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This Privacy Policy describes how we collect, use, and protect your personal information when you use our mobile application "Smokee." Your privacy is important to us, and we are committed to protecting it. This Privacy Policy applies to Smokee, our iOS mobile application (our “App”). In the below policy, we inform you about the scope of the processing of your Personal Data. General Information About our App When designing our App, we have made sure that no information that directly identifies you is collected. As however some countries have a broader definition of Personal Data this policy covers it. In this sense we would need to first of all explore the definition of Personal Data. Why do we have a privacy policy and what law applies? Italy's Legislative Decree no. 196 of 30 June 2003, as amended by the Legislative Decree no. 101 of 10 August 2018 (“DPC”) and the General Data Protection Regulation (“GDPR”) require us to inform you how we process your Personal Data. Doing so we will only use your Personal Data in accordance with the DPC and GDPR, and only as described in this Privacy Policy. What is Personal Data? Personal Data is any information relating to personal or material circumstances that relates to an identified or identifiable individual. This includes, for example, your name, date of birth, e-mail address, postal address, or telephone number as well as online identifiers such as your IP address and device ID. What is processing? "Processing" means any operation or set of operations which is performed upon Personal Data, whether or not by automatic means. The term is broad and covers virtually any handling of data. Responsible for data processing Responsible for data processing is Angelo Cirillo (Developer), (“we”, “us”, or “our”). If you have any questions or if you wish to exercise your rights, please contact us using cirillo2a@icloud.com. The Legal Bases for processing Personal Data In accordance with the DPC and GDPR, we have to have at least one of the following legal bases to process your Personal Data: a) you have given your consent, b) the data is necessary for the fulfillment of a contract / pre-contractual measures, c) the data is necessary for the fulfillment of a legal obligation, or d) the data is necessary to protect our legitimate interests, provided that your interests are not overridden. Processing of Automatically Collected Data Downloading the APP The APP can be downloaded from the Apple App service "App Store" a service of Apple Inc. Downloading it may require prior registration with the App store and/or installation of the respective App store software. Installing the APP As far as we are aware, Apple collects and processes the following data: device identifiers, IP addresses, location information, it cannot be excluded that Apple also transmits the information to a server in a third country. We cannot influence which personal data Apple processes with your registration and the provision of downloads in the respective app store and app store software. The responsible party in this respect is solely Apple as the operator of the Apple App Store. Firebase We use the Google Firebase developer App and related features and services provided by Google LLC and Google Ireland Limited. Google Firebase is a Platform for developers of apps for mobile devices. The Google Firebase Developer App offers a variety of features. A list of these features can be found at: https://firebase.google.com/terms/. Firebase's key security and privacy information can be found here: https://firebase.google.com/support/privacy. We use the following Google Firebase services in our App: i) Firebase Analytics, ii) Firebase Crashlytics, iii) Firebase Firestore, and iv) Firebase Authentication. By integrating Google services, Google may collect and process information (including personal data). It cannot be excluded that Google also transfers the information to a server in a third country. We cannot influence which data Google collects and processes. Device information Google and Apple may collect information from and about the device(s) you use to access the APP, including hardware and software information such as IP address, device ID and type, device-specific and APP settings and properties, APP crashes, advertising IDs (AAID), information about your wireless and mobile network connection such as your service provider and signal strength; information about device sensors such as accelerometer, gyroscope, and compass. Google Admob The APP uses the Google Admob service to display ads. Ads are personalized based on the device you are using. You can disable this via the settings on your device. Google may use the advertising ID of your device, as well as cookies and/or similar technologies, to collect personal data for the purpose of generating and displaying personalized advertising. More detailed information about what data Google collects and how it is processed can be found here. If you do not wish to participate in our advertising personalization or retargeting/tracking you can object to behavioral advertising at the following websites: Your Online Choices, Digital Advertising Alliance of Canada, Network Advertising Initiative, AdChoices and the European Interactive Digital Advertising Alliance (Europe only). Authorizations and Access We may request permission to store your APP data including your Internet Connection and Network, Location, Push Notifications. The legal basis for data processing is our legitimate interest and the provision of contractual or pre-contractual measures. You can deny access on your device via the Settings/Notifications/ options of your device; however, this means that our APP may not function as intended. Push messages When you use our App, you will receive so-called push messages from us, even if you are not currently using our App. These are messages that we send you as part of the performance of the contract. You can adjust or stop receiving push messages at any time via the device settings of your device. Insofar as you consent to the use of push messages, consent is the legal basis for the processing. Data processing by us Contacting us Personal Data is processed depending on the contact method. In addition to your name and e-mail address, IP address or telephone number, we usually collect the context of your message which may also include certain Personal Data. The Personal Data collected when contacting us is to handle your request and the legal basis is both your consent and our contract. We are present on social media on the basis of our legitimate interest. If you contact or connect with us via social media platforms, we and the relevant social media platform are jointly responsible for the processing of your data and enter into a so-called joint controller agreement. The legal basis is our legitimate interest, your consent or, in some cases, the initiation of a contractual service, if any. Registration and profile As part of the registration process, users depending on the account type chosen provide their a) Username; b) E-mail; c) Password; d) Date of birth (For age verification purposes); e) Profile Picture (Optional) for User accounts, and their a) Username; b) E-mail; c) Password; d) Description of the Field; e) Address; f) City; g) Post Code; h) Number of fields; i) Camp mobile number for Camp accounts. The data provided will be used for the purposes of creating and using the account and providing and/or using our APP and services. In the context of the use of our registration and login functions as well as the use of the user account, we store the IP address and the time of the respective user action. The storage is based on our legitimate interests, as well as the user's protection against misuse and other unauthorized use. