(Pursuant to the EU General Regulation on the protection of personal data n. 679/2016 and in compliance with Legislative Decree
196/2003 – Privacy Code)
DATA CONTROLLER:
ReelUp D.o.o. with registered office in Kidriceva ulica 19 5000 Nova Gorica ID ZA DDV: SI17046459 as Owner of the
treatment informs on the purposes and methods of processing personal data:
The processing of personal data concerns the set of operations applied to personal data (even if not registered in
a database), such as collection, registration, consultation, processing, communication, transmission, modification
or cancellation. The treatment carried out will be carried out electronically with the aid of digital tools and will be
based on the principles of lawfulness, correctness, confidentiality and integrity.
Projects:
Lolybox, a project conceived and executed by ReelUp D.o.o, has as its aim the establishment of an international community
leader in the management of personal data formed by users who have decided to regain control of it, which allows you to
receive only approved advertising from existing and active companies to receive a fee for it.
Creditworthiness has as its purpose the assessment of the economic reliability of people based on the data provided
in the appropriate online form. The goal is to propose a clear interpretation that allows the User to
know how it would be valued by a bank, a finance company or simply a supplier who, before
stipulate a contract, intends to know if the buyer is able to bear the installments of a loan.
Furthermore, ReelUp presents itself to the market as a provider of platforms and services related to various marketing activities
(CRM, IVR, SMS, DEM, Social Networking, Analytics, Google Adwords, personal search and company monitoring).
SOURCE OF PERSONAL DATA
We use the personal data provided by users when joining through online forms and during the
permanence through monitoring and the use of profiling cookies to make these advertisements and information known to them
commercial proposals more akin to their interests.
In case of any need, personal data could also be collected from completed paper documentation
directly by the user.
TYPE OF INFORMATION
To provide products and services we need to process information about you. The type of information collected
it depends on the choices of each user.
- We collect the information provided when creating an account (name, surname, age, gender, email, telephone and
cap), the use of our application, including the choice of categories of interests, tastes, habits, etc. (by title
example: well-being, sports, holidays, cultural events, technology, education, among others) and the sharing of
content. It can also be information related to this content such as the location of a photo or the date of
creating a file.
Content and communications provided are processed automatically to analyze the context. - We collect information about how you interact with our app and site regarding products and services e
the interactions with other users, the contents viewed, the functions used, the actions taken, the interactions; Now,
duration and frequency of these activities.
We use contact information synced or imported from a device to use as a tip
in the invitation to interested persons. - We collect information relating to transactions made on our app and site such as card number or others
characteristics of the same. - We receive and analyze content, communications and information provided by third party partners in relation to the actions ed
to the interactions undertaken in our application. - We collect information from and about mobile phones and other web-connected devices integrated with ours
products and services and we combine this information on the different devices you use to better personalize the
content (including advertisements) or features you view while using our products or to detect whether it has been
action was taken in response.
The information we collect from these devices includes: device attributes: information such as
operating system, hardware and software versions, browser type, plug-ins and apps.
Device operations: Information about operations and behaviors performed on the device, such as whether a
window is in the foreground or background or mouse movements (which help us distinguish users from bots).
Data from device settings: Information that you allow us to receive through your device settings
activated, such as access to GPS location, camera or photos.
Network & Connections: Information such as your mobile operator or ISP name, language, time zone, mobile phone number,
IP address, connection speed and, in some cases, the
information on other devices nearby or on the network.
Cookie data: Data from cookies stored on your device, including cookie IDs and settings.
-Advertisers, app developers and publishers can send us information about activities outside of ReelUp projects
information about your device, websites you visit, purchases you make, ads you view, and how you use their services.
We also receive information about online and offline stocks and purchases from third-party data providers who have the
right to provide this information. Each partner is required to be authorized to collect, use and share the
data before providing them.
