Privacy policy

1PERSONAL DATA COLLECTED

The Owner may process the following personal data in electronic format: first name, last name, pseudonym, username, age, gender, email address, wallet address, profile photo, place and date of birth, geolocation data, data relating to utility token transactions, etc.

2PURPOSES OF PROCESSING

The personal data collected are used to:

1. ensure the operation of the SwattRacing game;
2. transfer utility tokens in accordance with the terms and conditions set out in the Terms of Use;
3. optionally provide a promotional and newsletter service, subject to the express consent of the data subject.

3SCOPE OF COMMUNICATION AND DISCLOSURE OF PERSONAL DATA

To provide its services, the Owner uses third-party service providers (so-called data processors). The Owner enters into a contract with each of them that imposes strict confidentiality and the adoption of specific security measures in accordance with guidelines issued by the European Data Protection Board and other competent authorities.

The data processors to whom the Owner may disclose personal data are:

1. storage service providers (e.g., AWS cloud);
2. consultants and providers of professional services (e.g., accounting or legal firms);
3. entities providing customer support activities (e.g., call centers, help desks, etc.);
4. entities engaged in marketing activities, market research, or assisting in the promotion of SwattRacing, or providing commercial information (if the data subject has given specific consent for such purposes).

The list of data processors can always be requested from the Owner by writing to the address

privacy@maslabs.it.

Personal data are not transferred outside the European Union. If they were to be transferred, however, the Owner would notify the data subjects and adopt one of the measures provided by law (standard contractual clauses, transfer to countries approved by the European Commission, binding corporate rules, or express consent of the data subject).

Personal data are not disseminated.

4DATA RETENTION PERIOD

Personal data of data subjects registered in SwattRacing are kept for as long as the User’s registration remains active. Subsequently, the data are retained for a period of 10 years and in any event for as long as necessary to allow any claims or actions by the data subject to become time-barred. In such cases, the data are stored in a discreet manner and subject to specific restrictive access measures.

Data collected for the newsletter service or for commercial communications are deleted when the User unsubscribes from that service.

Other retention periods are indicated in the cookie policy.

Data may be processed for an additional period if the purposes of the processing change (e.g., exercise of data subject rights, litigation or threat of legal action, etc.).

5LEGAL BASIS FOR PROCESSING

The Owner processes personal data on the basis of the express consent given by the data subject and for the performance of obligations assumed under the Terms of Use.

Other processing may be carried out by the Owner if required by law (e.g., billing data) or by order of the authorities (e.g., disclosure of information in investigations), or if provided for in the contract.

6AUTOMATED PROCESSING

The Owner collects the User’s personal data related to physical activity performed when SwattRacing is active. Such data include: route, duration, type of movement (e.g., walking, running, cycling, etc.). The data thus obtained are subjected to an automated profiling process to measure the intensity and frequency of the User’s athletic performance in order to assign a score that is useful for participating in engagement Auctions on SwattRacing.

The scoring profiling algorithm is described in section [2.6.4] of the SwattRacing Game Regulations.

The Owner processes the User’s personal data for the profiling described above only upon the User’s explicit and specific consent given at the time of registration on SwattRacing. This consent is necessary to play on SwattRacing and is therefore a prerequisite for registering an account on SwattRacing.

7DATA SUBJECT RIGHTS

Pursuant to Articles 15 et seq. of Regulation (EU) 2016/679, the data subject may at any time request confirmation from the Owner as to whether personal data concerning him/her are being processed, indicating the purposes and categories of data. In that case, the data subject may at any time:

1. request access to and rectification of data if inaccurate and completion of incomplete data;
2. request erasure of data (upon the occurrence of one of the conditions set out in Art. 17(1) of the Regulation and subject to the exceptions provided in paragraph 3 of the same article);
3. request restriction of processing (when one of the cases indicated in Art. 18(1) of the Regulation applies);
4. obtain a copy of personal data in a structured, machine-readable format (in cases where the legal basis for processing is the contract or consent and it is carried out by automated means – the so-called right to data portability);
5. object to processing when particular situations concerning him/her arise;
6. withdraw consent (limited to cases where processing is based on consent).

8EXERCISE OF RIGHTS

For the exercise of the rights indicated in the previous paragraph, as well as to obtain further information, the data subject may contact the Owner by writing to the email address: privacy@maslabs.it.

If the data subject believes that processing of his/her data is unlawful or that the Owner has not properly responded to the exercise of the rights mentioned in the previous paragraph, he/she may lodge a complaint or appeal with the Data Protection Authority pursuant to Art. 77 of Regulation (EU) 2016/679 by following the procedures and forms published on the website www.edps.europa.eu

The data subject may also always go directly to the competent judicial authorities as provided in Art. 79 of Regulation (EU) 2016/679.

9COOKIES

When accessing the website, our servers send so-called “cookies” to the terminals of data subjects – files that allow information about the pages visited to be obtained to make the use of the various services quicker (technical cookies).

In addition to using this type of cookies, we also use Google Analytics to understand how data subjects interact with the website platform and to provide them with information about products or services that may be of interest (third-party cookies).

If data subjects wish to prevent cookies from tracking their activity, they should change their browser settings. If technical cookies are disabled, correct use of the services offered on the site is not guaranteed.

For more information on how to set preferences, you should visit the following browsers:

• Chrome;
• Safari;
• Internet Explorer;
• Mozilla.