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Privacy Policy

The following Privacy Policy is written by Panini S.p.A. – Single Shareholder, headquartered in Modena, Italy, viale Emilio Po 380 – 41126, Tel. +39 059 382111 - Fax +39 059 827431 (hereinafter “Panini”) as Data Controller of the personal data collected in our websites and applications for smartphones and tablets Adrenalyn XL ™ Online Game (hereinafter websites and applications are collectively referred to as "Application” and/or "Applications”), provided directly by you or however received or generated by us as a result of us processing your registration to our Application. You can access the Adrenalyn XL™ Online Game also using a personal account you already have in one of the social networks included in the registration form. In this case, please refer to the Privacy Policy and the data sharing options of the above mentioned social networks.

Panini considers your privacy essential. We therefore ask you to read this information carefully in order to make a freely given, specific, informed and unambiguous choice when you are requested to give your personal data to log in to the Applications or part of them and when your personal data are necessary to use services provided by the Applications for example to purchase of products or services. In general, all the personal data (hereinafter “Personal Data” and/or “Data”) collected by Panini through the Applications or given by you when you use services provided by the Applications (hereinafter “Services”) as fully described in the following section “C. Purposes of Personal Data Processing” of this Privacy Policy, will be processed lawfully and in a transparent manner in accordance with the principles stated in the current legislation on the protection of personal data, such as transparency, fairness, lawfulness, data minimisation, purpose limitation, accuracy, storage limitation, integrity and confidentiality.

This Privacy Policy is written on the basis of the transparency principle using a simple and not too legal language to increase the level of understanding of the statements given. This Privacy Policy is divided into sections (hereinafter collectively "Sections” and/or individually "Section”), each of them dealing a specific topic, so that you can immediately find what you are looking for and concentrate your attention on the topic of interest. The Panini Applications may contain links to other websites and/or smartphone applications. Panini is not responsible for privacy practices or the content of such websites and/or smartphone applications.

A- Type of Personal Data Processed

Personal Data collected through the Application are listed below.

Name, Last name, Contact Details and other Personal Data

When you create an account to log into the Application Panini may ask your personal information such as: email, name, last name, gender,username, contact details, month and year of birth, soccer team supported and country of residence. In the same way, you may be asked to indicate other Data such as data coming from your submission of texts, drawings or registration information, on the occasion of participation in competitions, promotions, interactive games (such as those belonging to the Adrenalyn category) and initiatives of any kind. Further Personal Data may be collected during the management of each relationship through the Application itself or may consist of those that you decide to provide to Panini through the use of the Application.

Some sections of the Application can include free text fields in which it is possible to provide Panini with information that may contain Personal Data. Being free fields, you may choose to communicate (even inadvertently) particular categories of Personal Data, such as those revealing political opinions, religious or philosophical beliefs, or union membership, as well as genetic data, biomedical data which can permit to uniquely identify a specific person, data related to health or sex life or sexual orientation.

Panini asks you not to disclose any of these types of data, unless you consider it strictly necessary to pursue the request you forward to us. Since the indication of such information is, as said, totally optional, if you choose to do so, Panini could process such data only with your explicit consent and in compliance with the current legislation. Panini, therefore, underlines the importance of expressing your explicit consent to the processing of these particular categories of Personal Data in case you decide to share them with Panini.

Personal Data of Third Parties

As mentioned in the previous paragraph, by providing in the Applications free text fields in which it is possible to forward any type of message, these could in fact contain Personal Data relating also to other people. In all cases in which you decide to share such Data, you will be considered a self-appointed Data Controller and, as such, you will have to assume all the relevant legal obligations and responsibilities. Therefore, in this regard, you undertake to hold Panini harmless from any dispute, claim, request for compensation for damage from data treatment etc. that could reach Panini from people whose Personal Data have been forwarded by you in violation of the applicable rules on the protection of Personal Data.

As, in such cases, Panini does not collect this information directly from the data subjects (but indirectly from you), you guarantee that this specific treatment can be based on the consent of these data subjects or on another suitable lawful basis that legitimizes the processing of the information in question.

Navigation Data and Cookies

The computer systems and software used to run the Applications acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of Internet communication protocols. This information is not collected by Panini to be associated with identified data subjects, but by its very nature could, through processing and association with data held by third parties, allow data subjects to be identified. This category of data includes the IP addresses or domain names of the computers used by the users connecting to the Application, the addresses in URI (Uniform Resource Identifier) notation of the requested services, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (good result, error, etc.) and other parameters related to the operating system and the user's computer.