PURPOSE OF THE TREATMENT:
Legal basis of the treatment:
Pursuant to art. 6 GDPR, the interested parties express their consent to the processing of their personal data for the
pursuit of the legitimate interest of the data controller or third parties, existing a relevant relationship with
these and taking into account their reasonable expectations, provided that the interests or rights and the
fundamental freedoms which require the protection of personal data.
Pursuant to paragraph 4 of the aforementioned art. “[…]in order to verify whether the processing for another purpose is compatible with
the purpose for which the personal data was initially collected, the data controller takes into account, inter alia:
a) of any link between the purposes for which the personal data were collected and the purposes of the envisaged further processing;
b) the context in which the personal data were collected, in particular with regard to the relationship between the interested parties and the
data controller;
c) the nature of the personal data, especially if particular categories of personal data are processed, or if they are
processed data relating to criminal convictions and offences;
d) the possible consequences of the envisaged further processing for the data subjects;
e) the existence of adequate guarantees, which may include encryption or pseudonymisation.”
How to use:
-We use the information in our possession according to the choices of the users and in the ways described to guarantee the
functions offered by ReelUp.
-We use the information we have to offer our Products, to customize features and content, and
to provide suggestions. To create personalized, exclusive and relevant products and services we use connections, the
preferences, interests and activities based on the data collected and provided directly and indirectly (including
any data subject to special protection in the case of explicit consent), the methods of use and interactions with
our products.
We also link activity information across devices to provide a more personalized experience
and consistent.
-We use location-related information, such as your current location, place of residence, places visited,
nearby businesses and individuals to provide, customize and improve our Products, including advertisements. The
location-based information may be based on such things as the exact location of the device (upon consent),
IP addresses and usage information.
-We use the information we have to develop, test and improve our Products through surveys and
searches.
-We use the information we have, including information about your interests, shares and connections, to select and
customize ads, offers and other content to display.
-We use the information we have (including activities outside our app such as websites you visit and
displayed ads) to help advertisers and other partners measure the effectiveness and distribution of theirs
services and their advertisements.
-We use the information we have to verify accounts and activity, combat harmful conduct, detect
and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security
protection inside and outside the app.
-We use the information we hold to send you marketing communications, provide information about our
Products and our policies and conditions. The information is also used to provide an answer when
contact us.
-We use the information we have (including information from research partners we work with) to
carry out and support research and innovation on topics related to general social welfare, progress
technologies, the public interest, health and well-being.
SCOPE OF COMMUNICATIONS
For the pursuit of the purpose and the exercise of our business, as well as for the execution of duties and obligations
closely related to the activity itself, ReelUp D.o.o may need to communicate personal data to
following categories
ie of subjects (The complete list can be requested at the email address privacy@reelup.eu):
-All employees of ReelUp D.o.o designated in charge of processing in relation to the performance of the duties and
of the tasks assigned to each as an act of appointment to data processing. Among these entities that provide services
for the management of the ReelUp information system and telecommunications networks (including e-mail);
- partner companies with which ReelUp has commercial agreements in order to present the advertisements and the proposals closest to the
interests. of users. These are affiliated companies also subject to the rules of the GDPR which we try to
check operating methods, pertaining to the following product categories: health and well-being (beauty, gym,
sports, health), finances (loans, mortgages, economy, banking, financing), food (food and supermarkets), clothing
(fashion), house utilities (bills, thick family), holidays (travel and tourism), cultural events (music, theatre, dance,
museums), work (job offers and job search), family, insurance, technology and catering (fast food, pizzerias, bars,
restaurants).
We also supply these companies with:
Aggregated insights to show how people are interacting with their storefront and campaigns
advertisements, videos and other content, within our app;
report on the types of people viewing your ads, ad performance, shared content.
- external companies such as service companies for the acquisition, registration and processing of data from
documents, or supports provided and originals of the same customers and subjects who carry out transmission activities,
enveloping, transport and sorting of communications with customers including the use of
instant communication such as e-mail, mail, telephone SMS and MMS or urgent communication channels
by telephone calls and faxes.
