Privacy Policy

This page contains information regarding the methods used to manage the website www.eatsplore.app (hereinafter, the “Website”), with reference to the processing of users’ personal data.
This privacy policy is also provided pursuant to Article 13 of Regulation (EU) No. 2016/679 (hereinafter, the “Regulation”), for all users who interact with the Website.

The purpose of this document is to provide information on the methods, timing, and nature of the information that data controllers must provide to users when accessing the Website, regardless of the purpose of the connection, in accordance with Italian and European legislation.

This policy may be subject to changes due to the introduction of new regulations; users are therefore invited to periodically review this page.

privacy@eatsplore.app.

1. Data Controller

The data controller of the personal data collected through this Website is SBB Ideas S.r.l. (hereinafter, “SBB Ideas”), with registered office at Piazza della Repubblica, 19 – 20124 | Milan (MI), Italy.

SBB Ideas can be contacted through the channels and contact details indicated in Section 11 of this policy.

2. Type of Personal Data

SBB Ideas processes the following types of personal data of users who browse and interact with the Website (hereinafter, “Dati”).

These include data provided directly by the user, such as, by way of example and not limitation: first name, last name, email address, and any personal data contained in email communications or attachments sent by the user via direct email or other communication channels indicated on the Website.

3. Purposes and Legal Basis of Processing

The personal data provided by the User will be processed, without the need for prior consent, for the following purposes (hereinafter, “Finalità”):

a. To allow Users to use the web services of the Website and to manage requests received through the contact details published on the Website. The legal basis for this purpose is found in art. 6, par. 1, lett. b) and f) of the Regulation, in particular: b) c) d) 4. 5.
- to give effect to pre-contractual measures adopted upon request of the user through the contact details published on the Website;
- the legitimate interest of the controller to: (i) inform the user, through the content of the Website, about the activities carried out by SBB Ideas; (ii) interact with the user interested in SBB Ideas' services, in case of requests not related to pre-contractual relationships, through the contact details published on the Website.

b. Perform maintenance and technical assistance necessary to ensure proper functioning of the Website and connected services.
The legal basis for this purpose is found in art. 6, par. 1, lett. f) of the Regulation, in particular:
- legitimate interest of the controller to: (i) prevent the occurrence of fraud or other crimes through the use of the Website;
(ii) improve the quality and structure of the Website, as well as to create new services, functionalities and/or characteristics of the same;
(iii) for the management and processing of statistical surveys (after anonymization of data) on Website usage.

c. Allow SBB Ideas to exercise its rights in court and combat illegal behavior.
The legal basis for this purpose is found in art. 6, par. 1, lett. f) of the Regulation, in particular:
- legitimate interest of the controller to: (i) prevent the occurrence of fraud or other crimes through the use of the Website;
(ii) for the management of litigation of the controller or a third party in court.

d. Fulfill legal and/or regulatory obligations.
The legal basis for this purpose is found in art. 6, par. 1, lett. c) of the Regulation, in particular:
- adempimento di un obbligo di legge a cui è soggetta SBB Ideas.

4. Nature of the provision of personal data

The provision of data directly provided by the User is optional. However, the failure to provide such data will result in the impossibility to receive responses to requests transmitted by the User.

5. Data processing methods

The processing of Users' data is carried out through the operations indicated in art. 4 of the Regulation and in particular: collection, use and processing, storage, consultation, transmission, anonymization and deletion. We also inform you that the User's data:

• will be processed in accordance with the principles of lawfulness, fairness, and transparency;
• will be collected for the legitimate purposes indicated above;
• will be adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• will be stored in a form that allows the identification of the User for a period not exceeding the achievement of the purposes as better defined in Paragraph 8 below;
• will be processed in such a way as to guarantee an appropriate security against destruction, loss, modification, unauthorized disclosure or access by third parties through technical and organizational security measures.

6. Communications of personal data

I dati personali degli Utenti saranno trattati, sotto l’autorità di SBB Ideas, dai dipendenti e collaboratori della stessa, in qualità di soggetti autorizzati al trattamento, appositamente nominati e istruiti.

