Privacy Policy

The purpose of this document is to inform the user (hereafter referred to as "Interested Party" ) regarding the processing of their personal data (hereafter referred to as "Personal Data" ) collected by the owner, n-Track Srl, with registered office in Via Nepal 16, Rome, CF / VAT number IT15290211000, e-mail address privacy@ntrack.com, (hereafter referred to as "Owner" ), through the website and the n-Track Studio application (hereafter referred to as "Application" ).

Changes and updates will be binding as soon as they are published on the Application. In the event of non-acceptance of the changes made to the Privacy Notice, the Interested Party is required to cease using this Application and may request the Owner to delete their Personal Data.

1. Categories of Processed Personal Data

The Owner processes the following types of Personal Data, provided voluntarily by the Interested Party:

• Contact details: e-mail, authentication credentials, any additional information sent by the Interested Party, etc.

The Owner processes the following types of Personal Data collected in an automated manner:

• Technical data: Personal Data produced by the devices, applications, tools and protocols used, for example, information on the device used, IP addresses, browser type, type of Internet provider (ISP). Such Personal Data may leave traces which, when combined with unique identifiers and other information received from servers, can be used to create user profiles

Failure by the Interested Party to provide Personal Data for which there is a legal, contractual obligation -- or if it constitutes a necessary requirement for the conclusion of the contract with the Owner -- will make it impossible for the Owner to establish or continue the relationship with the Interested Party. The Interested Party that communicates third-party Personal Data to the Owner is directly and exclusively responsible for its origin, collection, processing, communication or dissemination.

2. Cookies and similar technologies

The Application uses cookies, web beacons, unique identifiers and other similar technologies to collect the Personal Data of the Interested Party on the pages, links visited and other performed actions when the Interested Party uses the Application. They are then stored to be transmitted on the next visit of the Interested Party. You can view the complete Cookie Policy at the following address: https://ntrack.com/cookie-policy.php

Legal basis and purpose of the Data Processing

The processing of Personal Data is necessary::

• for the execution of the contract with the Interested Party, specifically:
  1. fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Interested Party
  2. registration and authentication of the Interested Party: to allow the Interested Party to register and download the Application, access and also to be identified through external platforms, receive instructions and tutorials via e-mail for use of the Application, and to install free updates.
  3. payment management: to manage payments by credit card or other tools
  
  
• by law, specifically:
  1. the fulfillment of any obligation required by current regulations, laws and regulations applicable to tax and fiscal matters
  
  
• on the basis of legitimate interest of the Owner, for:
  1. e-mail marketing purposes of the Owner's products and / or services: to directly sell the Owners's products or services using the email provided by the Interested Party in the context of the sale of a product or service similar to the one being sold. The Interested Party may object to the processing free of charge at any time through the Application.
  2. management, optimization and monitoring of the technical infrastructure: to identify and solve any technical problems, to improve the performance of the Application, to manage and organize information in a computer system (e.g. server, database, etc.)
  3. security and anti-fraud: to guarantee the security of the Owner's assets, infrastructures and networks
  4. statistics with anonymous data: to perform statistical analysis on aggregate and anonymous data to analyze the behavior of the Interested Party, to improve the products and / or services provided by the Owner, and better meet the expectations of the Interested Party

Based on the legitimate interest of the Owner, the Application allows interaction with external platforms or social networks whose processing of Personal Data is governed by the respective privacy policies to which the Interested Party can refer. The interactions and information acquired by this Application are subject to the privacy settings that the Interested Party has chosen on these platforms or social networks. This information - in the absence of specific consent to processing for further purposes - is used for the sole purpose of allowing the use of the Application and to providing the information and services requested. The Personal Data of the Interested Party may also be used by the Owner to protect themselves in court before competent judicial authorities.

4. Methods of processing and recipients of Personal Data

The processing of Personal Data is carried out using paper and IT tools with organizational methods and logic strictly related to the purposes indicated and through the adoption of adequate security measures.

Personal Data are processed exclusively by:

• persons authorized by the Owner who are committed to confidentiality or have a legal obligation of confidentiality;
• subjects who operate independently as separate data controllers or by subjects designated as data processors by the Owner in order to carry out all the processing activities necessary to pursue the purposes referred to in this information (for example, commercial partners, consultants, IT companies, service providers, hosting providers);
• subjects or entities to which it is mandatory to communicate Personal Data by law or by order of the authorities.

The subjects listed above are required to use the appropriate safeguards to protect Personal Data and can only access data necessary to perform the tasks assigned to them. Personal Data will not be disclosed indiscriminately in any way.

5. Location

Personal Data will not be subject to any transfer outside the territory of the European Economic Area (EEA).

6. Retention period of Personal Data

Personal Data will be kept for the period of time necessary to fulfill the purposes for which they were collected, specifically:

• for purposes relating to the execution of the contract between the Owner and the Interested Party, data will be kept for the entire duration of the contractual relationship and, after termination, for the ordinary prescription period of 10 years. In the case of judicial litigation, for the same duration, until the terms of enforcement of the appeals are exhausted
• for purposes related to the legitimate interest of the Owner, data will be kept until the fulfillment of this interest
• for the fulfillment of a legal obligation, by order of an authority and for legal protection, data will be kept in compliance with the time-frames given by these obligations, until such a time limitation is provided by the regulations in force
• for purposes based on the consent of the Interested Party, data will be kept until the consent is revoked

At the end of the retention period, all Personal Data will be deleted or stored in a form that does not allow the identification of the Interested Party.

Rights of the Interested Party

Interested Parties may exercise certain rights with reference to the Personal Data processed by the Owner. In particular, the Interested Party has the right to:

• be informed about the processing of their Personal Data
• withdraw consent at any time
• limit the processing of their Personal Data
• oppose the processing of their Personal Data
• access their Personal Data
• verify and request the rectification of their Personal Data
• obtain the limitation of the processing of their Personal Data
• obtain the cancellation of their Personal Data
• transfer their Personal Data to another holder
• lodge a complaint with the supervisory authority for the protection of their Personal Data and / or take legal action.

To exercise their rights, the Interested Parties can send a request to the following e-mail address privacy@ntrack.com. Requests will be dealt with by the Owner immediately and processed as soon as possible, in any case within 30 days.

Last updated: 21/09/2022