DATA CONTROLLER AND CONTACT DETAILS

LISCIANIGIOCHI S.P.A. is the Data Controller of the personal data processed through the website www.liscianigiochi.com and within the LISCIANIGIOCHI App Ecosystem.

The registered office is located at Via Giacomo Ruscitti, Zona Ind.le Sant’Atto, 64100 Teramo (Te), VAT No. 00723030672. For all privacy-related matters, you can contact the following email address: [email protected], or the phone number +39 0861 2311. The institutional website address is: https://www.liscianigiochi.com

PRIVACY FOR MINORS

Registration is only allowed for users who are 18 years of age or older; therefore, no personal information should be provided to LISCIANIGIOCHI by minors. For this reason, the parent and/or legal guardian must register in the reserved area and/or create one or more player profiles (USER). Please avoid using the real first and last name of minors when creating a profile and/or avatar. If, despite this prohibition, a parent or guardian becomes aware that their minor child has directly provided us with information, they must contact us at [email protected] for deletion/modification.

LISCIANIGIOCHI disclaims all liability in the event that the user provides incorrect, false, or third-party data, including data of minors, for whom they are not authorized and/or expressly permitted to provide such data and consent to processing. The user assumes full responsibility for such actions.

DESCRIPTION OF PROCESSING AND CATEGORIES OF DATA SUBJECTS

This notice explains how users' personal information is managed within the various sections of the company website and the Liscianigiochi app usage.

In particular, personal data is collected through:
a) completing the registration form for the reserved area;
b) requesting assistance through the helpdesk service;
c) online purchase of products (order management, product sale and delivery, returns and warranty management, and other activities necessary for product sales via e-commerce) with or without access to the reserved area;
d) account registration for app use in the Liscianigiochi App ecosystem and device usage (tablet, robot, phone) by players;
e) completing the online contact form;

The personal data collected will be processed in full compliance with applicable regulations, ensuring the security, confidentiality, and protection of the data in possession, respecting the fundamental rights and freedoms recognized to the data subjects, in accordance with the European Regulation 2016/679 (GDPR).

TYPES OF DATA COLLECTED AND DATA SOURCE

Data is collected from the data subject and is provided directly during account creation in the reserved area, when requesting assistance, making a purchase, registering on a tablet, using the apps, or sending a contact request.

Data collected: name, surname, email, phone number, address, user type and profession, VAT number, tax code, date of birth, system logs, data related to purchases made, payment methods.

Specifically, regarding the use of apps in the LISCIANIGIOCHI Ecosystem, the following categories of personal data are processed:

A. Lisciani APP Ecosystem:

  • COMMON DATA: name, surname, date of birth, email address, phone number, postal address of registered users; data entered in the player's profile (USER), such as the image, name, or gaming pseudonym. The profile of each player can be personalized with an image: LISCIANIGIOCHI recommends not uploading photos of minors to the player profile.
  • IT DATA: basic data of branded devices (phones, tablets, robots) and parents' devices associated with them (e.g., mobile phone); structure of friendships among various nicknames; login/logout logs.
  • APPLICATION DATA: identifiers of applications downloaded from the LISCIANIGIOCHI store and logs of the specific application used by the player.

B. APP TUTOR: The APP TUTOR collects information about activities to allow those with parental authority to monitor children's gaming activities (game screens, results and scores achieved, voice recordings). LISCIANIGIOCHI does not process this information but simply stores it and makes it available to the registered user for verification purposes.

Use of microphone and camera: some APPS use the microphone and camera for certain gaming features and store the collected information locally (i.e., in a device memory location), which therefore does not fall under LISCIANIGIOCHI's availability, not even for simple storage; the same applies to any voice recordings or images captured with the device outside the gaming context. All this information can be managed and deleted at any time by the registered user.

It is therefore the user's responsibility to delete personal data that APPS or players store on the device before disposing of or transferring it to third parties.

PURPOSE OF THE PROCESSING

Personal data are processed for the following purposes:

1. To authorize access to the Reserved Area and provide the requested services, maintain and manage the created account;
2. To inform the interested party that content and documents of interest are available in the Reserved Area;
3. To provide customer support for the company's products/services;
4. To comply with all related legal obligations, including administrative, accounting, fiscal, and financial processes associated with the delivery of the product or service provided;
5. In case of loss of access credentials, to activate the procedure to recover and reset the password;
6. To protect contractual rights and pursue the legitimate interests of the Data Controller, including, where necessary, asserting or defending a right in court;
7. To respond to requests for information regarding the products/services offered and any commercial or other requests submitted via forms;
8. To allow online purchase of products/services and conclude the purchase contract via e-commerce;
9. To prepare reports and perform internal checks;
10. To ensure security within the website and the LISCIANIGIOCHI APP ecosystem, managing and blocking fraudulent or unlawful uses;
11. To allow the use of apps available within the LISCIANIGIOCHI ecosystem (please note that for the use of the camera and voice recorder, the user's prior consent is required).

LEGAL BASIS

With regard to the processing of personal data for the purposes described in the previous section, the legal bases are:

  • Execution of a contract or pre-contractual measures (Art. 6 para.1.b of the GDPR) for purposes 1, 2, 3, 5, 7, 8, 11;
  • Compliance with legal obligations (Art. 6 para.1.c of the GDPR) for purposes 4, 9;
  • Pursuit of the legitimate interest of the Data Controller (Art. 6 para.1.f of the GDPR) for purposes 6, 10.

RECIPIENTS AND CATEGORIES OF RECIPIENTS

The personal data processed by the Data Controller is not disseminated.

