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PRIVACY POLICY

 

Privacy and cookie policy statement

(Updated as of 5th May 2019)

 

 

SUMMARY

A. COLLECTION OF INFORMATION.
B. USE OF PERSONAL DATA.
C. DISCLOSURE OF PERSONAL DATA.
D. RIGHTS RELATING TO PERSONAL DATA.
E. BROWSING DATA AND COOKIES.
F. MINORS.
G. SAFETY MEASURES.
H. UPDATES TO THE PRIVACY AND COOKIE POLICY.
I. VISITORS FROM THE EUROPEAN UNION.
Legal basis for data processing.
International Personal Data transfers.
I Your rights.
J. HOW TO CONTACT US.

 

www.mongeyapp.com, www.mongeyapp.it, www.mongey.it and the Mongey app (hereinafter referred to individually as a “Website”, and together as “Websites”) acknowledge the importance of privacy in addition to the importance of preserving the confidentiality of personal data. This Privacy Policy is applied to all products and services on the Websites provided and shows how information is collected, used and disclosed in relation to the users/members of the Websites. This Privacy Policy is also applied to the use of our services and products through a mobile device, apps or Websites that have been optimised for use on mobile devices.

All words with a capital letter and the meaning of which has not been defined in this document, will be explained in the Conditions of Use of the Website and thus can be found there.

 

 

A. COLLECTION OF INFORMATION

Your privacy is important for us, and for this reason, we ensure you that we will not collect more information than is strictly necessary with the aim of guaranteeing our services to users and protecting their accounts. The information that includes user names, passwords, telephone numbers and e-mail addresses will be collected from the user at the moment of registration on the Websites. If you are subscribing to a Mongey account through social media platforms such as Facebook, Instagram, Twitter, LinkedIn, YouTube etc., we can collect your name from the account and the profile pictures directly from these platforms.

If you choose to answer our additional questionnaires intended for registered Users/Members, we can also collect information relating to the User’s/Member’s civil status, nationality, sex, date and/or year of birth, annual income, monthly expenditure and preferences. If you prefer not to provide such information, the use of our services and products will not be affected.

If you are also registered as a seller or service provider, in addition to the information stated previously, we can also collect information regarding your identity, tax code, our profession or company as well as information relating to your commercial licence.

If you are registered on Mongey as a blogger or influencer, in addition to the information stated previously, we can also collect your live videos broadcast in streaming, the names of your social media accounts as well as your profile pictures and posts or comments made by Users/Members of the Websites.

If you contact our customer services department, we can record your conversation and collect further information so as to verify your identity.

In relation to any transaction and service, even when a payment or services subject to our purchaser protection schemes are necessary, information, including yet not limited to the current account number, invoicing and delivery, credit/debit card numbers, dates of expiry and safety code as well as information relating to the tracking of orders paid by cheque or in cash can be collected in order to facilitate the sale and purchase in addition to the payment of the purchase price of the products or services of the transaction on or procured through the Websites.

We register the details of all User’s/Member’s activities on the Websites.

We collect information concerning our Users/Members and potential Users/Members during trade fairs, sector-related events and other activities. The information that we can collect during these events include, yet are not limited to, user names, addresses, telephone and fax numbers and e-mail addresses.

We register all kinds of activities including those relating to the User’s/Member’s browsing on our platform, including those yet not limited to IP addresses, to purchaser’s browsing and behavioural patterns as well as information relating to the devices used. Moreover, we collect statistical information on Websites and on visitors of Websites, including, yet not limited to IP addresses browser software, operating system, software and hardware tools, webpages visited, number of sessions and unique visitors.

Some of the data that we collect can be defined as personal data according to the data protection law (“Personal Data”).

In order to allow us to provide our services and products to Users/Members, the latter must provide certain categories of data (that may also include Personal Data), such as user names, addresses, telephone numbers and e-mail addresses. If data is required, we will inform you at the moment of collection. In the case in which Users/Members do not provide sufficient data marked as necessary, we may not be able to complete the registration process or provide certain products or services.

