Privacy & Terms

Information and request for consent pursuant to and for the purposes of articles 13 and 14 of Regulation (EU) 2016/679

1. Data Controller

The data controller is Ummy s.r.l. Benefit Company, hereinafter Qomprendo, with registered office in Corso Castelfidardo, no.30/A Turin, Italy, 10029 in the person of the Legal Representative. The Data Controller can be reached at the address info@qomprendo.com

2. Purpose of processing

Your data will be processed:

Without your express consent (art. 6 GDPR) for the following service purposes:
- conclude contracts for the services of the Data Controller;
- fulfil pre-contractual, contractual and fiscal obligations arising from relations with you in place;
- comply with obligations established by law, regulation, community legislation or an order from the Authority;
- exercise the rights of the Data Controller, for example the right to defense in court;
- for the management of requests for information from users through the sending of emails and other contacts via form.
Only with your specific and distinct consent (art. 7 GDPR), for the following purposes:
- Send you via email, newsletters, commercial communications and/or advertising material about products or services offered by the Data Controller.

3. Method of Treatment

The personal data of users are treated with appropriate security measures; these measures are useful to prevent disclosure, modification, or other unauthorized uses. In addition to the Data Controller, other authorized parties may have access to the Personal Data and any third parties duly designated by the Data Controller.

4. Consequences of Data Refusal

Nature of the data provision and consequences of the refusal to respond.

The provision of data for the purposes set out in point 2.1 is mandatory. In their absence, we will not be able to guarantee the related services.

The provision of data for the purposes set out in point 2.2 is instead optional. You can therefore decide not to provide any data or subsequently refuse the possibility of processing for such purposes data already provided; in this case, you will not be able to receive newsletters, commercial communications, and advertising material related to the services and products offered by the Data Controller. You will still be entitled to the services referred to in point 2.1.

5. Retention Period

All personal data provided will be processed in compliance with the principles of lawfulness, fairness, relevance, and proportionality, only with the modalities, including computer and telematic, strictly necessary to pursue the purposes described above.

In any case, personal data will be kept for a period not exceeding that strictly necessary to achieve the purposes indicated. Therefore:

Personal Data collected for the management of requests will be stored for a term of 24 months;
Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the completion of this contract;
Personal Data collected for purposes attributable to the Data Controller's legitimate interest will be retained until the satisfaction of this interest. The User can obtain further information about the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller;
The Data Controller may be required to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority;
Personal data collected for marketing purposes will be stored for 24 months.
At the end of the retention period, the Personal Data will be deleted or made anonymous. Therefore, at the expiration of this term, the right of access, cancellation, rectification, and the right to data portability can no longer be exercised.

6. Data Communication

Without the need for express consent (Art. 6 GDPR), the Data Controller may communicate your data for the purposes set out in point 2.1 to Supervisory Bodies and/or Judicial Authorities as well as to all other subjects to whom communication is mandatory by law for the performance of the aforementioned purposes. Your data will not be disseminated.

7. Data Transfer

Your data will not be transferred outside the European Union. However, it should be understood that the Data Controller, if necessary, will have the ability to transfer data to the European Union and/or non-EU countries. In such cases, the Data Controller ensures that the data transfer outside the EU will comply with the applicable legal provisions, stipulating, if necessary, agreements that ensure an adequate level of protection and/or adopting the standard contractual clauses provided by the European Commission.

8. Rights of the Data Subject

Under Articles 15 and following of the Regulation, you, as a data subject, have the right to ask the Data Controller for:

the right to information, communication and transparency (Articles 12, 13 and 14, Article 1 Dl 104/2022);
access to your personal data (Article 15); \r\n- the correction or deletion of your data or the restriction of processing related to you (Articles 16, 17, 18);
to object to processing (Article 21);
data portability (Article 20); \r\n- if the processing is based on Article 6(1)(a) or Article 9(2)(a) of the Regulation, to withdraw your consent at any time without affecting the lawfulness of processing based on consent given before the withdrawal.