Even without the User's express consent, SBB Ideas may communicate the User's data for the Purposes referred to in Paragraph 3 above to SBB Ideas' supervisory and/or control bodies, judicial authorities, and all other subjects to whom communication is mandatory by law for the fulfillment of the said Purposes, in their capacity as independent data controllers.

Furthermore, SBB Ideas may entrust certain personal data processing operations carried out for the Purposes referred to in Paragraph 3 above to categories of recipients, specifically appointed by SBB Ideas, if necessary, as data processors, including, by way of example and without limitation:

• the technical service providers of the Website;
• the hosting providers that offer services for the hosting of the Website.

7. Transfer of Personal Data

Data management and storage will take place on SBB Ideas servers located within the European Union and/or third-party companies appointed and duly designated as data processors.

The User's personal data will not be subject to transfer outside the European Union.

Where the User's personal data should be transferred to countries outside the EU, such transfer may only occur in accordance with the terms and guarantees provided for in Articles 44 – 49 of the GDPR.

8. Data Retention Period

The User's personal data will be stored and processed for the entire duration of navigation and, after its termination, for whatever reason, for a period not exceeding 24 months (hereinafter, “Retention Period").

At the end of the Retention Period, personal data will be deleted, unless there are further legitimate interests of the Company and/or legal obligations that make it necessary, subject to minimization, to retain it.

9. Third-party Websites

The terms of this policy apply solely and exclusively to the Website and not to other websites owned by SBB Ideas or third parties that the User may access through links contained on the Website.

The Website contains links that redirect to websites of third parties. SBB Ideas does not exercise any control over the content of such websites nor has any access to the personal data of users visiting them. SBB Ideas, furthermore, has no access to the personal data of visitors/users of the websites or to the social network accounts of its Users with whom SBB Ideas maintains contractual relationships, but only to aggregated and anonymous data that it can use to evaluate the performance and effectiveness of its services.

The present Privacy Policy, therefore, does not apply to such websites, applications and platforms.

The owners of the said websites remain, therefore, the sole and exclusive holders and responsible for the processing of personal data of their users, remaining SBB Ideas foreign to such activity as well as to any possible responsibility, prejudice, cost that may arise from its failure or incorrect execution.

We therefore recommend that you carefully read the relevant privacy policies and terms of use of these websites before providing or consenting to the processing of your personal data.

10. Users’ Rights

The User, in his/her capacity as data subject, in accordance with the law, shall always have the right to revoke any consent given, and may also exercise the following rights at any time (hereinafter, Rights):

• the “right of access” and specifically to obtain confirmation of the existence or otherwise of personal data concerning him/her and their communication in an intelligible form;
• the “right of rectification” i.e. the right to request rectification or, if desired, the integration of personal data;
• the “right to erasure” i.e. the right to request deletion, transformation into anonymous form of data processed in violation of law, including those for which retention is no longer necessary in relation to the purposes for which personal data was collected or subsequently processed;
• the “right to limitation of processing” i.e. the right to obtain from SBB Ideas the limitation of processing in some cases provided for under the Regulation;
• the right to request SBB Ideas to indicate the recipients to whom it has notified any corrections, cancellations, or limitations of processing (carried out in accordance with Articles 16, 17, and 18 of the GDPR, in compliance with the notification obligation, except where this proves impossible or involves a disproportionate effort);
• the “right to data portability,” i.e., the right to receive (or transmit directly to another data controller) personal data in a structured, commonly used, and machine-readable format;
• the “right to object,” i.e., the right to object, in whole or in part:
  • - to the processing of personal data carried out by SBB Ideas for its own legitimate interests;
  • - to the processing of personal data performed by SBB Ideas for marketing or profiling purposes.

11. How to exercise your rights and lodge a complaint with the Privacy Authority

The User may in any moment exercise his/her Rights in the following ways:

• via e-mail at: privacy@eatsplore.app ;
• via certified email (PEC), at: sbbideas@pec.it ;
• by regular mail, at register office of SBB Ideas S.r.l. in: Piazza della Repubblica 19 - 20124 | Milan (MI).