Privacy Policy

Intro

The present Privacy Policy describes our practices regarding the personal information we collect from or about you. By using our services, Do you accept the terms of this policy: if you do not agree with what is described below, please do not use the service or provide your personal data. We are committed to protecting your privacy and to processing personal data in compliance with EU Regulation 2016/679 (GDPR) and of the applicable legislation. Below we explain what information we collect, how we use it, with whom we share it and what your rights are regarding its processing.

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Types of personal data collected

We collect different types of personal data directly by you or generated by the use of our services, including:

• Data provided by the user: information that you voluntarily provide by creating an account or using the service. For example, we may ask you for your first name, last name, email address, telephone number, postal address and login credentials (username and password). In addition, you may provide us with additional data when you fill out forms, participate in surveys, contact customer support, or communicate with us in other ways.
• Data collected automatically: information that is automatically collected when interacting with our services. This includes technical and usage data such as the IP address, browser type, operating system, unique device identifiers, the web page of origin, the pages visited, the dates and times of access, as well as information on how to interact with the content. We also collect cookies and similar technologies (e.g. web beacon, pixel) to understand how you use our site/app. These technologies help us recognize you, store your preferences and collect statistical data about the use of the service. You can manage or disable cookies through your browser settings, but this may affect some functionality of the service.
• Data from third parties: we may receive information about you from external sources. For example, if you decide to register or log in through a social media account (such as Facebook, Google, etc.), we will receive some data from your profile on those platforms (such as name, email and other information authorized by you). In addition, we may obtain data from partners with whom we work for payment or delivery services, or from analytics providers that help us improve the platform. In all cases, we ensure that third parties have your legitimate consent or are authorized to share that information with us.

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Purpose of using personal data

We use the personal data collected for a number of legitimate purposes, in particular:

• Provide and improve the service: we process your data to create and manage your account, authenticate you when you log in and provide you with the requested functionality. Your data allows us to personalize your user experience (for example, remembering your preferences) and to continuously improve our products/services, developing new features based on how users interact with the platform.
• Operational communications: we may use your contact details (such as email or telephone number) to send you essential service communications, such as registration confirmations, information on transactions carried out, updates related to the operation of the service, changes to terms or other policies. These communications are generally non-promotional in nature and are used to fulfill our contractual obligations and provide appropriate assistance.
• Customer Support: the data provided in support requests allows us to identify you and help you solve problems, answer questions or provide clarifications. We store correspondence and information related to your reports so that we can improve service and user satisfaction.
• Marketing and promotional communications: with your consent explicit (if required by law), we will use your contact details to send you newsletters, special offers, updates on new products or services and promotional communications that may interest you. You can at any time decide to Unsubscribe to these communications by following the opt-out instructions provided in the message or by contacting us directly. Please note that even if you opt out of promotional communications, we may still send you essential non-promotional communications (as described above).
• Internal analysis and improvement: we use aggregated data and information on the use of the service (including data collected through cookies and third-party analysis tools, such as Google Analytics) to understand usage trends, measure the audience and performance of our site/app, identify preferences and recurring problems, and thus optimize the offer. This data is processed anonymously or pseudonymized where possible, without directly identifying users, and helps us to make informed decisions about business development.
• Security and fraud prevention: we can process personal data to ensure the security of our users, detecting and preventing fraudulent activity, unauthorized access, violations of our systems or other uses that are illegal or contrary to the terms of use. These measures may include monitoring suspicious accounts or abnormal behavior, in order to protect both you and us from risks and liability.
• Legal and contractual obligations: in some cases, we need to use and store certain data for fulfill legal obligations or regulatory. For example, transaction-related information may be kept for tax or accounting purposes within the time required by law. In addition, we process personal data where necessary to assert or defend our contractual rights (for example, to manage any breaches, disputes or legal procedures). In these circumstances, processing is limited to what is strictly necessary to meet those obligations or needs.

