Protection of personal data

Dear User, we hereby inform you that Leg. Decree no. 196 of June 30, 2003 ("Civil Code regarding the protection of personal data", hereinafter "Code") and subsequent integrations and amendments, stipulates that the processing of personal data is performed in compliance with the rights and fundamental freedom, as well as the dignity of the parties concerned, with particular reference to the privacy, personal identity and the right to protect personal data.

The processing of your personal data by LINKS MANAGEMENT AND TECHNOLOGY S.p.A., with registered offices in Lecce, Via Rocco Scotellaro, no. 55 - Italy, Tax code and VAT number 03351210756 (hereinafter "LINKS", "Owner" or "Company"), as Owner of the data processing, will be carried out in compliance with the Code and will be processed accurately, lawfully and transparently, and shall protect your privacy and other rights.

Relatively to the app, we wish to inform that, when you install and/or upgrade the same app, personal data you have provided will be treated exclusively by the Store to which you have provided consent. LINKS will keep only technical data (such as, for example, operating system type and version or device type and model) that, in no case, make the user identifiable. The collection of such technical data is only intended to the provision of a better technical support.

With reference to your personal data that you might provide during registration and service use, the purpose of this disclosure is to allow you to understand how LINKS will process that data, before giving consent for your data to be processed. In accordance with article 13 of the Code, therefore, the following information is provided:

1. Purpose of processing: The data you provide will be processed:

A) for purposes directly connected and instrumental to providing and managing the Service;

B) subject to your prior consent, to bring information of a commercial and/or marketing nature to your attention, send advertising material about new products and services; carry out market research;

C) subject to your prior consent, to assess the quality of the Service and the level of user satisfaction through interviews carried out both directly and in partnership with specialised companies;

D) subject to your prior consent, to carry out statistical surveys.

2. Method of processing: The processing will be mainly carried out using IT/telematic tools or, if required, manually, adopting all the necessary precautions and care to avoid improper use or undue dissemination of the data. A hard copy and electronic copy of the personal data will be kept for the purposes indicated in paragraph 1 point A), and subject to your prior consent, points B), C) and D).

3. Type of data and mandatory nature of data conferment: Conferment of your data is optional, however, refusing to provide this data will result in the inability to provide the Service.

4. Recipients of the data: The personal data in question may be disclosed to employees or associates of the offices of the Owner who, working under the direct authority of the latter, are appointed responsible for or in charge of the processing under Articles 29 and 30 of the Code, and will receive appropriate operating instructions thereby. The same will apply to the employees and associates of the above-mentioned responsible parties -  under the responsibility of the persons in charge appointed by the Owner.

5. Data owner: The data owner is LINKS MANAGEMENT AND TECHNOLOGY S.p.A., with registered offices in Lecce, Via Rocco Scotellaro, no. 55 – Italy.

6. Data controller: the data controller is Mr. Giancarlo NEGRO, as the Sole Administrator and legal representative of the Company.

7. Scope of communication or disclosure of the Users' personal data: Some data may be communicated by LINKS, for the purposes previously indicated in paragraph 1, to third parties appointed to execute activities directly linked and instrumental to providing and supplying the Service.

8. Right to access personal data and other rights under Article 7 of Leg. Decree 196/2003: You may, at any time, exercise your rights under Article 7 of the Code which is quoted in full as follows: "Art. 7 – Right to access personal data and other rights. 1. The interested party has the right to obtain confirmation of the existence of personal data concerning him/her, even if not yet recorded, and its communication in an intelligible form. 2. The interested party shall have the right to be informed: a) of the origin of the personal data; b) of the purpose and manner of its processing; c) of the logic applied to the processing, if the latter is carried out by electronic means; d) of the identity of the organization and person responsible for handling personal data pursuant to Article 5, paragraph 2; e) of the parties or categories of parties to whom the personal data may be communicated or who may come into possession of it as the designated representative within the country, as persons responsible or in charge. 3. The interested party has the right to obtain: a) updates, corrections or, when interested, integration of the data; b) deletion, transformation into anonymous form or blocking of data processed in violation of the law, including any data not required to be kept for the purpose for which it was collected or subsequently used; c) confirmation that the operations described in points a) and b) have been brought to the attention, also as regards their content, of those to whom the data has been communicated or disclosed, unless compliance with this obligation is impossible or necessitates the use of means clearly disproportionate to the right being safeguarded. 4. The interested party may refuse, wholly or in part: a) for legitimate reasons to allow processing of his/her personal data, even if pertinent to the purpose for which it was collected; b) to allow the processing of his/her personal data for the purpose of sending material  for advertising or direct sales or, carrying out market research or commercial communication".

9. Method of exercising the rights under Article 7 of the Code: The user may, at any time, exercise the rights under Article 7 of the Code by sending an email to the following email address:, or a letter, by standard post, to the Owner of the personal data processing.