Privacy Policy

MyLibretto

MyLibretto is an app that works mainly locally, this means that the majority of the Personal Data added by the User will NEVER leave the device where the have been store, with particular focus on sensitive data such as name and surname, photo or student ID that are never stored or used for any reason, not even for advertising or analytics purpose.

The spicing informations of exams, fees, class schedule, etc.. are stored on the servers of MyLibretto only when the User creates a backup. This happens only to allow the User to restore his data later in the future. If the User wants to delete all his data from the servers of MyLibretto, he can reach the Holder (by using the contact info provided in this document) which will delete all the data afte that the User has provided the key of the backup that need to be deleted.

More data are collected for advertising and analytics purposes, more info are provided below.



Types of Data collected

Among the types of Personal Data that MyLibretto collects, by itself or through third parties, there are: Cookies, Usage Data, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and geographic position.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using MyLibretto.
Unless specified otherwise, all Data requested by MyLibretto is mandatory and failure to provide this Data may make it impossible for MyLibretto to provide its services. In cases where MyLibretto specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by MyLibretto or by the owners of third-party services used by MyLibretto serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through MyLibretto and confirm that they have the third party's consent to provide the Data to the Owner.



Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of MyLibretto (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. The User can ask for data deletion whenever he wants by contacting the Owner.



The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Analytics, Social features, Hosting and backend infrastructure, Content performance and features testing (A/B testing), Infrastructure monitoring and Advertising.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.



Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Social features
Firebase Dynamic Links (Google Inc.)

Firebase Dynamic Links is a social feature provided by Google Inc. Dynamic Links are tracked within Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User journey to and within MyLibretto.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Shield participant. - Privacy Policy

Hosting and backend infrastructure

This type of service has the purpose of hosting Data and files that enable MyLibretto to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of MyLibretto.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

Firebase Realtime Database (Google Inc.)

Firebase Realtime Database is a hosting and backend service provided by Google Inc.

Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Shield participant. - Privacy Policy

Infrastructure monitoring

This type of service allows MyLibretto to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of MyLibretto.

Crashlytics (Google Inc.)

Crashlytics is a monitoring service provided by Google LLC.

Personal Data collected: geographic position, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy

Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on MyLibretto, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside MyLibretto. For more information, please check the privacy policies of the relevant services.
In addition to any opt-out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

AdMob (AdMob Google Inc.)

AdMob is an advertising service provided by AdMob Google Inc.
In order to understand Google's use of Data, consultGoogle's partner policy..

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United States – Privacy Shield participant - Privacy PolicyOpt Out

Appodeal

Appodeal is an ads mediation service

Place of processing: United States – Privacy Policy

Analytics

The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)

Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of MyLibretto, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Shield participant - Privacy PolicyOpt Out

Fabric Answers (Google Inc.)

Fabric Answers is an analytics service provided by Crashlytics, a business division of Google Inc.
In order to understand Google's use of Data, consult Google's partner policy.

This service is designed for mobile apps analytics and can collect various information about your phone, highlighted in the Fabric Answers privacy policy.
In particular, MyLibretto uses identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Fabric Answers service. Fabric Answers may share Data with other tools provided by Fabric/Crashlytics, such as Crashlytics or Twitter.
The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. Users may opt-out of certain Fabric Answers features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Fabric related sections of this privacy policy, if available.

Personal Data collected: Cookies, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example) and Usage Data.

Place of processing: United States – Privacy Policy

Content performance and features testing (A/B testing)

The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of MyLibretto.

Firebase Remote Config (Google Inc.)

Firebase Remote Config is an A/B testing and configuration service provided by Google Inc.

Personal Data collected: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Shield participant - Privacy Policy



Owner and Data Controller

Lorenzo Greco
Via San Francesco d'Assisi 12
73010, Sogliano Cavour (LE)
ITALY

Owner contact email: lorenzogapp@gmail.com



Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of MyLibretto or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, MyLibretto may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, MyLibretto and any third-party services may collect files that record interaction with MyLibretto (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

MyLibretto does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within MyLibretto and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references
Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through MyLibretto (or third-party services employed in MyLibretto), which can include: the IP addresses or domain names of the computers utilized by the Users who use MyLibretto, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.

User

The individual using MyLibretto who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of MyLibretto. The Data Controller, unless otherwise specified, is the Owner of MyLibretto.

MyLibretto (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by MyLibretto as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User's device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).

This privacy policy relates solely to MyLibretto, if not stated otherwise within this document.


Date: 15/04/2018



Italian version