Personal Data Processing Policy – International Standard

Last updated: 13/02/2025

1. Introduction

This Personal Data Processing Policy ("Policy") provides a detailed description of the methods, purposes, and measures for collecting, using, storing, and protecting personal data ("Data") by Tanguear ("we", "us", or "our"). This Policy applies to all personal data processed in connection with our services on an international basis.

2. Scope

This Policy applies to all personal data collected, processed, and stored by Tanguear, regardless of the medium or method of collection, and covers all users who interact with our services.

3. Data Controller and Data Processor

• Data Controller: Tanguear acts as the Data Controller, determining the purposes and means of processing personal data.
• Data Processor: Third parties that process personal data on our behalf are designated as Data Processors and are bound by this Policy and the applicable contractual agreements.

4. Data Collection

We collect the following categories of personal data:

• Personal Identification Data: Name, surname, profile picture, etc.
• Contact Data: Email address, phone number, mailing address, etc.
• Preference Data: Information regarding user interests, tastes, and personal choices.
• Geolocation Data: Information about the user's physical location, necessary for providing localized services.
• Usage Data: Details on how the user interacts with our services (e.g., IP address, device information, browsing data, etc.).

5. Legal Basis for Processing

The processing of personal data is based on the following legal grounds:

• Consent: Where the user provides explicit consent.
• Contractual Necessity: Where processing is necessary for the performance of a contract to which the user is a party.
• Legal Obligation: Where processing is required by applicable law.
• Legitimate Interests: Where processing is necessary for our legitimate interests, provided that such interests are not overridden by the rights and freedoms of the user.

6. Purposes of Data Processing

Personal data is processed for the following purposes:

• To provide, manage, and improve our services.
• To personalize the user experience and deliver targeted content.
• To enable specific functionalities, such as localized event dissemination based on geolocation.
• To communicate with users, including updates, notifications, and promotional messages.
• To comply with legal obligations and manage any disputes that may arise.

7. Categories of Data Collected

The categories of personal data collected include, but are not limited to:

• Identification and contact information.
• Data related to personal preferences and behavior.
• Geolocation data.
• Usage and navigation data.

8. Data Retention

Personal data is retained only for as long as is necessary to fulfill the purposes for which it was collected, unless a longer retention period is required by law. Once the intended purpose is fulfilled, the data will be securely deleted or anonymized.

9. Data Sharing and International Transfers

• Data Sharing with Third Parties: Personal data may be shared with service providers, partners, or affiliates acting as Data Processors. These entities are subject to strict confidentiality and data protection clauses.
• International Transfers: In cases where personal data is transferred outside the European Economic Area (EEA) or other jurisdictions, Tanguear implements adequate safeguards (e.g., standard contractual clauses, certification mechanisms) to ensure a level of protection that is consistent with international standards.

10. Data Security Measures

Tanguear implements appropriate technical and organizational measures to protect personal data against unauthorized access, alteration, disclosure, or accidental or unlawful destruction. Such measures include, but are not limited to:

• Encryption of data in transit and at rest.
• Multi-factor authentication and robust access control mechanisms.
• Continuous monitoring, regular security audits, and system updates.

11. Data Subject Rights

Users have the following rights regarding their personal data:

• Right of Access: To obtain confirmation of data processing and access to their personal data.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure: To request deletion of personal data under certain conditions.
• Right to Restrict Processing: To request the limitation of data processing in specific circumstances.
• Right to Data Portability: To request that their personal data be transferred to another data controller.
• Right to Object: To object to the processing of personal data based on legitimate grounds.

To exercise these rights, users should contact us using the information provided in the "Contact Information" section below.

12. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance user experience and analyze the usage of our services. Users can manage their cookie preferences through their browser settings.

13. Updates and Modifications to the Policy

This Policy may be updated periodically to reflect changes in legislation or improvements in our data processing practices. Material changes will be communicated to users via our official channels or directly on our website.

14. Contact Information

For questions, requests, or to exercise your data protection rights, please contact us at:

• Email: info@tanguear.com
• Address: Piazza della Borsa, 7, 34141, Trieste, Italy
• Phone: +39 338 5383338

15. Complaints and Supervisory Authority

If a user believes that the processing of their personal data violates their rights, they have the right to file a complaint with the relevant data protection supervisory authority, such as the Data Protection Authority in their country.