cAPPture information about use of personal data

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People S.r.l., with registered offices in Milan, 20121, Via Alessandro Volta, 16, entered in the Milan Companies’ Registry at REA No. 1643391, VAT No. 13443050151 (“People” or “Company”) is a firm that designs, develops and conducts social market research, sampling surveys and opinion polls and is the owner of the software application cAPPture (henceforth “cAPPture”).

This is to inform you that under the provisions of Article 13 of the EU Regulation No. 2016/679 (henceforth also “GDPR”) data processed and/or received for use in cAPPture will be used for the purposes and in the ways indicated in this privacy notice.

This information notice is to be understood as an integral and substantial part of the Terms and Conditions of Use of cAPPture .

  1. Definitions
    1. cAPPture: Application is used for conducting market research which is managed by administrators and moderators selected by People, either in real-time or later (depending on the project), and offering the following possibilities:
      1. participate in individual or group discussions either simultaneously or consecutively (depending on the project): diaries, forums/blogs and groups;
      2. share opinions and personal attitudes about the topics dealt with (depending on the project);
      3. post your contributions in written, audio or video format;
      4. post photos and videos about yourself and your family/relatives/friends/acquaintances;
      5. post contents by third party authors in the public domain as web links, audio and video files, screenshots from smartphones;
      6. comment on the contributions of other participants and of the moderators;
      7. receive comments from other users (participants and moderators) about your own contributions shared on the platform;
      8. view and comment on verbal, visual and audio-visual information about communications, products and sensitive information owned by third parties and protected by confidentiality and secrecy rules;
    2. Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
    3. Personal data: any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    4. Particular data: Personal information that, by its nature, requires particular caution: particular data is the type that can reveal racial or ethnic origin, political opinions, religious or philosophical beliefs or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.
  2. Data processed
    1. The personal data and information provided and/or collected as a result of the user’s use of cAPPture through the participation in the activities referred to at point 1.1 above will be subject to processing within the limits and by the methods described in this privacy notice.
    2. For any particular data transmitted or communicated by the user when using cAPPture, specific written consent is required.
    3. Regarding the types of data indicated in Article 1.1 (d) above, if such data include images and/or recordings of minors, People will process such data in full compliance with current privacy legislation, within the limits and using the methods illustrated in this Privacy Notice, ensuring that the data are rendered anonymous and obtaining the prior consent/release for their use from the person exercising parental authority.
  3. Methods and purposes of processing data.
    1. Methods
      1. For the purposes referred to at point 3.2 below, personal information is processed by manual, digital and data transmission instruments using logic strictly connected to the purposes of cAPPture and, in any case, in a way that assures the security and confidentiality of the data in accordance with the provisions of Article 5 of the GDPR. Specifically, the information could be processed in the following ways:
        1. collecting of information from the data subject concerned;
        2. collecting of data from registers, lists of records or public documents;
        3. recording and processing on paper;
        4. recording and processing digitally;
        5. organising of filing systems in both automated and non-automated form;
      2. Of the data received, People will ensure: (i) their exact registering so that they correspond to the information given by the data subject; (ii) their updating following every notifying of change from the data subject; (iii) their retention in a form allowing the identification of the data subject for a period of time not exceeding that required for the purposes for which they were collected.
      3. Those privy to the information can include all subjects specifically designated by People as persons authorised for processing data to the extent and scope assigned to each, as well as the subjects to whom the data can be communicated or transferred as specified below.
      4. As regards the collecting of information, cAPPture:
        1. uses the IP (Internet Protocol) Address to collect information;
        2. does not use Browsing Data;
    2. Purposes
      1. People collects and processes personal data to:
        1. conduct market, statistical and/or sampling research;
        2. analyse consumption habits and/or choices;
        3. conduct opinion polls;
        4. obtain aggregate statistical information on the use of cAPPture;
        5. check the correct operation of cAPPture to solve any technical problems;
      2. The Company reserves the right to remove from its files any data received that, on checking, prove to be inaccurate, incomplete or not up to date.
  4. Communications and transfer of data.
    1. Communications
      1. The Company will only disclose personal data collected if this is necessary for achieving the purposes referred to in point 3.2, or is required to do so by law. Therefore such data can be communicated to: (i) public security authorities, public bodies or private companies, for the fulfilment of legal obligations; (ii) companies dealing with statistical calculations or market research. Data will be disclosed to these subjects by ensuring beforehand the anonymity of the data subjects concerned; (iii) affiliated companies and franchises; (iv) data processing and IT services companies (e.g. web hosting, data entry, management and maintenance of infrastructures and IT services, etc.); (v) companies and firms engaged by the Company to provide general consulting services; (vi) group companies in the form of parent, controlled or affiliated companies.
      2. You are specifically informed that, in accordance with the provisions of GDPR, it is required that we communicate or disclose the user’s data if demanded, by virtue of the law, by the police forces, judicial authorities, information and security bodies or other public subjects for the purpose of State defence or security or for preventing, detecting and suppressing offences.
      3. We are required to hold your personal data for all the time necessary to comply with our legal and contractual obligations. In this regard, we work to ensure that the user’s personal data are not only kept but updated if necessary. The user is therefore required to inform us of any modification to the user’s personal data to allow us to update or erase them accordingly.
      4. The User can contact us at any time by email at to know which of his/her personal data are in our possession and to request that they be updated or erased.
      5. If, following the user’s request referred to in point 4.1.4 above, no data concerning the user is confirmed as in our possession, the user will be requested to pay a contribution to expenses not exceeding the costs actually borne for the search carried out in the specific case.
      6. If no instruction is received from the user, after the expiry of a reasonable time, we will either store the data or erase them.
      7. In any case, as required by Article 5 (1e) of the GDPR, your personal data that have been processed will be kept for a period of time not exceeding that required for the purposes for which they were collected or subsequently processed.
  5. Rights of Data Subjects
    By writing to the following address: at any time you can exercise your rights towards People in accordance with the privacy regulations, which we reproduce for your convenience.
    The interested party has the right to obtain confirmation that the processing of personal data concerning him or her is ongoing and, if so, to obtain access to personal data and the following information:

