Pursuant to current data protection regulations (the "Privacy Regulations"), including Regulation (EU) 2016/679 (the "GDPR") and Italian Legislative Decree 196/2003 as amended by Legislative Decree 101/2018 (the "Privacy Code"), Flyip S.r.l., as data controller (hereinafter, the "Company" or the "Controller"), informs users (hereinafter the "Users" or, individually, the "User") of the website www.memofly.it (the "Site"), that it will process their personal data collected through the Site itself in the manner and for the purposes described below in this notice (the "Notice").

This Privacy Notice applies only and exclusively to the Site and not to other websites owned by the Company or owned by third parties that the User may access through links contained in the Site.

1. Types of data processed through the Site

The Company will process the following types of personal data of Users who browse and interact with the Site's web services, in particular:

Data collected implicitly during navigation

The computer systems, cookie technology and software procedures used for the operation of the Site acquire, during their normal operation, certain data whose transmission is implicit in the use of the Internet. This is information that is not collected to be associated with identified data subjects, but which by their very nature could, through processing and association with data held by third parties, allow Users to be identified.

This category of data includes, for example:

the IP addresses or domain names of the computers used by Users
the pages visited by Users within the Site
the domain names and addresses of the websites from which the User accessed the Site
the URI addresses of the requested resources
the time of the request
the method used to submit the request to the web server
the size of the file obtained in response
other parameters relating to the type of browser and operating system

Such data are also processed for the purpose of:

obtaining statistical information on the use of services
checking the correct functioning of the systems offered

2. Legal basis and purposes of processing

Data collected during navigation will be processed, without the User's prior consent being necessary, for the following purposes:

Site Navigation: to allow Users to browse the Site. The legal basis is the legitimate interest of the Company.
Technical Maintenance: to perform maintenance and technical assistance necessary to ensure the correct functioning of the Site.
Legal Protection: to allow the Company to exercise its rights in court and suppress unlawful behavior.
Fraud Prevention: to prevent fraud or other crimes through the use of the Site.
Statistics: to obtain statistical information on the use of services.

3. Nature of Data Provision

The provision of implicitly provided data by the User occurs automatically when browsing the Site.

4. Data Processing Methods

User data processing is carried out through the operations indicated in Article 4 of the GDPR. User data:

will be processed in compliance with the principles of lawfulness, fairness and transparency
will be collected for the legitimate purposes determined above
will be adequate, relevant and limited to what is necessary
will be kept for a period of time not exceeding the achievement of the purposes
will be processed in a manner that ensures adequate security

5. Access to Data

Data may be made accessible exclusively for the purposes stated above to: employees and collaborators of the Company or of related, controlled, affiliated companies, duly authorized by the same, as persons authorized to process data.

6. Communication of Data

Even without the express consent of the User, the Company may communicate User data to supervisory and/or control bodies, judicial authorities as well as to all other subjects to whom communication is mandatory by law.

7. Transfer of Data outside the EU

User data will not be transferred outside the European Union. Any transfer may take place only under the terms and with the guarantees provided by the Privacy Regulations.

8. Data Retention Period

Personal data will be kept for the duration of navigation and, subsequently, for a period not exceeding 6 months, except in cases where a different retention period is required by law.

9. User Rights

The User, as a data subject, will always have the right to:

Right of access: obtain confirmation of whether or not personal data exists
Right to rectification: request rectification or integration of personal data
Right to erasure: request erasure of data processed in violation of the law
Right to restriction: obtain restriction of processing
Right to portability: receive data in a structured format
Right to object: object to the processing of personal data

10. How to Exercise Rights

The User may at any time exercise their rights:

by sending a registered letter with return receipt to Flyip S.r.l., with headquarters in Nuoro at viale del Lavoro 17
by sending an email to: info@memofly.it

The User also has the right to lodge a complaint with the Data Protection Authority.

11. Data Controller

The Data Controller for personal data collected through this site is Flyip S.r.l., with headquarters in Nuoro at viale del Lavoro 17 and can be contacted at the email address: info@memofly.it.

12. Updates to the Notice

This Privacy Notice will be subject to periodic updates which will be highlighted on the Site.

Last updated: February 13, 2024