TAC Privacy Policy

TOUCH AND CONTACT S.R.L. hereinafter for brevity also "TAC", with registered office in 000131 - ROME, Via Adriano Olivetti n.24, Tax Code and VAT No. 153721210020 is the Data Controller (hereinafter: "TAC" or "Controller") pursuant to EU Regulation 679/2016 (hereinafter: "Regulation") and Legislative Decree 196/2003 and subsequent amendments (hereinafter: "Privacy Code") and considers privacy and the protection of your personal data one of the main objectives of its activity. We invite you, therefore, to read carefully this Privacy Policy because it contains important information on the protection of your personal data.

This privacy policy (hereinafter "Policy") relates exclusively to the processing of data communicated by the user or otherwise obtained as a result of the use of the App. In particular, our users following registration will be able to share their professional identity, interact with each other, exchange knowledge and professional information, as well as share documents, manage meetings and events.

ART. 1 - Data Controller and Data Protection Officer

The Data Controller, i.e. the subject who establishes the methods and the purposes of processing your personal data, is TOUCH AND CONTACT S.R.L., with registered office in 000131 - ROME, Via Adriano Olivetti n.24, Tax code and VAT number 153721210020. The Data Controller is available for any information concerning the processing of your personal data at the following address: support@touchandcontact.com.

TOUCH AND CONTACT S.R.L has designated DPPRO SRLS, Via Schiavonetti 270, 00173 Rome, VAT number 15306501006 as Data Protection Officer (DPO). The DPO can be contacted at the following email address dpo@touchandcontact.com.

ART. 2 - Categories of processed data, purpose of processing and nature of the data conferment

The personal data processed are the following:

1. Navigation data: The computer systems and software procedures used to operate the App, acquire during their normal operation some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified interested parties, but by their very nature could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users who connect to the App, URI (Uniform Resource Identifier) addresses of the resources requested, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters relating to the operating system and the user's computer environment. These data are used only to obtain anonymous statistical information on the use of the App to check its correct functioning, to identify anomalies and/or abuses, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the App or third parties. Will also be collected data relating to PC - Phone - Tablet - or other device used for navigation. This treatment is based on art. 6, par. 1, lett. b, of the Regulation as the treatment is necessary for the execution of a contract to which the person concerned is a party or the execution of pre-contractual measures taken at the request of the same. The conferment of personal data for these purposes is optional, but any failure to do so would make it impossible to activate or provide the services requested by the user.
2. Data provided voluntarily by the user: personal data provided voluntarily by the user to: - continue registration: to create an account, the user must provide certain data, including first name, last name, email address and/or cell phone number and a password - create a professional profile: the information related to the professional profile may include academic background, work experience, skills, photo, city or area of work; - creating meetings and events: through the synchronization of users' contacts or calendars with the Cloud Services offered by the Application, data from the address book and information on scheduled meetings will be collected to allow suggestions of connections with other users, organize meetings and/or events between participants and contacts. - profile/contact sharing with third parties: Users will be able to communicate and share the professional profiles also of other Users to non-registered third parties. These data will be processed to (i) recognize the user during the login phase; (ii) provide the user with the requested services and allow him to manage the services he uses; (iii) to provide the user with useful information on the use and optimization of the service. The processing of these personal data is necessary for the purpose of providing the requested services. This processing is based on art. 6, par. 1, lett. b, of the Regulation, as the processing is necessary for the execution of a contract to which the interested party is a party or the execution of pre-contractual measures taken at the request of the same. The provision of personal data for these purposes is optional, but failure to do so would make it impossible to activate or provide the services requested by the user.
3. Data provided by third parties: this hypothesis may occur: - when others request and purchase Services related to the Application so that a third party can use them, for example, employer companies provide personal data on employees. In this case the suitability and legitimacy of the use of the personal data of the employees will be the exclusive responsibility of the employer who will have to obtain prior authorization from their employees and/or collaborators; - when sending, receiving or interacting with messages related to the services of our App, as through the use of certain features information is collected on users, such as requesting a connection or sending reminders about events and/or meetings. These data will be processed in order to (i) recognize the user during the login phase; (ii) provide the user with the requested services and allow him/her to manage the services he/she uses; (iii) to provide the user with useful information on the use and optimization of the service. The processing of these personal data is necessary for the purpose of providing the requested services. This processing is based on art. 6, par. 1, lett. b, of the Regulation, as the processing is necessary for the execution of a contract to which the interested party is a party or the execution of pre-contractual measures taken at the request of the same. The provision of personal data for these purposes is optional, but failure to provide such data would make it impossible to activate or provide the services requested by the user.
4. User Location Data: information about your location is collected as a result of your use of the Services offered, in order to provide additional functionality such as knowing the proximity of other users. Location may be determined with varying degrees of accuracy, through: GPS functions, IP Address, data from your device's sensors, Information about what is in the vicinity of your device, such as Wi-Fi access points and cell phone signal towers, as well as Bluetooth-equipped devices. The types of location data collected also depend on your device and account settings. This data will be processed in order to (i) recognize the user during the login phase; (ii) provide the user with the requested services and allow him/her to manage the services he/she uses; (iii) to provide the user with useful information on the use and optimization of the service. The processing of this personal data is necessary for the purpose of providing the requested services. This processing is based on art. 6, par. 1, lett. b, of the Regulation, as the processing is necessary for the execution of a contract to which the interested party is a party or the execution of pre-contractual measures taken at the request of the same. The conferment of personal data for these purposes is optional, but failure to provide them would make it impossible to activate or provide the services requested by the user.
5. Further Purposes: promotional, commercial and marketing: subject to the user's consent, the user's personal data may be used by the Data Controller, both by telematic means (such as SMS, instant messaging, email, etc.) and by traditional means (such as post, telephone, fax and/or attachment to invoices), also for the following purposes 1) sending/communication of advertising, informative, promotional material on new products/services of "TAC" and/or of other subsidiaries/controlling and/or related companies, as well as of third companies; 2) direct sale and/or placement of products/services, facilities and promotions of "TAC" and/or of other subsidiaries/controlling and/or related companies, as well as of third companies; 3) verification of the degree of satisfaction of the quality of the product/service provided, studies and statistical and market research. The treatments carried out for the purposes of Marketing described in this section require the prior consent of the user, pursuant to art. 6, par. 1, lett. a of the Regulation. The provision of personal data for this purpose is therefore entirely optional and does not affect, in any way, the use of services. This means that if the user does not wish to give such consent, he/she will still be able to use the services made available through the App. The only consequence will be the non-receipt of offers and promotions from "TAC".
6. Further Purposes: communication of data to third parties: with the user's consent, the user's personal data may be communicated to third party companies and/or partners of "TAC", which in turn may use the user's data for the same purposes as in the previous point, both by telematic means (such as SMS, instant messaging, email, etc.) and by traditional means (such as mail, telephone). The treatments carried out for the purposes of communication of data to third parties described in this section require the prior consent of the user, pursuant to art. 6, par. 1, letter a of the Regulations. The provision of personal data for this purpose is therefore entirely optional and does not affect, in any way, the use of services. This means that if the user does not wish to give such consent, he/she will still be able to use the services made available through the App. The only consequence will be the non-receipt of offers and promotions from third parties.

ART. 3 - Period of conservation

Personal data will be stored for different times depending on the purpose for which they were collected: a) provision of services: we will keep the data for the time strictly necessary to achieve the purposes. In any case, since the processing is carried out for the supply of services, "TAC" will avail itself of the faculty, allowed by the law (art. 2946, Civil Code), to keep the personal data necessary to protect its own interests, for the time provided for by the law; b) Marketing and Communications to third parties: as a general rule, until the user revokes his consent. Further information regarding the data retention period and the criteria used to determine this period can be requested by sending a written request to the Data Controller at the addresses indicated in this policy. In any case, "TAC" reserves the right to retain personal data for the period of time provided for and allowed by Italian law to protect its interests (Art. 2947, paragraph 1 and 3, Civil Code).

