Betwyll respects your privacy and all the data that you provide to Betwyll are managed in compliance with rules and good practices of confidentiality and security. For any questions regarding this policy please write to info@betwyll.com

Owner of the processing of personal data

Betwyll Srl
via Ormea 48
10125 Torino

info@betwyll.com

Personal data collected

Betwyll records various personal data of users, through the app and the website, some of which are explicitly controllable by the user, others are gathered implicitly while using the app and the website themselves.

Data collected on the app with explicit request:

  • Name
  • Surname
  • Email address
  • Password
  • Language
  • Picture

Data logged by the app based on usage:

  • Registration date
  • Date and time of last login
  • Last device used to use the app

Data recorded on the website betwyll.com

  • Anonymous browsing data
  • Data for subscribing to the newsletter:
    • Name
    • Surname
    • Email address

Full details on each type of data collected can be provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the data collection.

Personal data may be freely provided by the user or, in the case of usage data, automatically collected during the use of the app and the Betwyll website.

Unless otherwise specified, all data required by Betwyll are mandatory. If the user refuses to communicate them, it might be impossible for Betwyll to provide the service. In cases where Betwyll indicates some data as optional, users are free to refrain from communicating such data, without this having any consequence on the availability of the service or its operativity.

Users who have doubts about what data is mandatory are encouraged to contact the owner.

The use of cookies-or other tracking tools-by the Betwyll app, the Betwyll site or the owners of third-party services used by Betwyll, if not otherwise specified, has the purpose of providing the service requested by the user, In addition to the additional purposes described in this document and in the Cookie Policy, if available.

The user assumes responsibility for the personal data of third parties obtained, published or shared through the tools of Betwyll and guarantees to have the right to communicate or disseminate them, freeing the holder from any liability to third parties.

Processing method and place of the data collected

Processing mode

The owner shall take appropriate security measures to prevent unauthorized access, disclosure, alteration or destruction of personal data.

The processing is carried out by means of IT and/or telematic tools, with organizational modalities and logics strictly related to the indicated purposes. In addition to the owner, in some cases, other subjects involved in the organization of Betwyll (administration, sales, marketing staff; lawyers; system administrators) or external subjects (such as service providers of third-party technical services, postal carriers, hosting providers, IT companies, communication agencies), also nominated, if necessary, responsible for the processing by the owner, may have access to the data. The updated list of the people responsible for the processing can always be required to the owner of the data.

Legal basis of the processing

The owner processes personal data relating to the user if one of the following conditions exists:

  • The user has consented for one or more specific purposes; Note: In some legislations the owner may be authorized to process personal data without the consent of the user or without any of the legal bases specified below, until the user opposes (“opt-out”) to such processing. However, this is not applicable if the processing of personal data is governed by the European legislation on the protection of personal data;
  • The processing is necessary for the execution of a contract with the user and/or the execution of pre-contractual measures;
  • The processing is necessary to fulfill a legal obligation to which the owner is subject;
  • The processing is necessary for the execution of a task of public interest or for the exercise of public powers the owner is assigned;
  • The processing is necessary for the pursuit of the legitimate interest of the owner or of third parties.

However, it is always possible to ask the owner to clarify the actual legal basis of each processing and in particular to specify whether the processing is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The data are processed at the operative offices of the owner and in any other place where the parties involved in the processing are based. For more information, contact the owner.

User personal information may be transferred to a country other than the one where the user is located. To obtain further information on the processing place, the user can refer to the Details section on the processing of personal data.

The user is entitled to obtain information on the legal basis of the transfer of data outside the European Union or to an international organization of public international law or consisting of two or more countries, such as the UN, as well as on the security measures adopted by the owner to protect the data.

The user can check if one of the transfers described above is taking place by examining the section of this document regarding details on the processing of personal data or requesting information from the owner by contacting him through the details mentioned at the beginning.

Retention Period

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

Therefore:

  • Personal data collected for purposes related to the execution of a contract between the owner and the user shall be retained until the execution of that contract is completed.
  • Personal data collected for purposes attributable to the owner’s legitimate interest will be retained until such interest is fulfilled. The user may obtain further information about the legitimate interest pursued by the owner in the relevant sections of this document or by contacting the owner.

When the processing is based on the user’s consent, the owner may retain personal data for longer until such consent is revoked. In addition, the owner may be obliged to retain personal data for a longer period in compliance with a law obligation or by order of an authority.

At the end of the retention period the personal data will be erased. Therefore, the right to access, cancellation, rectification and the right to data portability can no longer be exercised once this term is over.

