Privacy Policy
Privacy Policy
Policy on personal data processing based on REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 (GDPR)
Introduction
The following Terms and Conditions of Sale regulate the sale on this Application “learnitalianappylanguage.blogspot.com” (Application). Theia Moira Ltd, with a registered office in Malta, Triq il Kullegg Sliema SLM1379 Malta VAT number MT 2168-2832, (Company)
The Company shall acquire and process your data to process your request to purchase or download resources through the Application.
Registration
The Company shall process the personal data provided by you to enable you to register with the Application and make use of the services restricted to registered users.
Marketing
If you provide your explicit consent, the Company shall process your data to send you promotional communications and/or newsletters regarding products offered for sale by the Company or by third parties.
Soft Spamming
The Company is entitled to sell its products using the email that you communicated during your first purchase on the Application if this product is similar to the first sale (soft spamming). You may at any time notify the Company of your refusal to receive this type of communication.
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Pursuant to the GDPR, the Seller shall process the personal data provided by you as indicated in this privacy policy.
Article 1. Purpose of the processing. Legal basis. Mandatory or optional nature of data provision and consequences of any refusal.
The Company shall process the personal data provided by you for the following purposes:
a. to enable you to register with the Application and make use of the services restricted to registered users and for administrative/accounting purposes. The legal basis for the processing is the Company’s commitment to be compliance with a legal obligation or to take steps at the request of the data subject before entering into a contract, as the case may be;
b. in the case of the execution of an online purchase order, to allow the conclusion of the purchase contract and the proper execution of transactions related to the same (and, where necessary, to fulfil tax obligations). The legal basis for the processing is the Company’s commitment to compliance with a legal obligation or to perform a contract to which the data subject is a party;
c. limited to the email address provided by you when purchasing or downloading products offered on the Application, to enable the direct sale of similar products (soft spamming), without requiring your express and prior consent and provided that you do not exercise your right to object. The legal basis for the processing is the Company's legitimate interest in performing these activities. This legitimate interest is equal to the user's interest in receiving "soft spam" communication;
d. if you provide your explicit consent, for the Company to send you a newsletter for market research purposes also aimed at evaluating the level of customer satisfaction and to send you promotional communications about the products of the Company and/or third parties, by email (marketing purposes); The legal basis for the processing is your consent;
e. if the chat service is operational, for the Application to allow the activation of the service, through which you may contact the Company. The legal basis for the processing is the Company's legitimate interest in performing these activities. This legitimate interest is equal to the user's interest in using the chat service of the Website;
f. to respond to your requests through the customer care service. The provision of data is purely optional. However, as the said processing is necessary to respond to your request, your refusal to provide the relevant data will prevent you from obtaining an answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest in performing these activities. This legitimate interest is equal to the user's interest in using the customer care service of the Website;
g. to answer your requests by email, or by telephone. The provision of data is purely optional. However, as the said processing is necessary to respond to your request, your refusal to provide the relevant data will prevent you from obtaining an answer from the customer care of the Company. The legal basis for the processing is the Company's legitimate interest in performing these activities. This legitimate interest is equal to the user's interest in receiving an answer from the Company.
The provision of data for the purposes set out in at Point a) and b) is purely optional. However, as the said processing is necessary in order to provide the online purchasing your refusal to provide the relevant data will prevent you from completing an online purchase.
Consent for marketing purposes is purely optional. Failure to consent will have the following consequences.
Failure to consent to the processing of personal data for marketing purposes will prevent you from receiving promotional communication and newsletters regarding products of the Company and/or third parties and will prevent the Company from carrying out market research purposes aimed at evaluating the level of customer satisfaction.
It is understood that the Company may use your data to comply with legal obligations and to perform the purchase contract.
You may revoke your consent using the relevant link indicated in any promotional email sent by the Company.
Payment Card Data
To make a payment through one of the payment cards offered on the Application, you shall enter the data of the payment card directly on a page that will communicate through a secure encryption protocol with the payment service provider (which will act as an independent data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way.
In execution of the legal obligations provided for by Directive 2015/2366/ (EU) on payment services in the internal market (PSD2), You are informed that concerning purchases made on the Application by credit card, data necessary for the conclusion of the purchase process may include the phone number communicated by the User, or a different personal data necessary to complete the purchase process. To allow you to complete the purchase, the payment institution in charge of managing the transaction will send you an authentication code, which must be reported by the User during the purchase process to meet the authentication criteria provided by PSD2 (Strong Customer Authentication). The processing of your data for these purposes has as its legal basis the fulfilment of legal obligations and does not require your consent.
To provide the above-indicated data is necessary to make purchases on the Application.