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Sharing personal information

We are committed to Don't sell your personal data to third parties. We share information about you only under the following circumstances and with appropriate contractual guarantees for your privacy:

• Third-party service providers: we may communicate some personal data to trusted third parties who support us in providing the service. These include, for example, IT service providers (for data and website/app hosting), web traffic analysis services (analytics), payment platforms, shipping services or other partners necessary for business operations. These third parties process the data on our behalf, as data processors, and are contractually bound to use the information only for the agreed purposes, in compliance with this policy and applicable privacy legislation.
• Affiliated companies and business transfers: within our corporate group (if any), your data may be shared with affiliated, subsidiary or parent companies, only for purposes consistent with those described in this policy (for example, centralized service management, administrative support, internal reporting). In the case of mergers, acquisitions, company divestitures or other corporate reorganizations, user data could be among the transferred assets. In this case, we will notify you of any change in ownership, and we will ensure that the new owner continues to comply with the privacy commitments made in this policy.
• Legal obligations and authoritative requests: we may disclose your personal data if we believe in good faith that such access, use, storage or disclosure is reasonably necessary to: (a) comply with laws, regulations, valid legal process, or mandatory government requests (such as a search warrant, court order, or request from supervisory authorities); (b) enforce or apply terms of service and other agreements, or protect the rights, property, or security of us, our users, or others. In any case, we undertake to notify you, to the extent permitted, of any legal request relating to your personal data, in order to allow you to exercise any means of protection.
• User consent: in addition to the situations listed above, in all other cases where it is necessary to communicate data to third parties for different purposes, we will ask you for your explicit consent. For example, with your consent, we may share public testimonials or reviews containing your name, or transmit your data to business partners for co-marketing initiatives. You have the right to revoke any consent you have provided at any time, as described below in the section on your rights.

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International data transfers

The servers and IT infrastructures we use may be located in countries other than yours. Therefore, it is possible that your personal data will be transferred and stored outside the country in which you reside, including countries outside the European Economic Area (EEA). In the case of data transfers to third countries (not part of the EEA) that do not offer a level of data protection equivalent to the European one, we will take appropriate measures in accordance with Chapter V of the GDPR to ensure adequate protection of your data. These measures may include the use of standard contractual clauses approved by the European Commission, checks on compliance certifications (e.g. Privacy Shield if applicable, or recognized successor mechanisms) and assessments of local legislation on privacy. You can contact us for more information on the guarantees implemented in the event of an international transfer of your data.

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Data Retention

We keep your personal data only for Time needed to achieve the purposes for which they were collected, except for longer storage requirements provided for or permitted by law. In practice, this means that:

• The data collected to provide you with our services (for example, account information, transaction details) are kept for the entire duration of the contractual relationship and for the period strictly necessary after its conclusion to protect any remaining rights or obligations.
• If you request us to cancel your account or if you delete the service, we will delete or anonymize your personal data within a reasonable time, unless their further storage is required for legal obligations (for example, keeping records of activities or accounting documents for periods established by tax or civil law).
• The data collected for marketing purposes will be kept until you keep your subscription to promotional communications valid. If you decide to withdraw your consent or unsubscribe, we will stop using your data for these purposes and delete or anonymize them, unless their storage is necessary for other lawful purposes.

At the end of the applicable storage periods, or upon your valid request for cancellation, personal data will be securely deleted or irreversibly anonymized, so that it is no longer possible to link it to your identity.

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Data security

We take measures to technical and organizational security adequate to protect your personal data from unauthorized access, disclosure, alteration or destruction. These measures include, for example, the encryption of sensitive data, network protection systems (firewalls), access controls with authentication, periodic backups, and internal procedures for managing data. Our staff is trained to respect the confidential nature of personal information and to treat it in accordance with this information and with legal obligations.

However, keep in mind that no security system is unfailing 100%. Therefore, although we are committed to protecting your personal information, we cannot absolutely guarantee that breaches will not occur. In the event of unlikely data breaches that may pose a high risk to your rights, we will promptly notify you as required by applicable law, and we will take all necessary actions to mitigate their effects.

