AGB's

PRIVACY POLICY

 

INFORMATION* ON THE PROCESSING OF PERSONAL DATA in accordance with Articles 13/14 EU Regulation 2016/679 “General Data Protection Regulation”

Accessing services provided by Hotel Sole srl, as long as accessing the web sites related to Hotel Sole srl, some personal data directly and/or undirectly identifying specif persons my be acquired. The Data Controller, Hotel Sole srl, viale Dante, 82 - Riccione, RN - I-47838, hotelsole@hotelsole.com, P.IVA 01727400408.



Dear guest,
the company Hotel Sole srl (VAT no.: 01727400408) with registered office in Via Dante, 82 - 47838 Riccione (RN) ITALY, as Data Controller, wishes to provide to you information on the use of your personal data that you provided and/or is referable to you at the point of booking and stay at our hotel.
Pursuant to Articles 13/14 EU Regulation 2016/679, the data controller company wishes to inform you that it will handle personal data provided by you or referable to you in accordance with the provisions set out by the law.
The regulation states that the processing of your personal data (personal details, place of residence, contact details, email, mobile, data relating to preferences, information relating to the booking, to your stay, navigation data etc.) will be characterised by principles of accuracy, permissibility, transparency and privacy protection.

Processing takes place manually and/or using IT tools,

and is done and retained for the purposes they have been acquired for, meaninge for the time strictly necessary to fulfill the relative purposes:
1. To obtain and confirm your booking of accommodations and other services, and to provide such services as requested. Since this processing is required to define our contractual relationship and to perform under our contract with you, your consent is not required, unless certain “sensitive” information is submitted. Should you refuse to submit your personal information, we will not be able to confirm your booking or provide you with the requested services. Processing shall cease once you check out, although some of your personal information may (or in some instances, has to) continue to be processed for the purposes and in the manner described below;
2. To comply with our “Public Safety Law” (Article 109 Royal Decree n. 773, 18/6/1931) which requires that we provide identification data of our guests to the police, for purposes of public safety, in the manner established by the Ministry of the Interior (Decree of 7 January 2013). Data submission is mandatory, and does not require your consent. Should you refuse to provide such information, we will not be able to host you in our hotel. Data acquired for such purposes will be retained by us to comply with a specific investigatory demands from a court or the police or government agency, for 10 years;
3. To comply with applicable administrative, accounting, and tax regulations. For these purposes, your consent is not required. Personal information is processed by us and/or our internal and external persons in charge of data processing, and is disclosed outside the company only when and if required by law. Should you refuse to submit the required data for the above purposes, we will not be able to provide you with the requested services. Data acquired for such purposes is retained by us for the required statutory period (10 years – or longer, in case of tax audits);
4. To speed-up check-in on your next visit to our hotel. For such purposes, upon obtaining your consent (which can be revoked at any moment), your information will be retained until revocation upon request, and will be used the next time you are our guest, for the reasons listed supra;
5. To allow you to receive messages and telephone calls during your stay. Your consent is required for such purposes. You can revoke your consent at any time. Such processing, where consent is granted, shall end when you check out;
6. For purposes of protecting persons, property, and company assets, using a video-surveillance system for some areas of the hotel, which are duly identified by signage. Your consent is not required for such processing because it is conducted pursuant to our legitimate interest to safeguard persons and property against potential violence, theft, robbery, damage, and vandalism. Surveillance is also conducted for purposes of fire prevention and occupational safety and health. Recorded images are erased after 24 hours, except on holidays or other days the business is closed; images are never retained for more than one week. These images are not subject to third-party disclosure, except as required to comply with a specific investigatory demands from a court or the police.
7. To manage surveys and/or evaluations regarding the quality of the services provided by Hotel Sole srl and/or the perception of its image as a company. This processing will be carried out on the basis of the legitimate interest of the data controller.
8. Profiling and marketing purposes (optional)
Upon your express authorisation, personal data (as per Article 4(1) of EU Regulation 2016/679) provided by you or referable to you at the point of booking and/or stay may be processed for the following additional purposes:
A) direct marketing activity via the sending of publicity/promotional material through the post; email/ sms/mms, mobile applications or other digital communication channels.
B) client profiling activity aimed at improving the supply of goods and services by Hotel Sole srl (client profiling).
Please note that the processing procedures above may be managed to include your consumer preferences to improve the efficiency of Hotel Sole srl commercial policies and services; consequently you may receive discounts, offers or targeted promotions on the basis of your preferences and consumption habits.
The provision of data for the purposes described in A) – B) is optional so that all hotel services can still be supplied, even where you refuse to authorise the processing for the purposes listed in this point. The legal basis for the processing is represented by your express consent given by ticking the appropriate clauses and completing the double opt-in procedure. Personal data under Article 4(1) EU Regulation 2016/679 provided by you or relating to you will be processed in compliance with the law for the period of time taken to complete the purposes listed in point 2) with regard to the principle of balancing the legitimate interests of the data controller with the rights and freedoms of the customer who is the data subject. Your data will be processed in accordance with the time frames set out in the legal provisions, or in the absence of specific regulations, your data will be processed for as long as necessary to complete marketing and profiling activities; the data controller company guarantees that the processing of the data will not take place for an indeterminate period of time. We acknowledge that you are entitled at any time to withdraw your consent to the activities mentioned in point 2) by means of a simple informal written communication sent to the contact details of the data protection officer as specified below in this policy.
In accordance with the law, any data which has been processed before the withdrawal of consent shall be made safe.
9. In the event of registration and/or access through a third-party account, Hotel Sole srl may collect and access certain information of the User's profile from the corresponding social network, solely for internal administrative purposes and/or for the purposes indicated above.
10. In those cases in which it is necessary to process the User's data for the fulfilment of a legal obligation or for the execution of the existing contractual relationship between Hotel Sole srl and the User, the processing would be legitimized as it is necessary for compliance with said purposes.