These data are used for the sole purpose of obtaining anonymous statistical information on the use of the Application, to check its correct functioning and to identify anomalies and/or abuses. Except in cases where the data are used to ascertain responsibility in the event of hypothetical computer crimes against the Application or third parties, these data do not persist for more than seven days.

Information on the use of cookies is available in our Cookie Policy that we invite you to read by clicking the following link Cookie Policy

B- Personal Data Processing of Children below the Minimum Age established by law to grant consent to the Processing of Data

Children aged less than 16 years old or, in accordance with national local laws, below the age set to directly collect the consent to the processing from children but in any case not less than 13 years old (hereinafter "Minor of Age" or "Minors of Age"), require the consent of one of their parents or legal guardians to register on the Applications to access the sections reserved for registered users.

Users minor of 18 are not allowed to purchase goods or services from our Applications.

Minors of Age workflow registration is as follows:

  1. A Minor of Age must filling the registration form on the Application giving all the personal data requested together with the name, surname, degree of kinship, email address of a parent or legal guardian of his.
  2. Registration of the Minor of Age is on hold until his parent or legal guardian manages the request of the registration. To be able to do this, the parent of the legal guardian must create an account on Panini Parents/Legal Guardians Register by following the link included in the email received by Webprivacy Panini.
  3. Once created an account, the parent or the legal guardian will be able to review the data submitted by the Minor of Age, change them if not right and manage the optional consents that can be required to process the personal data of the Minor of Age for additional purposes such as Marketing and Profiling activities. These additional processings are based on parent/legal guardian explicit consent that is not mandatory to register Minor of Age to the Application.
  4. if the parent or guardian approves the registration request, Minor of Age will be able to access the Applications at any time without any other notification to the parent or guardian.
  5. Minor of Age will not able to change the personal data included in the registration form and only the parent or legal guardian are allowed to do it by entering the Panini Parents/Legal Guardians Register or by contacting Panini at the address webprivacy@panini.it
  6. In case the parent or the legal guardian don't use the link within 72 hours from the reception or doesn't give consent to the processing of the personal data requested in the registration form, Minor of Age will not able to access the sections of the Applications under registration and the data collected in the registration form will be canceled in 24 hours.

When Minor of Age gets to the age set by the law be eligible to grant consent to the processing of his personal data, the appointed parent or legal guardian will stop managing Minor of Age personal data.

C- Purposes of the Personal Data Processing

We will process your Personal Data for the following purposes:

  • allowing the execution of operations strictly connected and instrumental to the management of relationships with you, such as enabling restricted sections of the Applications; assisting you in case you lose the login/password data of your personal account on the Applications; executing contracts for the sale of goods and/or services, managing and fulfilling orders via E-Commerce platforms; allowing you to participate in games, initiatives, competitions and prize events (Services Provision);
  • allowing the correct execution of the contractual obligations we have assumed towards you and vice-versa (Contractual Obligations);
  • complying with laws, regulations and EU legislation or with provisions issued by authorities empowered by law and provisions issued by Supervisory and Control Bodies, as well as allowing tax and accounting compliance (Legal Compliance);
  • carrying out information activities about our products and/or services as well as promotional, commercial, marketing campaigns and market research through the use of automated systems without operator intervention (for example, e-mail), but also through traditional methods of contact, such as the postal service; performing customer satisfaction surveys (by sending questionnaires, conducting surveys or conducting surveys) (Marketing)
  • sending you, if you are using or have used a service on an Application or if you are buying or you have bought a product or a service through the Application, direct marketing and promotional communication via e-mail about similar products or services (Soft Spam);
  • setting-up groups of users by processing the data provided by our users so that we don’t send generalized commercial and promotional communications to all users in an indistinct way. This enables us to segment users, creating groups based upon common features for example, on the country of origin, language, gender, previous purchases, etc. This allows us to send commercial communications - through the use of automated systems without the intervention of the operator (for example, e-mail), but also through traditional methods of contact, such as the postal service - that are the most relevant and least invasive possible, limiting as far as possible the circumstance that you receive messages not of your interest (Profiling).