Without prejudice to any other administrative or judicial remedy, the data subject who believes that the processing of his or her data infringes the GDPR has the right to lodge a complaint with a supervisory authority, particularly in the Member State where he or she habitually resides, works or where the alleged infringement occurred, pursuant to Article 77 of the Regulation (the Italian supervisory authority is the Guarantor for the protection of personal data).

To exercise the above rights, the data subject may contact the Data Controller at the contact details provided in point 1 of this notice.

9. How to Exercise Rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. The requests are filed for free and processed by the Owner as quickly as possible, in any case within one month.

10. Changes to This Privacy Policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if technically and legally feasible, by sending a notification to Users through one of the contact details the Owner has. Please therefore regularly check this page, referring to the date of the last modification indicated at the bottom.

Last edited on March 27, 2023

Information and request for consent pursuant to and for the purposes of articles 13 and 14 of Regulation (EU) 2016/679

1. Data Controller

The data controller is Ummy s.r.l. Benefit Company, hereinafter Qomprendo, with registered office in Corso Castelfidardo, no.30/A Turin, Italy, 10129 in the person of the Legal Representative. The Data Controller can be reached at the address info@qomprendo.com

2. Data Protection Officer

The data protection officer is Debora Marianna Pagano

Contacts: privacy@qomprendo.com

3. Purpose of processing

The personal data provided by users will be used for:

Improve the App and its services;
Inform you about available services;
Authorize access to the App and services offered by the app;
Analysis on the performance of the app and the services we offer;
Create content and surveys within the App;
Manage your participation in special programs, surveys, campaigns, through notifications within the app itself;
The security of our services, including user authentication;
Support users in using the App;
Comply with the Terms of Use and other agreements;
Carry out data analysis exclusively in pseudonymised form;
Investigate possible fraud or other violations of the Terms of Use or this Notice;
The resolution of disputes in which the interested party or the Data Controller are involved.

4. Categories of data processed

The personal data processed are:

A - Contact details (name, surname, email): such data are necessary for account creation

B -Images (the user can upload a profile picture)

D -Comments: such data can be shared with consent

The personal data provided by you will not be transferred to countries outside the European Union.

5. Method of Treatment

Users' personal data are treated with appropriate security measures; these measures are useful to prevent disclosure, modification or other unauthorized uses.

In addition to the Holder, persons authorized by the Holder and the External Managers may have access to Personal Data. The list is available upon written request sent to the Data Controller accompanied by the applicant's identification document.

6. Consequences of Data Refusal

In case of non-authorization to process the data provided in points A (contact details) the interested party will not be able to use the App.

In case of non-authorization to process the data provided in point B (images) and in point C (Comments) the interested party will not be able to use specific services for which the processing of the related data indicated in the point defined as "Categories of processed data" is provided.

All consents can be revoked and modified at any time in the area provided in the user's account within the App.

7. Retention Period

The data are processed and stored for the time required by the purposes for which they were collected. Therefore:

The Personal Data collected for purposes related to the execution of a contract between the Holder and the User will be retained until the execution of that contract is completed.
The Personal Data collected for purposes related to the legitimate interest of the Holder will be retained until the satisfaction of such interest. The User can obtain further information regarding the legitimate interest pursued by the Holder in the relative sections of this document or by contacting the Holder.
The Holder may be required to keep 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 anonymized. Therefore, at the expiration of that term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

8. Rights of the Interested Party

Users can exercise certain rights with reference to the Data processed by the Holder. In particular, the User has the right to:

Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously expressed.
Oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right of opposition are indicated in the section below.
Access their Data. The User has the right to obtain information about the Data processed by the Holder, on certain aspects of processing and to receive a copy of the Data processed.
Verify and request rectification. The User can verify the correctness of their Data and request its updating or correction.
Obtain treatment limitation. When certain conditions are met, the User can request the limitation of their Data processing. In this case the Holder will not process the Data for any other purpose other than their preservation.
Obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Holder.
Receive their Data or have them transferred to another holder. The User has the right to receive their Data in a structured format, commonly used and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another holder. This provision is applicable when the Data are processed with automated tools 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.
Propose complaint. The User can lodge a complaint with the competent personal data protection control authority or act in court. To do so you can use a model provided by the Privacy Guarantor.

