PRIVACY POLICY

pursuant to Articles 12 et seq. of Regulation (EU) 2016/679

ZAHEL TRUST AND FOUNDATION EOOD, in its capacity as owner of the processing of personal data (the Data Controller) in accordance with Article 4, paragraph 1, point 7, of Regulation (EU) 2016/679, issues this information to the User, namely all those who download the app SwattRacing.

Capitalized terms shall have the meaning ascribed to them in the Terms of Use.

The Data Controller may process the following personal data in electronic format: first name, last name, pseudonym, username, age, gender, e-mail address, Wallet address, profile photo, place and date of birth, geolocation data, utility token transaction data, etc.

Personal data collected is used for:

• guarantee the development of the SwattRacing;
• transfer utility tokens according to the terms and conditions indicated in the Terms of Use;
• carring out, eventually, a promotional service and newsletter, subject to the express consent of the User.

To provide its services, the Data Controller uses third party service providers of various kinds (so-called data processors). With each of them, the Data Controller enters into a contract that requires the utmost confidentiality and the adoption of special security measures in accordance with the guidelines prepared by the European Data Protection Board.

The data processors to whom the Data Controller may disclose personal data are:

• storage service providers (e.g.: AWS's cloud);
• consultants and professional service providers (e.g., professional accounting or legal firms);
• subjects that carry out activities of assistance to the customers (ex. call center, help desk, etc.);
• subjects who carry out marketing activities, market surveys or contribute to the promotion of SwattRacing or who provide commercial information (if the User has given specific consent to the processing for such purposes).

The list of data processors can always be requested from the Data Controller by writing to the addresses indicated in the following paragraph 8.

Personal data is not transferred outside the European Union. In this case, however, the Data Controller will notify the User and will take one of the measures provided for by law (standard clauses, communication to countries approved by the European Commission, BCR, express consent of the User).

Personal data is not subject to dissemination, except for express choice of the user.

Personal data of the interested parties registered on SwattRacing is kept for the time in which the registration is in force. Subsequently, the data is retained for a period of 10 years and in any case for the period necessary for the accrual of the statute of limitations on possible actions or claims of the User. In this case, the data is stored discreetly and subject to special access restriction measures.

The data collected for the newsletter service or for commercial communications is deleted when the User unsubscribes from this service.

Other retention periods are indicated in the cookie policy.

The data may be processed for a further period if the purpose of the processing changes (e.g., exercise of the User 's rights, litigation or threat of legal action, etc.).

In the latter cases, the data will be processed only for the time necessary to protect the rights.

The Data Controller processes personal data by virtue of the express consent given by the User as well as for the execution of the obligations undertaken with the Terms of Use.

Other processing can be performed by the Data Controller if required by law (e.g., billing data services) or by order of the authority (e.g., exhibition of information as part of investigations) or if foreseen by the contract.

The Data Controller collects the User's personal data related to the motor activity carried out when SwattRacing is active. These data are: route, duration, movement activity (e.g.: walking, running, cycling, etc.). The data thus obtained are subjected to an automated process of profiling to measure the intensity and frequency of athletic performance of the User in order to give him a score useful to participate in the engagement auctions on SwattRacing.

The score profiling algorithm is described in the [...] section of SwattRacing.

The Data Controller treats the personal data of the User for the profiling described above only after explicit and specific consent given by the User at the time of registration on SwattRacing. The above consent is necessary to play on SwattRacing and is therefore a necessary condition for the registration of an account on SwattRacing.

Pursuant to Articles 15 et seq. of Regulation (EU) 2016/679, the User may at any time request confirmation from the Data Controller as to whether or not personal data relating to him/her are being processed, specifying the purposes and categories of the personal data. In this case, the User may always:

• request access to and rectification of data if inaccurate and integration of incomplete data;
• request the cancellation of the personal data (on the occurrence of one of the conditions indicated in art. 17, paragraph 1, of the Regulation and in compliance with the exceptions provided for in paragraph 3 of the same article);
• request the limitation of processing (in the event of one of the cases indicated in art. 18, paragraph 1 of the Regulation);
• obtain a copy of the personal data in a structured and machine-readable format (in the event that the legal basis of the processing is the contract or the consent and the same is carried out by automated means - the so-called right to portability of personal data);
• oppose the processing in case of particular situations that concern him/her;
• revoke the consent (limited to the hypothesis in which the processing is based on consent).

In order to exercise the rights indicated in the previous paragraph, as well as to receive further information, the User may contact the Data Controller by writing to the e-mail address: […].

The User, in the event that he/she perceives an unlawful processing or in the event he/she believes that the Data Controller has not correctly responded to the exercise of the rights referred to in the previous paragraph, may lodge a complaint or appeal to the Italian Data Protection Authority pursuant to art. 77 of Regulation (EU) 2016/679 by following the procedures and forms published on the website garanteprivacy.it.

The User, moreover, can always apply directly to the appropriate Courts as provided for by art. 79 of Regulation (EU) 2016/679.

By accessing the Website, are sent from Satorlife’s servers to the terminals of the Users, the so-called "cookies", ie files that allow to obtain information about the pages that are visited to make faster use of various services (technical cookies).

In addition to using this type of cookie, Satorlife also use Google Analytics to understand how the Users interact with the Website platform and to provide them with information on products or services that may be of interest (third party cookies).

In the event that Users wish to prevent cookies from tracking the activity, is it possible to modify the browser settings. In case of deactivation of technical cookies is not guaranteed the proper fruition of the services offered on the site.

For further information on how to set the preferences, it is recommended to visit the following browsers:

• Chrome;
• Safari;
• Internet Explorer;