PayPal
The User may make purchases using PayPal. In this event, you will be directed to a page outside the Website, where you must indicate the personal data requested by PayPal to complete the purchase process (PayPal will act as a data controller). These data will not pass through the server of the Company which, therefore, will not process such data in any way. To provide the above-indicated data is necessary to make purchases on the Website.
Special Categories of Personal Data. Judicial Data.
The Company does not process special categories of personal data or judicial data.
Geolocation
You may receive a notification on your device (fixed and/or mobile) which will allow the identification of the device itself (Geolocation). You may allow or refuse such a setting. Your choice will not affect the functionality of the Site. The data relating to the position of the device will not be collected and or stored by the Company. The legal basis for the processing is the legitimate interest of the Company in providing services appropriate to the position of the User. This legitimate interest is equal to the User's interest in receiving services as relevant as possible to his or her position.
Article 2. Methods of Processing Personal Data
The processing of your data will be carried out by electronic or automated means, in the manner and with the appropriate tools to ensure security and confidentiality by the GDPR.
The information and methods of processing will be relevant and not excessive in relation to the type of services provided. Data will be managed and protected in environments where access is under constant control.
Article 3. Data Disclosure
For the purposes described in this privacy policy, the personal data provided by you may be disclosed or communicated to the following parties:
1. to all those parties (including Public Authorities) that have access to the data by regulatory or administrative measures
2. to third parties in charge of printing, enveloping, shipping (e.g., suppliers, even concerning drop shipping activity) and/or delivery and/or collection of products purchased through the Website
3. to forwarding agents and to parties responsible for the delivery and/or collection of the products purchased
4. to parties who process online payment transactions
5. to companies, consultants or professionals in charge of the installation, maintenance, updating and management of the Company's hardware and software or which the Company uses for the provision of its services
6. to the companies that send the newsletters and/or other informative communications transmitted on behalf of the Company
7. to the employees and/or collaborators of the Company
8. to the company in charge of the customer care service
9. companies managing online payment transactions
10. third parties in charge of repairing damaged products or products subject to the legal guarantee of conformity
11. to all those public and/or private parties, natural and/or legal persons (legal, administrative and tax consultancy firms), where the communication is necessary or of practical use for the correct fulfilment of contractual obligations undertaken about the services provided through the Website, and of legal obligations.
Your data may be disclosed only in anonymous and aggregated form for statistical or research purposes.
Article 4. Data Controller
You can contact the Company, as a Data Controller, at the following addresses:
by email, writing to: info@appylanguange.com
by selecting the Application Contact Form;
You may address requests relating to the processing of your personal data to both the Data Controller and the Data Protection Officer.
Article 5. Data Storage
Personal data will be stored according to the following: (i) for marketing purposes, until consent is revoked. For inactive users, personal data will be deleted after one year from the sending of the last email that may have been viewed; (ii) for the purpose of executing the sales contract, for 10 years from the date of receipt of the purchase order; (iii) for the purpose of legal defence, until the judgement becomes final; (iv) for the purpose of complying with the law, for the time necessary for this purpose; (v) for the purpose of executing any service requested through the Website, for the time necessary to execute the request.
Article 6. Rights of the Data Subject
Pursuant to GDPR (Article 13), you have the right to:
1. request access to and rectification or erasure of personal data or restriction of processing or object to their processing, in addition to the right to data portability;
2. withdraw consent at any time without prejudice to the lawfulness of processing based on consent given prior to the withdrawal;
3.lodge a complaint before a supervisory authority (e.g. the OIDPC, Office of the Information and Data Protection Commissioner).
The above-mentioned rights may be exercised by making a request to the contacts indicated above.
Article 7. Amendments
The Company reserves the right to change this privacy policy at any time, giving suitable notice to users and ensuring in any case adequate and similar protection of personal data. In order to view any changes, you are invited to regularly consult this privacy notice.
Definitions and legal references
This Application (or this Application)
The property that enables the provision of the Service.
Agreement
Any legally binding or contractual relationship between the Owner and the User, governed by these Terms.
Business User
Any User that does not qualify as a Consumer.
European (or Europe)
Applies where a User is physically present or has their registered offices within the EU, regardless of nationality.
Owner (or We)
Indicates the natural person(s) or legal entity that provides this Application and/or the Service to Users.
Service
The service provided by this Application is described in these Terms and on this Application.
Terms
All provisions applicable to the use of this Application and/or the Service as described in this document, including any other related documents or agreements, and as updated from time to time.
User (or You)
Indicates any natural person or legal entity using this Application.
Consumer
Any User qualifying as a natural person who accesses goods or services for personal use, or more generally, acts for purposes outside their trade, business, craft or profession.