Pursuant to the same article, you have the right to ask for the cancellation, conversion into anonymous form or the blockage of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing.

The interested party has the right to oppose, in whole or in part: for legitimate reasons to the processing of personal data concerning him, even if pertinent to the purpose of the collection; to the processing of personal data concerning him for the purpose of sending advertising material or direct selling or for carrying out market research.

9. How to exercise rights

To exercise the User's rights, Users can direct a request accompanied by an identification document to the contact details of the Holder indicated in this document. The requests are filed free of charge and processed by the Holder as soon as possible, in any case within a month.

10. 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 technically and legally feasible, by sending a notification to the Users through one of the contact details that the Data Controller possesses. Please therefore regularly consult this page, referring to the date of the last modification indicated at the bottom.

Last edit Jenuary 8, 2024

These Terms of Use (this "Agreement") constitute a legal agreement between the user ("User") and Ummy S.r.l. Società benefit ("Company"), for the use of the Qomprendo application on mobile devices, the website, the servers used by the application, the files saved on such servers and all related services, functionalities and contents offered by the Company (collectively referred to as "App"). This App is owned by: Ummy S.r.l. Società benefit, registered office in Corso Castelfidardo 30/A Turin Postal Code 10129 Italy, VAT number 12862840019, Contacts: ummysrl@pec.it - privacy@qomprendo.com

Art. 1. - Acceptance of Terms

Please read this Agreement carefully. By creating an account, accessing the App or using it, you acknowledge that you accept and agree to be bound by the terms of this Agreement. IF YOU DO NOT AGREE TO THESE TERMS, YOU MAY NOT ACCESS OR USE THE APP. We reserve the right to modify this Agreement as necessary. We will send a notification via email, through the App, or by presenting a new version of the Agreement for acceptance, in case of changes that will materially affect the user's rights. Continued use of the App after the effective date of an updated version of the Agreement implies acceptance of the updated Agreement.

Art. 2 - Registration and Eligibility

To use the App, you may be asked to create or update an account ("Account") and provide certain personal information, which may include your name, date of birth and email address. This information will be stored and used in accordance with our Privacy Policy, which can be viewed in the app. You consent to provide accurate and complete information to the Company and to promptly update such information in case of changes. To create an Account and access the App, you must register using an email address for sending the access code.
The user will have at his disposal an area of the app exclusively dedicated to him called "profile" through which he can access and can periodically check the settings of his profile.
By registering for the app, the user will need to provide an email address or a username (hereafter the "id"). Access cannot be carried out simultaneously from two or more locations and the user cannot assign or transfer them to third parties, except under his full and exclusive responsibility. In this regard, it is recalled that the user will be held responsible towards the owner and any third party for any and all action, transaction and/or fact occurred and/or executed through the use of the id and/or the access code.
The user is required to preserve the confidentiality and secrecy of the access credentials and is obliged to promptly inform the app of any possible unauthorized use of them or of their loss, by email to the address info@qomprendo.com
The owner cannot be held liable in any way, directly or indirectly, in any form or on the basis of any liability regime, for injuries or damage of any kind resulting from, or related to, the user's failure to comply with the provisions of this article.
The user will also be required not to carry out nor to allow or permit third parties the following behaviors (not exhaustive and continuously updated):
- carry out actions of any kind and/or nature aimed at circumventing, disabling or interfering in any way with the security related applications of the app's services or other applications that prevent, limit or restrict the use or copying of any material present on the same;
- use of the app's services for any illicit purpose or in violation of any applicable regulation;
- interfere with or damage the services and systems of the app or their relative enjoyment by any user, by any means, including by uploading files or otherwise disseminating viruses, adware, spyware, bugs or other harmful electronic tools;
- carry out actions aimed at circumventing tools for robot exclusion or other measures that the app may use to prevent unauthorized access to its services.

Art. 3. Use of the App

All content sent through the App is governed by the Company's Privacy Policy. These Terms of Use prevail in all cases of conflict between this Agreement and the Company's Privacy Policy.

