Privacy Policy and Processing of Personal Data

Foreword

This Privacy Policy (the “Policy”) describes how we collect, use, process, store and protect your personal data in connection with your access to the www.baiabasa.com website (the “Site”).

The Information is provided to users (the “User” or “Users”) pursuant to Regulation (EU) 2016/679 (General Data Protection Regulation, “GDPR”), Legislative Decree 196/2003 (“Privacy Code”) and subsequent amendments and further applicable legislation on the protection of personal data, including the General Provision of the Guarantor for the protection of personal data of 8 May 2014 on cookies.

What is described in this Policy applies to all sites as well as any application, service or tool (collectively “Services” or “Platforms”) Baiabasa, regardless of the technical means of access and use (for example, via mobile devices).

1. Data Controller and Data Protection Officer (DPO)

Baiabasa, in the person of its legal representative pro tempore, is the data controller for the purposes of this informative note.

Baiabasa reserves the right to designate a Data Protection Officer (DPO). The User may contact the Data Controller for matters relating to the processing of personal data referred to in this Policy, at privacy@baiabasa.com.

2. Personal data processed

Baiabasa processes personal data provided directly by the User, data collected automatically through the User’s devices, including mobile devices, and User data possibly collected by third parties.

Personal data provided by the User

• Account Information. When you register a new account on the Site, we may ask you to provide certain information such as your first name, last name, date of birth, social security number, address, business phone number, mobile phone number, business activity, job title, and email address;
• Communications with Baiabasa: When you communicate with Baiabasa , you may be provided information through communications, chat with support (or otherwise) or during troubleshooting.

Personal data collected automatically when you use the Site

• Site Usage Information. We collect data when you interact with our Services and communicate with Baiabasa. This data is what we necessarily collect through the Site and devices (including mobile devices) you use when accessing the mobile version of the Site. These may include: unique device ID or code, device type, originating URL, IP address.
• Log Data and Device Information. We automatically collect log data and device information when a User accesses and uses the Site, even if the User has not created an account or logged in. Such information includes, among other things: information about how the User used the Service, IP address, date and time of access, hardware and software information, device information, unique identifiers, crash data, cookies, and the pages the User viewed before or after using the Services. We use cookies and other similar technologies, including, for example, web beacons, pixels, and mobile device identifiers to collect and process this data to capture data about the pages and links you visit and other actions you take when using our Services, in accordance with this Policy. For more information about our use of such technologies, please see our Cookie Policy below Insert link.
• Data that identifies you, such as your name, address, telephone numbers, email addresses, User name or VAT number/tax code and corporate data that you may wish to send us that you provide when setting up your Baiabasa account or subsequently, plus additional identifying data that you provide when using our payment services as a seller.
• Data related to offers, purchases or sales that you provided during a transaction. Content you share with other users through our Home, Profile or Messaging tools.
• Financial information (e.g. credit card and bank account numbers, payment details) provided for a transaction.
• Shipping, billing and other information you provide for the purchase or shipment of an item, as well as information required for customs clearance (such as tax or other identification numbers) and related shipping information (such as tracking number and tracking number) if the item was shipped through one of our programs.
• In some cases: age, gender, country of birth, nationality, employment status, family status, interests and preferences.
• In the event of Dispute Resolution or by updating or adding information to your Baiabasa account, participating in our business community discussions, user chats, information requests, dispute resolution, Customer Service calls recorded with your consent, or if you contact us for any other reason regarding our Services.

Other data that the law requires or authorizes us to collect and process and that is necessary for your authentication or identification, or for verification of the data we collect.

 

Personal data collected by third parties

Social Media. We give the opportunity to use social media sites to access the Baiabasa Platform (e.g. through the Facebook Connect feature), to link your user account to the relevant social media site and to share content via plug-ins provided by the social media site. In addition, we use social media sites to promote our activity on dedicated Baiabasa pages (e.g. on Instagram). Such data processing generally takes place in co-ownership between Baiabasa and the social media, which jointly determine the purposes and means of processing. As the case may be, the relevant social media allow Baiabasa to access certain data about the user that they collect and process (profile name, profile picture, city, account registration email address, gender, date of birth, friends and contacts on social media, content visited or liked, and data on ads shown and other information that the user makes publicly accessible on social media) as part of the provision of their services, depending on the data protection settings chosen by the user via the relevant social media. Through the data protection settings made available by social media, the user has the ability to control the personal data that he or she allows Baiabasa and the social media to access.

We make use, in particular, of the following social media, whose links to their respective policies on the processing of personal data are given below:

– Facebook, Ltd. and Instagram: https://it-it.facebook.com/help/325807937506242

– Linkedin https://www.linkedin.com/legal/privacy-policy

– Twitter Privacy (twitter.com);

– Instagram InstagramPrivacy Policy – Termly

3. Purpose of the treatment

We use your personal information for a variety of purposes related to the provision and promotion of our Site.

In particular, we process your personal data for the following purposes:

Delivery of Services

• Delivery of the Service as per the General Conditions of Service.
• Profiling based on interactions with our Site, searches, profile data and preferences, and other content you provide to us in order to: (i) personalize your experience (such as organizing search results or displaying works based on searches based on your tastes – not for related marketing communications); (ii) enable the operation of the Baiabasa algorithm .
• Sending service or support messages such as updates, security alerts, and account notifications.
• Customer service.

Legal basis: necessary for the execution of the service contract between Baiabasa and the User.

• Improvement of services.
• Exercise of rights and defense in court by the owner.
• Prevention of fraud, spam, abuse, security incidents and other activities that are potentially harmful to the Site and the User.
• Monitoring restrictions on selling outside of Baiabasa and any breaches of our terms and conditions or applicable legislation.
• Statistical elaborations on anonymised and aggregated data.
• Provision of our payment services.
• Resolving issues related to your Baiabasa account , resolving disputes, providing other services within Customer Service and resolving rate issues. For this purpose, we may contact you by notification via email, phone, SMS, push notification on your mobile device or by mail. If we contact you by phone, we may use for efficiency reasons automated calls with tape announcements or automated text messages in accordance with our User Agreement and Payment Services Agreement, to the extent permitted by applicable law.
• Processing of general location data (such as IP address or zip code) for the purpose of providing location-based services (such as radius search and other personalized content based on general location data).
• Posting and promoting listings and related content on the sites or third party operators of sites, applications, services and tools with which we partner. When we share your ad content and any related personal data with third parties, we do so based on an agreement that limits the third party’s use of such personal data to the purposes necessary to fulfill its contractual obligations to us. Third-party providers are contractually obligated to process this data by protecting it with appropriate security measures. Third-party vendors are strictly prohibited from passing on personal data contained in your advertisements to other third parties.

Where necessary, we pass on your personal data to data controllers and the following recipients for one or more of the purposes described above:

Other Baiabasa users only in case of litigation

External service providers and shipping companies (such as DHL, UPS, etc.)

Payment service providers including companies in the PayPal Inc. group.

External operators of sites, applications, services and tools

 

Legal basis: legitimate interest of the holder.

The provision of data for the purposes of providing the services listed above is required for the execution of the contract between Baiabasa and the User. Failure to do so would make it impossible to execute the contract.

Marketing and profiling

• Contact you via email, telephone, SMS, MMS, push notifications, messaging systems (such as Whatsapp), social media, regular mail or other available means to: (i) send advertising messages; (ii) learn about the User’s opinions through surveys or questionnaires and to inform about our services; (iv) commercial communications through social media platforms (such as Facebook, Twitter or Google).
• Perform profiling based on the characteristics and preferences of the User (based on the information provided by the User, his interactions with the platforms automatically detected by Baiabasa, information obtained from third parties and search history) to send targeted promotional messages, marketing, and other information that we believe may be of interest to the User.
• Contacting you about public interest issues or other events in connection with your ability to use our services. This may include inviting you to participate in an exhibition or other public interest related campaign.
• Manage referral programs, rewards, surveys, sweepstakes or other promotional activities or sponsored events.
• Measure the performance of our email marketing campaigns (e.g. by analyzing open and click-through rates) customize, measure and improve our advertising.

Legal basis: explicit informed consent of the User possibly given prior to processing.

• Contact the User via email, telephone, SMS, MMS, push notifications, messaging systems (e.g. Whatsapp), social media, regular mail or other available means to present the User with commercial offers.

Legal basis: legitimate interest of the holder.

The provision of data for the purposes outlined above is optional, but failure to provide such data would prevent Baiabasa from sending the User marketing communications in the forms and limits outlined above.

• Provision of our Services, including, without limitation, activating and executing transactions with other users (including transmitting personal information to other users as necessary to execute the transaction, including in the case of terminated, failed or subsequently cancelled transactions), providing and enhancing features such as payment processing, ratings and Baiabasa account management , providing other services that you may use (as described in connection with such services) and activities to ensure the functionality of our Services.
• Delivery of purchased items through logistics/shipping service providers, including delivery notifications (such as tracking number), to the extent permitted by applicable law without your consent.

 

We process your personal data in accordance with the legal obligations to which we are subject. This includes the following purposes:

Participation in proceedings (including judicial proceedings) conducted by public authorities or government agencies, in particular for the purpose of detecting, permitting the investigation and prosecution of unlawful conduct.

Prevention, detection and mitigation of the impact of illegal activities (e.g. fraud, money laundering and terrorist financing).

Security of information related to our Services.

Retention and storage of your personal data to meet specific retention requirements required by law.

Where necessary, we pass on your personal data to data controllers and the following recipients for one or more of the purposes described above:

Law enforcement agencies, courts, government agencies or public authorities, intergovernmental or supranational bodies.

Third Party Service Providers.

Third parties involved in legal proceedings, in particular, if they present us with an order/injunction having legal force, a court judgment or any other act issued by a judicial authority.

Credit check bureaus or companies, if required by applicable laws (e.g., information about late payments, payment defaults or other irregularities that could be associated with your creditworthiness/indebtedness).

