PRIVACY POLICY PURSUANT TO REGULATION (EU) 2016/679 (GDPR)

1. Introduction

This privacy policy is provided pursuant to Articles 13 and 14 of Regulation (EU) 2016/679 (hereinafter "GDPR") and describes how Genia Business S.r.l., with registered office at Via Caduti del Pilastro 8, 40055 Castenaso (Bologna), Italy, as Data Controller, processes the personal data of users, Partners, and other individuals using the “Hi, it’s oN me” application (hereinafter the "App" or the "Platform")[cite: 2].

The Platform allows users to create, organize, and attend events, while allowing commercial, professional, or business entities (hereinafter "Partners") to host, promote, and manage events aimed at users[cite: 2].

This policy applies solely to data processing performed by Genia Business regarding the App[cite: 2]. General terms of service, participation rules, subscriptions, and reward systems are governed separately in the License Agreement and Terms of Use[cite: 2].

2. Data Controller

The Data Controller is Genia Business S.r.l., Via Caduti del Pilastro 8, 40055 Castenaso (Bologna), Italy, which determines the purposes and means of personal data processing carried out through the App[cite: 2].

For inquiries regarding personal data processing, data subjects may contact the Controller using the contact details provided in the App or on the official website[cite: 2].

2-bis. Contact Details of the Data Controller

For inquiries regarding this privacy policy, personal data processing, or exercising data subject rights, you may contact[cite: 2]:

Genia Business S.r.l.
Registered Office: Via Caduti del Pilastro 8, 40055 Castenaso (Bologna), Italy
E-mail: info@geniabusiness.com
Certified Email (PEC): geniabusiness@legalmail.it
Phone: +39 051/6051081
Contact Person: Anselmo Petraroli (CEO of Genia Business Srl)[cite: 2]

3. Categories of Personal Data Processed

Genia Business processes personal data provided directly during registration or service use, as well as data generated through Platform interactions[cite: 2].

This includes identification and contact data (such as name, surname, nickname, email address, phone number, and login credentials)[cite: 2]. It also includes profile data, preferences, events organized or attended, interactions with other users and Partners, uploaded media, and support inquiries[cite: 2].

The App processes event attendance records, no-shows, cancellations, feedback, user reports, QR code scans at partner venues, referral invites, and platform activity[cite: 2].

Regarding reward and trust mechanisms, Genia Business processes data related to Reliability Scores, Good Karma Points, badges, and user reviews to foster platform safety and prevent abusive behavior[cite: 2].

For Partners, processed data includes business names, representative contact info, events hosted or sponsored, agreed perks or reimbursements, and attendee reviews[cite: 2].

For payment, subscription, or virtual credit transactions, Genia Business processes purchase records, transaction logs, refund histories, and information required for accounting and tax compliance[cite: 2].

4. Purposes of Processing

Data is processed to enable App registration, account administration, user verification, and platform access[cite: 2].

Data is processed to facilitate event creation, publication, and participation, as well as communication between users and Partners, attendance confirmations, reviews, and support requests[cite: 2].

Attendance, cancellation, and interaction logs are processed to compute internal account Reliability Scores to preserve event reliability and minimize no-shows[cite: 2].

Reward data is processed to award, update, and manage Good Karma Points connected with event attendance, hosting, reviews, QR scans, and friend referrals[cite: 2].

Feedback is processed to allow users to review events, hosts, and partner venues, computing average ratings and profile badges[cite: 2].

Billing, payment, and transaction data are processed to administer paid services and comply with tax and legal requirements[cite: 2].

Partner data is processed to manage partnerships, publish events, coordinate sponsored activities, and review collaboration performance[cite: 2].

Data may be processed for security verification, fraud prevention, enforcement of Terms of Use, and dispute defense[cite: 2].

Subject to prior consent where required, data may be processed to send marketing communications, newsletters, or promotional updates[cite: 2].

5. Legal Basis for Processing

Processing is based on contract performance or pre-contractual measures requested by the user to provide App features, manage accounts, and administer subscriptions[cite: 2].

Processing is based on legal obligations regarding administrative, accounting, and tax compliance[cite: 2].

Processing is based on the legitimate interest of Genia Business to secure the Platform, prevent fraud, enforce Terms of Use, defend legal rights, and manage internal reliability algorithms[cite: 2].

Where required by law, processing is based on user consent (such as for promotional communications), which may be revoked at any time[cite: 2].

6. Reliability Systems, Good Karma Points, Feedback, and Reputational Features

The App maintains internal mechanisms to promote community reliability[cite: 2]. Data on attendance, cancellations, QR scans, and reviews are processed for this purpose[cite: 2].