In those cases in which it is necessary to process the User's data for the fulfilment of a legal obligation or for the execution of the existing contractual relationship between Hotel Sole srl and the User, the processing would be legitimized as it is necessary for compliance with said purposes. Elsewhere, the processing undertaken in the performance of surveys and/or evaluations regarding the quality of the services provided by Hotel Sole srl and/or the perception of its image as a company will be carried out on the basis of the legitimate interest of the data controller.
The Data Controller will not transfer personal data in foreign Extra-UE countries where GDPR is not fulfilled but eventual case where your express consent will be required.

Further information and clarifications pertaining to the processing mentioned above are provided below:

– Personal data provided by you or referable to you may be processed employing partially or fully automated means through the use of hard-copy, electronic, and/or magnetic means.
– Personal data connected to you will not be circulated but may be passed or be brought to the attention of appropriately trained operators who form part of the data controller company and/or external parties collaborating with the companies as data processing officers or independent controllers such as – by way of example, which is not intended to be exhaustive:

  • Companies, firms and/or contractors engaged to process and manage personal data;
  • Companies, firms and/or contractors engaged in consultancy and/or technical, company or ICT management;
  • Other parties to whom it is necessary to pass data for the proper and complete fulfilment of the contractual relationship and/or to meet legal requirements and/or to achieve the specified purposes.

– You are also informed that you are entitled to make a request to the data controller company (Hotel Sole srl) for access to your personal data, rectification, deletion, restriction of data processed; you are, moreover, entitled to object to the processing of personal data and to exercise your right to portability. The rights contained in this paragraph may be exercised as provided for by Articles 15, 16, 17, 18, 20, 21 EU Regulation 2016/679 which we have reproduced at the foot of this policy document for your convenience. All the rights may be exercised in relation to the data controller company; you may also object to the supervisory authority under the national legislation in force.
– For any clarification and to exercise the rights above, you are free to apply to the Data Controller Hotel Sole srl who can be reached at Via Dante, 82 – 47838 Riccione (RN) ITALY, or on telephone no. +39 0541 692800 or via email at hotelsole@hotelsole.com.


This policy document complements and completes information already known to the data subject

EXTRACT FROM EU REGULATION 679/2016

Article 15 Right of access by the data subject The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed and, where that is the case, access to the personal data and the following information: a) the purposes of the processing; b) the categories of personal data concerned; c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations; (d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period; (e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing; (f) the right to lodge a complaint with a supervisory authority; (g) where the personal data are not collected from the data subject, any available information as to their source; (h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such data processing for the data subject. 2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. 3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form. 4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
Article 16 Right to rectification The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
Article 17 Right to erasure (“right to be forgotten”) The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies: a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; 4.5.2016 IT Official Journal of the European Union L 119/43 b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing; c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2); d) the personal data have been unlawfully processed; e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject; f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1). 2. Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. 3. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary: a) for exercising the right of freedom of expression and information; b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3); d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or e) for the establishment, exercise or defence of legal claims.
Article 18 Right to restriction of processing 1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies: a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data; b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead; c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims; d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject. 2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State. L 119/44 IT Official Journal of the European Union 4.5.2016 3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
Article 20 Right to data portability 1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where: a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and b) the processing is carried out by automated means. 2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible. 3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller. 4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
Article 21 Right to object 1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. 2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing. 3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes. 4.5.2016 IT Official Journal of the European Union L 119/45 4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information. 5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications. 6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.


