INFORMATION PURSUANT TO ARTICLE 13 OF EU REG. NO. 2016/679 ("GDPR")
This Policy describes which of your personal data is collected by KuriU S.r.l., for what purposes and how it is processed. Below you will also find the information you need to exercise your rights under the GDPR.
In general, we collect your data when you browse and create an account on the KuriU application (hereinafter, "App") or on https://www.kuriu.it/ (hereinafter, "Site"), when you create content, when you ask questions and participate in discussions, including through our social pages @kuriu_app Instagram, Facebook, TikTok and YouTube (hereinafter, "Social Pages"). Please note that the personal data collected during these processes will be processed in order to enable you to enjoy the services offered by the App and the Site by means of access to restricted areas and also to provide better services, marketing and support for you and other users, as outlined below.
1. Who processes your data: the data controller
KuriU S.r.l., Italian tax registration and VAT number 16956811000, with registered office in Rome, viale Bruno Buozzi n. 60, privacy@kuriu.it (hereinafter "KuriU" or “Data Controller”) is the controller of your personal data.
Limited to data collected through our Social Pages, they are joint controllers of your personal data as published within the platforms themselves. Please review their privacy policy for more information.
2. What data we process - Type of data processed
Navigation data. The computer systems and software procedures in charge of the operation of the App and the Site acquire, in normal operation, some personal data that are then implicitly transmitted in the use of Internet communication protocols. This is information that is not collected in order to be associated with identified interested parties, but could, through processing and association with data held by third parties, make it possible to identify users (e.g. IP addresses, domain names of computers used by users who connect to the App and the Site, time of the request, numeric code indicating the status of the response given by the server; the addresses in URI - Uniform Resource Identifier - notation of the resources requested) and other parameters relating to the user's operating system and computer environment.
This data, which is not associated with directly identifiable users, is processed, for the time strictly necessary, for the sole purpose of obtaining anonymous statistical information on the use of the App and the Site and to check its regular operation.
Personal data will be processed mainly by automated means manually with paper supports, with logics strictly related to the aforementioned purposes and for the time strictly necessary to achieve the same purposes, and in any case through the use of instruments suitable to guarantee their security and confidentiality and in compliance with the relevant regulations in force.
Your contact and account information. We will retain the contact information you provide to us (e.g., first name, last name, email, city where you live, date of birth, gender) when you create an account on the App or Site and when you complete your biography, when you interact with other users. We may also process your fiscal code in case you report copyright infringement to us, in accordance with the purpose outlined below.
Information about your use of the App and Site. Your use of our App and Site involves processing of data about the browser and device you are using and, limited to the Site, your IP address (this is the number that identifies a specific device on the Internet and is necessary for your device to communicate with the sites). We may analyse which site you came from, what you accomplished and did not accomplish on our App and Site.
Your behaviour in the App and on the Site. If you authorize us and then upon your consent, we will keep track of the content you have accessed on the Site and in the App in order to improve your experience on the platform.
3. Where we get your data - Method of data collection:
Directly from you. For example, if you create an account, post a comment on our App, on our Site, ask us a question by e-mail, through the App or Site or our Social Pages or through other communication channels, if you decide to participate in one of our surveys. If you do not provide us with your information, we cannot allow you to create an account.
From third parties. For example, if you choose to use features from other platforms (such as Google, Apple, Facebook, Twitter, and Amazon) to create an account, the third party site will, with your consent, transmit certain data about you to us, such as but not limited to your username, where you live, and your e-mail address.
Through your use of the Site's features. We use cookies and other technologies, such as pixel tags on our Site, in order to collect data about your usage and better target promotion. To learn more, please review our Cookie Policy.
(https://www.kuriu.it/cookie-policy/cookie_policy.pdf).
4. Why and for how long we process your data - Purpose and legal basis for data processing; retention period
a) To provide you with services on the App and Site, to give you information and assistance in activating your account and then to allow you to create an account. The processing of your data is necessary to give you access to the App and to the Site and their features, to respond to your requests and to provide you with assistance when you use our services. In particular, creating an account allows you to use various features of the App and Site, such as creating a personal profile, creating and sharing content, enjoying and interacting (feedback and comments) with content from other users, saving content as favourites, searching for content, and viewing and navigating maps. The legal basis for this processing is the provision of the services on the App and the Site, in accordance with the terms and conditions of service that you have accepted, as well as the execution of pre-contractual measures that you may have requested before activating these services. The retention period of your data is equal to the period of activity of your account, which in any case will be deleted in case of inactivity for 24 months starting from your last access or your last action on the account. Specifically, during account activation, if you do not confirm within 24 hours through the link sent to you, your account will be deleted.
b) To enable you to ask for information and interact with other users. Through the "Comments" section, which you can access at your express request, you can participate in discussions, ask for information, and leave comments or other information related to your experiences, including details of what you have created as content, which can be viewed by other users. The legal basis for this processing is your consent, to be given when you accept the terms and conditions of use of the App and Site services. The retention period of your data is equal to the period of activity of your account for the use of the services of the App and the Site, according to the terms and conditions of use that you have accepted and within the limits described. In particular, in case of deletion of your account due to inactivity for 24 months, we will anonymize your comments and published posts.
c) To allow you to publish content on the App and Site. KuriU allows you to publish content and share it with users in accordance with the terms and conditions you have agreed to. For this purpose we use your account information, in particular your username and first and last name, entered when creating your account. The legal basis for this processing is the need to fulfill contractual obligations under the terms and conditions of use you have signed up to. The retention period in relation to this purpose is equal to the period of your content's permanence on the App and Site. Should you wish to delete your data from the published content, you must exercise your moral rights as the author of the content itself, consistent with the terms and conditions of service you have agreed to (regarding deletion of your data from the App and Site, see below under "Your Rights").
