PRIVACY POLICY OF “EFFETTO VIOLA”

This Privacy Policy governs the processing of personal data (“Data” or “Personal Data”) of users (“Users”) who use the mobile application called “Effetto VIOLA” (the “App” or the “Service”). Please read it carefully to understand how we collect, use, and protect your Data.

1. DATA CONTROLLER

Effetto Viola S.r.l.
Via Bocca di Lupo 6, 4 – 40123 Bologna (IT)
Email: info@effettoviola.it

The Controller ensures compliance with applicable data protection laws, including Regulation (EU) 2016/679 (“GDPR”), Legislative Decree 196/2003 as amended, and other local/international regulations (e.g., CCPA in California).

2. DEFINITIONS

  • Personal Data: any information that, directly or indirectly, identifies or makes an individual identifiable.
  • Processing: any operation performed on Personal Data (collection, consultation, use, communication, deletion, etc.).
  • User: the individual who uses the App.
  • Third-Party Services: services, platforms, SDKs, or infrastructures by external providers (Google Cloud, Firebase, Meta SDK, etc.) integrated by the Controller to ensure proper App functionality.

3. TYPES OF DATA COLLECTED

3.1 Data Provided by the User

  • Basic Information (gender and age): Upon first use, the App asks whether the User is male/female and if they are older or younger than 30. This is used mainly for displaying relevant ads and improving the user experience.
  • Contact Data and Token (only for purchases via effettoviola.eu): If purchased through effettoviola.eu, the App may receive a JWT token (email included) stored in Firebase to manage premium content access.

3.2 Browsing and Usage Data

  • Technical Data: Automatically collected info (IP address, device type, OS version, language, etc.).
  • Approximate Location: Used to set language/currency and improve content relevance.
  • Interactions & Statistics: Collected via Firebase Analytics, Google Analytics, Meta SDK, mostly aggregated/pseudonymized.

3.3 Advertising Data

The App displays personalized ads based on the provided info (gender, age group) or usage data.

3.4 Data Collected via Support Email

By emailing info@effettoviola.it, the User voluntarily provides their address and any necessary info to resolve the request.

3.5 Data Collected by External Stores

In-app purchases are managed independently by Apple (App Store) or Google (Google Play). The App does not handle payment data.

Note: The App does not intentionally collect sensitive data (health, political opinions, religion, biometrics, etc.). If provided inadvertently, the Controller will take steps to remove it.

4. PURPOSES AND LEGAL BASIS OF PROCESSING

  1. Service Provision: Allow access to music content, manage ads. Legal basis: contract performance (Art. 6(1)(b) GDPR) and/or legitimate interest (Art. 6(1)(f) GDPR).
  2. Personalization & Marketing: Ads based on gender, age, usage data. Legal basis: legitimate interest and/or consent.
  3. Analysis & Improvement: Statistical data (Google Analytics, Firebase, Meta SDK) to optimize the user experience. Legal basis: legitimate interest or consent when required.
  4. Premium Content Management: Verify access for purchases made on effettoviola.eu. Legal basis: contract performance.
  5. Support & Communications: Respond to requests, questions. Legal basis: contract performance.

5. THIRD-PARTY SERVICES

The App uses external services (Google Cloud, Firebase, Meta SDK, Google Analytics, FlutterFlow, Git, etc.) to provide or improve functionalities, ensuring appropriate privacy safeguards. Apple/Google handle in-app purchases as independent controllers.

6. METHODS OF PROCESSING & SECURITY MEASURES

Processing is carried out with IT/telematic means, with adequate security measures (encryption, secure protocols, etc.). Data is stored on Google Cloud, Firebase, and certified infrastructures.

7. DATA RETENTION

  • Usage Data: Retained for up to 12 months from last interaction.
  • JWT Token: Retained as long as subscription/purchase is valid, then deleted or anonymized within 12 months.
  • Support Email Data: Retained for the time needed to handle the request and for any administrative/legal purposes.

8. DATA RECIPIENTS

  • Processors: Service providers (hosting, analytics) under specific DPAs.
  • Independent Controllers: Apple/Google for payments, other payment platforms if applicable.
  • Legal Obligations: Data may be disclosed to Authorities if required by law.

9. AGE LIMITS

No formal age limit is imposed. If a minor under 13/16 accesses from a jurisdiction requiring parental consent, it is the guardian’s responsibility. The Controller does not knowingly collect data from minors without authorization.

10. POLICIES FOR CALIFORNIA (CCPA) OR OTHER JURISDICTIONS

If you reside in California (or a similar jurisdiction) and local law applies, you may have additional rights (access, deletion, opt-out of “sale” of data). To exercise them, contact: info@effettoviola.it.

11. DATA BREACH PROCEDURES

In case of high-risk data breaches, authorities and affected Users will be informed, as required by law.

12. USER RIGHTS

  • Access, Rectification, Erasure, Restriction, Objection, Portability, Withdraw Consent.

You can exercise these rights by emailing: info@effettoviola.it. You also have the right to file a complaint with the competent Data Protection Authority.

13. PUSH NOTIFICATIONS & COMMUNICATIONS

The App sends push notifications about new features, music tracks, etc. You can disable them in your device settings.

14. TECHNOLOGIES SIMILAR TO COOKIES

The App may use local storage, app state, unique identifiers, or similar technologies for pseudonymized tracking. You may limit these in your device settings or opt-out mechanisms.

15. UPDATES & CHANGES

The Controller reserves the right to update this Policy at any time, informing Users through available means (push notifications, in-App notices, emails).

16. CONTACTS

Effetto Viola S.r.l.
Via Bocca di Lupo 6, 4 – 40123 Bologna (IT)
Email: info@effettoviola.it

Last updated: January 4, 2025

This Privacy Policy is drafted in accordance with the GDPR, Legislative Decree 196/2003 as amended, and local regulations (e.g. CCPA).