 

 

B. USE OF PERSONAL DATA

We collect and use your Personal Data for the following purposes:

1. To verify the User’s/Member’s identity;
2. To verify the requirements to become a User/Member of the Websites and/or to become a blogger or influencer of the Websites;
3. To treat the registration as a User/Member, providing ID for the log-in for the Websites and to maintain and manage the aforementioned registration;
4. To provide Users with an assistance service as well as a response in case of requests, feedback, complaints or disputes;
5. To facilitate communication between Users/Members on the Websites, to process any activities carried out by all Users/Members, including transactions and payments.
6. To assess the safety of the account as well as any risks encountered by Users/Members, detecting and preventing any kind of illegal activity punishable by law;
7. To personalise our communications with Users/Members according to the browsing registers, information regarding devices that we have collected as well as the histories of all activities carried out by all Users/Members, to carry out research or statistical analyses with the aim of improving the content and appearance of the Websites and to improve our offer of products and services, including, for example, the use of data rendered anonymous for machine learning purposes;
8. To identify, develop and market products and services that we consider could be appreciated, including through browsers and devices, in accordance with applicable laws. The cookies or other similar technologies may be used to provide advertisements according to your browsing activities and interests (see section E) COOKIES below). Where required by applicable law, we will request your consent prior to sending you any marketing-related communications.
9. Moreover, we can use your Personal Data for other purposes that are incompatible with the purposes that we have disclosed (such as storage purposes of public and scientific interest or for historical research or statistical purposes) if and where this is permitted by applicable laws on the subject of data protection.

 

 

C. DISCLOSURE OF PERSONAL DATA

Mongey is authorised by the User/Member to disclose and transfer his/her Personal Data to our partners and to service providers of which we avail ourselves of in order to provide you with services or to those who otherwise process Personal Data for the purposes described in this Privacy policy or who are notified when we collect the Personal Data of all Users/Members. Examples of these partners or service providers include:

1. All our corporate partners;
2. Commercial platforms, such as Google, Twitter, LinkedIn, Facebook, Instagram and VKontakte, Amazon as well as others and analytical service providers regarding Users’/Members’ behaviour, with the aim of personalising the content that is seen when you visit our Websites. These commercial platforms can link the information collected on our Websites with data on their platforms and with data collected from other Websites or from other sources with the aim of carrying out targeted advertising. The activities that these third-party commercial platforms perform are regulated by their privacy policies, not by this Privacy Policy;
3. Payment service providers to help the User/Member with payments regarding transactions or which provide withdrawal services for salespeople. The activities carried out by payment service providers can be disciplined by their own privacy policies, not by this privacy policy;
4. Logistics partners to provide delivery services for purchasers as well as warehousing services for salespeople;
5. Cloud service providers to provide cloud storage services;
6. Warranty service providers to provide warranty services;
7. Customer service providers to provide after-sales services;
8. Risk management service providers to assess the safety of Users’/Members’ accounts as well as the risks that could be potentially incurred through transactions.

These Service Providers must comply with our safety and data privacy requirements and they are granted the possibility to use your Personal Data only for the purposes specified previously and not for no other purposes whatsoever.

With regards to the aforementioned purposes, we can share your Personal Data with Mongey affiliate companies and/or their appointed Service Providers, which includes a group of companies that manage online leads and mobile markets in the consumer and B2B trade, in addition to cloud and other services.

Where Mongey and its staff deem it necessary and in order to comply with applicable laws or to ascertain, establish or defend our rights before a court or to protect our vital interests or those of any other individual, we can also disclose and transfer your Personal Data to our professional consultants, to authorities appointed to apply the law, to insurance companies, to governmental and regulatory authorities and other organisations, or otherwise as requested or granted by applicable laws.

Mongey will be able to disclose your Personal Data to an existing or potential purchaser (and respective agents and consultants) in relation to a purchase, to an existing or potential merger or takeover of any part of our business, as long as we inform the purchaser that he/she must use his/her Personal Data only for the purposes specified in the Privacy policy.