D- Lawful Basis for Processing Personal Data, Mandatory/Discretionary Provision of Personal Data and Consequences in case of not providing

The lawful basis for processing the Personal Data, in accordance with the purposes set in the earlier Section of this Privacy Policy (“Purposes of the Data Processing”), is as follows. The provision of Personal Data and the related processing for the purposes related to Services Provision and Contractual Obligations, is strictly functional to the performance of the requested service and the correct execution of the contractual relationship with you and therefore they constitute a necessary condition for the establishment of the contractual relationship itself and the lawful basis of the processing. Consequently, failure to provide the Personal Data requested for this purpose, or the inaccuracy of the data provided, will make it impossible for Panini to carry out the service and the contractual relationship and would legitimize Panini to refuse to carry it out.

The provision of Personal Data, and the related processing for purposes related to Legal Compliance, is necessary for Panini in order to comply with the related legal obligations. When you provide your Personal Data to Panini, we must process them in accordance with applicable laws which may include the storage and communication to the competent authorities for compliance with tax, customs or other obligations.

The provision of Personal Data, and the related processing of such data for the purposes related to the Marketing activity, is based on your explicit consent collected through a specific checkbox. You are not forced to provide such consent to Panini and, if you do so, you are free to withdraw it at any time without suffering any consequence (other than not receiving marketing communications from Panini). You can withdraw your consent for this purpose by following the instructions contained in the "Data Subjects Rights" section of this Privacy Policy.

The provision of Personal Data, and the related processing, for the purposes related to the activity of Soft Spam is based on the legitimate interest of Panini to send marketing communications via e-mail regarding products and services similar to those you have already used or purchased through the application. You can stop the receipt of these communications without suffering any consequence (other than that of not being able to receive further communications of this kind by Panini) using the link at the bottom of each of the e-mails received for that purpose.

The provision of Personal Data, and the related processing, for the purposes related to the Profiling activity is based on your explicit consent collected through a specific checkbox. You are not obliged to provide such consent to Panini and, if you do so, you are free to revoke it at any time without suffering any consequence (other than not being able to benefit from the personalization of Panini's commercial offers). You can withdraw your consent for this purpose by following the instructions provided in the "Data Subjects Rights " section of this Privacy Policy.

E- Personal Data Sharing

The Personal Data will be made known to the Panini staff in charge of the development and management of the Applications that is authorized to process them for the purpose of achieving the aforementioned purposes and who are committed to confidentiality or otherwise have received an appropriate legal obligation to confidentiality.

Personal Data may be shared, used and transferred within the companies belonging to the Panini group for accounting and administrative purposes.

Personal Data will be made known to third parties, appointed as Data Processors, as they process Data on behalf of Panini (for example, companies responsible for managing and processing sales orders, suppliers with whom it is necessary to interact for the Service Provision such as hosting providers, platform providers for sending e-mails or, again, suppliers who perform technical maintenance activities including the maintenance of network equipment and electronic communications networks, suppliers who develop interactive games and competitions, software developers for the payment systems, suppliers providing the technological platform and payment gateway for orders for products in the e-payments area, payment service providers for e-payments activities).

Personal Data may be shared with third parties with whom Panini has ongoing contractual relationships concerning services functional to the performance of the activity (such as couriers for the delivery of products, audit firms, persons, companies or professional firms that provide assistance and advice on the subject, administrative, legal, tax, financial and credit recovery firms relating to the provision of the Services).

Finally, Personal Data will be communicated when requested to the competent taxation offices, or to other public bodies, according to the provisions of the laws in force.

Personal Data is not intended for publication or dissemination.

F- Personal Data Transfer

Given the international presence of Panini, some of your Personal Data may be shared with recipients, referred to in the previous paragraph, which could be found in countries outside the EU or the European Economic Area. Panini ensures that the processing of your Personal Data by these parties will be in compliance with applicable law. Therefore, the transfers will be made with adequate guarantees, such as adequacy decisions, models of Standard Contractual Clauses approved by the European Commission or other guarantees considered adequate.

More information is available by writing to Panini at the following address:webprivacy@panini.it

G- Personal Data Retention

The Personal Data processed for the purpose of Services Provision and Contractual Obligations will be retained by Panini for the time strictly necessary for the execution of the requested service and for the correct execution of the contractual relationship with you. As this Personal Data is processed to provide you with the Services and allow the execution of the contractual relationship, Panini may keep them for a longer period, in particular for what may be necessary in order to protect the interests of Panini against possible claims arising from the Services Provision.

