Data Controller

City Cards Italia s.a.s. -  Piazza della Repubblica,  32 - 20124 Milano (Italia)

Holder's email address: account@mycitycards.com

Types of Data Collected

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Web Site and warrants that he/she has the right to communicate or disseminate it, releasing the Owner from any liability towards third parties.

Method and location of data processing

Processing methods

The Data Controller adopts appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using computer and/or telematic instruments, with organisational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other subjects involved in the organisation of this Web Site (administrative, sales, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) also appointed, if necessary, Data Processors by the Data Controller, may have access to the Data. The updated list of Data Processors can always be requested from the Data Controller.

Legal basis for processing

The Controller processes Personal Data relating to the User where 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 authorised to process Personal Data without the need for the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such processing. However, this does not apply if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
• processing is necessary for the performance of a contract with the User and/or the performance of pre-contractual measures;
• processing is necessary for the performance of 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 public authority vested in the Controller;
• processing is necessary for the pursuit of the legitimate interest of the Controller or of third parties.

However, it is always possible to ask the Controller to clarify the concrete legal basis of each processing operation and in particular to specify whether the processing is based on law, required by a contract or necessary to conclude a contract.

Location

The Data are processed at the Data Controller's premises and at any other place where the parties involved in the processing are located. For further information, please contact the Data Controller.
The User's Personal Data may be transferred to a country other than the one where the User is located. To obtain further information on the location of the processing, the User may refer to the section on Personal Data processing details.
The User has the right to obtain information about the legal basis for the transfer of Data outside the European Union or to an international organisation under public international law or consisting of two or more countries, such as the UN, as well as about the security measures taken by the Controller to protect the Data.
Retention period

Data are processed and kept for the time required by the purposes for which they were collected.
Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User may obtain further information regarding the legitimate interest 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 keep the Personal Data for a longer period until such consent is revoked. Moreover, the Controller may be obliged to keep the Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period the Personal Data will be deleted. Therefore, at the end of this period, the right of access, deletion, rectification and the right to Data portability can no longer be exercised.

Purposes of the Data collected

The User's Data are collected to enable the Data Controller to provide the Service, to comply with legal obligations, to respond to requests or enforcement actions, to protect its rights and interests (or those of Users or third parties), to detect any malicious or fraudulent activities, and for the following purposes: Contacting the User, Registration and authentication provided directly by this Website, Access to accounts on third party services, Statistics, Displaying content from external platforms, Managing contacts and sending messages, Managing support and contact requests, Hosting and backend infrastructure, Remarketing and behavioral targeting, Infrastructure monitoring, Payment management, Commercial affiliation, Tag management, Interaction with social networks and external platforms, Transfer of Data outside the EU, Interaction with live chat platforms, Management of User databases, Interaction with data collection platforms and other third parties, Advertising, Registration and authentication, Management of web conferences and online telephony, Performance testing of content and functionality (A/B testing), Information gathering and Data Linking.

Personal Data Processing Details
Personal Data are collected for the following purposes and using the following services:

• Contacting the User

Contact form (this Application)
The User, by filling in the contact form with his/her Data, consents to the use of such Data to respond to requests for information, quotes, or of any other nature indicated in the header of the form.
Personal Data collected: email.

Mailing list or newsletter (this Application)
By registering for the mailing list or newsletter, the User's email address is automatically added to a list of contacts to whom email messages containing information, including of a commercial and promotional nature, relating to this Web Site may be sent. The User's email address may also be added to this list as a result of registering on this Web Site or after making a purchase.
Personal Data processed: email.
Legal basis for processing: Consent.

Tag management
This type of services is functional for the centralised management of tags or scripts used on this Website.
The use of these services entails the flow of the User's Data through them and, where appropriate, their retention.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland.
Legal basis for the transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.
Data Retention Period: 18 months.

Interactions with social networks
This type of service allows for interactions with social networks, or other external platforms, directly from the pages of this Website.
The interactions and information collected by this Website are in each case subject to the User's privacy settings for each social network.
This type of service may still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to disconnect from the respective services to ensure that the data processed on this Website is not linked back to the User's profile.

Twitter Tweet button and social widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services for interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data Processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook "Like" button and social widgets are interaction services with the social network Facebook, provided by Facebook, Inc.
Personal data processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transfer of Data outside the EU: Standard data protection clauses adopted by the European Commission.
Data Retention Period: 3 months.