Purpose of processing the data collected

In addition to the purposes strictly related to the use of the app, for which the conferral of the authorization to use the data is mandatory, Betwyll uses the data provided by the user to carry out use analysis, to contact the user for email communications related to the use of the app and to initiatives of its interest.

In order to obtain further detailed information on the purposes of the treatment and on the personal data which are actually relevant for each purpose, the user may refer to the relevant sections of this document.

User Rights

Users may exercise certain rights with respect to the data processed by the owner.

In particular, the user has the right to:

  • Revoke his/her consent at any time. The user may revoke the consent to the processing of his/her personal data previously expressed.
  • Oppose the treatment of his/her data. The user may oppose the processing of his/her data when it happens on a legal basis other than consent. Further details on the right of opposition are given in the section below.
  • Access his/her data. The user is entitled to obtain information on the data processed by the holder, on certain aspects of the treatment and to receive a copy of the data processed.
  • Check and ask for rectification. The user can verify the correctness of his/her data and request their updating or correction.
  • Get the treatment limitation. When certain conditions are fulfilled, the user may request the limitation of the processing of his/her data. In this case the owner will not process the data for any other purpose other than their preservation.
  • Get the cancellation or removal of his/her personal information. When certain conditions are fulfilled, the user may request the cancellation of their data by the owner.
  • Receive his/her data or have them transferred to another owner. The user has the right to receive his/her data in a structured format, of common use and readable by automatic device and, where technically feasible, to obtain the transfer without hindrance to another owner. This provision is applicable when the data is processed by automated means and the processing is based on the user’s consent, on a contract of which the user is part or on contractual measures related thereto.
  • Propose complaint. The user may submit a complaint to the supervisory authority responsible for the protection of Personal data or to act in judicial proceedings.

Details of the right to oppose

When personal data is processed in the public interest, in the exercise of public authority of which the owner is invested or to pursue a legitimate interest of the owner, users are entitled to oppose the treatment for reasons related to their particular situation.

Users are made aware that, where their data are processed for direct marketing purposes, they can oppose the treatment without giving any motivation. To find out whether the owner processes data for direct marketing purposes, users can refer to the relevant sections of this document.

How to exercise one’s rights

To exercise their rights, users can send a request to the contact details of the owner indicated in this document. Requests are filed free of charge and processed by the owner as soon as possible, in any case within one month.

Learn more about the processing

Defense in court

The personal data of the user may be used by the owner in court or in the preparatory phases to a possible trial for the defense against abuses in the use of the website, of Betwyll app or its related services by the user.

The user declares to be aware that the owner may be obliged to disclose the data by order of the public authorities.

Specific information

At the user’s request, in addition to the information contained in this privacy policy, the app Betwyll and its website may provide the user with additional and contextual information regarding specific services, or the collection and processing of personal data.

System logs and Maintenance

Due to operation and maintenance needs, the Betwyll app, the website and any third party services they use may collect system logs, i.e. files that record interactions and may also contain personal data, such as the user’s IP address.

Information not contained in this policy

Further information regarding the processing of personal data may be required at any time to the owner of the processing using the contact details.

Answer to “Do Not Track” requests

The Betwyll website does not support the “Do not Track” requests.

To find out if any third party services used support them, the user is invited to consult their respective privacy policies.

Changes to this Privacy policy

The owner of the data processing reserves the right to make changes to this privacy policy at any time informing the users on this page and, if possible, on the app and on the website, and, if technically and legally feasible, sending a notification to the users through one of the contact details the holder has. Please consult this page regularly, referring to the date of last edit indicated at the bottom.

If the changes affect processing whose legal basis is the consent, the owner will require the user’s consent again, if necessary.

Details on the processing of personal data

Google Analytics

The services contained in this section allow the owner to monitor and analyse the traffic data and serve to keep track of the user’s behaviour.

Google Analytics is a Web analysis service provided by Google LLC (“Google”). Google uses the personal data collected for the purpose of tracking and examining the use of this application, compiling reports and sharing them with other services developed by Google.

Google may use your personal information to contextualize and personalize your ad network ads.

Personal data collected: cookies and usage data.

Place of treatment: USA Privacy Policy Opt Out. Subject adhering to the Privacy Shield.

MailChimp

This type of service allows you to manage a database of email contacts, phone contacts, or contacts of any other type, used to communicate with you.

These services may also allow you to collect data about the user’s message display date and time, as well as user interaction with them, such as information about clicks on links placed in messages .

MailChimp (The Rocket Science Group, LLC.)

MailChimp is an address management and email delivery service provided by The Rocket Science Group, LLC.

Personal data collected: Email, name, surname, country, various types of data

Place of Treatment: USA – Privacy Policy .