Privacy disclaimer

This privacy statement is intended to provide all information on data processing personal data carried out by BITMOBI LIMITED and VITAMINWEB LIMITED, as joint data controllers Users who browse and who are registered on the Site (as better indicated below).

1. INTRODUCTION - WHO WE ARE?

BITMOBI LIMITED, with registered office in 85 Great Portland Street, London (UK), W1W 7LT, Company Number 10791489, e VITAMINWEB LIMITED, with registered office in 85 Great Portland Street, London (UK), W1W 7LT, Company Number 11743628 (hereinafter, jointly, the "Joint Controllers"), owners of this site / app (hereinafter, for simplicity, “Site”), as joint controllers of the personal data of users who browse and who are registered on the Site (hereinafter, the "Users"), provide below the privacy policy pursuant to art. 13 of EU Regulation 2016/679 of 27 April 2016 (hereinafter, the "Regulation" or the "Applicable Law").

2. HOW TO CONTACT US?

The Joint Controllers take the utmost account of the right to privacy and the protection of personal data of the Users, who may contact the Joint Controllers at any time, using the following modality:

• - by sending an e-mail message to the address of the Joint Controllers:
  - BITMOBI LIMITED: info@hostesswing.com;
  - VITAMINWEB LIMITED: support@wing.club.

The Joint Controllers have not identified the figure of the Data Protection Officer (RPD or DPO), as are not subject to the designation obligation provided for by art. 37 of the Regulation.

3. WHAT DO WE DO? - PURPOSE OF THE TREATMENT

Browsing the Site allows Users to access a dating services platform for dating and a portal of free and / or paid advertisements and offers advertisers a space and one suitable structure to publish their ads, so that they are visible on the web also through the engines of search, allowing Users to get in touch, meet virtually, exchange ideas, find opportunities and create a network of contacts (hereinafter, "Service").

In relation to the activities that can be carried out through the Site, the Joint Controllers collect personal data relating to Users.

This Site and any services offered through the Site are reserved for individuals who have completed the eighteenth year of age. To this end, at the time of registration, the Joint Controllers may request the documentation that is appropriate and satisfactory in order to verify the identity of the User (which, by way merely by way of example, digital copy of the identity document and / or photographic self-portraits in digital). Therefore, the Joint Controllers do not collect personal data relating to persons under the age of 18. On request of the Users, the Joint Controllers will promptly delete all personal data involuntarily collected and related to subjects under the age of 18.

Users personal data will be lawfully processed by the Joint Controllers for the following purposes from treatment:

a) Contractual obligations and provision of the Service: to allow navigation and registration on the Site or to implement the Terms and Conditions of Use of the same, which are accepted by the User during registration, to take advantage of the Services offered through the Site, including the ability to publish advertisements and access chat services and also to fulfill specific requests of the'User. User data collected by the Joint Controllers for the purpose of any registration on the Site include: the nickname voluntarily chosen, year of birth, city of residence / domicile, e-mail address, mobile number, digital copy of the identity document, the photographic self-portrait in digital format, as well as all the information personal data of the User possibly and voluntarily published. Unless the User gives the Joint Controllers one specific and optional consent to the processing of personal data for the additional purposes provided for in the following paragraphs, the Users personal data will be used by the Joint Controllers for the sole purpose of ascertaining the identity of the User (also through validation of the e-mail address), thus avoiding possible scams or abuses, and contacting the User for reasons of service only (eg. to send notifications relating to services offered on the Site). For the best functioning of the Site and to facilitate interaction between Users, the latter can see the registration date of other Users. Without prejudice to the provisions elsewhere in in this privacy statement, in no case will the Joint Controllers make it accessible to other Users and / or to third parties dati personali degli Utenti.

b) administrative-accounting purposes, or to carry out activities of an organizational, administrative, financial and accounting, such as internal organizational activities and activities functional to the fulfillment of obligations contractual and pre-contractual;

c) legal obligations, or to fulfill obligations established by law, by an authority, by a regulation or by European legislation.

The provision of personal data for the processing purposes indicated above is optional but necessary, since failure to provide them will make it impossible for the User to browse the Site, register on the Site and use the Services offered by the Joint Controllers on the Site.

Personal data that are necessary for the pursuit of the processing purposes described herein paragraph 3 are indicated with an asterisk within the registration form or are otherwise indicated as mandatory.

4. FURTHER PROCESSING PURPOSES

4.1 Marketing and newsletters (sending of advertising material, direct sales and communication commercial)

Some of the Users personal data (ie the e-mail address) may also be processed for the purpose of marketing and sending newsletters (sending advertising material, direct sales and commercial communication, sending newsletters containing information in relation to news relevant to the sector relating to activity of the Site), or so that the User can be contacted by mail, e-mail, telephone (fixed and / or mobile, with automated call systems or call communication with and / or without the intervention of an operator) and / or SMS and / or MMS to propose to the User the purchase of products and / or services offered by the Joint Controllers themselves and / or by third-party companies, to present offers, promotions and commercial opportunities.

In case of lack of consent, the possibility of registering on the Site will not be affected in any way.

In the event of consent, the User may at any time revoke the same, making a request with the methods indicated in the paragraph 8.

The User can also easily oppose further sending of promotional communications via e-mail by clicking on the appropriate link for the withdrawal of consent, which is present in each promotional e-mail and newsletter. Once the consent has been revoked, a notification will be sent to the User to confirm the fact withdrawal of consent.

If the User intends to withdraw his consent to the sending of promotional communications by telephone, however, while continuing to receive promotional communications via e-mail, or vice versa, please send one request to the Joint Controllers in the manner indicated in the paragraph 8.