The Reliability Score evaluates user dependability over time (excluding Partner venues) based on attendance, hosting reliability, and cancellations[cite: 2].

Good Karma Points operate as an internal engagement system for private users, earned through onboarding, event participation, QR scans, and referrals[cite: 2].

Scoring data may determine privileges, feature access, or temporary account restrictions[cite: 2].

Users confirming attendance via QR code may review hosts and venues to update public rating averages and badges[cite: 2].

In response to host absence or attendee disputes, the App may evaluate QR scans, technical logs, and approximate location data near the venue[cite: 2]. Location checks occur strictly with user permission[cite: 2].

Prior to an event, the App verifies host proximity to the venue[cite: 2]. If mobile data is offline during this check, location data is saved temporarily on local device storage, synchronized to AWS servers upon reconnection, and instantly cleared locally[cite: 2].

Specific criteria for scores, points, and badges are governed by the Terms of Use[cite: 2].

7. Data Sharing and Third Parties

Personal data may be shared with other users or Partners strictly as necessary to coordinate event attendance and run App features[cite: 2].

Data may be communicated to technical service providers (cloud hosting, authentication, payment processing, maintenance, analytics, legal advisors, or public authorities)[cite: 2].

Specifically, the Platform integrates the following third-party infrastructure[cite: 2]:

Third parties handling data on behalf of Genia Business act as Data Processors pursuant to Art. 28 GDPR[cite: 2].

8. Public Visibility on the Platform

Certain profile details (nickname, profile picture, hosted events, attendance, badges, and feedback) are visible to other users and Partners[cite: 2]. For Partners, business names, descriptions, and aggregate ratings are visible[cite: 2].

9. International Data Transfers

Data is primarily processed within the European Economic Area (EEA)[cite: 2]. Specifically, the primary database resides on Amazon Web Services (AWS) in Frankfurt, Germany[cite: 2].

Any technical data transfers outside the EEA are governed by European Commission Adequacy Decisions or Standard Contractual Clauses (SCCs)[cite: 2].

10. Data Retention Periods

Personal data is retained for the duration of the active contractual relationship[cite: 2].

Following account deletion, personal data is erased or anonymized within 24 months, unless longer retention is required for legal, tax, or fraud prevention compliance[cite: 2].

Accounting, invoice, and payment transaction logs are retained for up to 10 years in compliance with statutory requirements[cite: 2].

Event histories, QR scan records, and reward logs are retained for the duration of the account and for up to 24 months following deletion[cite: 2].

Abuse reports, bans, and suspension records are retained for up to 5 years following case closure, without prejudice to defense requirements in legal proceedings[cite: 2].

11. Data Provision

Providing registration, account, and payment data is mandatory to deliver the requested services; refusal makes it impossible to use the Platform[cite: 2]. Marketing consent remains strictly optional[cite: 2].

12. Minors and Child Safety Standards (Zero Tolerance for CSAE / CSAM)

The App is strictly prohibited to individuals under 18 years of age[cite: 2]. Users must be of legal age to register[cite: 2]. If an account belonging to a minor is discovered, it will be terminated and associated data deleted[cite: 2].

In adherence to Google Play Child Safety Standards, Genia Business enforces zero tolerance for Child Sexual Abuse and Exploitation (CSAE) and Child Sexual Abuse Material (CSAM)[cite: 2]. Any related activity results in permanent ban and immediate referral to law enforcement[cite: 2].

Dedicated Child Safety Contact Point[cite: 2]:
Contact Person: Anselmo Petraroli
E-mail: info@geniabusiness.com (Subject: "Child Safety Urgent Report")
Address: Via Caduti del Pilastro 8, 40055 Castenaso (Bologna), Italy[cite: 2]

13. Security Measures

Appropriate technical and organizational measures are implemented to safeguard data against unauthorized access, loss, or unlawful processing[cite: 2].

14. Rights of the Data Subject

Data subjects have the right to access, rectify, delete, restrict, or port their personal data, and to object to processing pursuant to the GDPR[cite: 2]. Consent may be withdrawn at any time without affecting past processing legality[cite: 2].

15. Complaints to Supervisory Authorities

Data subjects have the right to lodge a complaint with their competent data protection supervisory authority (in Italy, the Garante per la protezione dei dati personali)[cite: 2].

16. Amendments

Genia Business may update this privacy policy to reflect platform or regulatory changes[cite: 2]. Updates will be posted on the App and website[cite: 2].

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