 

4. Methods of processing and storage of personal data

Baiabasa treats the User’s personal data with electronic and automated methods, as well as manually, through subjects specifically authorized by Baiabasa. These subjects carry out treatments using technical and organizational security measures adequate to ensure the protection of personal data and confidentiality of the User.

Some of the main security measures employed by Baiabasa to protect the User’s personal data:

– specific instructions to personnel authorised to process the data;

– continuous training of personnel authorised to process;

– control of access to computer systems;

– Encryption in data storage/storage;

– Encryption in data transmission;

– firewall and antivirus;

– pseudonymisation of data.

The User’s personal data will be stored by Baiabasa applying appropriate technical and organizational security measures, for pre-established periods of time or, however, for periods that can be determined according to specific processing and storage logic. At the end of the retention periods, personal data will be automatically deleted by Baiabasa , in a secure manner in accordance with our rules on data retention and deletion.

• 15 years from collection: data processed necessarily for the provision of services and the execution of the contract between Baiabasa and the User, excluding profiling.
• 2 years from collection: (i) data processed for the operation of the Website (data collected automatically through the User’s devices, such as log files, IP address, etc.); (ii) data processed for the profiling necessary for the automated decision-making process carried out by means of an algorithm, illustrated in the part relating to the purposes of processing; (iii) data collected through social media.
• 5 years from collection: data processed for direct marketing purposes, marketing based on profiling and for sending commercial offers relating to products or services already purchased in the past by the User.

The periods of conservation of personal data indicated may be extended by Baiabasa in order to comply with legal obligations or possible requests by the authorities.

In case of cancellation of the account: the information that the User has shared on the Site (comments) may continue to be visible to the public on the Site. Copies of this data (e.g. access logs) are kept by Baiabasa , in pseudonymized form, with the security measures and for the retention periods indicated in this Policy.

5. Recipients of personal data and dissemination

The User’s personal data are processed on behalf of Baiabasa by data controllers who provide adequate guarantees. In addition, the User’s personal data are communicated by Baiabasa to autonomous holders, as part of their data processing activities, and to joint controllers, as part of processing activities in respect of which the purposes and means of treatment are determined jointly with Baiabasa.

Data Processors:

• analysis and statistics on aggregate data:

Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA

Google Ireland, Gordon House, Barrow Street, Dublin 4, Ireland

https://support.google.com/policies/troubleshooter/7575787?visit_id=636759015068431447-3280245928&rd=2

Autonomous holders of the treatment:

• professionals and consultants (e.g. accountants);
• authorities, in specific cases, for the exercise of rights and to comply with specific requests;
• other companies, if any, in the event of a merger or acquisition of Baiabasa .

 

Joint Data Controllers:

– Facebook, Ltd. and Instagram: https://it-it.facebook.com/help/325807937506242

– Linkedin https://www.linkedin.com/legal/privacy-policy

– Twitter Privacy (twitter.com);

– Instagram InstagramPrivacy Policy – Termly

 

6. Diffusion

As part of the provision of services some of the User’s personal data is disclosed to the public through the Site.

Other Users have access to certain information that you share on the Site. For example, they will be able to see profile information, posted comments, and posted media content. Other users may also see any information that you have chosen to share in your profile.

When you use the Site your name may be displayed by the public and associated with all your public activity on Baiabasa . If his name is associated with his User name, the people to whom his name has been disclosed will be able to personally identify his activities on Baiabasa .

7. User Rights

The User may exercise his rights under the legislation on the protection of personal data through the control panel of his account, or by contacting the person in charge of data protection Baiabasa at privacy@baiabasa . com or at the headquarters of Baiabasa .

The User may, in particular, exercise the following rights:

• Withdraw consent to processing for direct marketing and profiling for marketing purposes, where given;
• Withdraw consent for access to your device where given;
• Request explanations and significant information with respect to the operation of the algorithm to require human intervention in the relevant automated decision-making process, as well as express their opinion and challenge decisions resulting from the automated process (Art. 22 GDPR);
• Access to personal data processed and stored by Baiabasa and obtain information on the treatment pursuant to art. 15 RGPD;
• Rectification of personal data, where inaccurate, or integration of personal data, where incomplete, pursuant to art. 16 RGPD;
• Cancellation of personal data pursuant to art. 17 RGPD;
• Limitation of processing in accordance with art. 18 RGPD;
• Receive your personal data in a structured, commonly used and machine-readable format (right to data portability) pursuant to Art. 20 GDPR;
• Object to the processing pursuant to Art. 21 of the GDPR;
• To lodge a complaint with a supervisory authority pursuant to Article 77 RGPD, if it considers that the processing has been carried out in violation of the applicable legislation on the protection of personal data.

If you have chosen to link your account to a third party application, such as Facebook or Google, you can change the settings and remove permission through the Site settings.

8. Other forecasts

Data protection procedures adopted by third parties

This Policy only covers the processing of personal data that we collect from you in connection with the Site. If you disclose your information to a third party or visit a third party site through a link on our Services, the privacy policies and practices of such third parties will apply to all personal information that you provide or that they collect from you.

Changes to the information

This Privacy Policy may be modified at any time by posting the updated version on the Site. Any material changes to this Privacy Policy will be announced by email to the User.