Following the exercise of the right to object to the sending of promotional communications via e-mail, it is possible that, for technical and operational reasons (eg formation of contact lists already completed shortly before receiving the opposition request), the User continues to receive some additional promotional messages. Should the User continue to receive promotional messages after 24 hours from the exercise of the right of opposition, please report the problem using the contacts indicated in the next paragraph 8.

5. LEGAL BASIS

Contractual obligations (as described in paragraph 3, letter a)): the legal basis consists of art. 6, paragraph 1, lett. b) of the Regulations, or the processing is necessary for the execution of a contract of which the User is part or to the execution of pre-contractual measures adopted at the request of the same.

Administrative-accounting purposes (as described in paragraph 3, letter b)): the legal basis consists in art. 6, paragraph 1, lett. b) of the Regulations, as the processing is necessary for the execution of a contract and / or the execution of pre-contractual measures adopted at the request of the User.

Legal obligations (as described in the previous paragraph 3, letter c)): the legal basis consists of art. 6, paragraph 1, lett. c) of the Regulation, as the processing is necessary to fulfill a legal obligation to which the Joint Controllers are subject to.

Further processing purposes: for processing related to marketing activities and sending newsletters (as described in the previous paragraph 4.1)), the legal basis consists of art. 6, paragraph 1, lett. a) of Regulation, or the provision by the User of the consent to the processing of their personal data for one or more specific purposes. For this reason, the User is asked to provide a specific one free and optional consent, to pursue this processing purpose.

6. PROCESSING METHODS AND DATA STORAGE TIMES

Users personal data will be processed using manual and IT tools, with logic strictly related to the purposes themselves and, in any case, in order to guarantee the security and confidentiality of data themselves.

Users personal data will be kept for the time strictly necessary to fulfill the purposes primary described in the previous paragraph 3, or in any case as necessary for the protection in place civil law of the interests of both the Users and the Joint Controllers. With specific reference to the digital copy of the identity document and the photographic self-portrait in digital version, such data will in any case deleted by the Joint Controllers once the registration process is completed or in any case once it will be correctly ascertained the identity of the Users and their validated profile.

In the case referred to in paragraph 4.1 above, the personal data of Users will be kept for the times strictly necessary to carry out the purposes illustrated in the same and, in any case, as long as the law allows further storage for these specific purposes, including defense against legal requests.

If the User decides to block and / or delete their profile, all stored data relating to the User are deleted. If the complete deletion of the Users data is not permitted or necessary for law, the data is blocked for further processing. Before the final cancellation, in any case the profile is temporarily frozen for 30 days.

In any case, any retention terms provided for by law or regulations.

7. SCOPE OF COMMUNICATION AND DISCLOSURE OF DATA

The Users personal data may be transferred outside the European Union and, in this case, i Joint Controllers will ensure that the transfer takes place in accordance with Applicable Regulations , in in particular, in accordance with art. 45 (Transfer on the basis of an adequacy decision) and 46 (Transfer subject to adequate guarantees) of the Regulation.

Employees and / or collaborators of the Joint Controllers may become aware of the Users personal data, in charge of managing the Site. These subjects, who have been instructed pursuant to art. 29 of the Regulation, will process the Users data exclusively for the purposes indicated in this statement and in compliance of the provisions of the Applicable Regulations.

Third parties that may be able to process may also become aware of the Users personal data personal data as Data Processors, such as, by way of example, service providers IT and logistics functional to the operation of the Site, outsourced or cloud service providers computing, professionisti e consulenti.

Users have the right to obtain a list of any appointed data processors, by making a request in the manner indicated in the paragraph 8.

8. USER RIGHTS

Users may exercise the rights guaranteed to them by the Applicable Regulations by contacting the Joint Controllers in the following ways:

• - by sending an e-mail message to the address of the Joint Controllers:
  - BITMOBI LIMITED: info@hostesswing.com;
  - VITAMINWEB LIMITED: support@wing.club.

Pursuant to the Applicable Law, Users are informed that they have the right to obtain the indication (i) of the origin of the personal data; (ii) the purposes and methods of the processing; (iii) of the logic applied in case of processing carried out with the aid of electronic tools; (iv) of the extremes identification of the owners and managers; (v) the subjects or categories of subjects to whom the data personal data can be communicated or who can learn about them as managers or in charge.

Furthermore, Users have the right to obtain:

a) access, updating, rectification or, when interested, integration of dati;

b) the cancellation, transformation into anonymous form or limitation of data processed in violation of law, including those that do not need to be kept for the purposes for which the data are been collected or subsequently processed;

c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also for n as regards their content, of those to whom the data have been communicated or disseminated, except in the case in which this fulfillment proves impossible or involves a manifestly disproportionate use of means with respect to the protected right.

In addition, users have:

a) the right to withdraw consent at any time, if the processing is based on theirs consent;

b) the right (where applicable) to data portability (right to receive all personal data that concern in a structured format, commonly used and readable by an automatic device);

c) the right to object:

i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if relevant to the purpose of the collection.

ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending material advertising or direct sales or for carrying out market research or communication commercial;

iii) if personal data are processed for direct marketing purposes, at any time, al processing of their data carried out for this purpose, including profiling to the extent that it is connected to such direct marketing.

d) if they believe that the processing that concerns them violates the Regulation, the right to lodge a complaint to a supervisory authority (in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation occurred). The Italian Supervisory Authority is the Guarantor for the protection of personal data, based in Piazza Venezia no. 11, 00187 – Rome (http://www.garanteprivacy.it/).

The Joint Controllers are not responsible for updating all links that can be viewed here Information, therefore whenever a link is not functional and / or updated, Users recognize and they accept that they must always refer to the document and / or section of the websites referred to by its link.