Privacy Policy

1. Introduction and Overview

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The "Minimo" platform leverages technology responsibly to benefit numerous businesses worldwide, firmly advocating for the right to privacy and confidentiality. At "Minimo," we consider privacy a fundamental part of the value we offer our customers.

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2. Scope of this Privacy Policy and Our Role

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As a provider of IT services, we provide this Global Privacy Policy to explain how we, VIAN by Andrea Vitto, collect, use, share, or otherwise process information when you interact with us and our offerings, services, and experiences, or when, possibly others provide us with your information.

This Privacy Policy is global, meaning it applies to all pages and offerings from Minimo and describes our privacy practices when processing personal information needed to manage, improve, and develop our business and personalize your experience while interacting with the Minimo platform.

Vian di Vitto Andrea determines the purposes and means of processing personal information, as described in this Privacy Policy, and thus acts as the "data controller" (or similar/equivalent terms) for purposes recognized by some data privacy laws. We may conduct processing activities as data controllers or processors for the purposes set out in our Privacy Policy. If you have questions about the processing of your personal information, please contact us in the dedicated section "indicate the section." Email link to privacy@minimo.co

This Privacy Policy does not apply where Vian di Vitto Andrea processes personal information as a service provider (or equivalent role under data privacy laws, such as data processor) on behalf of a client or entity acting as a data controller, for example, customers of our software product. When acting as a service provider, the privacy policy of the relevant data controller and our agreements with that company or entity will govern our processing of such personal information.

In certain circumstances, there may be more than one data controller processing your information. In some situations, we act as independent data controllers on our processing activities, meaning we make decisions on how your personal information will be processed independently from other data controllers. Other data controllers have their obligations under applicable information privacy laws. Vian di Vitto Andrea is not responsible for the processing of other data controllers (including our customers) and you should contact them directly for questions on how they process your personal information and to exercise your privacy rights in relation to that processing.

3. Data Controller and Processor

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The data controller is the sole proprietorship Vian di Vitto Andrea, VAT: 03043840648, by the owner Vitto Andrea, tax code: VTTNDR99T30F839U, residing at San Martino Valle Caudina (Av) via Tinci n° 2.

The data controller can be reached at the following email address: privacy@minimo.co and/or at the following certified email address: andreavitto@pec.it

The data processor includes Amazon AWS, Digital Ocean, 360Dialog, RDcom

The DPO is Avv. Sonia Catalano (Tax Code: CTLSNO90S42A783Y) with an office in Benevento at Via Vitulanese, n. 108.

The DPO can be reached at the following email address: dpo@minimo.co and/or at the following certified email address: catalanosonia@pec.it.

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4. The Minimo Platform

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4.1 Minimo Platform and Your Information

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The personal information we also centrally use includes all the information Minimo knows about you, as an end user of our services or as a contact of one of our customers (such as a subscriber to a customer's email list) whose personal information has been entered into the Minimo platform. This includes information such as your credentials; your name and contact details; payment information; information about your activities, behaviors, interests, and preferences (including purchase history); and information we have collected about you from third-party sources.

4.2 Organization Account Information

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We are not responsible for the privacy or security practices of other organizations, and you should consider both the organization's policies and whether you are comfortable enabling the organization with access to your information before connecting to their services.

5. Information We Collect and Receive from You

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The personal information we receive about you depends on the context of your interactions with Minimo, how you configure your account, and the choices you make, including your privacy settings. The personal information we receive from you may also depend on the services, features, or experiences you use, your location, and applicable law. Here are some cases:

1. Creating an account. We collect information when you (or your organization) create an account, interact with the Minimo platform, or activate a subscription. Personal information may include your name, address, phone number, and email, country, profile picture, billing information (your payment data), usernames, and credentials.
2. When a company provides it. We collect information when a company you interact with provides us with information about you, including details such as your name, email address, and phone number.
3. Customer Support, Product Research, Training, and Feedback. We may collect personal information such as your name, email address, phone number, and any other personal information you choose to share when you contact us for support, provide us feedback, participate in optional surveys, subscribe to marketing, participate in our events, engage in product research or training, or otherwise interact or communicate with us.
4. Social and Community Content. We receive the content you post on our social media pages and our community pages.
5. Online Behavioral Data. We may automatically collect certain information about your use and interactions with our websites, customer websites or e-commerce stores, the platform, social media sites, and marketing campaigns that we or our customers organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and whether you are a customer contact, whether a campaign presented or sent to you using our offerings was displayed, delivered, opened, clicked, whether it was bounced or treated as spam.
6. Device Information. We may collect information about your device such as Internet Protocol ("IP") addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our access and security features.
7. Content from Third-Party Services. We receive information about you when you access a third-party service with your account or when you link your account to a third-party service. For example, you may choose to link your account with your bank accounts or social media platforms.
8. Usage Information. We may collect information about your use of the Platform, such as the pages you have viewed, the services and features you have used or interacted with, the type of browser, and details about any links or communications with which you have interacted.
9. Location Information. Some features of the Minimo platform may collect precise information about the user's location, device movement information, or both, if permission is granted in the device settings.
10. Information from Cookies and Other Technologies. Minimo and our service providers may use common tools such as cookies, web beacons, pixels, shared local objects, and similar technologies (collectively "cookies") to collect information about you ("Cookie Information") so we can provide the requested experiences, recognize your visit, track your interactions, and improve your and other customers' experience. You have control over some of the information we collect from cookies and how we use it. For full details on how we use cookies and similar technologies, see our Minimo Cookie Policy. For full details on how we use cookies and similar technologies when you use or interact with our Minimo offerings, also see our Minimo Cookie Policy _________________.
11. Locally Stored Information. Some of our web-enabled desktop services and offerings sync with information on your computer. In doing so, we may collect information such as device information, product usage, and error reports. We may also store personal information locally on your device.
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6. How We Use Personal Information

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We collect and process personal information where:

• We have your consent to do so;
• We have a contract with you and it is necessary to process your personal information to perform our contract with you, including to provide you with the benefits of the Minimo platform and managing our business;
• Processing is in our legitimate commercial interest (in those jurisdictions where legitimate commercial interest is a legitimate basis for processing) such as managing our operations, improving and developing the Minimo platform, communicating with you, marketing our offerings and services, and personalizing your experience, and to detect illegal activities;
• We need to comply with legal requirements, including applicable laws and regulations.

Personal information is used for the following purposes:

• to provide you with the features and benefits of the Minimo platform and associated services, create your account, and manage our relationship with you;
• to improve and develop our products and services by analyzing how they are used and interacted with, as well as evaluating the use and interactions with our platform and certain content that our customers send or view through the platform, including conducting data analysis to develop insights about you, your needs, and preferences so that we can make predictions, recommendations, and more informed products for our customers;
• to manage our business, including resolving disputes and about billing;
• to assess your suitability to receive financial or other marketing offers, products, and services;
• to provide features such as discounting, coupons, points accumulation, etc.;
• to connect you with experts and other users;
• to communicate with you, for example, sending you electronic notifications;
• to protect against misuse or abuse of our services and ensure compliance with our terms, including in relation to content submitted or viewed by our customers through the platform;
• to market our services, products, and experiences, including the delivery of gifts and promotional material, product advice, and other non-transactional communications via email, mail, phone, SMS, or push notifications, in accordance with your marketing preferences;
• to personalize your experience and tailor recommendations, advertisements, and offers presented to you, also through the development of insights about you and your needs based on your interactions with the products, services, and offers on our platform;
• to combine and anonymize information about your interactions with Minimo to create aggregated and anonymous statistics to be used in research and for marketing, promotion, improvement, and development of our platform;
• to provide support and resolve disputes;
• to conduct research, including collaborating with academic institutions;
• to comply with our legal and regulatory requirements;
• to manage registrations and participation in events, including sending related user communications;
• to record visitors to our offices for security reasons and manage confidentiality agreements that visitors may be required to sign;
• to protect the rights, property, safety, or protection of the Minimo platform, our customers, employees, or others and prevent fraudulent or illegal activities;
• to exercise our rights in the course of judicial, administrative, or arbitral proceedings;
• to process your information for other purposes compatible with the disclosed purposes if and where this is permitted by applicable law.