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent. Profile As a registered user, you have the opportunity to create a user profile with just a few clicks and details. If you make use of the option, the relevant profile data you provide will be transferred to your profile. Of course, you can change the information at any time via the settings in your profile. When creating a profile, you can submit both Personal Data and Special Category Data. You have choices about the information on your profile. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services. It’s your choice whether to include sensitive information on your profile and to make that sensitive information public. Please do not post or add Personal Data to your profile that you would not want to be available. The legal basis for the processing of your Personal Data is the establishment and implementation of the user contract for the use of the service. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account. When using our services We process the data of our registered users in order to be able to provide our contractual services as well as to ensure the security of our services and to be able to develop it further. Some of the Personal Data you provide may be considered “special” or “sensitive”. This includes Personal Data concerning for example your health, racial or ethnic origins, sexual orientation, and religious beliefs. By choosing to provide this data, you consent to our processing of that data. You have choices about the Personal Data you upload and share. You don’t have to provide Personal Data; however, Personal Data helps you to get more from our Services. It’s your choice whether to include Special Category Data and to make that Special Category Data public. Please do not upload or add data that you would not want to be available. The legal basis for the processing of your personal and Special Category Data is the establishment and implementation of the user contract for the use of the service as well as your consent. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account. You may withdraw your consent and request us to stop using and/or disclosing your personal and Special Category Data by submitting your request to us. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent. Contacting others Of course, we also process your chats and communications with other users as well as the content you publish, as necessary for the operation of the services. In addition to the information, you may provide us directly, we receive information about you from others. Users may provide information about you as they use our services, for instance as they interact with you or if they submit a report involving you. We also share some users’ information with service providers and partners who assist us in operating the services. You share information with other users when you voluntarily disclose information on the service (including your profile). Please be careful with your information and make sure that the content you share is stuff that you’re comfortable being visible. The legal basis for the data processing is the fulfillment of our contractual obligations and, in individual cases, the fulfillment of our legal obligations as well as your consent. Information that we receive from others In addition to the information you provide to us directly, we receive information about you from others, including other users who provide us with information about you when they use our Services. For example, we may receive information about you from other users when you contact them about us. We collect information about your activities on our Services, such as how you use them (e.g., the date and time you logged in, features you used, searches you performed, clicks and pages you were shown, ratings you clicked on) and how you interact with other users (e.g., users you connect and interact with, the time and date of your exchanges). General Principles Minors Persons under the age of 18 should not transmit any Personal Data to us without the consent of their parents or legal guardians. We do not request Personal Data from minors and children and do not knowingly collect such data or pass it on to third parties. Automated decision-making Automated decision-making including profiling does not take place. Do Not Sell We do not sell your Personal Data. Sharing We will not disclose or otherwise distribute your Personal Data to third parties unless this is a) necessary for the performance of our services, b) you have consented to the disclosure, c) or the disclosure of data is permitted by relevant legal provisions. In addition, we may disclose your Personal Data: in connection with law enforcement, fraud prevention or other legal proceedings; as required by law or regulation. Storage All data collected is generally transferred to our Google Firebase Firestore database. The legal basis for the data processing is our legitimate interest in providing our App. We ensure that processing is governed by Processing Agreements that include Standard Contractual Clauses to ensure a high level of data protection. We store the data until you delete your user account. Insofar as legal retention periods are to be observed, storage also takes place beyond the time of deletion of a user account. Data Security Our data processing is subject to the principle that we only process the Personal Data that is necessary for the use of our services. In doing so, we take great care to ensure that your privacy and the confidentiality of all Personal Data are always guaranteed. We also use technical and organizational security measures (TOMs) throughout the company to protect the data we manage from you against accidental or intentional manipulation, loss, destruction or against access by unauthorized persons. Nonetheless, databases or data sets that include Personal Data may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, we will notify all affected individuals whose Personal Data may have been compromised, and the notice will be accompanied by a description of the action being taken to reconcile any damage as a result of the data breach. Notices will be provided as expeditiously as possible after which the breach was discovered. Your Rights and Privileges a) Privacy rights You can exercise the following rights: ● Right to information ● Right to rectification ● Right to object to processing ● Right to deletion ● Right to data portability ● Right to withdraw consent ● Right to complain to a supervisory authority ● Right not to be subject to a decision based solely on automated processing. If you wish to exercise any of your rights, please contact us. b) Updating your information If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion, or object to its processing, please do so by contacting us. c) Withdrawing your consent You can revoke consents you have given at any time by contacting us. The legality of the data processing carried out until the revocation remains unaffected by the revocation. d) Access Request In the event that you wish to make a Data Subject Access Request, you may inform us in writing of the same. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the respective legal regulations mentioned above). e) Complaint to a supervisory authority You have the right to complain about our processing of Personal Data to a supervisory authority responsible for data protection. Updates and Questions We may update this policy from time to time. If we make changes, we will revise the effective date at the end of this section. If you would like to contact us regarding our privacy practices for any reason, please do so using cirillo2a@icloud.com. We encourage you to periodically review this policy to be informed of how we use and protect your Personal Data. This policy was last updated on Thursday, 11 May, 2023