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Cookies consist of portions of code installed in the browser that assist the Owner of the website in providing the service according to the purposes described. Some of the purposes for which the Cookies are installed may also require the User's consent.

Technical Cookies and Cookies to collect aggregated statistical information

1. Activity strictly necessary for the functioning of the service:
This Application uses Cookies to save the User's session and to carry out other activities that are strictly necessary for the operation of the same.
2. Activity regarding the saving of preferences and optimisation:
This Application uses Cookies to save browsing preferences and to optimise the User's browsing experience. Among these Cookies are, for example, those to set the language and the currency.


Other types of Cookies or third-party tools that might use them

Some of the services listed below collect statistics in aggregated form and may not require the consent of the User or may be managed directly by the Owner – depending on how they are described – without the help of third parties.
If any third-party operated services are listed among the tools below, these may be used to track Users' browsing habits – in addition to the information specified herein and without the Owner's knowledge. Please refer to the privacy policy of the listed services for detailed information.

Cookies usedby “hotelsole.com”

Third party profilation cookies

Google Analytics Cookies

Our web site implements Google Analytics by Google, Inc., a tool that helps website owners measure how users interact with website content. Please read the Google Analytics privacy document for more details about the data collected by Google Analytics at https://www.google.com/analytics/learn/privacy.html.

Google Adwords & Google Remarketing Cookies

Our web site could implement Google Adwords and Google Remarketing features. Both of them are managed and owned by Google Inc.. Further info available at https://support.google.com/adwords/answer/2407785?hl=en. Users can disable these related cookies in the "Settings" section of the web browser. In case of navigation problem please clear web browser's cahce and refer to https://tools.google.com/dlpage/gaoptout.

Plugin and Social widgets

Our web site could feature plug-in to allow social network users to share contents they like with "friends"/"followers", and/or provide "comment/like" features. These plug-in retain, manage and acces local on the user's computer stored cookies to allow the used social network to identify it's related members when interacting with thes plug-in.
"Like" Button (by facebook.com social network managed and owned by Facebook, Inc., 1601 S. California Ave, Palo Alto, CA 94304, USA).
“Tweet” Button by Twitter (by sito twitter.com, managed by by Twitter, Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA).
"g+1” Button (Google Plus social network, by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
“Instagram” Button (by Istagram social network, by Instagram, Inc., 181 South Park Street Suite 2, San Francisco, CA 94107 USA, controlled by Facebook, Inc.).
YouTube (by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA).
)
Our web site has no control about the data "fetched by" and "trasmitted to" the plug-in holder; to access the purposes of your data management and use please directly refer to provider privacy policies web pages:
- Facebook: http://www.facebook.com/about/privacy
- Twitter: https://twitter.com/privacy
- Istagram: https://help.instagram.com/155833707900388
- YouTube: https://support.google.com/youtube/answer/7671399?p=privacy_guidelines&hl=it&visit_id=0-636630367742014615-2116603040&rd=1
- g+1: http://www.google.co.uk/intl/it/policies/

Clicky

Our web site could use performance cookies provided by "use monitoring service" “Clicky”, in order to perform statystical statistical measures and trend relevation. Clicky is an analysis web tool that allows web sites managers to understand how visitors interact with the accessed web site. It allows to recognize and count visitors, as long as identify how the web users are suing the web site. This helps us in the continuos improvement of our web site, allowing, for instance, our users to easy find the information they are looking for. Further information can be found at http://clicky.com/terms

Mouseflow

Our web set could make use of Mouseflow cookie. Please refer to MouseFlow web site to verify how to disable this feature at http://mouseflow.com/opt-out/
Here below are enlisted cookiew that may be enforced by MouseFlow; these cookies are needed and essential to MouseFlow functionality, and there are no third party coookies installed:
mf_session: techinal cookie, for session retantion: is a cookie to identify browser session.
mf_user: techinal cookie, 90 days retention: cookie to identify new or old user.

CrazyEgg

Our web set could make use of CrazyEgg cookies, an on-line analysis service, by Crazy Egg, Inc. ("CrazyEgg"); the related cookies purpose is to analyze our we site use. Data is retained in pseudoanonym profiles. These pseudoanonym profiles are used to analyze users behaviour in order to enhace our offers and web site experience. Without expressed user's consent, These pseudoanonym profiles can not be related to other user's personal data we could have already collected in other different context. User's information about our web site use (including IP adress) that are generated by those cookies are transferred to CrazyEgg servers in the US and there stored. CrazyEgg will use these information to provide reports on our web site use and activities.
It is always possibile to perform the "opt-out" operation from CrazyEgg data retrival following indication provided at http://www.crazyegg.com/opt-out Further information about CrazyEgg privacy policy are available at: https://mixpanel.com/privacy/

 

