Privacy Policy

This page describes the management methods of the site https://www.u2y.io/ ("Site") with reference to the processing of the personal data of the users who access and navigate on the web page. The information is provided only for the website of Up2You S.r.l. ("Up2You", "We" or "Company") and not for other websites that may be consulted by the user. 

Following consultation of the Website, data relating to identified or identifiable persons may be processed. We may also receive personal information from you through our chatbot system or through the contact details on our Website, for the purposes and in the manner set out below.

HOW DO WE COLLECT AND USE PERSONAL DATA?

This Site acquires personal data ("PersonalData" or "Data") as part of its normal operation, the transmission of which is an integral part of Internet communication protocols. This Data, depending on how you interact with the Site, may include: profile information, contact information, browsing preferences and interests, and information about your location. 

Data collected when browsing the Site 

The Site may automatically allow the user to be identified when browsing by collecting certain personal information such as the IP addresses or domain names of the computers used by users who connect to the Site, the URI(Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, a numerical code indicating the status of the response given by the web server (successful, error, etc.) and other parameters relating to the user's operating system and computer environment. 

This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site and to check that it is functioning correctly. 

The Data may be used to ascertain responsibility in the event of computer crimes against the Site or at the request of the authorities.

• Data provided voluntarily by the user

We may acquire your Personal Data through the voluntary submission of requests by you, using the email address you provide on the Up2You Site and/or through the chatbot system and/or the "contact us" form in the appropriate section of our Site.

We may collect your personal information when you decide to contact us to receive information about our projects.

If you write to us, we may ask you to provide us with the following data:

• first and last name;
• telephone number;
• e-mail address;
• personal information provided to us through the message sent. 
  

PURPOSE

We use the Personal Data we collect for a variety of purposes including, but not limited to: to process requests sent to Up2You through the Site and the chatbot system and to analyse how we can improve our services and user experience. 

The purposes are listed in more detail in the table below.

WITH WHOM DO WE SHARE USER INFORMATION?

We can share information: 

- with commercial partners and with third parties to satisfy user requests (such as the supplier who supports the management of the Site, etc.) as set out in Table 1 below;

- judicial or public authorities, in accordance with their obligations under the law or to repress unlawful conduct;

- internally, with the staff in charge of processing users' Personal Data according to the authorisation profile issued by the Company.

To find out more you should consult our Extended Privacy Policy.

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WHAT ARE THE USER'S RIGHTS?

Users, as data subjects, have the right at any time to obtain confirmation of the existence or otherwise of Personal Data processed and to know its content and origin, verify its accuracy or request its integration, updating or rectification (Articles 15 and 16 of the Regulation).

Pursuant to Articles 17,18 and 21 of the European Regulation 2016/679 - GDPR, each user has the right to request the deletion, restriction of processing, transformation into anonymous form or blocking of Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing. As data subject, users also have the right to revoke their consent at any time, without prejudice to the validity of the processing carried out prior to revocation. Finally, users have the right to lodge a complaint with the Data Protection Authority, pursuant to Article 77 GDPR.

For more information on your rights and how to exercise them, we invite all users to read our Extended Privacy Policy below.

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QUESTIONS ABOUT OUR PRIVACY POLICY?

If you have any questions about our privacy policy, please do not hesitate to write to us at: privacy@u2y.io

Before accessing or using our Site, please ensure that you have read and understood our collection, processing, storage, use and disclosure of your Personal Data as described in this privacy policy.

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ANNEX 1 - LIST OF OUR BUSINESS PARTNERS 

ANNEX 2 - THIRD PARTY TRACKING TECHNOLOGIES

PRIVACY POLICY OF UP2YOU6

Extended information6

What is the privacy policy about?6

2.Who is the Data Controller?6

3.What personal data do we collect?7

What kind of Personal Data do we process?7

3.2.Automatically collected information7

4.What Personal Data do we not collect?8

5.Why do we process your Personal Data?8

6.To whom are your Personal Data disclosed?12

7.What are your rights in relation to the processing of Personal Data, how can they be exercised?12

8.How long do we keep Personal Data?13

9.How do we protect your Personal Data?14

10.Cancellation of services14

11.Applicable law14

12. Complaint to the Supervisory Authority14

Table 1 - LIST OF OUR BUSINESS PARTNERS14

Tab 2 - TRACKING TECHNOLOGIES18

PRIVACY POLICY OF UP2YOU

Extended information

1. What is the privacy policy about? 

This privacy policy ("Privacy Policy") describes how the website ("Site") of Up2You S.r.l. manages the processing of personal data ("PersonalData" or "Data") of users who access and consult our website. 

The information is provided only for the Up2You S.r.l. website and not for other websites that may be consulted by the user via external links. 

