Penguinpass collects some Personal Data from its Users.
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Personal Data: Cookies; Usage Data
Personal Data: email address
Personal Data: address; city; company name; country; date of birth; email address; fax number; first name; last name; phone number; province; state; Tax ID; VAT Number; website; ZIP/Postal code
Personal Data: various types of Data
Personal Data: Approximate location permission (continuous); Approximate location permission (non-continuous); Calendar permission; Camera permission; Contacts permission; Precise location permission (continuous); Sensors permission; Storage permission
Personal Data: Cookies; Usage Data
Personal Data: various types of Data as specified in the privacy policy of the service
Personal Data: various types of Data as specified in the privacy policy of the service
Personal Data: address; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; various types of Data
Personal Data: various types of Data as specified in the privacy policy of the service
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Penguinpass may request access to your address book.
The Owner may use the Personal and Usage Data collected through penguinpass to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
The Owner of penguinpass may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Penguinpass may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
Penguinpass may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
Penguinpass may send push notifications to the User.
Penguinpass srl - Corso Europa 10, 20122, Milano, Italia | P.I. 08866100962
Owner contact email:info@penguinpass.co
Penguinpass srl - Corso Europa 10, 20122, Milano, Italia | P.I. 08866100962
Owner contact email:info@penguinpass.co
Among the types of Personal Data that penguinpass collects, by itself or through third parties, there are: email address; first name; last name; date of birth; phone number; VAT Number; company name; address; fax number; country; state; province; ZIP/Postal code; city; Tax ID; website; various types of Data; Cookies; Usage Data; gender; profession; Calendar permission; Contacts permission; Camera permission; Precise location permission (continuous); Approximate location permission (continuous); Approximate location permission (non-continuous); Sensors permission; Storage permission.
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 penguinpass.
Unless specified otherwise, all Data requested by penguinpass is mandatory and failure to provide this Data may make it impossible for penguinpass to provide its services. In cases where penguinpass 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 penguinpass or by the owners of third-party services used by penguinpass 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.
Users are responsible for any third-party Personal Data obtained, published or shared through penguinpass.
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 penguinpass (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.
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Contacting the User, Managing contacts and sending messages, Handling payments, Hosting and backend infrastructure, Device permissions for Personal Data access, Registration and authentication, Analytics, Data transfer outside the EU and Displaying content from external platforms.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Dataâ€.
Depending on the User's specific device, penguinpass may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of penguinpass.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by penguinpass.
Used for accessing the User's approximate device location. Penguinpass may collect, use, and share User location Data in order to provide location-based services.
Used for accessing the User's approximate device location. Penguinpass may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for penguinpass to derive the approximate position of the User on a continuous basis.
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Used for accessing the camera or capturing images and video from the device.
Used for accessing contacts and profiles on the User's device, including the changing of entries.
Used for accessing the User's precise device location. Penguinpass may collect, use, and share User location Data in order to provide location-based services.
Used for accessing data from sensors that Users may use to measure what is happening inside their body, such as for instance, heart rate.
Used for accessing shared external storage, including the reading and adding of any items.
Personal Data is collected for the following purposes and using the following services:
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 is a web analysis service provided by Google Inc. (“Googleâ€). Google utilizes the Data collected to track and examine the use of penguinpass, 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 processed: Cookies; Usage Data.
Place of processing: United States –Privacy Policy–Opt Out.
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning penguinpass. Your email address might also be added to this list as a result of signing up to penguinpass or after making a purchase.
Personal Data processed: email address.
By filling in the contact form with their Data, the User authorizes penguinpass to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: address; city; company name; country; date of birth; email address; fax number; first name; last name; phone number; province; state; Tax ID; VAT Number; website; ZIP/Postal code.
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List. Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Personal Data processed: various types of Data.
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via penguinpass.
Personal Data processed: various types of Data.
Penguinpass requests certain permissions from Users that allow it to access the User's device Data as described below.
Penguinpass requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Approximate location permission (non-continuous); Calendar permission; Camera permission; Contacts permission; Precise location permission (continuous); Sensors permission; Storage permission.
This type of service allows you to view content hosted on external platforms directly from the pages of penguinpass and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Maps is a maps visualization service provided by Google Inc. that allows penguinpass to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States –Privacy Policy.
Payment processing services enable penguinpass to process payments by credit card, bank transfer or other means. To ensure greater security, penguinpass shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy –Privacy Policy.
This type of service has the purpose of hosting Data and files that enable penguinpass to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of penguinpass. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland –Privacy Policy.
ArubaCloud is a hosting service provided by Aruba S.p.A.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Italy –Privacy Policy.
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailgun is an email address management and message sending service provided by Mailgun, Inc.
Personal Data processed: address; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; various types of Data.
Place of processing: United States –Privacy Policy.
By registering or authenticating, Users allow penguinpass to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, penguinpass will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States –Privacy Policy.
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Penguinpass may request access to your address book.
The Owner may use the Personal and Usage Data collected through penguinpass to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
The Owner of penguinpass may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Penguinpass may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
Penguinpass may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
Penguinpass may send push notifications to the User.
Penguinpass uses Trackers. To learn more, Users may consult theCookie Policy.
The Owner may process Personal Data relating to Users if one of the following applies:
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via penguinpass.
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 penguinpass 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.
In addition to the information contained in this privacy policy, penguinpass may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
For operation and maintenance purposes, penguinpass and any third-party services may collect files that record interaction with penguinpass (System logs) or use other Personal Data (such as the IP Address) for this purpose.
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.
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within penguinpass 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.
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.
Information collected automatically through penguinpass (or third-party services employed in penguinpass), which can include: the IP addresses or domain names of the computers utilized by the Users who use penguinpass, 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.
The individual using penguinpass who, unless otherwise specified, coincides with the Data Subject.
The natural person to whom the Personal Data refers.
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.
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 penguinpass. The Data Controller, unless otherwise specified, is the Owner of penguinpass.
The means by which the Personal Data of the User is collected and processed.
The service provided by penguinpass as described in the relative terms (if available) and on this site/application.
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 are Trackers consisting of small sets of data stored in the User's browser.
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
This privacy policy relates solely to penguinpass, if not stated otherwise within this document.
Latest update: February 18, 2021
iubendahosts this content and only collectsthe Personal Data strictly necessaryfor it to be provided.