User rights

In accordance with current data protection laws (in particular Articles 15-22 of the GDPR), Do you have a number of rights relating to your personal data. At any time you can exercise the following rights, by contacting us through the channels indicated in the section Contacts of this information:

• Right of access: you have the right to obtain confirmation of whether or not your personal data is being processed and, if so, to obtain access to such data together with information on how we process them. Upon request, we will provide a digital or paper copy of your data in our possession.
• Right to rectification: if you believe that your personal data in our possession is inaccurate or incomplete, you have the right to request its correction or integration. We will promptly update/correct incorrect information, ensuring that the data is accurate and up to date.
• Right to cancellation: also known as Right to be forgotten, allows you to request the cancellation of your personal data when these are no longer necessary for the purposes for which they were collected, or if you have revoked your consent (where the processing is based on consent) or in other cases provided for by Art. 17 GDPR. Please note that this right is not absolute: we may have legal bases or specific obligations that require us to keep some data despite your request (for example, to comply with legal obligations). In any case, we will inform you of the possible impossibility of deleting some data and the related reasons.
• Right to restrict processing: you have the right to request that the processing of your data be temporarily restricted when certain hypotheses occur, for example if you contest the accuracy of the data (for the period necessary to verify its accuracy) or if the processing is illegal but you object to the cancellation, asking instead for its limitation. During the restriction, the data will be kept but not further processed without your consent, except as necessary for legal reasons.
• Right to object: you can object at any time, for reasons related to your particular situation, to the processing of your personal data based on our legitimate interest. In this case, we will refrain from further processing your data, unless there are compelling legitimate reasons to proceed (for example, overriding your rights and freedoms) or the processing is necessary to ascertain, exercise or defend a right in court. If your data is processed for direct marketing purposes, you always have the right to object and, in doing so, the data will no longer be used for this purpose.
• Right to data portability: where technically feasible and applicable, you have the right to receive in a structured, commonly used and machine-readable format the personal data that you have provided to us and that are processed by automated means based on your consent or in the execution of a contract. You can also ask us, if technically possible, to transmitting such data directly to another owner indicated by you.
• Right to withdraw consent: in cases where we process your data based on your consent, you have the right to revoking such consent at any time. The revocation does not affect the lawfulness of the treatments carried out previously, but it means that from that moment on we will cease the activity for which you had initially consented. For example, you can revoke your consent to marketing communications by following the unsubscribe link in the emails received or by contacting us.
• Right to complain: if you believe that the processing of your data takes place in violation of data protection legislation, you have the right to propose grievance to the competent supervisory authority (in Italy, the Guarantor for the Protection of Personal Data). However, we encourage you to contact us first, so that we can respond directly to your concerns and find a friendly solution.

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We remind you that to guarantee the effective exercise of your rights, we may need: verify your identity before following up on the request, for example by asking you to provide some information or confirmation credentials. We will do our best to respond to requests quickly and in any case within the legal deadline (normally, within 30 days of receiving the request).

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Children's privacy

The protection of Children's privacy is especially important. Our services are not aimed at children or young people under the age established by law for the validity of the consent to the processing of personal data. In particular, we do not collect knowingly Information about children under 14 years (limit set by Italian legislation implementing the GDPR) without the verifiable consent of parents or those exercising parental responsibility. If we become aware that we have unintentionally collected personal data from a minor without adequate parental consent, we will delete them as soon as possible. If you are a parent or guardian and you are concerned that your underage child has provided us with information, please contact us immediately and we will take the necessary steps.

We recommend that parents and guardians educate their children about the safe and responsible use of their personal data online.

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Changes to this Policy

We reserve the right to update or modify periodically this Privacy Policy, for example in the event of changes in the services offered or to adapt it to regulatory changes. Any substantial update will be posted on this page and, if appropriate, notified through available channels (such as email or account notifications), so that you can always know what information we collect and how we use it. At the top of the information we will indicate the Date of last update. We encourage you to check this page regularly to stay informed about our privacy practices. Continued use of the service after the changes take effect implies acceptance of the changes made.

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Contacts

For questions, concerns or requests regarding this Privacy Policy or the processing of your personal data, do not hesitate to contact us. We are at your disposal to provide additional clarifications and to allow you to exercise your rights. You can reach us through the following channels:

• Email (customer support): support@welobadge.com
• Email (legal affairs/privacy): daniel@welobadge.com
• Postal address: WeLoBadge, LLC — 131 Continental Dr, Suite 305, Newark, DE 19713, USA
• Telephone (international support): +1 740 272 5732 (international calling rates may apply)

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We will respond to your communications as soon as possible, generally by 30 days. If necessary, we may ask you to provide additional information to confirm your identity or to better understand your request. Your collaboration helps us protect the security of your data and fulfill requests in compliance with the law.

Thank you for reading our Privacy Policy. We are committed to protecting your personal data and appreciate the trust you place in us using our services.