Mongey will preserve the Personal Data of all Users/Members and will disclose it to any person or service or product provider or as requested or permitted by applicable laws, such as tax and accounting legislation.
The information that User/Member sends to the Websites for publication may be publicly available on the Websites and therefore accessible to any Internet user. The User/Member must be cautious when he/she decides which information to send to Mongey for publication.

Mongey will be able to provide aggregated data or which has been rendered anonymous by third parties, but when we do so, the information that we share is in a de-identified format from which it is impossible to identify you personally.

Mongey has established relationships with third-parties as well as with other Websites with the aim of guaranteeing Users/Members advantages, not offered by us, with regards to products or services. Access to such third parties and to their website is offered through the use of hyperlinks to the aforementioned websites, our Websites or through the offer on Websites in co-branding in which both we and the third parties share the same Uniform Resource Locator (URL), domain name and the same pages contained in the domain name on internet. In some cases, the User/Member may be required to give his/her Personal Data for the purposes of registration or request for services and products provided by such third parties or partners in co-branding activities. This Privacy and Cookie Policy does not apply to the aforementioned third-party and co-branding websites. The privacy policies of those third parties can differ from this document and we do not have any control over the information provided by you during the registration with third parties. It is recommended to consult the specific privacy policies of the third-party and co-branding websites before giving feedback on offers, products or services advertised by such entities.

 

 

D. RIGHTS RELATING TO PERSONAL DATA

Pursuant to current legislation on this subject, the User/Member has the right to access his/her Personal Data stored by Mongey as well as other rights. If the User/Member is a Visitor from the European Union, he/she must refer to section I. VISITORS FROM THE EUROPEAN UNION below for further information.
If you have any questions regarding this Privacy Policy or if you intend to gain access to or correct your Personal Data, you can send us a written request to: info@mongeyapp.com
If, and to the extent permitted by applicable law, we can charge you a reasonable commission for processing any request made in relation to your Personal Data.
 

 

E. BROWSING DATA AND COOKIES

 

Does Mongey use "cookies"?
Yes, the Mongey Website uses "cookies".
The Website uses "cookie" as well as other technologies so that all users have the most pleasurable and efficient browsing experience possible.

By continuing to visit the Website or to use our services, you tacitly declare to accept the use of "cookies" and similar technologies for the purposes described later on in this Privacy policy.

 

What is a "cookie"?
A "cookie" is a small piece of data that is saved usually in the browser of the User’s computer, tablet or smartphone used to surf the web.

 

Classification of cookies

- According to who issues them: "cookies" can be classified in the following categories:

"A first-party cookie": This is the "cookie" that is stored (more precisely: "saved") in the User’s browser on the instructions provided by the Website visited by the User;
"A third-party cookie": This is the "cookie" that is stored (more precisely: "saved ") in the User’s browser on the instructions provided by other Websites;
At this point, it is natural to ask oneself: "What do other Websites have to do with the fact that I am browsing on only one particular Website?" Well, they are relevant because perhaps banners (advertising spaces) managed by other Websites (or rather loaded from their server) are hosted on the Website you are visiting, which can easily leave their own "cookies" on your mobile device.

- According to the time the “cookie” remains on the User’s device: Depending on their lifecycle, "cookies" can be further classified as follows:

"Session cookies": These are removed when the User closes the browser and that, therefore, have an extremely limited duration;

"Permanent cookies": These are stored for a long period of time. However, this type of "cookie" has an expiry date. "Permanent cookies" enable Websites to recall information and settings on the User’s subsequent visits, making browsing more practical, rapid and efficient.
- According to the function they carry out: These "cookies" can be further classified as follows:

"Technical cookies": These are required to support browsing to provide a service rested by the User. They are not used for other purposes and are usually installed directly by the owner of the Website.