Account Closure: If you close your account, your personal information will generally no longer be visible to third parties on our Services within 24 hours, and your closed account information will be deleted within 30 days of its closure, except as noted below. "TAC" reserves the right to retain your personal information after account closure if reasonably necessary to comply with legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, and enforce the License Agreement. Any information retained after your account is closed will be depersonalized. Information shared with third parties (e.g. through InMail, messages, etc.) will remain visible after the account is closed or the information is deleted from the user's profile. Please note that "TAC" does not control the data that other users may have copied from the Services offered.

ART. 4 - Categories of data recipients

For the above-mentioned purposes, your personal data collected by "TAC" may be known by (i) internal employees and consultants, as part of their work duties, acting as subjects authorized to process and instructed by the Owner; (ii) employees and consultants of companies controlling or controlled by "TAC" or connected to it, as subjects authorized and instructed to process; (iii) external consultants and third parties (suppliers of technical and technological services, credit and banking institutions, suppliers of services instrumental to the management/maintenance of the Application, as well as third party call center companies, marketing companies and advertising and market research services. The aforementioned categories of subjects act as managers appointed by "TAC".

Through the use of the Services offered by the Application it will also be possible to exchange communications between users and third parties, including for example invitations, email messages, groups and messages between links.

ART. 5 - Treatment modalities

The data processing is carried out through paper, computer and telematic supports by internal subjects specifically appointed. The data are stored in electronic archives and, residually, on paper with full assurance of the minimum security measures required by law.

ART. 6 - Transfer of data abroad

The user's personal data collected by TAC will be processed mainly in Italy and in any case in countries that are part of the European Union, however, some processing activities may be carried out in countries outside the EU, however, ensuring the necessary standards of security, protection and data protection, as required by national and supranational regulations, such as the adoption of Standard Contractual Clauses approved by the European Commission.

ART. 7 - The rights of the interested party

Pursuant to the Regulations, the interested parties may exercise the following rights with regard to the Data Controllers: - request and obtain information regarding the existence of their data at the Data Controller as well as regarding the processing of personal data carried out by the same, as well as obtain access to the same; - to request and obtain the receipt in a structured, commonly used and machine-readable format of one's own data provided to the Data Controller, if the processing is based on consent or on a contract and is carried out by automated means, as well as, where technically possible, the transfer of such data to another Data Controller - request and obtain the modification and/or correction of data that are inaccurate or incomplete; - to request and obtain the deletion of one's own data if it is not necessary - or no longer necessary - for the above purposes, or in the presence of the other conditions provided for by law (see art. 17 of the Regulations); - to request and obtain the limitation of the processing of one's own data if the data subject contests its accuracy or in the further cases provided for by art. 18 of the Regulation; - to oppose the further processing of his/her data in the cases expressly defined in article 2) above. Such requests may be addressed to "TAC" by sending a request to support@touchandcontact.com. Requests sent by e-mail or other channels that do not allow the identification of the applicant, must be accompanied by a copy of the applicant's identity document in order to verify the identity of the applicant. In accordance with current legislation, in addition to the above rights, the interested party also has the right to lodge a complaint with the competent supervisory authority which in Italy is the Guarantor for the protection of personal data, Piazza di Monte Citorio n. 121 00186 ROMA, Fax: (+39) 06.69677.3785, garante@gpdp.it, protocollo@pec.gpdp.it.

ART. 8 - Cookies

For further information, we invite interested parties to read the Cookie Policy, prepared by the Owner, at the following link https://touchandcontact.com/Cookies.

ART. 9 - Changes and updates

The Owner may freely modify or update all or part of this document, also in consideration of changes in laws or regulations governing the protection of personal data. It is understood that any such changes or updates will be notified to users and other interested parties on the homepage of the Site and through other channels available from time to time as part of the Services (for example, in-app communications or email communications for registered users). At the time of a new access to the Site and Services by the data subject, the Data Controllers will ask the data subject to confirm that he or she has read the new version of the Privacy Policy applicable to the processing of his or her data. System to be provided in order to carry out any additions that may be necessary.