    1. the purposes of the processing;
    2. the categories of personal data concerned;
    3. recipients or categories of recipients to whom personal data have been or will be disclosed, in particular recipients from third countries or international organizations;
    4. where possible, the expected retention period of personal data or, if not possible, the criteria used to determine that period;
    5. existence of the right of the data subject to request the controller to rectify or delete personal data or to restrict the processing of personal data concerning him or her or to object to their processing;
    6. right to lodge a complaint with a supervisory authority;
    7. where the data are not collected from the data subject, all available information on their origin;
    8. the existence of an automated decision-making process, with particular regard to profiling, and, at least in such cases, significant information on the logic used, as well as the importance and expected consequences of such processing for the data subject.

    The interested party also has the right to:

    • be informed of the existence of adequate safeguards pursuant to art. 46 GDPR relating to the transfer where personal data are transferred to a third country or to an international organization;
    • obtain a copy of the personal data being processed;
    • obtain the rectification of inaccurate personal data concerning him/her without undue delay in the cases referred to in art. 17, paragraph 1, GDPR, writing to the following address:;
    • obtain the deletion of personal data concerning him/her without undue delay;
    • obtain the limitation of processing in the cases referred to in art. 18, paragraph 1, GDPR;
    • receive in a structured format, of common use and machine-readable personal data concerning him/her provided to a controller and to transmit such data to another controller without obstacles by the controller in the cases referred to in art. 20 GDPR; to exercise his/her right to data portability to other subjects, the interested party must make an explicit request by writing to the following address:;
    • oppose at any time, for reasons related to his/her particular situation, the processing of personal data concerning him/her, including profiling;
    • not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him/her or similarly significantly affects him or her.

    If the processing of data is based on the consent of the data subject, the latter has the right to revoke this consent at any time by making an explicit request by writing to the following address:
    The exercise of these rights can be exercised with a request addressed to People sent by phone, by e-mail to the address indicated above or also by registered letter A/ R to be sent to the following address: Milan, 20121, Via A. Volta, 16.

  6. The Data Controller for all intents of the law and the Data Protection Officer are:
    • Data Controller: People S.r.l., with registered offices in Via Alessandro Volta 16, 20121, Milan, entered in the Milan Companies’ Registry at REA No. 1643391, VAT No. 13443050151.
    • Data Protection Officer: Roberto Parruccini, Fiscal code No. PRRRRT77D28H501O, VAT No. IT08173271001, with office in Milan, 20122, Via Durini, 2.
    • The data subject can contact the Data Controller and/or the Data Protection Officer by writing to .