Practical example:
Let’s imagine that a User is authenticated on (logs into) the Website that he/she is visiting. The "technical cookie" that will be issued on the browser of the User’s device and is needed so that the authentication remains active for the entire duration of his/her browsing session. In fact, a good service would not be provided if the User were to be logged out of the Website every 5 seconds, forcing him/her therefore to login again. In this case, the "technical cookie ", keeps the authentication on the Website active (and therefore also the access to all services potentially reserved exclusively to Users that are logged in) until the User stops surfing the internet by closing his/her browser.
It is also important to point out that a "technical cookie" of this kind is programmed to be active much longer than a single browsing session. In fact, it could also last several months. This means that, every time the User goes back to visit the, he/she will find him/herself automatically logged in, because the "technical cookie" stored in his/her browser will make sure that he/she is immediately and automatically recognised by the Website. This type of "cookie" is entirely legitimate also without the User’s authorisation on the browser of whom they are stored.
"Profiling cookies": These are used to create User-related profiles with the aim of sending advertisements on-line according to the preferences shown by the same while browsing on-line.

Practical example:
The User carries out research on the Website, the content of which (or rather the search string used, for example "company name xyz") is recorded by means of a "cookie" in his/her browser, to remind him, the next time he/she visits the web, of all the products he/she had searched and seen previously and which he/she could be particularly interested in (and likely to purchase). This is not allowed without providing a suitable Privacy policy and obtaining the User’s consent.

In the example above, the profiling cookie is a "first-party" cookie. However, very often it happens that this type of cookie is a "third-party" cookie. This is the case every time in which the Website visited hosts third-party advertising (e.g. Google Adsense), which issues "cookies" on the User’s device with the aim of understanding his/her purchasing preferences.

"Analysis and tracking cookies": This type of "cookie" has given rise to a few difficulties regarding its classification, the solution to which appears complicated.
By taking a quick glance, one would likely consider them "profiling cookies". What more than “statistics” would evoke the concept of profiling? However, the law, in reality, considers "analysis cookies" to be instrumental to the functioning of a Website, and for this reason, it includes it in the category of "technical cookies". Therefore, it seems that there is no obligation to request any kind of consent.
Actually, this may not be the case, as these "cookies" are, in most cases, issued not directly by the Website itself, but by a third party, mainly Google to Analytics, and therefore only for this reason they are subject to the same regime as the "profiling cookies ". This is because, if we read the "Cookie policy" carefully, in point a) of foreword 1, dedicated specifically to "technical cookies", it is written as follows: These are not used for further purposes and are normally installed directly by the owner or operator of the Website. Therefore, if the "cookie" is not installed directly by the editor, then it is a “third-party cookie". Consequently, "third-party cookies" should be subject to the same regime as "profiling cookies".

 

Which "cookies" does Mongey use?

- Technical cookies;
- Analysis and tracking cookies: Mongey, with the aim of analysing the use of the Website, avails itself of the web analysis service Google Analytics provided by Google. More specifically, Google Analytics uses "cookie" (both of a temporary and permanent nature) to anonymously collect information on the methods of use of the Website by its Users (including IP addresses) that will be transmitted from the User’s browser to the Google server. The information collected will be used by Google with the aim of assessing the use of the Website by the User, to fill in a report on the activities of the Website useful for operators of the same Website and to provide other services relating to the activities of the Website as well as the use of internet.
Further information on the Google Analytics service and the procedures to follow in order to disable "cookies" can be found by clicking on the following links:
- Privacy policy;;
- Use of cookies.

Please note that such data does not enable the personal identification of the User.

 

Can "cookies" be avoided?

Of course. Each User, if he/she so wishes, can disable them.
Each browser has its own method to either limit or disable cookies.
Here are a few links where it is possible to find information to modify browser settings:

Google Chrome;
Mozilla Firefox;
Internet Explorer;
Microsoft Edge;
Safari for macOS;
Safari for iOS.

