- 1. Scope of application of this policy.
- 2. Data Controller.
- 3.Information we process.
- 4. Use and purpose of the information.
- 5. Provision of data.
- 6. Data of minors.
- 7. Data of minors.
- 8. Data transfer outside EU.
- 9. Personalization.
- 10. Use of data from Log-in with Google or Facebook.
- 11. Data Retention.
- 12. Your rights.
Privacy policy
Gentile utente/visitatore,
in the use of the services offered by Crubster we process some personal data concerning you, according to the methods listed in this statement.
We want you to understand what information we collect and how we use it, for this reason we have created this policy, with which we also clarify your rights and how you can intervene to exercise control of your data.
1. Scope of application of this policy.
This Privacy Policy applies to your use of www.crubster.com and any other site, application, or service provided by Crubster. However, the policy does not apply to links to third-party sites that you may access through our services.
2. Data Controller.
The data controller is Crubster S.r.l., with headquarters in via Carmelitani Scalzi 20 in Verona, Italy, email: info@crubster.com, pec: crubster@legalmail.it. You can contact us at these addresses for more information on how we process your data and to exercise your rights.
3.Information we process.
When you use the www.crubster.com website and any other website, application, or service provided by Crubster, we collect information that you voluntarily provide to us (e.g., registration data, content, media, etc.). We can combine this data to provide you with a better service, and collect data passively (for example through cookies and other tracking technologies) in order to offer you a more personalized service. When you use our services through redirection from third party websites or when you visit third party websites through our services, those third party websites may share information with us about your use of their services. Any information we receive from third-party websites may be incorporated into the information we provide to you.
Below is an example list of the data processed:
- Contact information (name, telephone number, postal and e-mail address)
- Username and password
- Account information managed by third party sites (eg Facebook) if used to authenticate you to the service
- Billing information
- Payment data
- Photos, videos, audio, texts used in reviews and posts in our services
- Geolocation information
- Device information (e.g. IP address, language preferences, any device IDs, ad IDs)
- Your activity on the Crubster services and voluntarily disclosed by you
- Information provided and managed for customer assistance (e.g. calls, emails, communications managed via application)
- Information provided and managed for dispute resolution activities (e.g. calls, emails, communications managed via application)
4. Use and purpose of the information.
The processing of your data is aimed at the correct provision of the web/application service provided by Crubster and the user registration procedures.
On the basis of Crubster's legitimate interest we may use some data (to the minimum extent possible) in order to improve and develop our service, as well as to prevent fraud or infringement, as well as to send you occasional communications relating to our service to the contacts you have provided us iwhen registering.
Except for the data necessary for the correct functioning of the web service and/or application, you can express your consent to the processing of further data, for example to receive communications or notifications and to obtain a personalized experience regarding advertising and marketing messages, provided by Crubster or a third party. Consent can be issued and subsequently managed through the Crubster application or, in some cases (e.g. revocation of consent for receiving newsletters), directly via email.
For the best functioning of the site and/or the application, you could also, freely and optionally, provide data relating to your position, and grant access to peripherals of your device such as a camera, microphone (to insert multimedia content into the application more quickly) and push notifications.
Crubster also processes the data in order to fulfill its legal obligations.
Where, in accessing the service, the user stipulates a contract (e.g. sponsorship) with Crubster, the latter will process the data necessary for the execution of the contract or for pre-contractual measures adopted at the request of the data party.
Below is an example list of the data processed for each category:
| Execution of the contract | ● Allow registration and management of accounts, access to our services and their use ● Process payments, assign credits ● Improve our services ● Ensure the security and integrity of our services ● Communicate with users ● Show contents (even when they contain personal data such as images, videos, audios, texts etc.) ● Respond to questions and comments ● Resolve disputes |
| Legitimate interest | ● Provide a personalized experience by grouping users based on usage, interests and preferences ● Send information communications to users regarding, for example, news relating to our services or offers, etc. ● Prevent fraud and other potentially illegal or unauthorized activities |
| Fulfill a legal obligation | ● Comply with applicable laws ● Provide payment services and carry out related anti-money laundering controls |
| Consensus | ● Send newsletters and commercial communications ● Provide you with personalized advertising ● Obtain data from the sensors of the devices on which our application is installed (e.g. position while the application is open, audio and video when the user enters such content directly from the application) ● Allow push notifications on devices where our application is installed |
The processing can be carried out with or without the aid of electronic tools. The processing is carried out by Crubster, by the persons in charge of the same expressly authorized and/or by additional subjects appointed as external data processors (you can ask for more information at the contact details indicated in this policy).
5. Provision of data.
To access our service it is necessary to provide some data (contact information and, in case of payment, billing and payment data), the provision of this data is strictly necessary for the purpose of accessing the services offered by Crubster. Optional data is clearly identified in the registration forms. Any refusal by the data subject to provide the necessary personal data will make it impossible to access the services offered by Crubster (and/or, where appropriate, the contractual relationship with Crubster). Optional data can instead be freely granted or denied by the data subject. However, it should be noted that the experience of using the service could be affected by the failure to provide some optional personal data.
When using our services you may voluntarily (and optionally) decide to share other data with us, such as video, audio, images and textual content, or data obtained from your device such as your location.
Crubster does not process special categories of personal data (we refer to data revealing racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, relating to health or sex life, biometric data and genetic). We invite you not to share them on the app (for example, avoid talking about your food allergies in reviews) should you still make this data publicly available, we will process it in accordance with and within the limits of the regulatory provisions that allow data belonging to categories to be processed particulars made manifestly public by the data subject (you can still freely decide to remove them or have the content anonymized).
6. Data of minors.
The minimum age to use Crubster's services is 14 years old. If we should find personal data relating to minors under the age of 14 on the service, we will take appropriate measures to arrange for their cancellation. Parents or persons responsible for minors under the age of 14 whose data have been processed on the service can contact us at the addresses indicated in this statement to obtain support in deleting the data and/or profiles created.
7. Data of minors.
Personal data may be communicated for the purposes referred to in this policy to external collaborators and, in general, to all those public and private subjects to whom the communication is necessary for the correct fulfillment of the purposes indicated in this policy. Personal data is not subject to disclosure, except for the public data of the user profile and for the contents that the user decides to make public.
Below are a number of instances in which we share your information with third parties:
| Suppliers | We may share information with certain suppliers employed to guarantee or improve the use of the services offered (e.g. bank intermediaries or subjects who provide assistance to outbound users), or to guarantee the security of the service (e.g. external companies that deal with fraud detection). |
| Commercial partners | We may share, with your consent, information with selected and reputable business partners. The sharing of such data is based on your consent. Crubster, while selecting its commercial partners, is not able to guarantee from them a level of protection equal to the one it offers itself, nor is it responsible for their behavior. |
| Ad networks | In providing its services, Crubster may work with advertisers and third-party advertising service providers to target ads to you and measure performance. The relative identifiers and/or cookies could be shared by Crubster with these third parties to allow them to carry out advertising activities subject to the user's consent, which can be expressed through the application and/or through a specific cookie banner present on the website (you can request more information from contact details indicated in this statement). |
| Other Third Parties | We may share data with external websites with which you interact through our site (for example to obtain a percentage of the purchases you have to make on third-party sites reached through our platform, without this involving an increase in the final price for you) . However, keep in mind that, in providing its service, Crubster may present users of the site/application with links that refer to third-party sites/applications. This policy does not apply to these sites/applications. You will find the relative privacy policy applicable in each third-party site/application. |
8. Data transfer outside EU.
Your personal data will not be transferred outside the European Union. In some cases, Crubster may transfer personal data outside the European Union through selected technological partners, to countries for which an adequacy decision has been issued or on the basis of standard contractual clauses approved by the European Commission and which present additional guarantees based on the sorting of destination of the data (you can request more information at the addresses indicated in this statement).
9. Personalization.
In order to offer you a service as much as possible in line with your preferences, we may use the data you share with us and data relating to how you interact with our services (e.g. data we acquire from cookies, social interactions, usage times, etc. ) in order to create a user profile on the basis of which to personalize your experience on the platform and meet your tastes.
You can always intervene manually on the categories on which this profile is based within the application settings menu.
Also take into account that some third-party services used on the platform (e.g. Advertisers and advertising service providers) could use their user profiles to propose more relevant advertisements, subject to your consent.
We specify that Crubster does not currently make automated decisions, including profiling, which have legal or similar effects for users.
However, we are sensitive to the requests we receive and we do everything possible to ensure the transparency of the fully or partially automated decisions we take, regardless of their effects.
10. Use of data from Log-in with Google or Facebook.
Crubster uses and saves information relative to the user and his contacts recieved via Google APIs and adheres to Google API Services User Data Policy, including the Limited Use requirements and the respective policies by Facebook.
11. Data Retention.
Crubster retains data relating to your use of its services for as long as necessary to fulfill the relevant purposes described in this Privacy Policy and to the extent required (or permitted) by law, such as for accounting and tax purposes or as otherwise communicated.
Upon your request to close your account and delete your profile information, we will delete any information that we are not required or permitted to retain by law within the six month deadline.
12. Your rights.
At any time, you can exercise the right to:
- ask for confirmation of the existence or otherwise of your personal data on our systems;
- obtain information about the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients to whom the personal data have been or will be communicated and, when possible, the retention period;
- obtain the rectification and cancellation of data;
- obtain the limitation of the processing;
- obtain data portability, i.e. receive the data in a structured format, commonly used and readable by an automatic device, and transmit them to another data controller without impediments;
- oppose the processing at any time and also in the case of processing for direct marketing purposes;
- oppose an automated decision-making process relating to natural persons that has legal or similar effects, including profiling (we specify that Crubster does not currently take decisions of this type, we are in any case sensitive to users' requests and we do everything possible to guarantee the transparency of fully or partially automated decisions, regardless of the effects thereof);
- revoke the consent at any time without prejudice to the lawfulness of the processing based on the consent given before the revocation;
- propose a complaint to the supervisory authority (Privacy Guarantor - www.garanteprivacy.it).
You can exercise your rights by sending a request to Crubster at the contact details indicated at the beginning of this statement.
This policy was updated on 01.01.2023
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