Privacy Policy

For information regarding your collected personal data, the purposes, and the entities with whom the data is shared, please contact the Data Controller.

Data Controller
ABIRK SA  | Corso Elvezia 37 | 6900 Lugano

Types of Data Collected
The Controller does not provide a list of types of Personal Data collected.

Full details on each type of collected data are provided in dedicated sections of this privacy policy or through specific informational texts displayed before the data collection itself. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application. Unless otherwise specified, all data requested by this Application is mandatory. If the User refuses to provide them, this Application may be unable to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data without this affecting the availability or functioning of the Service. Users who have doubts about which Data is mandatory are encouraged to contact the Controller. The possible use of Cookies - or other tracking tools - by this Application or by third-party service providers used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, as well as for additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for third-party Personal Data obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate them, releasing the Controller from any liability to third parties.

Methods and Place of Data Processing
Processing Methods
The Controller adopts appropriate security measures to prevent unauthorized access, disclosure, alteration, or destruction of Personal Data. Processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Controller, in some cases, the Data may be accessible to certain types of persons involved in the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Controller. An updated list of these parties may be requested from the Data Controller at any time.

Legal Basis for Processing
The Controller processes Personal Data concerning the User if one of the following conditions exists:

The User has given consent for one or more specific purposes. Note: In some jurisdictions, the Controller may be permitted to process Personal Data without the User's consent or another legal basis specified below, as long as the User does not object ("opt-out") to such processing. This is not applicable if the processing of Personal Data is governed by European legislation regarding Personal Data protection.
Processing is necessary for the performance of a contract with the User and/or for pre-contractual measures.
Processing is necessary to comply with a legal obligation to which the Controller is subject.
Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller.
Processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party. However, it is always possible to ask the Controller to clarify the specific legal basis for each processing operation and in particular to specify whether the processing operation is based on the law, provided for by a contract, or necessary to conclude a contract.

Place
The Data is processed at the Controller's operating offices and in any other place where the parties involved in the processing are located. For further information, please contact the Controller. The User's Personal Data may be transferred to a country other than their own. To find out more about the processing location, the User can refer to the section concerning the details about Personal Data processing.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures taken by the Controller to protect the Data.
The User can check whether one of the described transfers takes place by examining the section of this document related to the details about Personal Data processing or by requesting information from the Controller using the contact details provided at the beginning.

Storage Period
The Data is processed and stored for the time required by the purposes for which it was collected.

Therefore:
Personal Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully performed.
Personal Data collected for purposes related to the legitimate interests of the Controller shall be retained as long as needed to fulfill such purposes. The User can obtain further information regarding the legitimate interests pursued by the Controller in the relevant sections of this document or by contacting the Controller.
When processing is based on the User's consent, the Controller may retain Personal Data longer until such consent is revoked. Furthermore, the Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the storage period, the Personal Data shall be deleted. Therefore, upon expiration of this period, the right to access, delete, rectify, and the right to Data portability cannot be exercised.

User Rights
Users can exercise certain rights regarding Data processed by the Controller.

In particular, the User has the right to:

Withdraw consent at any time. The User can withdraw previously given consent for the processing of their Personal Data.
Object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details about the right to object are provided in the section below.
Access their Data. The User has the right to obtain information about Data processed by the Controller, certain aspects of the processing, and receive a copy of the processed Data.
Verify and request rectification. The User can verify the accuracy of their Data and request its update or correction.
Obtain the restriction of processing. When certain conditions apply, the User can request the limitation of their Data processing. In this case, the Controller will not process the Data for any purpose other than its storage.
Obtain the erasure or removal of their Personal Data. When certain conditions apply, the User can request the erasure of their Data by the Controller.
Receive their Data or have it transferred to another Controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred without hindrance to another Controller. This provision is applicable when the Data is processed by automated means and the processing is based on the User's consent, on a contract of which the User is part, or on contractual measures connected to it.
Lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.
Details about the Right to Object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Controller, or for the purposes of the legitimate interests pursued by the Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are informed that if their Data is processed for direct marketing purposes, they can object to the processing without providing any reasons. To find out whether the Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

Exercising Rights
To exercise their rights, Users can make a request to the contact details of the Controller indicated in this document. Requests are processed free of charge by the Controller as soon as possible, in any case within one month.

Cookie Policy
This Application uses Cookies and other Identifiers. To learn more, the User can consult the Cookie Policy.

Additional Information about Processing
Legal Defense
The User's Personal Data may be used by the Controller for legal defense in court or in the stages leading to possible legal action arising from improper use of this Application or the connected Services by the User. The User declares to be aware that the Controller may be required to disclose the Data by public authorities' order.

Specific Information
Upon request from the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data.

System Logs and Maintenance
For operation and maintenance purposes, this Application and any third-party services it uses may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy
Further information related to the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.

Response to "Do Not Track" requests
This Application does not support "Do Not Track" requests. Users are encouraged to check whether any third-party services used support them by referring to their respective privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by informing Users through this page and, if possible, through this Application, as well as by technically and legally feasible, sending a notification to Users via one of the contact details in possession. Therefore, please frequently check this page, referring to the last modified date indicated at the bottom.

If the changes concern processing operations for which the legal basis is consent, the Controller will collect the User's consent again, if necessary.

Last Modified: October 29, 2020