Registration and Authentication
By registering or authenticating, the User allows this Website to identify him/her and give him/her access to dedicated services.
Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. Where this is the case, this Website may access certain Data stored by the third party service used for registration or identification.
Some of the services below may also collect Personal Data for targeting and profiling purposes; please refer to the description of each service to learn more.

Hosting and infrastructure
The purpose of these types of services is to host Data and files that allow this Website to function, enable its distribution and provide an infrastructure ready for use to deliver specific features of this Website.
Some of the services listed below, if any, may run on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
The infrastructure is located in France and is provided by the Company:

OVH Srl (Single Shareholder) Share Capital €. 10.000,00 i.v.
Tax Code and VAT No. 06157670966 Milan Company Register No. 06157670966
REA n° 1873458.
Registered Office: Via Carlo Imbonati, 18 20159 Milan

• Payment processing

Payment handling services allow this Application to process payments by credit card, bank transfer or other means. The data used for payment are acquired directly by the operator of the payment service requested without being processed in any way by this Application.
Some of these services may also allow for the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

PayPal (Paypal)
PayPal is a payment service provided by PayPal Inc., which allows the User to make online payments.
Personal Data collected: various types of Data as specified by the privacy policy of the service.
Place of processing: See Paypal's privacy policy - Privacy Policy.

• Platform and hosting services

These services are intended to host and operate key components of this Application, making it possible to deliver this Application from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, user registration management, comment and database management, e-commerce, payment processing etc. The use of these tools involves the collection and processing of Personal Data. Some of these services operate through servers located geographically in different places, making it difficult to determine the exact location where Personal Data is stored.

PrestaShop (PrestaShop S.A.)
PrestaShop is a platform provided by PrestaShop S.A. that allows PrestaShop S.A. to develop, operate and host an e-commerce web site.
Personal Data collected: various types of Data as specified in the service's privacy policy.
Place of processing: France

• Statistics

The services contained in this section allow the Data Controller to monitor and analyse traffic data and serve to keep track of the User's behaviour.

Google Ads conversion monitoring
Google Ads conversion monitoring is a statistics service provided by Google LLC or Google Ireland Limited, depending on where this Website is used, which links data from the Google Ads ad network with the actions performed within this Website.
Personal data processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States - Ireland
Legal basis for the transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

Google Analytics with anonymised IP
Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google uses the Personal Data collected in order to track and examine the use of this Website, compile reports and share them with other services developed by Google.
Google may use the Personal Data to contextualise and personalise the advertisements of its advertising network.
This Google Analytics integration anonymises your IP address. The anonymisation works by shortening the IP address of Users within the borders of the member states of the European Union or in other countries which are party to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and abbreviated within the United States.
Personal Data Processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States - Ireland.
Legal basis for the transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

Twitter Ads Conversion Tracking (Twitter, Inc.)
Twitter Ads conversion tracking is a statistics service provided by Twitter, Inc. that links data from the Twitter ad network with actions taken within this Website.
Personal Data Processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.

User ID Extension for Google Analytics
Google Analytics on this Web Site uses a feature called User ID. This allows for more accurate tracking of Users by assigning each one a unique ID for various sessions and devices, but in a way that does not allow Google to personally identify an individual or permanently identify a specific device.
The User ID extension also allows Data from Google Analytics to be connected with other User Data collected by this Website.
Personal Data Processed: Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States - Ireland.
Legal basis for transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

Facebook Ads conversion tracking (Facebook pixel) (Facebook, Inc.).
Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Facebook, Inc. that links data from the Facebook ad network with actions taken within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook Ads, Instagram, and Audience Network ads.
Personal Data Processed: Usage Data; Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States.
Legal basis for transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

Advertising report generation functionality in Google Analytics
Google Analytics on this Website has enabled advertising report generation capabilities, which collect additional information from the DoubleClick cookie (web activity) and device ad IDs (application activity). This allows the Owner to analyze specific Data related to Users' behaviors and interests (Traffic Data and Ad Interaction Data from Users) and, if enabled, Demographic Data (age and gender information).
Users can opt out of Google cookies by visiting Google's [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example);
Tracking Tool; various types of Data as specified by the privacy policy of the service.
Legal basis for processing: Consent.
Place of processing: United States - Ireland.
Legal basis for transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

Google Analytics Demographic Data and Interest Reports
Google Analytics Demographic and Interest Data Reports is an advertising report generation feature that makes Demographic and Interest Data available within Google Analytics for this Web Site (Demographic Data means Age and Gender Data).
Users can opt out of Google's cookies by visiting Google's [Ad Settings] (https://adssettings.google.com/authenticated).
Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.
Legal basis for processing: Consent.
Place of processing: United States - Ireland.
Legal basis for transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.