Data relating to identified or identifiable persons may be processed as a result of visiting this Site. We may also receive personal information from you via our chatbot system and/or the "contact us" form in our dedicated section on the Site.

2. Who is the Data Controller? 

The Data Controller is Up2You S.r.l. ("Up2You" "We" "Company" or "Owner") with registered office in Via Orseolo 12, 20144, Milan (MI). 

3. What personal data do we collect?

We collect and process Personal Data in different ways:

• Personal Informationvoluntarily provided by you: we collect Personal Information about you when you actively provide it to us, such as when you contact us using our chatbot or by writing to us at our email address or through the "contact us" form on the Site. In the event that you use the PlaNet platform, we may collect Personal Data necessary to register your account and we may process images that you upload to the platform in order for you to earn points and earn ECOin. For some of our services, such as the PlaNet platform, we process your Personal Data as a Data Controller and not directly as a Data Controller.
• Personal Information Collected Through Use of the Site: We automatically collect certain Personal Information as you navigate and use our Site.

What kind of Personal Data do we process?

• Information on preferences and interests: preferences set for notifications and viewing our Site;
• Social Profiles: When you register on our Website via social media, when you interact with our Website via social media, we may receive information from the social platform about your personal account and any other information that allows the social media platform to share with third parties. We inform users that the following links to social channels and platforms are present on our Website: Facebook and Linkedin.
• Location data: we can approximate the location of the user based on their IP address. 
• Personaldata: personal data, contact data and images uploaded through the use of the PlaNet platform.

3.2. Automatically collected information 

When you use our Website, interact with us through your smartphone, a computer, a mobile device, our chatbot system, we and our third party partners may automatically collect information about how you access and use the Website as well as information about the device you use to access the Website. We use this information to improve and personalise your experience, to monitor and improve our Website and for other internal purposes. We generally collect this information through a variety of tracking technologies, including cookies, pixels, web beacons, embedded scripts, location identification technologies, and similar technologies (collectively, "tracking technologies").

You can accept or reject these technologies by changing your privacy preferences in the profile settings of your browser.

The information we collect automatically may be combined with other personal information we collect directly from users. 

The information we may collect automatically is:

• information about the use of the Site (e.g. which website the user came from, how many times the user clicked on an item); 
• Personal data relating to interactions with our marketing communications (e.g. whether or not a user clicks on an image or hyperlink); 
• information about the devices you use to access and interact with the Site (for example, this lets us know whether you use a computer, tablet or smartphone, your screen resolution, operating system, Wi-Fi connection, Internet browser and IP address, information about server log files). 
• Behavioural data: information derived from a combination of device ID and system events that can be used to identify behavioural trends and patterns and send marketing communications related to services offered by the Company. Consumption Habits; 
• AnalyticalInformation: We may collect Analytical Data, or use third party analytical tools, to help us measure traffic and usage trends on the Site and to better understand the demographics and behaviours of our users.

4. What Personal Data do we not collect?

We do not collect or process the following Personal Data relating to you: 

• racial or ethnic origin; 
• political opinions;
• religion or philosophical convictions;
• health or medical conditions;
• criminal background;
• union membership;
• Genetic or biometric data; 
• life or sexual orientation.

We ask our users not to send us, and not to disclose, any of the above Personal Data through the Site or directly to our contacts.

5. Why do we process your Personal Data? 

Users' Personal Data are processed for: 

a.Answering questions and dealing with users' requests 

To respond to requests and queries relating to our services that you submit using the Contact Details provided by Up2You. We may respond to your requests using our chatbot system which will ensure timely assistance to you requesting support or by email using the "contact us" form on the Site.

Legal basis of processing: to manage, in an appropriate and timely manner, the requests of users and to ensure the service offered by Up2You.

b.Ensuring the technical functioning of the Site

We collect and use your Personal Information to technically administer the Site and ensure that it functions properly. We may use the Personal Information you provide to respond to your reports or complaints regarding the proper functioning of the Site.

Legal basis of processing: our legitimate interests in ensuring the proper functioning of the Site from a technical/IT point of view.

c.Inform you of changes to the terms and conditions of use of the Site and provide you with this Privacy Policy

To send information about changes to the terms and conditions of use of the Site and to provide this Privacy Policy. 

Legal basis for processing: our legitimate interest in informing you well in advance of the entry into force of such changes.

d.Compliance with legal obligations

To comply with our legal obligations, orders from governmental authorities which may include orders from authorities outside your country of residence, when we reasonably believe that we are required to make such disclosures and when disclosure of your Personal Data is strictly necessary to comply with such legal obligations or governmental orders.

