Privacy Policy of ​Covid Tracker 19

This Application collects some Personal Data from its Users.

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Policy summary
Personal Data collected for the following purposes and using the following
services:
○ Displaying content from external platforms

Full policy
Owner and Data Controller
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there
are: Usage 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 Service, comply with its legal
obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third
parties), detect any malicious or fraudulent activity, as well as the following: Displaying content from
external platforms.

For specific information about the Personal Data used for each purpose, the User may refer to the section
“Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

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

● Displaying content from external platforms

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 notifying 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

Latest update: November 24, 2020