However, it may be communicated to external parties designated as Data Processors (such as third-party technical service providers, hosting providers, IT companies, communication agencies, postal couriers, providers of website management and development services, server and network maintenance services, online shop infrastructure providers, customer support services, providers who develop, manage, and maintain the LISCianigiochi APP ecosystem, and those involved in user registration) or to subjects authorized to process the data as they operate under the authority of the Data Controller, or other parties involved in the organization of this website (administrative, commercial, marketing staff, legal representatives, system administrators).

Finally, it may be communicated to parties authorized to access it due to legal provisions, regulations, or EU laws. For compliance with legal obligations or to ascertain liability in the case of computer crimes against the website, the data may be communicated to or stored with third parties.

For credit card data, the Stripe platform is used (https://stripe.com/it), and the data is not processed by Liscianigiochi Spa, but solely by the platform itself. For transactions made by the User/Interested Party through the Stripe platform, please refer to the privacy notice: https://stripe.com/it.

The updated list of Data Processors can always be requested from the Data Controller.

TRANSFER ABROAD

The data is processed at the operational offices of the Data Controller and at any other location where the parties involved in the processing are located, therefore the Data Controller does not transfer these personal data to third countries or to international organizations outside the EU.

However, it reserves the possibility to use cloud services; in such cases, service providers will be selected from those offering adequate guarantees, as provided by Art. 46 of the GDPR. For the processing of information and data that may be communicated to these parties, equivalent levels of protection adopted for the processing of personal data of its employees will be required. In any case, only the data necessary for pursuing the intended purposes will be communicated, and regulatory tools will be applied.

DATA RETENTION PERIOD

The Data Controller retains and processes personal data for the time necessary to fulfill the purposes indicated, or for the period during which the Data Controller will keep the service active.

In particular:

  • Registration data will be processed until the account is closed, taking into account the technical time necessary for this;
  • Data processed for legal obligations will be retained for 10 years from the end of the contractual relationship;
  • Data processed for the execution of pre-contractual activities, in case of non-finalization of the purchase, will be deleted 5 months after the data is collected;
  • Data voluntarily provided by the user by filling out the "Contact" form will be retained for a maximum of 12 months or for the duration of the product warranty (since requests may also refer to technical assistance on the products within the warranty period);
  • In the case of legal disputes, for the entire duration of the dispute, until the expiration of the time limits for appeals;
  • Information regarding the registered user and player profiles will be retained for the time of use of the LISCIANIGIOCHI apps, plus 12 months, unless it is necessary to retain them for longer to comply with fiscal or legal obligations or to address complaints. Users of the apps are those who use the LISCIANIGIOCHI device at least once within 12 months ("active accounts"). If the device is not used for a consecutive period of 12 months ("inactive account"), an email notification sent by LISCIANIGIOCHI will inform the user that all their data will be deleted after 30 additional days of inactivity; a new access of the device to the LISCIANIGIOCHI apps will qualify the account as active again for another 12 months;
  • Log records are kept for a maximum of 6 months.

After these periods, the data will be deleted or anonymized, unless their further retention is necessary to fulfill arising contractual obligations, legal requirements, or to comply with orders issued by Public Authorities and/or Regulatory Bodies, as well as to prevent fraudulent activities or in the case of disputes.

MODALITIES AND NATURE OF DATA PROVISION

The data is collected and recorded in a lawful and fair manner for the purposes indicated above, in compliance with the principles and provisions of Article 5, paragraph 1 of the GDPR.

Personal data is processed using manual, computer, and telematic tools with logic strictly related to the purposes themselves and, in any case, in a manner that ensures their security and confidentiality.

Providing the data for the aforementioned purposes is entirely optional. Any refusal by the data subject to provide personal data, the lack of consent, or its withdrawal for one or more purposes, will result in the impossibility of using the services connected to those purposes.

Failure to provide the data may result in the inability to receive the requested services or access the LISCIANIGIOCHI APP Ecosystem and fully use the device.

SECURITY MEASURES

The transfer, storage, and processing of the data of the data subject collected through the website are ensured through appropriate technical and security measures. Some of the main security measures include:

  • All the information of the data subject is protected by the access keys chosen by the user, and passwords are not stored in plain text;
  • The website is equipped with an encrypted HTTPS connection;
  • A secure e-commerce platform is used, with integrated security protocols;
  • Complex passwords are used;
  • The data of the data subjects are collected, stored, and kept on a secure server, protected by firewalls, and physically located in a web farm with controlled access situated in the EU.

RIGHTS OF THE DATA SUBJECT

In accordance with and within the limits and conditions set out by the data protection legislation regarding the exercise of the rights of the data subjects (Articles 15 to 21), concerning the processing covered by this notice, as a data subject, users may exercise certain rights with regard to the data processed by the Data Controller.

In particular, the data subject has the right to:

  • Withdraw consent at any time (where required)
  • Object to the processing of their data
  • Access their data
  • Verify and rectify their data
  • Limit the processing of their data
  • Request the deletion or removal of their personal data
  • Data portability

Furthermore, the data subject has the right to lodge a complaint with the competent data protection authority or to take legal action, in case they believe that the processing of their data violates the GDPR, under Article 77 of the GDPR.

How to exercise the rights

If you wish to request further information about the processing of your personal data or to exercise your rights, you can contact us in writing at the email address [email protected] using the appropriate "Rights Exercise Form". Requests are free of charge and will be processed by the Data Controller as soon as possible, in any case within one month.

AUTOMATED PROCESSING

In no case, with respect to the processing indicated below, does the Data Controller carry out processing that involves automated decision-making processes based on personal data of natural persons.

CHANGES TO THIS PRIVACY POLICY

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users via email and on the Website.

The Data Controller will collect the data subject’s consent again, if necessary.

Last modified: 21/06/2024