The following privacy policy is provided pursuant to Article 13 of the EU Regulation 2016/679 ("GDPR") and Legislative Decree 196/2003 and subsequent amendments and additions, ("Privacy Code"), which guarantee the protection of personal data, as well as the free movement of the same, and is intended to illustrate the methods of processing and categories of personal data concerning data subjects ("Users") who subscribe to Buzzoole's platform, via web and via App (hereinafter, the "Platform"), as a brand (hereinafter, the "Brand") or content creator (hereinafter, the "Content Creator").
This data will be processed by Buzzoole S.p.A., with registered office at Via Vannella Gaetani 27, 80121 Naples (NA), in its role as Data Controller (hereinafter, "Buzzoole" or "Data Controller"), which can be contacted at the following address: customercare@buzzoole.com.
According to the abovementioned legislation, your personal data’s processing will be based on the principles of correctness, lawfulness, relevance, transparency and protection of your privacy and rights.
1. Categories of personal data processed.
Browsing data: the Data Controller will process the User's browsing data on the Platform (e.g. IP addresses, the domain names of the devices used by the Users who connect), since the computer systems and software procedures in charge of the operation of this site acquire, in the course of their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols. This information is not collected to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow the identification of Users.
These data are used for the sole purpose of obtaining anonymous statistical information and to check its proper functioning, and are deleted immediately after processing. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Platform.
Data voluntarily provided by the User: the Data Controller will process the User's personal data that have been voluntarily provided by the User through the following ways:
- for registration to the Platform and request for services offered by Buzzoole, through the different functionalities of the Platform, upon completion of the Platform registration form. In this context, the Data Controller will acquire data differently depending on whether the User is a Brand or a Content Creator.
- In case the User is a Content Creator, the data will be acquired through registration to the
Platform by logging into an account present in a social network (by way of example,
Instagram) and, therefore, please refer to the relevant privacy policy of the social
network (Google / Youtube: http://www.google.com/policies/privacy;
Facebook: https://www.facebook.com/privacy/policy/;
Instagram: https://privacycenter.instagram.com/policy;
TikTok: https://www.tiktok.com/legal/privacy-policy-row;
Twitter/X: https://twitter.com/en/privacy). To register on the Platform, log in and collect data, Buzzoole uses the API services of the platform used by creator for the authentication: Facebook, Instagram, Youtube, TikTok, Twitter.
Creators can revoke that Buzzoole access to their data via the dedicated pages in the social platforms, as for example the Google security settings page at https://security.google.com/settings/ - In case the User is a Brand, the Brand will provide their identification and contact information (such as, by way of example but not limited to: first and last name) for the purpose of registration on the Platform.
2. Purpose and legal basis of data processing.
The Data Controller will process your personal data for the following purposes:
- to enable the normal operation of the Platform and the proper provision of the service for which it is intended, as well as for the possible defence of the Data Controller in court, in the event, for example, of hypothetical crimes committed against it.
- to enable registration to the Platform and related services offered by Buzzoole to Brands and Content Creators. The legal basis identified is the performance of a contract to which the data subject is a party and/or pre-contractual measures taken at the data subject's request [Art. 6 (1) (b) GDPR].
- upon your explicit and free consent, the Data Controller will process your data for direct marketing purposes by sending communications about news and market trends, having commercial purposes of services and/or products offered by Buzzoole, by automated means (e.g. email). The legal basis for the processing is found in Article 6 (1) (a) of the GDPR;
3. Rights of data subjects
We inform you that, in accordance with current regulations, you are granted the following rights:
- to request and obtain information about the existence of your data in the availability of the Data Controller, as well as access to such data;
- to request and obtain the amendment and/or correction of your personal data, if you believe that they are inaccurate or incomplete;
- to request and obtain the deletion of your personal data and/or the restriction of their processing, if they are no longer necessary for the processing purposes pursued, and once the retention period indicated in the previous paragraph has expired;
- for data processed through automated systems, to request and obtain such data in a structured and machine-readable format, as well as the transfer to another Data Controller.
These rights may be exercised, in the manner, under the conditions and within the limits set forth in Articles 12 and 23 of the GDPR, by writing to the Data Controller at the following address: customercare@buzzoole.com
We also inform you that in accordance with the regulations in force, you may lodge any complaints regarding the processing of your personal data with the Garante per la protezione dei dati personali (GPDP).
4. Data retention period.
Your data will be kept by the Data Controller for the period strictly necessary to achieve the purposes described above. In particular, the retention times for each purpose are indicated below:
- in relation to the purpose referred to in point a), for the proper functioning of the Platform, the Data Controller will retain your data for 30 days.
- in relation to the purpose referred to in point b), for the provision of the services requested from Buzzoole, the Data Controller will retain your data for the time as long as necessary for the execution of the contract and for a further period, equal to 10 years, from the termination of the contract, in order to comply with sector regulatory requirements (e.g. in accounting matters);
- in relation to the purpose referred to in c), for the purpose of direct marketing, the Data Controller will retain your data until your consent is revoked and, in any case, for a period not exceeding 24 months from the same;
- in relation to the purpose referred to in letter d), with reference to automated processing, the Data Controller will retain your data until you object and, in any case, for a period not exceeding 12 months.
5. Method of processing and Recipients of personal data.
We inform you that your data will be processed with the support of electronic means.
The data collected in this way will be processed for the above-mentioned purposes and may be communicated to persons appointed as Data Processors or Persons Authorized to Process, who are in charge of carrying out the above-mentioned processing activities, subject to appropriate instruction by the Data Controller.
The data may also be communicated to third parties, appointed as Data Processors, which the Data Controller uses to carry out the aforementioned activities. The list of Data Processors is available from the Data Controller and can be requested by contacting the following address: customercare@buzzoole.com.
6. Communication to countries outside the European Economic Area (“EEA”).
Data processed in the manner and for the purposes mentioned above will not be disclosed to countries located outside the European Economic Area ("EEA").
7. Data Protection Officer.
The Company has also designated, pursuant to Article 37 GDPR, a Data Protection Officer ("Data Protection Officer", hereinafter "DPO", from the English acronym).
The DPO can be contacted at the designated email address: DPO@buzzoole.com.