-We provide information and content to research partners and academics to conduct research in support of ours
company and our mission to further enhance our services to provide users with an experience
better, more intuitive and personalized, to increase their involvement and increase new subscriptions.
- We share information with public authorities in accordance with a legal obligation for the purpose of exercising
their institutional mission, and only in relation to a specific investigation in the general interest, in accordance with
Union or Member State law. Communication requests sent by public authorities should
always be written, motivated and occasional. We may also respond to legal requests if we deem it appropriate
good faith that what is made mandatory by the law of the jurisdiction in question, concerns users who
comply with such jurisdiction and that it complies with internationally recognized standards. - We provide information to third party partners and receive it from them regarding the reliability of accounts to prevent fraud,
misuse or other harmful activity on and off our Products.
-If we have reason to believe that it is necessary to detect, prevent and address unauthorized uses of
Products, violations of our conditions or regulations, or other harmful or illegal activities, to protect ourselves
(including our rights, properties or services) users or third parties including as part of regulatory investigations or requests or for
prevent death or imminent bodily injury. The information we receive can be accessed and stored for
an extended period of time when they are the subject of a proceeding or legal obligation, an investigation
government or investigations into possible violations of our terms or laws, or to avoid harm.
POSSIBILITY OF TRANSFER TO THIRD COUNTRIES
The information could be transferred, transmitted, archived, processed outside the countries of residence of the
users, for the needs due to the services we provide and in any case always according to the purposes described herein
legislation.
PROFILING
The interested parties allow to declare their preferences and to receive personalized information based on the
own characteristics according to the provisions of the law of the Union or of the Member State to which the holder is subject
of the treatment which provides for the right to obtain the intervention of the data controller, to express one’s own opinion
opinion and to contest the decision.
1 Cookies:
When you visit a website that uses cookies, it sends small text files to your device (whether it is
computer, smartphone, tablet, etc.) used by the User. On the next visit by the user, these files
will be retransmitted to the site that generated them to ensure better e
navigation experience aside
of the user. The information they contain can be used, for example, to improve services
offered and the browsing experience by the User.
The ReelUp website uses both first-party and third-party technical and profiling cookies.
It is possible to deny your consent to the use of profiling cookies by clicking on the appropriate link and reading the
related (present) information. By closing the banner, scrolling the page or clicking any element of the
page outside the banner, the User consents to the use of all cookies, including profiling ones.
A trace of the consent given by the User remains through a specific technical cookie (which the user can block).
in this way, the User will not see the cookie banner during subsequent visits.
It is possible to block the installation of profiling cookies at any time by changing the settings
browser (as better specified below) by continuing to use the services and contents offered by the site, but in
in case of disabling the technical cookies of it will not be possible to navigate correctly on the ReelUp website.
The profiling cookies used, the related privacy information and the management methods are specified below
own consent:
First-party profiling cookies:
Opt out
Third-party profiling cookies:
Product Privacy Policy Opt out
AddThis Privacy Policy Opt out
Google AnalyticsPrivacy PolicyOpt-out
Google AdWords Privacy Policy Opt out
Bing Ads Privacy Policy Opt out
Criteo Privacy Policy Opt out
Facebook Privacy Policy Opt out
Hasoffer Privacy Policy Opt out
Google Optimize Privacy Policy Opt out
Hotjar Privacy Policy Opt out
Double click Privacy Policy Opt out
Google Adsense Privacy Policy Opt out
Google AdServices Privacy Policy Opt out
How to disable cookies?
Each browser allows you to block both “first-party” and “third-party” cookies, or both. Right away
we refer to the procedures for disabling cookies relating to each browser to which the User can access:
Chrome
Firefox
Internet Explorer
Safaris
To delete cookies already stored on the computer, it will be sufficient for the User to read the guide of the browser used
and follow the instructions provided there.
