Swap Party Privacy Policy

Privacy policy in accordance with the code on personal data protection (Italian Legislative Decree no. 196 dated 30 June 2003).
Italian Legislative Decree no. 196 dated 30 June 2003 (the Privacy Code) is aimed at ensuring that the processing of your personal data occurs in compliance with the rights, fundamental freedoms and dignity of persons, with particular reference to confidentiality and personal identity.
We hereby inform you, in accordance with Art. 13 of the Privacy Code, that the personal data provided by you or otherwise acquired as part of the activities performed by us, may be subject to processing for purposes related to the exercise of our activity of dissemination, by means of the “Swap Party” mobile application, of advertisements and offers relating to items of clothing that users can put on sale and/or exchange with other users registered to the Swap Party application.

  1. Personal data processing means its collection, registration, organisation, storage, processing, modification, selection, extraction, comparison, use, dissemination, deletion, distribution, interconnection and anything else that is useful for implementing the service offered by us, including the combination of two or more of those operations.
  2. The processing of your data for the purposes indicated above will take place mainly by automated and electronic methods. In any case, tools suitable for ensuring the security and confidentiality of the data will be used, by way of the adoption of the means of security required by the Privacy Code in relation to personal data protection.
    The data processing controller has implemented the minimum security measures required by the Privacy Code to prevent the loss of the data, any unlawful use and unauthorised access to the same.
  3. The personal data processing controller is Swap Party S.r.l., with registered office in Pisa, Via Umberto Forti 6 (Swap Party). The processing managers are the employees and/or professionals instructed by Swap Party, who perform the aforementioned activities under its direct supervision and responsibility. The complete and updated list of the processing managers is available and consultable at the headquarters of Swap Party.
  4. The provision of personal data by you is optional; however, any refusal to provide your personal data upon registering to the “Swap Party” mobile application (the App) makes it impossible to implement our services in your favour, particularly the possibility of advertising and accessing offers for the purchase and/or exchange of items of clothing, as well as your registration to that App.
  5. Your personal data may also be processed as part of the activities of the Website and Swap Party for the following purposes:
    • purposes strictly connected and instrumental to the management of relationships with you and to the supply of the service offered via the App;
    • purposes related to the obligations provided by laws, regulations and EU legislation, as well as by instructions imparted by authorities legitimated to do so by law or by supervisory or control bodies;
    • marketing, promotion and sale of products and services of Swap Party or third party partner companies, done by ordinary mail, SMS, MMS, telephone, e-mail, as well as market investigations and surveys of the degree of satisfaction of users on the quality of the services rendered and the functionality of the App, implemented directly or through the work of specialist companies by way of personal or telephone interviews, questionnaires, etc.;
    • analysis of user habits and profiling.
  6. With your consent, in addition, your personal data may be communicated by Swap Party to the following categories of third party companies which, in the capacity of autonomous processing controllers, will process your personal data for their own marketing purposes, direct sales and sending of advertising material by way of traditional mail, telephone, SMS, MMS or e-mail: [(i) subsidiary and associated companies or those belonging to the same corporate group as Swap Party, (ii) companies active in the field of communication and media, (iii) commercial partner companies of Swap Party.]
    Your personal data may also be communicated by Swap Party to external entities that perform functions related and instrumental to the operations of the App and services offered by way of it, such as, merely by way of example, the management of the IT system, assistance and consultancy on accounting, administrative, legal, tax and financial matters, which will from time to time be appointed as processing managers or processing officers in accordance with the provisions of the Privacy Code, as well as to entities granted the right to access the data by legal provisions or by orders of the authorities.
  7. The consent to the processing of your personal data for the purposes set out in paragraphs 5 (c), 5 (d) and 6 above is free and optional and, where you do not consent, the possibility of registering to the App will not be affected in any way. Even where you consent, you can at any time revoke the same, by making a request to Swap Party at the e-mail address privacy@swapparty.com . Any lack of consent to the processing of your personal data for the purposes set out in paragraphs 5 (c), 5 (d) and 6 above will involve the impossibility for you to receive communications of a commercial and promotional nature which may be of interest to you, along with the impossibility for Swap Party and its partners to be able to analyse your consumer habits in order to offer you opportunities and products/services of interest to you, as well as to communicate your personal data to the third parties indicated above.
  8. The processing controller will use the personal data communicated by you for the purpose of allowing you to make use of certain services or to obtain information in relation to use of the services provided by the App; however, the computer systems and software that operate the App may acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of web and mobile communication protocols.
    That information is not collected to be associated with identified interested parties but by its very nature it could, through processing or association, allow for the user to be identified. This data is used only to obtain anonymous statistical information on use of the App (such as, in particular, the number of accesses) and to check its correct operation. The data is deleted immediately after processing. This procedure does not involve the processing of direct identification information.
  9. We inform you that you may, at any time, exercise the rights provided by Art. 7 of the Privacy Code, in particular:
    • obtain confirmation of the existence or otherwise of personal data relating to you, even if not yet registered, and its communication in intelligible form;
    • oobtain the indication of the origin of the personal data, the purposes and methods of processing, the logic applied in the case of processing performed using electronic tools, the identification details of the controller, manager and representative appointed in accordance with this policy, the entities or categories of entities to which the personal data may be communicated or which may come to know of it in the capacity of appointed representative in the State territory, of manager or officer;
    • obtain: (i) the update, rectification or, where appropriate, supplementation of the data; (ii) the deletion, transformation into anonymous form or block on data processed in breach of the law, including that whose storage is not necessary for the purposes for which the data was collected or subsequently processed; (iii) certification that the operations set out in points (i) and (ii) have been brought to the attention, also as regards their content, of those to whom the data has been communicated or disseminated, except where that fulfilment is found to be impossible or involves the use of manifestly disproportionate means compared to the protected right;
    • object, in whole or in part: (i) for legitimate reasons to the processing of personal data relating to you, even if pertinent to the purpose of its collection; (ii) to the processing of personal data relating to you for sending advertising material or direct sales or for the completion of market research or commercial communication;
    • select the methods by which you wish to be contacted for the purpose set out in point 5 (c), and, in particular, indicate if you wish to be contacted by way of so-called traditional methods (ordinary mail and telephone with operator), by way of so-called automated methods (e-mail, SMS, telephone without operator, etc.) or both categories.

To exercise the rights provided by Art. 7 of the Privacy Code you can write to Swap Party srl, via U.Forti, 6 56121 Pisa – Italia