In any case, for those who really do not want to use "cookies", the simplest thing to do is to use the "incognito browsing mode".
The possibility to activate the incognito browsing mode is included in the main browsers such as Chrome, Firefox and Internet Explorer. By activating such mode, it is possible to surf the web without leaving any trace on the device used.

Therefore, if you wish, you can browse the Mongey Website without using any "cookies" at all, simply by using the "incognito browsing mode" on your browser.

If there are parts of this Privacy policy that are not clear to you, or you simply wish to have clarifications on what you have read, please send us an e-mail to the following address: info@mongeyapp.com

 

 

F. MINORS

Websites and their contents are not aimed at minors (people aged under 18) and we do not intend to sell any products or services to minors. If a minor has provided us with his/her Personal Data without his/her parents’ or guardians’ consent, the parent or guardian should contact us by sending an e-mail to info@mongeyapp.com to request the deletion of such information.

 

 

G. SAFETY MEASURES

We use commercially reasonable safety methods to prevent unauthorised access to the Websites, we maintain the accuracy of the data and guarantee the proper use of the information we possess.
For all Users/Members registered on the Websites, some of your information may be seen and modified through your account, that is protected by a password. It is advisable not to give your password to anyone. Our staff will never ask you for your password during a phone call or in an e-mail unless requested by the User/Member. If you share a computer with other users, it is advisable not to save your log-in credentials (e.g. User ID and password) on that shared computer. Reminder: It is important that Users log out of their account and close the browser window when they finish their browsing session.
No transmission of data on Internet or on any wireless network can be guaranteed as being perfectly safe. Consequently, while we try to protect the Users’/Members’ information in our possession, we are not able to guarantee the safety of all the information that the User provides us and therefore this is carried out at his/her own risk.

 

 

H. UPDATES TO THE PRIVACY AND COOKIE POLICY
Every now and then we can update this Privacy policy in order to comply with constantly changing regulatory, technical or commercial developments. When we update our Privacy policy, we will adopt adequate measures to inform you of such, coherently with the importance of the modifications we have carried out. We will obtain your consent to any substantial modification to be made to the Privacy policy if and when it is requested by applicable laws on the subject of data protection.
Any modification made to this Privacy policy will be communicated by us by posting a variation to the Privacy policy on our Websites. Once this has been posted on the Websites, the new Privacy policy will enter into force immediately. It is possible to see when the last time the Privacy policy has been updated by checking the date of the “latest update” that can be seen at the top of this Privacy policy.

 

 

I. VISITORS FROM THE EUROPEAN UNION
This section of the Privacy Policy applies only if you use our Websites or services mentioned in this Privacy Policy in a state that is a Member State of the European Union, and integrates the information stated in this Privacy Policy.
If you are resident in the European Economic Area (EEA), your data controller is QUEEN 5 SRL – Economic and Administrative Index N°: RM-1524651 – Tax Code: 14486711006 – V.A.T. N° 14486711006 - Headquarters: Via Antonio Bertoloni 14, 00197 Roma (Italy). For contact details, please refer to section J) HOW TO CONTACT US below.

 