The user is responsible for every activity undertaken in relation to the App and must comply with all local, provincial, national and international laws and regulations, as well as all applicable regulatory codes. The user agrees that each of the following actions constitutes a material violation of this Agreement and agrees to ABSTAIN FROM:

a. reselling, renting, leasing, lending, granting by sub-license agreements, distributing or otherwise transferring the rights to the App;
b. modifying, decoding, decompiling or disassembling the App;
c. copying, adapting, altering, modifying, translating or creating derivative works from the App without the written authorization of the Company;
d. allowing the use of the App to third parties by means including (but not limited to) shared use through a network connection, except for use in accordance with the terms of this Agreement;
e. circumventing or disabling any technological feature or measure of the App aimed at protecting intellectual property rights;
f. using the App in an attempt to evade, or in combination with any device, program or service designed to evade, the technological measures used to control access to, or rights over, a content file or other work protected by copyright laws of any jurisdiction;
g. using or accessing the App to compile data in such a way that it can be used or is usable by competing products or services;
h. using your Account to advertise, solicit or transmit any commercial advertising, including chain letters, junk mail or repeated messages to anyone;
i. using your Account to carry out any illegal conduct;
j. uploading materials to transmit any communication that infringes or violates the rights of parties, whatever they may be;
k. uploading any media that contain expressions of hate, abuse, offensive, obscene, pornographic, sexually explicit images or conduct or any type of content that could give rise to civil or criminal liability under applicable laws and regulations, or that otherwise conflict with this Agreement and the Company's Privacy Policy;
l. uploading any type of material that contains computer viruses or codes, files or programs designed to interrupt, destroy or limit the functionality of any computer or of this website.
Any prohibited use of the App will result in reporting to your employer and could lead to the immediate revocation of your user account.

Art. 4. App's Limited License

We grant the user a personal, global, revocable, non-transferable and non-exclusive license to access and use the App for personal and non-commercial purposes, under the terms of this Agreement.

Any right, title, and interest in or to the App not explicitly granted through this Agreement is reserved to the Company. If you wish to use the software, title, trade name, trademark, service mark, logo, domain name and/or any other distinctive brand features or any other content owned by the Company, you must obtain written permission from the Company. Requests for such authorization can be sent to ummysrl@pec.it

To avoid any doubt, the Company holds the rights to all texts, images, photos, audios, videos, location data, and all other forms of data or communications that it creates and makes available in relation to the App, including (but not limited to) interfaces, interactive features, graphics, design, compilation of User Content and compilation of aggregate user review ratings, as well as all other elements and components of the App, excluding User Content (as defined below). Except as expressly and unequivocally provided in this document, we do not grant any explicit or implicit right and all rights on and to the App, as well as the contents of the Company, belong to us.

The contents present on the app, such as, for example, published on the app itself, including the menus, web pages, graphics, colors, schemes, tools, fonts and the design of the app, diagrams, layout, methods, processes, functions, and the software that are part of the app, are protected by copyright and all other intellectual property rights of the owner or any third parties contracted by the same. Reproduction, in whole or in part, in any form, of the app and its contents, without the express written consent of the owner, is prohibited.
The user is in no way authorized to carry out any reproduction, on any medium, in whole or in part of the app and its contents. Any act of reproduction must be, from time to time, authorized by pec ummysrl@pec.it or, if necessary, by the authors of the individual works contained in the site. Such reproduction operations must still be carried out for lawful purposes and in respect of copyright and other intellectual property rights and of the authors of the individual works contained in the site.