On-line Booking Engines

Vertical Booking

This web site could make use of Vertical Booking, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. Generated cookies enforce the "shopping carter" facilities and are destroyed on navigation session end. All related systems (rooms, services, vouchers) only use a session cookie, PHPSESSID, that are destroyed at navigation session end, or at timout deadline. Further info at http://www.verticalbooking.com/

Bookingone

This web site could make use of Bookingone, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by Bookingone please refert to http://www.bookingone.it/
http://www.bookingone.it/privacy.html

Iperbooking

This web site could make use of Iperbooking, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by Iperbooking please refert to http://www.iperbooking.com/
http://www.iper.net/privacy.cfm

Simple Booking

This web site could make use of Iperbooking, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by Simple Booking please refert to http://www.simplebooking.it/privacy/

GP Dati

This web site could make use of GP Dati, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by GP Dati please refert to http://www.gpdati.com/home
http://www.gpdati.com/home/privacy

Booking Engine Ericsoft

This web site could make use of Ericsoft S.r.l. booking engine, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by Ericsoft S.r.l. booking engine please refert to http://www.ericsoft.com/it-it/Termini-di-utilizzo

BeGenius s.r.l

This web site could make use of BeGenius srl booking engine, a partner providing on-line booking engine platform; on-line booking are mandatory performed via it's intermediation and without it no on-line booking is possible. For further information about cookies generated by BeGenius srl booking engine please refert to http://www.begenius.it/

 

Newsletter and CRM

Mailup

This web site could make use of MailUp® (www.mailup.it), a professional solution to manage newsletters, email marketing campaigns, sms/text marketing campaigns, in order to analyze web trafic, optimize and enhace contets and quality of our messages. MailUp is a system localized in Italy and provided by NWEB SRL (www.nweb.it), that manages the system in full respect of the laws in order and in accordance with the recipient. Thw application dows not use cookies and uses the injection of unique tracking identifiers links instead and a transparent image 1 pixel wide, to allow the application to reveal the donwnload of the message's embedded images, allowing the application to track message opening by the recipient, or equivalent system based on css (style sheets) to detect message opening. These teechniques are usually known as "web bugs". The sender can potentially activate or not activate this kind of tracking, as is also able to provide further tracking codes, originated by web analytics systems. The information eventually stored by MailUp are the full time of the images/css download or the clicks on one of the embedded by the sender tracked links. Regarding SMS/TEXT, the full time of delivery to the recipent is stored. This detail is only available for a limeted numer of countries, including Italy, Spain France, Germay, Portugal, Portogallo, Uk. On MailUp servers the web log will also store the IP adress of the recipient used to download the image/css or the clicks on one of the embedded by the sender tracked links, with 6 month retantion. These pieces of information will be only available for giudiciary purposes when required in force of law requirements Further information available at http://www.mailup.it/informativa-privacy/utilizzo-dei-cookies.htm

PiùMail

This web site could make use of PiùMail, a professional solution to manage newsletters, email marketing campaigns, sms/text marketing campaigns, in order to analyze web trafic, optimize and enhace contets and quality of our messages. PiuMail is a system localized in Italy and provided by EDITA Srl (https://www.edita.it/), that manages the system in full respect of the laws in order and in accordance with the recipient. Thw application dows not use cookies and uses the injection of unique tracking identifiers links instead and a transparent image 1 pixel wide, to allow the application to reveal the donwnload of the message's embedded images, allowing the application to track message opening by the recipient, or equivalent system based on css (style sheets) to detect message opening. These teechniques are usually known as "web bugs". The sender can potentially activate or not activate this kind of tracking, as is also able to provide further tracking codes, originated by web analytics systems. The information eventually stored by PiuMail are the full time of the images/css download or the clicks on one of the embedded by the sender tracked links. Regarding SMS/TEXT, the full time of delivery to the recipent is stored. This detail is only available for a limeted numer of countries, including Italy, Spain France, Germay, Portugal, Portogallo, Uk. On PiuMail servers the web log will also store the IP adress of the recipient used to download the image/css or the clicks on one of the embedded by the sender tracked links, with 6 month retantion. These pieces of information will be only available for giudiciary purposes when required in force of law requirements Further information available at https://www.edita.it/privacy/

 

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http://www.youronlinechoices.com/it/le-tue-scelte/.

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This page is available, via hyperlink at the bottompage or in the menu, in all pages of this web site

 

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page. Therefore, please check this page often, referring to the date of the last modification given at the bottom. If a User objects to any of the changes to the Policy, he/she must cease using this Application and can request that the Data Controller removes his/her Personal Data. Unless stated otherwise, the previous privacy policy shall continue to be applied to all Personal Data collected up to that moment.


Revision 2018-05-25

 

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