PRIVACY POLICY

This Privacy Policy will be effective from 10 July 2018.

This Privacy Policy (“Information”) describes the personal data processing by AR Market S.r.l. (hereinafter, “AR Market” or the “Company”), through the web page https://www.armarket.it/ (the “Website”), the web page https://www.masterupgame.com/, the AR Market application (the “App”), the AR Market Junior application (the “App”), the other Apps belonging to the AR MARKET family (Logopedia Game; The Ugly Duckling; Space Edu Park, Project Media System – PMS ) and the “Escape Game Christmas Adventure”. According to the applicable data protection legislation, the Company is the Controller and the Processor of the personal data processing. The legislation taken into consideration will mainly consist of the new European Regulation about data protection 679/2016 (the “GDPR”), and, as regards specifically the national panorama, from the Privacy Code (Legislative Decree 196/2003), adapted by the recent Legislative Decree  no. 101/2018. We collect user information in order to improving their experience using the website and the apps.

To fill in the contact form on the website, the user must be over 16 years old to allow us to collect and store his personal data. We don’t knowingly collect personal information from children under 16, and as result there is no responsibility. If you are under 16, we recommend that you don’t fill in the contact form on the website.

ARKit & Camera Usage

We do not share, collect or store data used by ARKit, Photo APIs, Camera APIs, or other software for depth of facial mapping information. Our App “The Ugly Duckling” uses Apple’s TrueDepth API only to track the movement of eyes, mouth and face to visualize a duck beak. The camera images are only used for gameplay and fun purposes: are used to make a unique user experience, are never stored remotely, given to third parties, or used for any non-gameplay purposes.

App Space EduParK: Educational App for secondary school, for user target  11-13, we do not collect any personal or sensitive data related to minors in the App.

WHO IS THE CONTROLLER OF DATA PROCESSING?

Identity: AR Market Srl

C.F./P.IVA 14821441004

Address: Viale di Val Fiorita, 86, 00144 Roma RM

Phone Number: +39 3420012278

Email: info@armarket.it

WHICH PERSONAL DATA DOES AR MARKET TREAT?

“Personal data” means, according to the article 4 of the GDPR, any information relating to an identified or identifiable natural persona (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.

According to the same provision, “processing” means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Concretely we treat:

Personal information provided by the users: the Company will be treating following data when the user creates a new account:

Identification information (first name, second name, email, address and telephone number);

user’s codes and password.

Data on personal characteristics (birth date and gender);

In the case in which there will be providing information concerning third parties, the user expressly guarantees to have obtained a previous authorisation of the latter which allows to transfer the information above mentioned, exempting the Company from any responsibilities. In any case, the Company is enabled to initiate periodical verifications in order to control such circumstance, adopting all the means provided under the applicable law with the right diligently.

Gathered personal data: every access to the official website or the apps, the Company will be gathering and elaborating automatically the following personal data:

Technical information, including the IP address that is used to connect the computer to internet, the access data, the typology of browser and the version used, the operative system and the platform;

Information regarding browsing on the official website or the apps, including the uniform resource locator (in short URL), all the services that the user looked up and search for; the responding time of the page; the download errors; the total time of the visit; information about the user-website interaction and the methods used to exit website;

Information obtained through cookies implemented by the Company on the official website. Below, you find additional information on the use of cookies.

WHAT IS THE PURPOSE OF USING USERS PERSONAL DATA?

La Società tratterà i dati personali per i seguenti scopi:

Manage the services and the functions of the official website and the apps;

user’s IP address or device ID might be identified by analytics platforms to help us assess the usage of our website, the app and the other services;

detect and the prevent eventual identify frauds;

in the case the user contacts the client service, elaborate the request and provide the best service possible;

make internal analysis and reports for future campaigns;

be able to detect all fraudulent access and navigation;

prepare a commercial website on the user, using the data gathered during the management of purchased products and services; unless the user decides differently during the registration process or if opposing to such treatment in a second moment; and

Develop a commercial profile on the user, based on the personal data provided and those obtained throughout the user’s navigation on the official website and the apps, with the purpose to analyse and foresee several aspects, namely the user’s preferences and personal interests; and, therefore, be able to send commercial communications adapted to the user’s preferences and interests, as well as to personalize AR Market official website or services; activities that will be made once the user provided his/her consent.