Art. 5. - Use of the app and user responsibility

The access and use of the app, including communication with the owner, are activities conducted by the user exclusively for work purposes.
The user is personally responsible for the use of the app and its contents. Indeed, the owner cannot be held responsible for non-compliance with current law rules of the web app and its content by each of its users, except for liability for fraud and serious fault. In particular, the user will be solely responsible for the communication of incorrect, false information or related to third parties without their consent, as well as considering the incorrect use of them.
The owner declines all responsibility for any damages resulting from the inaccessibility of services on the app or any damages caused by viruses, damaged files, errors, omissions, service interruptions, content deletions, problems related to the network, providers or telephone and/or telematic connections, unauthorized access, alterations of data, non-functioning and/or defective operation of the user's electronic equipment.
The user is responsible for the custody and correct use of their personal information, including credentials that allow access to reserved services, as well as any harmful consequence or prejudice that should result to the company or third parties due to incorrect use, loss, theft of such information.
The Owner has taken all reasonable precautions to prevent the publication on the app of content and images that may be considered offensive to the decency, human rights and dignity of people, in all possible forms and expressions. In any case, if the aforementioned content is deemed offensive to religious or ethical sensitivity or decency, the interested user is asked to communicate this condition to the owner, who however warns that any eventual access to content considered offensive or injurious is made by the user at his own discretion and his exclusive and personal responsibility.
The Owner has also adopted every useful precaution so that all the information on the app is correct, complete and updated; however, he does not assume any responsibility towards users about the accuracy and completeness of the content published on the app, except as otherwise provided by law. If a user finds errors or lack of updates of the information on the app, he is asked to communicate it to the owner using the email box: ummysrl@pec.it

Art. 6 - Exclusion of liability

As previously stated, the owner carries out with utmost diligence the care and maintenance of the app and its contents, however, he assumes no responsibility for the correctness, completeness and timeliness of the data and information provided on the app or on the sites linked to it. Therefore, any responsibility for errors or omissions arising from the use of data and information on the app must be excluded.
The owner declines all responsibility, including the presence of errors, the correction of errors, the responsibility of the server hosting the site; he is also not responsible for the use of the information contained, their correctness and reliability. In no case, including negligence, the owner will be liable for any direct or indirect damage that may result from the use, or inability to use, the materials present on the site.

Art. 7 - Limitations to service delivery

The owner cannot be held responsible for any damages resulting from the failure to provide the service due to incorrect or non-functioning electronic means of communication for reasons beyond his foreseeable control. For example, but not limited to, the malfunction of servers and other electronic devices not integral part of the Internet, malfunction of installed software, computer viruses on the possible presence of viruses or other harmful and damaging computer components, as well as from actions of hackers or other users with access to the network. The user therefore agrees to indemnify and hold harmless the owner from any liability and/or claim in this regard.

Art. 8 - Trademarks

All trademarks and distinctive signs on the app, even those related to individual activities carried out by the owner, are exclusive to the owner or to the companies referring to him.
The owner has the right to exclusive use of these trademarks. Therefore, any unauthorized or illegal use is strictly prohibited and results in legal consequences. It is in no way allowed to use these trademarks and any other distinctive sign present on the app to unduly, even indirectly, benefit from the distinctive character or the reputation of the owner's trademarks or in a way that prejudices them and their owners.
The domain qomprendo.com as well as the various declinations and subdomains are owned by the owner. No use, even indirect, is allowed, except with specific written authorization from the owner or the owners.

Art. 9. Changes to the App

Changes, expansions and improvements to the App occur periodically and without notice.

We may also, at any time, end the total or partial operation of the App or disable some of its features. The use of the App does not entitle you to the supply or continuous availability of the App. Any modification or elimination of the App or specific features will occur at our sole and absolute discretion, without any obligation or liability towards the user.

Art. 10 - Data processing

The user's data is processed in accordance with the regulations on the protection of personal data, as specified in the specific section containing the information pursuant to art. 13 EU Regulation 2016/679 (Privacy Policy). For more information, access the privacy section in the app.

Art. 11 - Safeguard clause

In the event that one of the clauses of these general conditions of use were void for any reason, this will not compromise in any case the validity and compliance of the other provisions included in these general conditions of use.

Art. 12 - Contacts

Any request for information can be sent via email to the following address ummysrl@pec.it and by post to the following address: Corso Castelfidardo 30/A Turin Zip 10129 Italy

Art. 13 - Applicable law and competent court

These general conditions of use are governed by Italian law and interpreted according to it, without prejudice to any different overriding mandatory rule of the country of habitual residence of the buyer. Therefore, the interpretation, execution, and resolution of the general conditions of use and sale are subject exclusively to Italian law.
2. Any disputes relating to and/or arising from them must be resolved exclusively by the Italian judicial authority. In particular, if the buyer is a consumer, any disputes must be resolved by the court of the place of domicile or residence of the same according to the applicable law.

These conditions were drafted in June 2023.