LinkedIn Conversion Monitoring (LinkedIn Corporation)
LinkedIn Conversion Monitoring is a statistics service provided by LinkedIn Corporation that links data from the LinkedIn ad network with actions taken within this Web Site.
Personal Data Processed: Usage Data; Device Information; Tracking Tool.
Place of processing: United States.
Legal basis for transfer of Data outside the EU: Standard Data Protection Clauses adopted by the European Commission.
Period of Data Retention: Retention of Data for as long as necessary to fulfill the purpose.
Place of processing: France

More information about Personal Data

• Sale of goods and services online

The Personal Data collected is used to provide services to the User or to sell products, including payment and possible delivery. The Personal Data collected to finalize the payment may be that related to the credit card, bank account used for the transfer or other payment instruments provided. The Payment Data collected by this Application depends on the payment system used.

User Rights

Users may exercise certain rights with respect to the Data processed by the Data Controller.
In particular, the User has the right to:

• Revoke consent at any time. The User may revoke the previously expressed consent to the processing of his/her Personal Data.
• object to the processing of their Data. The User may object to the processing of its Data when it is done on a legal basis other than consent. Further details on the right to object are provided in the section below.
• access to one's own Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing and to receive a copy of the Data processed.
• verify and request rectification. The User may verify the correctness of its Data and request that it be updated or corrected.
• obtain restriction of processing. When certain conditions are met, the User may request the limitation of the processing of its Data. In this case, the Data Controller will not process the Data for any purpose other than its preservation.
• Obtain the deletion or removal of their Personal Data. When certain conditions are met, the User may request the deletion of their Data from the Data Controller.
• receive their Data or have it transferred to another Data Controller. The User has the right to receive its Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transferred unimpeded to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, a contract to which the User is a party or contractual measures related thereto.
• Propose Complaint. The User may propose a complaint to the competent data protection supervisory authority or take legal action.

Details of the right to object
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller or in pursuit of a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users should note that if their Data were processed for direct marketing purposes, they may object to the processing without providing any reasons. To find out whether the Data Controller processes Data with direct marketing purposes, Users may refer to the respective sections of this document.

How to Exercise Rights
To exercise the User's rights, Users may address a request to the contact details of the Controller indicated in this document. Requests are filed free of charge and processed by the Controller as soon as possible, in any case within one month

Additional information on treatment

Defense in Court
The User's Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares that he/she is aware that the Data Controller may be obliged to disclose the Data by order of public authorities.

Specific Disclosures
Upon the User's request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual disclosures 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, i.e., 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 in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Responding to "Do Not Track" Requests
This Application does not support "Do Not Track" requests.
To find out whether any third-party services used support them, the User is encouraged to consult 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 on this page and, if possible, on this Application as well as, when technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller . Therefore, please consult this page regularly, referring to the date of last modification indicated at the bottom.

If the changes affect processing whose legal basis is consent, the Controller will collect the User's consent again, if necessary.
Definitions and legal references

Personal Data (or Data).
Personal Data is any information that, directly or indirectly, including in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data
This is the information automatically collected through this Application (including by third party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used in forwarding the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.. ) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the length of time spent on each page) and the details of the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters relating to the User's operating system and computer environment.

User
The individual using this Application who, except where otherwise specified, coincides with the Data Subject.

Data Subject
The natural person to whom the Personal Data refers.

Data Controller (or Processor)
The natural person, legal entity, public administration and any other entity that processes Personal Data on behalf of the Data Controller, as set out in this privacy policy.

Data Controller (or Controller).
The natural or legal person, public authority, service or other body which, individually or jointly with others, determines the purposes and means of the processing of personal data and the instruments adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application
The hardware or software tool by which Users' Personal Data are collected and processed.

Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.

European Union (or EU).
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.

Cookie
Small portion of data stored within the User's device.

Legal references
This privacy policy is written on the basis of multiple legislative orders, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy covers this Application only.