7. How We Share Your Information

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We may share your information in the following circumstances:

• with your consent. In accordance with our data management principles, except as stated below, we share your information with third parties only when you have expressly indicated to us to do so;
• when you connect with the Minimo platform you may be provided with offers, products, and services. If you choose to interact with the Minimo platform, request its services or offers, or otherwise link or sync your account with a product or service, you consent and direct Minimo to share your information, including personal information, to our potential Platform Partner providing the service or offer. For example, when we send your personal information to partners to generate offers to review, when we send information about your application directly to our partners, or when we send you to the partner's site so you can provide information directly to them.When this happens, you must still submit your application on the Platform Partner's site. Remember that any information you provide to any Platform Partner, whether through us or on your own, will be subject to their privacy practices and terms and conditions.
• for some product features, we may use third-party API services, such as Google products, for certain product features. If you choose to use such features, you acknowledge and agree to be bound also by the privacy rules of third parties, such as Google's Privacy Rules for API services, YouTube. You can manage API data by visiting Google's security settings page or other service providers at the specified addresses.
• Example in the case of Google Analytics https://security.google.com/settings/security/permissions.
• when you connect to your social media account. Some of our features allow you to connect to a social media account or share information on social media platforms, such as Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the privacy policies of the social media provider (not this Privacy Policy). You should share only strictly necessary information on social media.
• for joint functions, sales, promotions, and events. We may share your information with third-party companies that provide features, sales initiatives, promotions, or events jointly with us.
• with financial service providers. We may share personal information with collection agencies, credit agencies, and loan service providers and members of payment card associations. We may also share your personal information with other companies, lawyers, credit agencies, agents, government agencies, and payment card associations in relation to matters concerning fraud, credit, defaults, or credit recovery.
• when you post and make your information public. We may offer you the opportunity to post reviews, questions, comments, suggestions, or other content, which may include personal information, such as your name or username. Anything you share in a public forum is public and you should think carefully before deciding to share.
• with service providers or agents. We may share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Policy. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of the information provided to them consistent with the privacy practices outlined in this Policy. Service providers or agents may include companies that assist us in our advertising, marketing, and sales activities, help us with our technology offerings (such as hosting, security, or anti-fraud providers), and help us manage our business. 360Dialog https://docs.360dialog.com/useful/imprint-and-dataprivacy , Amazon AWS https://aws.amazon.com/privacy/, RDcom https://rdcom.com/en/privacy-policy/
• for mergers and acquisitions. If we are involved in a merger, sale of assets, financing, liquidation, bankruptcy, or acquisition of all or part of our business to another company, we may share your information with that company and its advisors before and after the transaction date.
• no sale of personal information to third parties. We do not sell and will not sell personal information to third parties. We share personal information with third parties for the commercial purposes described in this Policy.
• with our affiliates and subsidiaries and your right to limit the sharing of information. We may share your information with our affiliates and subsidiaries for everyday business purposes as described in this Policy, also for marketing purposes, to improve and develop our offerings, and to personalize your experience on our Platform. Some laws may grant you the Right to limit our information-sharing activities in certain circumstances.

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8. Cookies and Other Tracking Technologies

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The Site uses "cookies." By using the Site, you consent to the use of cookies in accordance with this Privacy Policy. Cookies are small files stored on the user's computer hard drive. There are two broad categories of cookies: technical cookies and profiling cookies. Technical cookies are necessary for the proper functioning of a website and to allow user navigation; without them, the user may not be able to view pages correctly or use some services. Profiling cookies are intended to create user profiles in order to send advertising messages in line with the preferences expressed by the user during navigation. Cookies can also be classified as:

• "session" cookies, which are deleted immediately at the close of the navigation browser;
• "persistent" cookies, which remain within the browser for a certain period of time. They are used, for example, to recognize the device that connects to a site facilitating user authentication operations;
• "own" cookies, generated and managed directly by the operator of the website on which the user is browsing;
• "third-party" cookies, generated and managed by parties other than the operator of the website on which the user is browsing.

