacenPeople.
Rights of the data owner
Data owners residing in the EU have the right to exercise, at any time, the rights referred to in Articles 7 et seq. of the Privacy Code and articles 15 et seq. GDPR, and in particular the right to obtain from PnP:
- confirmation that a data processing is currently in progress concerning him and, in this case, to obtain access to these data and to this privacy note;
- updating, rectification or integration of inaccurate personal data concerning him;
- the cancellation of personal data concerning him if: a) they are no longer necessary with respect to the purposes for which they were collected or otherwise processed; b) the interested party revokes the consent on which the treatment is based and if there is no other legal basis; c) the interested party opposes the processing and there is no legitimate overriding reason to proceed with the same; d) personal data have been processed unlawfully; e) personal data must be deleted to fulfill a legal obligation under Union or Member State law to which the data controller is subject;
- a limitation of Data Processing if: a) the data subject disputes the accuracy of personal data, for the period necessary for the data controller to verify the accuracy of such personal data; b) the processing is illegal; c) personal data are necessary for the interested party to ascertain, exercise or defend a right in court; d) the interested party has opposed the processing of personal data for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication, through the use of automated call systems without intervention an operator by e-mail and / or through traditional marketing methods by telephone and / or paper mail;
- the attestation that the above operations have been brought to the attention, also with regard to their content, of those to whom the data had been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a use of means manifestly disproportionate to the protected right;
- the personal data concerning him / her provided to a data controller in a structured format, commonly used and readable by automatic device and to transmit this data to another data controller without impediments by the data controller who supplied them. In exercising its rights in relation to the portability of data pursuant to paragraph 1, the data subject shall have the right to obtain direct transmission of personal data from one controller to another, if technically feasible;
The User also has the right to object, in whole or in part, a) to the processing of data for purposes relevant to the purpose of collection, where there are legitimate reasons; b) to the processing of data for direct marketing purposes and using automated methods. This opposition extends to traditional commercial communications, but the faculty for the interested party to exercise the right of partial opposition remains unaffected. Therefore, the interested party can decide to receive only communications using traditional methods or only automated communications or none of the two types of communication.
Furthermore, the User has in any case the right to raise a complaint with the Guarantor Authority.
How to exercise rights
The User may, at any time and compatibly with temporary technical difficulties, review, update, correct or delete the PDs present in his own MeC Profile, or even completely eliminate this profile, through the appropriate functionalities present on the internal pages of the PnP Platform.
In addition, the User can exercise his rights by sending a request with registered letter to PLACENPEOPLE SRL, at its registered office, as indicated in the “contacts” section of the Site and the Apps, or alternatively by communicating this request through an official contact channel (the channels considered official are defined in the “contacts” section of the Site).
PnP carries out the operations or provides the requested information without undue delay and, in any case, within a period of 30 days from receipt of the request. This deadline may be extended for up to two months, if necessary, taking into account the complexity and the number of requests. The data controller informs the User of such extension, and of the reasons for the delay, within one month from receipt of the request. If the interested party submits the request by electronic means, the information is provided, where possible, by electronic means, unless otherwise indicated by the interested party.
The operations and information in question are carried out and / or provided to the User for free. However, if the requests of the interested party are found to be unfounded or excessive, in particular due to their repetitive nature, PnP may at its discretion:
- a) charge a reasonable service fee and, in any case, not more than € 15.00, taking into account the administrative costs incurred to provide the information or communication or take the required action;
- b) refuse to satisfy the request.
If it has reasonable doubts about the identity of the person who submits the request for information, PnP can always request further to confirm the identity of the person concerned.
- Invitation service
The Platform offers the possibility for the User to send an invitation to their contacts to register in the Community, specifying the name and email address of the recipient. This service provides that the recipient can see who the sender of the invitation is. Placenpeople will proceed to a single submission for each request, and will not store data related to that recipient in its databases. If the MeC that sends the invitation covers a coordination role within the community, it will have the possibility to send invitations to specific roles (for example, to become an organizer); in this case the recipient will be able to view the sender’s contact details, such as name, e-mail, mobile phone number or other PD.
- Operational messaging
The Platform offers a notification service via e-mail or cellular communications regarding the user (such as confirming reservations, receiving feedback, etc.). PlacenPeople strongly recommends to pay attention to such communications. However, the user who does not wish to receive such communications can forward them to the junk mail box or delete his own MeC profile.
- Profile management service
PlacenPeople can offer a profile management service at the request of the user and for a fee. This service is provided according to specific regulations. The user who wishes to make use of this service must expressly authorize PlacenPeople, by means of a written document or voice recording, to carry out on its behalf operations on the profile itself, in accordance with the provisions of the regulation.