Legal basis for processing: compliance with our legal obligations.

e.Conducting market and satisfaction surveys as a result of the service provided

To carry out market and/or satisfaction surveys regarding the service provided by Up2You. These surveys will be used to provide statistical samples useful for improving the activities promoted by the Company. 

Legal basis of processing: our legitimate interest in collecting information about the quality of the intervention rendered for the purpose of improving Up2You's services. 

f.Data analysis to derive trends and improve the Up2You website

We collect Personal Data about you in order to analyse trends and consumption patterns. This helps us to improve and adapt our Site to the preferences identified by users and the services in general. 

Legal basis of processing: by staying and browsing on our Website, you allow us to improve our offer and make your experience more immediate and easier to use.

g.Knowing the preferences and tastes of users of the Up2You site

We collect Personal Data about you in order to learn more about the tastes and preferences of users of the Site, so that we can tailor our offers to the characteristics of visitors to the Site and our customers. 

Legal basis for processing: the prior explicit consent of the data subject to profiling.

h.Sending communications of a promotional nature

As part of our business, we may collect Personal Data about you in order to send you commercial communications aimed at promoting Up2You's services. 

Legal basis of the processing: the prior explicit consent of the person concerned to the marketing activities promoted by the Company.

We remind you that you always have the possibility to refuse to receive marketing communications even if you have already given your consent, simply by unsubscribing from the newsletter service or by notifying us by e-mail.

If you have already used our services, we may contact you by e-mail to provide you with information about similar activities and to keep you up to date with Company news.

Legal basis of processing: our legitimate interest in directly promoting Up2You's activities and services to our users.

You have the possibility to refuse this specific direct marketing treatment at any time by sending an e-mail and/or using the contact information listed in this Privacy Policy.

i.Using the PlaNet platform

We may process your Data to enable you to use the PlaNet platform and register to access the service, conduct missions and increase your points and ECOin. For the purpose of activating your profile, we may request the following personal information:

• First and last name of the user;
• E-mail address;
• Reference password.

In addition, in order to receive points and increase their ECOin, we will allow users to upload photographs of themselves in the context of the missions they have selected.

In the interests of account security, we ask you from now on to select 'strong' passwords with at least 8 characters, alphanumeric and the presence of symbols. 

With regard to the use of this service, we would like to point out that the Company will process the Personal Data of its users to ensure the operation of the platform and the registration of users. For this reason, Up2You acts as Data Processor and not as Data Controller.

Legal basis of processing: the service contract signed with the companies that decide to use Up2You's services.

j.Use the services from time to time on the Site

We may process your Data to enable you to use the services offered through the Company and presented on the Site from time to time. In order to activate certain services, we may ask you to provide us with information on the payment method you wish to use. We inform you that payments are handled by Stripe. For further information on how Stripe processes data, please refer to the privacy policy on the company's website.

For some of these processing operations, we would like to inform you at this stage that we may act as Data Processors and not directly as Controllers, depending on the relationship with our client companies and the services rendered.

Legal basis of processing: the service contract signed with the Company.

k.Allowing the user to submit a project

If you would like to contact us to present your project and would like to become part of Up2You's network of collaborators, please fill in the form on our website and provide the following information.

• E-mail address;
• first and last name;
• name of the reference company or association to which it belongs;
• reference site;
• project description.

Legal basis of processing: pre-contractual negotiations with a view to establishing a cooperation relationship.

l.Promoting the "Invite a Friend" service

In the event that you wish to make Up2You's services known to other contacts, you may provide us with certain information about the data subject. In this case, we may also have to process the Personal Data of a third party recipient of the service. 

Once the e-mail address of the selected contact has been provided, we will send a message to the recipient of the service, in order to inform them about our activities. 

We would also like to remind you that the use and communication of Personal Data of third parties is subject to privacy legislation and - for this reason - we would like to clarify that we will provide the recipient of the service with information on the processing of their personal data at the time of the first contact, in accordance with the provisions of Article 14 GDPR.

Legal basis of processing: we will process Personal Data exclusively to inform the recipient of the possibility of contacting Us and in order to provide him/her with information on the processing of his/her Personal Data.

m.Preventing fraud and abuse

We will use information about fraudulent or criminal activity relating to the use of our services for the purposes of detecting and preventing fraud or abuse.

Legal basis for processing: our legitimate interests in protecting our organisation from fraudulent activities.

n.Legal protection of our interests

To enforce our terms and conditions of business, to protect our business operations, to protect our rights, privacy, safety or property, and/or that of our affiliates, and to enable us to pursue available legal remedies or limit any damages we may sustain.

Legal basis for processing: our legitimate interests in protecting our organisation in accordance with the law. 

6. To whom are your Personal Data disclosed?

In addition to the staff duly authorised by Up2You to process the Personal Data of users who request our services, the information provided by the interested parties may be communicated to our business partners (see Table 1) and to suppliers for the maintenance of this Website.