EXERCISE OF THE RIGHTS PROVIDED FOR BY THE GDPR
The rights granted to users by the General Data Protection Regulation (General Regulation on the Protection of
Data) are the right of access (art.15), rectification (art.16), cancellation (art.17), limitation (art.18) and
opposition (Article 21).
The deadline for responding to users is, for all rights (including the right of access), one month, which can be extended up to
3 months in particularly complex cases. In any case, there will be a reply within one month of the request, even in
case of denial. It is up to the holder to evaluate the complexity of the match and establish the amount of any
contribution to be requested from the interested party, but only if the requests are manifestly unfounded or excessive
(even repetitive) (art. 12.5) or if more “copies” of personal data are requested in the case of the right of access
art. 15, paragraph 3); in the latter case, the owner must take into account the administrative costs incurred.
Users of the ReelUp community can request information on data processing for control purposes. The
right of rectification (art.16) provides for the possibility of obtaining the correction of data that do not correspond to the real ones ed
also updating in case the data is no longer current. The cancellation of the data for which it intervened
the integration must be explicitly requested, even if the retention obligation could arise from one
legal provision. The right to cancellation takes into account “the available technology and implementation costs” ed
it is excluded: for the exercise of the right to freedom of expression and information; for the fulfillment of an obligation
legal, for the execution of a task carried out in the public interest or in the exercise of public powers to which it belongs
invested the data controller; for reasons of public interest in the field of public health; for purposes of
archiving in the public interest, for scientific or historical research or for statistical purposes; for the assessment, exercise or
defense of a right in court. The right to limitation (art. 18) can be exercised if the data subject requests rectification
of the data pending such rectification by the owner or opposes their treatment (pursuant to article 21) in
awaiting evaluation by the owner Excluding storage, any other processing of the data referred to
requests the limitation is prohibited unless certain circumstances exist (consent of the interested party,
verification of rights in court, protection of the rights of other natural persons
ca or juridical, public interest
relevant). The right to object (Article 21 of the GDPR) by the interested party is possible unless they are demonstrated
“legitimate reasons for proceeding with the processing which prevail over the interests, rights and freedoms
of the interested party” or “for the assessment, exercise or defense of a right in court”. In case the data
personal data processed for direct marketing purposes, the interested party has the right to object at any time to the
processing of personal data concerning him. Finally, if personal data are processed for scientific research purposes or
historical or for statistical purposes according to the law, the interested party, for reasons connected with his particular situation, has the right to object
to the processing of personal data concerning him, except if the processing is necessary for the execution of a task
public interest.
For all that concerns the above, requests may be sent to the email address privacy@reelup.eu
DURATION OF THE TREATMENT
Personal data will be used for the duration necessary to provide services from us. If the user requests the
deletion of your data, the processing of the same by us will be stopped. In case of account closure
we keep personal data even subsequently (for a period not exceeding 10 years) to fulfill ours
legal obligations, resolve any disputes and maintain security by preventing abuse and fraud.
OWNER AND MANAGER OF THE TREATMENT
The data controller is ReelUp D.o.o. with registered office at Kidriceva ulica 19 5000 Nova Gorica ID ZA DDV:
SI17046459 Primorski Tehnološki Park, Mednarodni Prehod 6 5290 Šempeter Pri Gorici.
FURTHER INFORMATION
Management:
Our Services are dynamic. As we introduce new features, we may ask for new information to be collected. Self
we significantly change the way we use data or this Privacy Policy users will be
informed only in the case of material changes to have the opportunity to review the changes before they become
effective. If after we post a notice regarding changes to this Privacy Policy
privacy our services will continue to be used, the collection, use and sharing of personal data
will be subject to the updated Privacy Policy.
Safety:
We implement security protections built to protect your data. We regularly monitor our systems for
detect possible vulnerabilities and attacks. However, we cannot guarantee that such data is inaccessible or that it will not
may be disclosed, altered or destroyed as a result of a breach of any of our safeguards, whether physical,
technical or managerial.
Sale and merger:
