PRIVACY POLICY OF HARMOONIA
Legal information This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).
This privacy policy relates solely to this Application, if not stated otherwise within this document. Latest update: May 25, 2018.
This Application collects some Personal Data from its Users.
Policy summary
Personal Data collected for the following purposes and using the following services:
Access
to third-party accounts Facebook account access Permissions: About Me,
Access
Friend Lists, Activities, App Notifications, Birthday, Contact email, Friends’
Likes, Interests, Likes and List of Friends
Contacting the User
Mailing List or NewsletterPersonal Data: email address
Displaying content from external platforms
YouTube video widget, Google Maps widget and Instagram widgetPersonal Data:
Cookies and Usage Data
Location-based interactions
Geolocation and Non-continuous geolocationPersonal Data: geographic
position
Registration and authentication
Direct registrationPersonal Data: email address, first name, last name,
password, phone number and username Instagram Authentication, Google OAuth,
Linkedin OAuth, MailChimp OAuth, OneDrive OAuth, GitHub OAuth, Twitter OAuth
and YouTube OAuthPersonal Data: various types of Data as specified in the
privacy policy of the service
Social features
Inviting and suggesting friendsPersonal Data: Various types of Data
Further information about Personal Data
Access the address book
This
Application may request access to your address book.
Contact information
Owner and Data Controller LINK
CAMPUS UNIVERSITY Owner contact email: info@harmoonia.it
Full policy
Owner
and Data Controller
LINK CAMPUS UNIVERSITY
Owner contact email: info@harmoonia.it
Types
of Data collected
Among the types of Personal Data that this Application collects, by itself or
through third parties, there are: first name, last name, phone number,
username, email address, password, geographic position, Cookies, Usage Data and
Various types of Data.
Complete details on each type of Personal Data collected are provided in the
dedicated sections of this privacy policy or by specific explanation texts
displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data,
collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory
and failure to provide this Data may make it impossible for this Application to
provide its services. In cases where this Application specifically states that
some Data is not mandatory, Users are free not to communicate this Data without
consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to
contact the Owner. Any use of Cookies or of other tracking tools by this
Application or by the owners of third-party services used by this Application
serves the purpose of providing the Service required by the User, in addition
to any other purposes described in the present document and in the Cookie
Policy, if available.
Users are responsible for any third-party Personal Data obtained, published or
shared through this Application and confirm that they have the third party’s
consent to provide the Data to the Owner.
Mode and place of processing the Data
Methods
of processing
The Owner takes appropriate security measures to prevent unauthorized access,
disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools,
following organizational procedures
and modes strictly related to the purposes indicated.
In addition to the Owner, in some cases, the Data may be accessible to certain
types of persons in charge, involved with the operation
of this Application (administration, sales, marketing, legal, system
administration) or external parties
(such as third-party technical service providers, mail carriers, hosting
providers, IT companies, communications agencies) appointed,
if necessary, as Data Processors by the Owner. The updated list of these
parties may be requested from the Owner at any time.
Legal basis of processing
The
Owner may process Personal Data relating to Users if one of the following
applies:
Users have given their consent for one or more specific purposes. Note: Under
some legislations the Owner may be allowed to process Personal Data until
the
User objects to such processing (opt-out), without having to rely on consent or
any other of the following legal bases.
This, however, does not apply, whenever the processing of Personal Data is
subject to European data protection law;
provision of Data is necessary for the performance of an agreement with the
User and/or for any pre-contractual obligations thereof;
processing is necessary for compliance with a legal obligation to which the
Owner is subject;
processing is related to a task that is carried out in the public interest or
in the exercise of official authority vested in the Owner;
processing is necessary for the purposes of the legitimate interests pursued by
the Owner or by a third party. In any case, the Owner will gladly help to
clarify the specific legal basis that applies to the processing, and in
particular whether the provision of Personal Data is a statutory or contractual
requirement, or a requirement necessary to enter into a contract.
Place
The
Data is processed at the Owner’s operating offices and in any other places
where the parties involved in the processing are located.
Depending on the User’s location, data transfers may involve transferring the
User’s Data to a country other than their own.
To find out more about the place of processing of such transferred Data, Users
can check the section containing details about the processing of Personal
Data.
Users are also entitled to learn about the legal basis of Data transfers to a
country outside the European Union or to any international organization
governed
by public international law or set up by two or more countries, such as the UN,
and about the security measures taken by the Owner to safeguard their
Data.
If any such transfer takes place, Users can find out more by checking
the relevant sections of this document or inquire with the Owner using the
information provided in the contact section.
Retention time
Personal
Data shall be processed and stored for as long as required by the purpose they
have been collected for. Therefore:
Personal Data collected for purposes related to the performance of a contract
between the Owner and the User shall be retained until such contract has been
fully performed.
Personal Data collected for the purposes of the Owner’s legitimate
interests shall be retained as long as needed to fulfill such purposes. Users
may find specific information regarding the legitimate interests pursued by the
Owner within the relevant sections of this document or by contacting the
Owner.
The Owner may be allowed to retain Personal Data for a longer period
whenever the User has given consent to such processing, as long as such consent
is not withdrawn. Furthermore,
the Owner may be obliged to retain Personal Data for a longer period whenever
required to do so for the performance of a legal obligation or upon order of an
authority.
Once the retention period expires, Personal Data shall be deleted. Therefore,
the right to access, the right to erasure, the right to rectification and the
right to data portability cannot be enforced after expiration of the retention
period.
The purposes of processing
The
Data concerning the User is collected to allow the Owner to provide its
Services, as well as for the following purposes:
Registration and authentication, Contacting the User, Location-based
interactions, Displaying content from external platforms,
Social features and Access to third-party accounts. Users can find further
detailed information about such purposes of processing and
about the specific Personal Data used for each purpose in the respective
sections of this document.
Facebook permissions asked by this Application
This
Application may ask for some Facebook permissions allowing it to perform
actions with the User’s Facebook account and to retrieve information, including
Personal Data, from it.
This service allows this Application to connect with the User’s account on the
Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook
permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
Basic information
By default, this includes certain User’s Data such as id, name, picture,
gender, and their locale.
Certain connections of the User, such as the Friends, are also available. If
the User has made more of their Data public, more information will be
available.
About Me
Provides access to the ‘About Me’ section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Activities
Provides access to the User’s list of activities.
App Notifications
Send notifications.
Birthday
Provides access to the birthday.
Contact email
Access the User’s contact email address.
Friends’ Likes
Provides access to the list of all of the pages the friends have liked.
Interests
Provides access to the User’s list of interests.
Likes
Provides access to the list of all of the pages the User has liked.
List of Friends
Detailed information on the processing of Personal Data
Personal
Data is collected for the following purposes and using the following
services:
Access to third-party accountsThis type of service allows this Application to
access Data from your account on a third-party service and perform actions with
it.
These services are not activated automatically, but require explicit
authorization by the User.Facebook account access (this Application) This
service allows this Application to connect with the User’s account on the
Facebook social network, provided by Facebook, Inc. Permissions asked: About
Me, Access Friend Lists, Activities, App Notifications, Birthday, Contact
email, Friends’ Likes, Interests, Likes and List of Friends. Place of
processing: US Privacy Policy.
Contacting the UserMailing List or Newsletter (This Application) By registering
on the mailing list or for the newsletter, the User’s email address will be
added to the contact list of those who may receive email messages containing
information of commercial or promotional nature concerning this Application. Your
email address might also be added to this list as a result of signing up to
this Application or after making a purchase. Personal Data collected: email
address.
Displaying content from external platforms This type of services allows you to
view content hosted on external platforms directly from the pages of this
Application and interact with them.
This type of service might still collect web traffic data for the pages where
the service is installed, even when Users do not use it.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that
allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US Privacy Policy.
Google Maps widget (Google Inc.) Google Maps is a maps visualization service
provided by Google Inc. that allows this Application to incorporate content of
this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US Privacy Policy.
Instagram widget (Instagram, Inc.) Instagram is an image visualization service
provided by Instagram, Inc. that allows this Application to incorporate content
of this kind on its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: US Privacy Policy.
Location-based interactionsGeolocation (This Application)
This Application may collect, use, and share User location Data in order to
provide location-based services. Most browsers and devices provide tools to opt
out from this feature by default. If explicit authorization has been provided,
the User’s location data may be tracked by this Application.
Personal Data collected: geographic position.
Non-continuous geolocation (This Application)
This Application may collect, use, and share User location Data in order to
provide location-based services. Most browsers and devices provide tools to opt
out from this feature by default. If explicit authorization has been provided,
the User’s location data may be tracked by this Application.
The geographic location of the User is determined in a manner that isn’t
continuous, either at the specific request of the User or when the User doesn’t
point out its current location in the appropriate field and allows the
application to detect the position automatically.
Personal Data collected: geographic position.
Registration and authentication
By registering or authenticating, Users allow this Application to identify them
and give them access to dedicated services.
Depending on what is described below, third parties may provide registration
and authentication services. In this case, this Application will be able to
access some Data, stored by these third party services, for registration or
identification purposes.
Direct registration (This Application) The User registers by filling out the
registration form and providing the Personal Data directly to this
Application.
Personal Data collected: email address, first name, last name, password, phone
number and username. Instagram Authentication (Instagram, Inc.) Instagram
Authentication is a registration and authentication service provided by
Instagram, Inc. and is connected to the Instagram social network.
Personal Data collected: various types of Data as specified in the privacy policy
of the service. Place of processing: US Privacy Policy.
Google OAuth (Google Inc.) Google OAuth is a registration and authentication
service provided by Google Inc. and is connected to the Google network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service. Place of processing: US Privacy Policy.
Linkedin OAuth (LinkedIn Corporation)
Linkedin Oauth is a registration and
authentication service provided by Linkedin Corporation and is connected to the
Linkedin social network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service. Place of processing: US Privacy Policy.
MailChimp OAuth (The Rocket Science Group, LLC.) MailChimp OAuth is a
registration and authentication service provided by The Rocket Science Group,
LLC and is connected to the MailChimp service.
Personal Data collected: various types of Data as specified in the privacy
policy of the service.
Place of processing: US Privacy Policy. OneDrive OAuth (Microsoft
Corporation)OneDrive OAuth is a registration and authentication service
provided by Microsoft Corporation and is connected to the OneDrive
network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service.
Place of processing: US Privacy Policy. GitHub OAuth (GitHub Inc.) GitHub OAuth
is a registration and authentication service provided by GitHub Inc. and is
connected to the GitHub network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service.
Place of processing: US Privacy Policy. Twitter OAuth (Twitter, Inc.) Twitter
Oauth is a registration and authentication service provided by Twitter, Inc.
and is connected to the Twitter social network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service.
Place of processing: US Privacy Policy. YouTube OAuth (Google Inc.) YouTube
OAuth is a registration and authentication service provided by Google Inc. and
is connected to the YouTube network.
Personal Data collected: various types of Data as specified in the privacy
policy of the service.
Place of processing: US Privacy Policy.
Social features, Inviting and suggesting friends (This Application) This
Application may use the Personal Data provided to allow Users to invite their
friends – for example through the address book, if access has been provided –
and to suggest friends or connections inside it.
Personal Data collected: Various types of Data.
Further information about Personal Data
Access the address book, This Application may request access to your address book.
The rights of Users
Users
may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following:
Withdraw their consent at any time. Users have the right to withdraw consent
where they have previously given their consent to the processing of their
Personal Data.
Object to processing of their Data. Users have the right to object to the
processing of their Data if the processing is carried out on a legal basis
other than consent. Further details are provided in the dedicated section
below. Access their Data. Users have the right to learn if Data is being
processed by the Owner,
obtain disclosure regarding certain aspects of the processing and obtain a copy
of the Data undergoing processing.
Verify and seek rectification. Users have the right to verify the accuracy of
their Data and ask for it to be updated or corrected.
Restrict the processing of their Data. Users have the right, under certain
circumstances, to restrict the processing of their Data. In this case, the
Owner
will not process their Data for any purpose other than storing it. Have their
Personal Data deleted or otherwise removed. Users have the right, under certain
circumstances, to obtain the erasure of their Data from the Owner.
Receive their Data and have it transferred to another controller. Users have
the right to receive their Data in a structured, commonly used and machine
readable format and, if technically feasible, to have it transmitted to another
controller without any hindrance. This provision is applicable provided that
the Data is processed by automated means and that the processing is based on
the User’s consent, on a contract which the User is part of or on
pre-contractual obligations thereof.
Lodge a complaint. Users have the right to bring a claim before their competent
data protection authority.
Details about the right to object to processing
Where
Personal Data is processed for a public interest, in the exercise of an
official authority vested in the Owner or for the purposes of the legitimate
interests pursued by the Owner, Users may object to such processing by
providing a ground related to their particular situation to justify the
objection.
Users must know that, however, should their Personal Data be processed for
direct marketing purposes, they can object to that processing at any time
without providing any justification. To learn, whether the Owner is processing Personal
Data for direct marketing purposes, Users may refer to the relevant sections of
this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the
contact details provided in this document. These requests can be exercised free
of charge and will be addressed by the Owner as early as possible and always
within one month.
Additional information about Data collection and processing
Legal
action
The User’s Personal Data may be used for legal purposes by the Owner in Court
or in the stages leading to possible legal action arising from improper use of
this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal
data upon request of public authorities. Additional information about User’s
Personal Data
In addition to the information contained in this privacy policy, this
Application may provide the User with additional and contextual information
concerning particular Services or the collection and processing of Personal
Data upon request. System logs and maintenance
For operation and maintenance purposes, this Application and any third-party
services may collect files that record interaction with this Application
(System logs) use other Personal Data (such as the IP Address) for this
purpose. Information not contained in this policy
More details concerning the collection or processing of Personal Data may be
requested from the Owner at any time. Please see the contact information at the
beginning of this document.
How “Do Not Track” requests are handled
This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do
Not Track” requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time
by giving notice to its Users on this page and possibly within this Application
and/or – as far as technically and legally feasible – sending a notice to Users
via any contact information available to the Owner. It is strongly recommended
to check this page often, referring to the date of the last modification listed
at the bottom.
Should the changes affect processing activities performed on the basis of the
User’s consent, the Owner shall collect new consent from the User, where
required.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other
information,including a personal identification number, allows for the
identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party
services employed in this Application), which can include: the IP addresses or
domain names of the computers utilized by the Users who use this Application,
the URI addresses (Uniform Resource Identifier), the time of the request, the
method utilized to submit the request to the server, the size of the file received
in response, the numerical code indicating the status of the server’s answer
(successful outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilized by the User, the various time details
per visit (e.g., the time spent on each page within the Application) and the
details about the path followed within the Application with special reference
to the sequence of pages visited, and other parameters about the device
operating system and/or the User’s IT environment.
User
The individual using this Application who, unless otherwise specified,
coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural or legal person, public authority, agency or other body which
processes Personal Data on behalf of the Controller, as described in this
privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which,
alone or jointly with others, determines the purposes and means of the
processing of Personal Data, including the security measures concerning the
operation and use of this Application. The Data Controller, unless otherwise
specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and
processed.
Service
The service provided by this Application as described in the relative terms (if
available) and on this site/application. European Union (or EU)
Unless otherwise specified, all references made within this document to the
European Union include all current member states to the European Union and the
European Economic Area.
Cookies
Small piece of data stored in the User’s device.