In any case, Panini specifies that the retention time related to gaming data, any orders and purchases you have made is equal to 12 months from the date on which the Application will be removed from the web and from the Apple stores and Google Play . At the end of this period the Data that permit the identification, even indirect, of a physical person will be made anonymous and maintained, only in the form of aggregated data, for statistical purposes. Panini also specifies that your authentication credentials to the Application Services will be valid for a period of 18 months from the last login (the underlying logic is that Panini has calculated that the retention time identified is the period of time with reference to the possible frequency of publication of an Application based on sporting event such as, for example, the Italian Football Championship). At the end of this period the data will be made anonymous.

The Personal Data processed for the purposes of Legal Compliance will be retained by Panini for the period envisaged by specific legal obligations or applicable legislation.

The Personal Data processed for the purposes of Marketing and Profiling will be retained by Panini until the revocation of the consent you have given. Once your consent is withdrawn, Panini will no longer use your Personal Data for such purposes, but may retain them, particularly as may be necessary in order to protect Panini's interests from possible liability based on such processing.

Panini informs you that, in order to respond to the principle of limitation of conservation, the data processed for the purposes of Marketing and Profiling will in any case be maintained for a maximum of 18 months from the last login in accordance with the logic used for the retention of authentication credentials to the Application Services referred to above.

The Personal Data processed for the purpose of Soft Spam will be kept by Panini until you object to the process through the link found at the bottom of each of the Soft Spam e-mails sent.

H- Data Subject Rights

At any time you are entitled, as Data subject, to:

  • request access to your Personal Data, (and/or a copy of such Personal Data), as well as further information on the current treatment of them;
  • request the correction or updating of your Personal Data processed by Panini, where they are incomplete or out of date;
  • request the deletion of your Personal Data from the Panini databases, where you deem the processing unnecessary or illegitimate;
  • request the limitation of the processing of your Personal Data by Panini, where you believe that your Personal Information is not correct, necessary or is unlawfully processed, or if you had opposed its processing;
  • exercise the right to data portability, i.e. to obtain a copy of the Personal Data supplied to Panini that relates to you in a structured format, for common use and readable by an automatic device, or to request transmission to another Data Controller;
  • oppose the processing of your Personal Data, using a legal basis relating to your particular situation, which you believe should prevent Panini from processing your Personal Data;
  • revoke your consent for the purposes of Marketing and Profiling and to oppose the processing for the purpose of Soft Spam. We remind you that the express consent for forwarding promotional communications referred to the Marketing and Profiling purposes extends not only to communications sent through the use of automated systems without the intervention of the operator (for example, e-mail), but also the traditional methods of contact, such as the postal service. It is always possible to withdraw consent to the treatment, even in a disjointed way, for example, deciding to receive such communications only through postal service and not through automated systems such as e-mail

Please note that the Personal Data you provided to Panini may be changed at any time, by logging in to the Application or by writing to: webprivacy@panini.it. You may exercise the above rights by means of the methods indicated above.

We inform you that for the Marketing purposes you can revoke and terminate at any time the sending of this commercial information, can be revoked by changing, at any time, the preferences of the user profile by logging in to the Application or by writing to the e-mail address indicated above. In the case of communications received through IT tools, you can revoke your consent following the procedure indicated at the bottom of the communication (via the "Unsubscribe" button).

You can also stop receiving Soft Spam using the appropriate link at the bottom of each e-mail received (via the " Unsubscribe " button).

Consent for the purpose Profiling can be revoked by changing, at any time, the preferences of the user profile within the Application or by writing to the e-mail address indicated above.

Panini also informs you that you always have the right to lodge a complaint with the competent Supervisory Authority (for example that of the State in which you have your habitual residence, in Italy the Guarantor for the Protection of Personal Data) if you believe that the processing of your data is contrary to the legislation in the field of personal data protection actually applicable.

I- Privacy Policy Amendments

This Privacy Policy version 1.0 is effective from August 20, 2018. Panini reserves the right to modify or simply update its content, in part or completely, also due to changes in the applicable legislation. Panini will be able to inform you of these changes as soon as they are introduced and they will be binding as soon as they are published on the Application. Panini invites you to visit this section regularly to get to know the most recent and updated version of the Privacy Policy in order to be always updated on the Personal Data collected and on the use that Panini makes of them.