LEGITIMATION

Legal basis for the treatment of your personal data according to the above-described purposes are as follows:

the execution of our contractual relationship with the user and AR Market;

the processing of the user’s personal data for the identification and prevention of fraudulent identity is necessary for the fulminant of the company’s obligations in the field of money laundering;

the fulfilment of the Company’s legitimate interest, consisting in: (I) manage the services and functionalities of the official website and the app and (II) in case users contact the customer service, to process the request and provide the best possible service; (III) preserve the supervision, administration and protection of our services, content and official web page; (IV) perform internal analyses and reporting for future campaigns; and (V) create a commercial profile based on the users, using data derived from the management of the contracted products and services, and send electronic commercial communications related to similar products or services; unless you indicate otherwise, choosing the corresponding negative box in the registration process. In any case, users have the right to oppose to these treatments at any time through the e-mail address info@armarket.it, in that case AR Market will interrupt the processing of the data, with the exception of reasons provided by law;

the permission to develop a commercial profile on users, based on the personal data given to the Company and the data collected through users’ browsing on the official website, in order to analyse or predict aspects such as personal preferences or interests; and therefore be able to send to users commercial communications tailored to users’ preferences or interests, as well as customizing AR Market website or devices.

All this will take place on condition that the prior consent has been given to the treatment. The user has the right to withdraw the consent at any time via the e-mail address info@armarket.it.

In any commercial communication we will inform users how to cancel the registration in a simple and free way. We will answer to every request as soon as possible and, in any case, within the establishes legal deadline.

In cases where the Company needs some personal data to fulfil its legal or contractual obligations, the provision of the necessary personal data is mandatory. If this information is not provided, the Company will not be able to maintain its contractual relationship with the user or fulfil its obligations.

WHO WE SHARE PERSONAL DATA WITH?

We can share user’s personal data with other companies part of the group Herotech Srl, placed in European Union for the same purposes by which we collect and obtain users data, for reasons of Company reorganization or in case of divestiture of a business.

The Company has signed an agreement with suppliers to provide certain services (e.g. informatic services, virtual infrastructures, cloud computing, consulting services and full management of digital marketing actions, etc.) which can access and/or elaborate personal data under their conditions as person in charge of the process. Nevertheless, personal data will not be transferred in countries placed outside the EU area that do not offer an adequate level or appropriate guarantees of protection.

No personal and anonymous data will be shared with third parties, unless: (1) you provided permission, (2) it is required by law, (3) we believe it is necessary to protect our rights or property, or (4) the third party is the successor or purchaser of our Company’s assets. Consent will not be required for disclosure in cases (2), (3) and (4) above, but we will attempt to make notifications, to the extent we are required or permitted by law to do so.

HOW LONG DO WE STORE USERS DATA?

The Company will store personal data for the entire contractual/commercial relationship, unless a request of cancellation (according with the means indicated in “your rights” section of this PP); and, beyond these, until the expiration of the mandatory limitations terms in accordance with the applicable regulations in force. AR Market takes appropriate measures to protect and secure personal information from unauthorized access or disclosure.

LINK AND USE OF COOKIES

The official website and this app can include, show or install links directed to other websites for convenience and information. Such website can operate independently from AR Market. It is possible  that all pages having links to our official website or our apps adopt special privacy policies, so we strongly recommend reading theirs too when visiting their official pages. Except for websites or web pages owned by AR Market, or under the control of AR Market, the Company assumes no responsibility for the contents, the use or the practices applied concerning privacy by other websites having direct links to AR Market page that users visit.

In the official website and in the app is possible to select some functionalities that operate on the personal data that AR Market Srl share with other entities or websites (such as “share” button on Facebook, Twitter or email). Those functionalities transmit data to third parties which can use personal data in agreement with their privacy policies. Third parties may use personal data in accordance with particular privacy policies. These features are operated by third p arties that are not associated with AR Market Srl. We strongly recommend to read these third-party privacy policies when using the corresponding features.

AR Market Srl has the right to use its own cookies on third parties’ cookies while browsing the site to improve browsing experience or show ads suited to some preferences and tastes. These cookies collect information about user and his/her browsing.

USERS’ RIGHTS

Users have a series of rights about their personal data collected by us (article 12 and following of EU Regulation 679/2016). AR Market Srl provides various options to know what personal data we will recompile, how they are used and the means we use.

You can contact our team any time to exercise the following rights:

Right to access;

right to request the correction of their data or the possible integration of missing information;

right to request the elimination of personal data if the circumstances required by current legislation are met;

right to opposition to the processing of personal data;

right to data portability.

It’s possible to contact us at any time to exercise these rights to the e-mail address info@arealitymarket.com by attaching a photocopy of a valid identity document.

Furthermore, anytime  the consent can be revoked: (i) according the instruction of the communication; (ii) contacting us by e-mail at info@arealitymarket.com and attaching a photocopy of a valid identity document.

Likewise, and in case of an infringement attributable to AR Market Srl of its legal obligations on the protection of personal data, the right to lodge a complaint with the competent Italian Data Protection Authority is provided for.

UPDATES OF OUR PRIVACY POLICY

AR Market Srl reserves the right to update this privacy policy periodically at a notice of three (3) days, to reflect changes in our practices on personal data. We will then publish a notice clearly visible on the official website to notify any significant change to our policy, indicating at the top of the webpage the date of the last update.