LEGAL BASIS FOR DATA PROCESSING

We process Personal Data for the purposes specified in this Privacy Policy, as described previously. Our legal basis to process Personal Data will depend on the Personal Data in question as well as the specific context in which we collect it. However, we normally collect and process your Personal Data when the processing of such is deemed necessary in order to enter into any type of contract between you and QUEEN 5 Srl (e.g. to provide you with the services you require as well as to identify and authenticate you, enabling you to use the Websites) and if necessary, to comply with legal obligations (e.g. to comply with applicable accounting laws and to provide public security forces with mandatory statements); required to safeguard our legitimate interests and that do not prevail over your rights; and/or where such is based on your consent.
If we collect and use your Personal Data by relying on our legitimate interests (or those of any third party), said interests will normally be those of wishing to make our Websites and services work, managing our business relationship with you and to communicate with you, when necessary, to provide you our services and in our legitimate commercial interests, for example, when we reply to your questions, we improve our Websites and services, we carry out marketing activities, or with the aim of guaranteeing the safety of our Websites and services and to identify or prevent any illegal activities such as fraud. We can also have other legitimate interests and, if this is the case, we will clearly inform you of such at the appropriate time.
If we ask you to provide your Personal Data in order to allow us to comply with a legal requirement or to enter into a contract with you, we will clearly inform you at the appropriate time and tell you whether it is compulsory or not to provide your Personal Data (together with the possible consequences incurred by the failure to provide your Personal Data). In some cases, you may be required to provide us with your Personal Data for processing purposes as specified above, with the aim of being able to provide you with all our services and to allow you to use all the features on our Websites.
We will retain your Personal Data as long as we have a valid, legitimate corporate need to do so, e.g. to provide you with services or products or as requested or permitted by applicable law, such as tax and accounting legislation. When we no longer have a valid, legitimate corporate need to process your Personal Data, we will either delete it or make it anonymous or, if this is not possible (e.g. because your Personal Data have been stored in the back-up), we will store it safely and exclude it from any further processing until it is possible to delete it.
If you have any questions on this matter or if you need any further information on the legal basis on which we collect and use your Personal Data, please contact us using the contact details provided in section J) HOW TO CONTACT US below.

 

 

INTERNATIONAL PERSONAL DATA TRANSFERS

Our business may make it necessary to transfer your Personal Data to States located outside European Economic Area (EEA), including States that cannot provide the same level of data protection as your State of residence, such as the USA and China. We adopt adequate measures in order to guarantee that who receives your Personal Data is bound by confidentiality obligations and we also implement appropriate measures in order to guarantee that your Personal Data will be protected in accordance with this Privacy Policy, such as the standard contractual clauses. You can request a copy of these clauses by sending an e-mail to info@mongeyapp.com

 

 

YOUR RIGHTS

If you are a resident in the European Economic Area (EEA), you are entitled to the following rights on the subject of data protection, that you can exercise at any time whatsoever by contacting us using the contact details provided in section J) HOW TO CONTACT US below:

You have the right to access, correct, update or request the deletion of your Personal Data.
You have the right to oppose the processing of your Personal Data when it is based on our legitimate interests and separately, the right to oppose direct marketing activities.
You have the right to ask us, in certain situations, to limit the processing of your Personal Data or request the portability of the same.
You have the right to unsubscribe (opt-out) at any time whatsoever, from the marketing communications that we send you. You can exercise this right by clicking on “unsubscribe” or “opt-out” seen in the marketing e-mails that we send you. In order to unsubscribe from other forms of marketing (such as postal marketing or telemarketing activities), please contact us using the contact details provided in section J) HOW TO CONTACT US below.
If we have collected and processed your Personal Data with your consent, you have the right to withdraw your consent at any time whatsoever. The withdrawal of your consent will neither influence the lawfulness of any processing activities carried out prior to your withdrawal, nor will it influence the processing of your Personal Data carried out by relying on the legal basis to carry out processing activities other than consent-based operations.
You have the right to put lodge a complaint with a data protection authority with regards to our collection and use of your Personal Data. For further information, please contact your local Antitrust Data Protection Authority.
We reply to all requests we receive from Users/Members who wish to exercise their rights in accordance with applicable laws on data protection.
If you are aware of any changes that are need to be made to or of any inaccuracies in your Personal Data, you must inform us of such changes so that our archives can be updated and rectified.

 

 

J. HOW TO CONTACT US

For any requests regarding what is stated in this Privacy Policy, please contact us at the following e-mail address info@mongeyapp.com

 

QUEEN 5 SRL
queen5srl@pec.it
Economic and Administrative Index N°: RM-1524651
Tax Code: 14486711006
V.A.T. N°: 14486711006
Headquarters: Via Antonio Bertoloni 14, 00197 Rome (Italy)

 

 

Enjoy browsing!
This Privacy Policy is subject to being updated by Mongey.
The version published on the Website is the one currently in force.

 

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Last update: 5th May 2019