Data Controller

MDP Srl, Piazza Carlo Mirabello 1, 20121, Milano.

Holder’s e-mail address:¬†info@mdpstudio.com

Types of Data Collected

Among the Personal Data collected by this Application, either independently or through third parties, are: email; Cookies; Usage Data; geographic location; first name; last name; gender; date of birth; address; nation; state; province; postal code.

Full details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of such data.
Personal Data may be freely provided by the User or, in the case of Usage Data, automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. If the User refuses to provide them, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users in doubt about which Data are mandatory are encouraged to contact the Data Controller.
The possible use of Cookies – or other tracking tools – by this Application or the owners of third party services used by this Application, where not otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and warrants that he or she has the right to communicate or disseminate it, releasing the Owner from any liability to third parties.

How and where the collected Data is processed

Mode of treatment

The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out by means of computer and/or telematic tools, with organizational methods and logics strictly related to the indicated purposes. In addition to the Data Controller, in some cases, other parties involved in the organization of this Application (administrative, sales, marketing, legal, system administrators) or external parties (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis of the processing

The Owner processes Personal Data related to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the need for the User’s consent or another of the legal bases specified below, as long as the User does not object (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • processing is necessary for the performance of a contract with the User and/or the execution of pre-contractual measures;
  • processing is necessary to fulfill a legal obligation to which the Controller is subject;
  • the processing is necessary for the performance of a task of public interest or the exercise of public authority vested in the Controller;
  • processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each processing and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the Holder’s operational offices and at any other location where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the country in which the User is located. To obtain more information about the location of the processing, the User may refer to the section on Personal Data processing details.

The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Data Controller to protect the Data.

The User may verify whether any of the transfers just described takes place by reviewing the section of this document on details of the processing of Personal Data or request information from the Controller by contacting it at the contact details given at the beginning.

Storage period

Data are processed and kept for the time required by the purposes for which they were collected.

Therefore:

  • Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
  • Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest pursued by the Controller in the relevant sections of this document or by contacting the Controller.

When processing is based on the User’s consent, the Controller may retain Personal Data longer until that consent is revoked. In addition, the Controller may be required to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, at the expiration of this period the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Processing of Collected Data

User Data is collected to enable the Data Controller to provide the Service, comply with legal obligations, respond to requests or enforcement actions, protect its rights and interests (or those of Users or third parties), detect any malicious or fraudulent activities, as well as for the following purposes: SPAM protection, Address management and emailing, Advertising, Traffic optimization and distribution, Content commentary, Location-based interactions, Statistics, Displaying content from external platforms, Contacting the User, Interaction with social networks and external platforms, and Remarketing and behavioral targeting.

To obtain detailed information on the purposes of processing and the Personal Data processed for each purpose, the User may refer to the section “Detailed Information on the Processing of Personal Data.”

Details of the processing of Personal Data

Personal Data are collected for the following purposes and using the following services:

  • Content commentary
  • Contacting the User
  • Managing addresses and sending email messages
  • Interaction with social networks and external platforms
  • Location-based interactions
  • Traffic optimization and distribution
  • SPAM protection
  • Marketing
  • Remarketing e behavioral targeting
  • Statistics
  • Displaying content from external platforms

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.

In particular, the User has the right to:

  • Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his/her Personal Data.
  • Object to the processing of their Data. You may object to the processing of your Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
  • Access to your Data. You have the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request correction. Users may verify the accuracy of their Data and request that it be updated or corrected.
  • Obtain restriction of processing. When certain conditions are met, the User may request the restriction of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
  • Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data by the Data Controller.
  • Receive their Data or have their Data transferred to another owner. The User has the right to receive his or her Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User’s consent, a contract to which the User is a party or contractual measures related thereto.
  • propose complaint. The User may bring a complaint to the relevant data protection supervisory authority or take legal action.

Details of the right to object

When Personal Data are processed in the public interest, in the exercise of public powers vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are advised that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

To exercise the User’s rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Holder as soon as possible, in any case within one month.

More information about the treatment

Litigation defense

The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of its possible establishment for the defense against abuses in the use of this Application or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific Disclosures

Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual disclosures regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e., files that record interactions and may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Application does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is encouraged to consult their respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application as well as, if technically and legally feasible, by sending a notification to Users through one of the contact details it has. Therefore, please consult this page frequently, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Controller will collect the User’s consent again, if necessary.