These companies:

• may also be based outside Europe;
• will never directly use the Personal Data communicated by Up2You;
• will not sell the Personal Data disclosed by the Company to third parties.

By subscribing to the Services on the Site, you acknowledge that you allow the Company, through the analysis of the Data made by the service provider, to come into possession of the following information:

• number of times the mail has been opened for Up2You services;
• number of clicks on links contained in the e-mail sent;
• not opening e-mails relating to Up2You's services;
• dis-enrolment;
• complaints;
• possible use of the content of the e-mail via social media;
• number and value of individual user purchases.

The communication of the Data shall be carried out in full compliance with the legislation in force concerning guarantee clauses. 

If necessary, Personal Data may be transmitted to the competent public and judicial authorities in order to prevent fraud or unlawful acts.

7. What are your rights in relation to the processing of Personal Data, how can they be exercised?

The subjects to whom the Personal Data refer have the right at any time to obtain confirmation of the existence or otherwise of such Data and to know its content and origin, verify its accuracy or request its integration, updating, rectification (Articles 15 and 16 of the Regulation), and precisely:

• ¥Right of access. The right to obtain access to personal information about you along with certain related information;
• ¥Right to Data Portability. The right to receive personal information in a common format and to have it transferred to another data controller;
• ¥Right of rectification. The right to obtain rectification of Personal Data without undue delay if the Personal Data is inaccurate or incomplete;

Pursuant to Articles 17, 18 and 21 of the Regulation, you have the right to request the deletion, limitation of processing, transformation into anonymous form or blocking of Data processed in breach of the law, as well as to object in any case, for legitimate reasons, to their processing:

• ¥Right to erasure. The right to obtain the deletion of your Personal Data without undue delay in certain circumstances, such as if your Personal Data is no longer necessary in relation to the purposes for which it was collected or processed; 
• ¥Right to restriction of processing. The right to obtain, in specific circumstances identified by applicable law, a limitation of the processing of your Data for a specified period of time, for example when you contest the accuracy of Personal Data, for the time to verify the accuracy and correctness of such Data.
• ¥Right to object. The right to object, on grounds relating to your particular situation, to the processing of Personal Data, and to object to the processing of Personal Data for direct marketing purposes, insofar as this is related to such direct marketing.

As a data subject, you also have the right to withdraw your consent at any time, without prejudice to the validity of the processing carried out prior to the withdrawal. 

The rights may be exercised by contacting the Data Controller and/or the Data Protection Officer at the following addresses:

• e-mail: privacy@u2y.io
• by mail, c/o Via Orseolo 12, 20144, Milan (MI)

8. How long do we keep Personal Data?

We intend to keep your Personal Data for as long as you have not requested deletion. Up2You undertakes, in accordance with the terms of service set out on our Site, to keep the Data entered by you and to make it available to you for processing through the tools offered by our services.

• Up2You reserves the right to retain anonymised or aggregated customer information for statistical use to improve the services provided on the basis of a legitimate interest. 

What transfers can we make?

We may disclose some of your personal data and information to our partners and suppliers for activities related to the use of the services offered through the Site. For some of the processing operations mentioned above, we may use providers and suppliers located outside the territory of the European Union. In these circumstances, we assure you that the transfer of Data outside the EU will be carried out in compliance with the applicable legal provisions by entering into, if necessary, agreements that guarantee an adequate level of protection and/or by adopting the standard contractual clauses provided by the European Commission. 

9. How do we protect your Personal Data?

Information security is very important to us, and we have put in place safeguards to preserve the integrity and security of the information we collect and share with our Site suppliers.

However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a security breach, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other action, in accordance with applicable laws and regulations.

10. Cancellation of services 

To stop receiving information from Up2You or to cancel your registration on the Website, you must send an e-mail to: privacy@u2y.io.

11. Applicable law 

This Privacy Policy is governed by and will be interpreted in accordance with the provisions of and any other mandatory legislation applicable in the European Union. 

12. Complaint to the Supervisory Authority  

The data subject has the possibility to lodge a complaint with the Italian Data Protection Authority, which can be contacted at https://www.garanteprivacy.it/.

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Tab. 1 - LIST OF OUR BUSINESS PARTNERS 

Up2You's business partners are defined as:

Commercial Partners

• Companies and/or professionals involved in the provision of IT services, including hosting companies, for Up2You;
• Companies that provide newsletter services on behalf of Up2You, where consent has been given;
• Companies and/or professionals involved in providing marketing & sales services for Up2You;
• Companies and/or professionals involved in customer support for Up2You 
• Auditing company.
  

Tab 2 - TRACKING TECHNOLOGIES