You can find information on how to change your browser settings to disable cookies in your browser settings. In some countries, you may also be able to make changes to cookie settings using our cookie preferences tool. If you disable some or all cookies, the service or parts of the service may not work. For more information, see the Minimo Cookie Policy. (insert cookie link)

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9. For Advertising and Analysis

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VIAN by Vitto Andrea may use advertising networks and other providers to display advertising on our Minimo platform or to manage our advertising on other sites. Our advertising partners may place cookies on non-affiliated websites in order to publish advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such ads.

For legal reasons. We may share your information with third parties for legal reasons without your consent and as permitted by law, including:

• when we reasonably believe that disclosure is necessary to comply with a subpoena, court injunction, or other applicable law, regulation, or legal process;
• to protect the rights, property, or safety of Minimo, our customers, or others;
• to protect against or defend against attacks;
• to enforce, remedy, or apply our Terms of Service or other agreements;
• to prevent fraud, cybersecurity attacks, or illegal activities;
• for credit recovery;
• with regulatory agencies, including government tax agencies, if necessary to help detect and combat fraud and/or protect our customers, users, and/or the Minimo platform, or in required institutional risk control programs.

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10. Your Rights and Choices About Information

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10.1 Your Rights

At Minimo, we believe you have rights over the information concerning you, your family, and/or your business. If someone else has entered or processed information on the Minimo Platform about you or on behalf of you, your family, or your business (and we are processing such information as a data controller), you can request to receive a copy of your information, even if you do not have an account with us. You can contact us here privacy@minimo.co

10.2 Verification

To help protect the privacy and security of your information, you may be asked to provide additional information to verify your identity and/or your data ownership rights before we exercise your data rights. If we are unable to verify your identity or data ownership rights, we may not be able to provide you with data rights until you can provide us with the appropriate documents.

10.3 Information Retention

Data is processed exclusively by specifically authorized personnel, including personnel in charge of carrying out extraordinary maintenance operations. Unless you expressly ask us to delete your personal information, we retain your personal information for as long as necessary to meet our data retention requirements and provide you with services and benefits of the Minimo platform and successfully conduct our business. However, even if you request deletion, we may be required to retain your information for as long as necessary to:

comply with our legal or regulatory compliance requirements (e.g., maintaining records of transactions you have made with us);
exercise, establish, or defend a right in court;
protect against fraudulent or abusive activity on our service.
This means we may retain different information for different periods. If your account is deleted because you have not used it for a long time, we may delete this information immediately.

There may be occasions when we are unable to completely delete, anonymize, or anonymize your information due to technical, legal, regulatory, or other operational reasons. In such cases, we will take reasonable steps to securely isolate your personal information from any further processing until we can delete, anonymize, or anonymize it.

10.4 International Transfers of Data

Minimo reserves the right to store and process your personal information in servers located in other states, or in any other country in which Minimo or its affiliates, subsidiaries, or service providers operate facilities in compliance and as permitted by applicable Laws and regulations. Some of these countries may have data protection laws different from the laws of your country (and, in some cases, may not be as protective).

When we transfer, store, or process personal information outside your jurisdiction, we take adequate security measures to require that your personal information remain protected in accordance with this Privacy Policy and applicable law. We may use contracts or standard contractual clauses approved by the European Commission or, as applicable, equivalent clauses approved by the UK government, to ensure the protection of user information. For more information on the transfer safeguards we rely on and where they have been made available, contact us using the details in the privacy@minimo.co section.

10.5 Security of Your Personal Information

We use physical, technical, and organizational safeguards designed to protect your information. However, despite these controls, we cannot fully guarantee or ensure the security of your information.

10.6 Changes to Our Privacy Policies

From time to time, we may change or update our Privacy Policy. We reserve the right to make changes or updates at any time. If we make significant changes to how we treat your personal information, we will inform you by posting a notice on our platform or in a community post; sending you a notification; or by other means consistent with applicable law.

10.7 Collection and Use of Personal Information of Children

Our services are not intended or directed at children. We do not knowingly collect personal information from children. If you believe we may have information from a child, contact us at privacy@minimo.co and/or dpo@minimo.co

10.8 How to Contact Us

If you have any questions or comments about this Privacy Policy or our practices, please contact us.

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