d) To send you essential information related to your account, your use of the App and Site services. We use your email to send you important information about the status of your account (for example, if your account is about to be deactivated in accordance with the terms and conditions of service you have agreed to and within the limits described therein), about the security of the App and Site services, or about changes made to this policy, as well as use information about your device to improve our services. The legal basis for this processing is KuriU's legitimate interest in informing you about your account and its services that you have used and in protecting the integrity of its information systems against security threats. The data retention period in connection with this processing is equal to the period of use necessary to carry out the above communications.
e) To prevent or control unlawful conduct or to protect and enforce rights. For example, we may use your data to prevent or prosecute torts, violations of our own or third parties' intellectual/industrial property rights or computer crimes or crimes committed through telematic networks. The legal basis for such processing is KuriU's legitimate interest in protecting its rights and preventing wrongdoing. The retention period for your data is equal to the time reasonably necessary to enforce our rights from the time we learn of the wrongdoing or its potential commission.
f) To enable you to report a problem and/or violations of current and applicable law to us. We will process your personal data when you report to us a violation of the terms and conditions of the App and Site as well as violations of applicable law, such as by way of example, copyright violations, at the same time we will process your data in case a third party reports to us that a violation has been committed by you, in order to assess it. The legal basis for this processing is KuriU's legitimate interest in protecting its rights and preventing wrongdoing, as well as in some cases (such as copyright violations) to fulfill legal obligations. The retention period is equal to the period necessary to handle the report received.
g) To give feedback to your requests collected through the Social Pages. We will use your data to answer to your requests received through our Social Pages, either as public comments or private messages. The legal basis for this processing is the performance of a contract to which the data subject is a party or the performance of pre-contractual obligations, and the retention period is equal to the time necessary to fulfil the data subject's requests.
h) To monitor and improve our services, App and Site and to provide you with personalized content. With your consent, KuriU analyses your personal data (for example, that contained in the biography you post on the App/Site), usage, preference and use of our services, to improve our approach to you and our users in general, through automated processing including profiling, as well as to send and share personalised content with you, such as contacting you to ask you questions about its App and Site, sending you surveys and questionnaires based on your activities, in order to improve our services. It does this so that we can make better decisions in relation to services, advertising and content that are based on a greater awareness of how our users use our services and to provide you with a more personalized experience by showing you content that is consistent with and tailored to your preferences, including your interaction preferences in the App and on the Site. The legal basis for this processing is your consent. The retention period for your data is equal to the period of activity of your account, which in any case will be deleted in the event of inactivity for 24 months starting from your last access or your last action on the account, without prejudice to the possibility of withdrawing your consent at any time.
i) Limited to the App, to allow us to track your activities in the App. When you first download the App you will be asked via pop-up if you would like KuriU to track your activities in the App, also through tracking systems such as pixel, in order to track your activity in the App and in order to measure of our advertising campaigns. The legal basis is your consent, which you can give by clicking "allow" within the pop-up. The retention period is equal to the duration of your account, without prejudice to the possibility of withdrawing your consent at any time.
j) Limited to the App, to allow us to know your location. When you first download the App you will be asked via pop-up if you would like KuriU to track your location in order to provide you with content near you. The legal basis is your consent, which you can give by clicking "while using the app" or "only this time" within the pop-up. The retention period at the browsing session duration, without prejudice to the possibility of withdrawing your consent at any time.
k) In order to send you commercial and promotional communications relating to the App and the Site. Subject to your consent, we may send you commercial communications relating to the activities and news of the App and the Site, including asking you to participate in surveys aimed at improving our services, by filling in an online form. The legal basis is your consent, which we will ask you for at the time you activate your account or later. The retention period is equal to the period of activity of your account, which in any case will be deleted in the event of inactivity for 24 months from your last access or your last action on the account, without prejudice to the possibility of withdrawing your consent at any time. Once the retention period has expired or consent has been revoked, personal data relating to any surveys in which you have participated will be retained exclusively in anonymous and aggregate form.
l) To send you commercial communications from our partners. Subject to your consent, we may send you commercial communications relating to the activities of our partners, who, like us, deal with travel, experiences and free time (the full list of partners is available at the following link https://www.kuriu.it/documents/it/business-partner/index.html). The legal basis is your consent, which we will ask you for at the time you activate your account or later. The retention period is equal to the period of activity of your account, which in any case will be deleted in the event of inactivity for 24 months from your last access or your last action on the account, without prejudice to the possibility of withdrawing your consent at any time.
5. Nature of provision of personal data
For the purposes (a) to (g) in the previous paragraph, the provision of data is necessary to enable you to create an account on the App or Site and interact with other users and receive the other services on the App and Site.
For the purposes from (h) to (l), the provision of data is optional, a refusal will not affect the purposes from (a) to (g). The data subject may withdraw his or her consent at any time, but this will in no way affect the processing carried out prior to such withdrawal.
6. Where your data is processed - data transfer
The data will be processed and stored at KuriU's offices and at KuriU's suppliers, with whom KuriU has entered into agreements for the processing of personal data in accordance with Article 28 GDPR, within the European Union.
Exclusively with regard to data collected on our Social Pages, the same will be stored on the aforementioned platforms, according to the privacy policies of the latter, which we invite you to consult.
7. Who we share your data with - recipients of personal data
Provided that, where required by law, we will obtain your prior consent and complete any formalities required by law, we may share your data with the following third parties.
With other users of the App and the Site. If you use the question and discussion section of the App and Site, you may interact with other users, to whom your comments, location, and other information you wish to share will be made known.
With service providers. KuriU uses third-party services (cloud, customer care, analytics, profiling, search, hosting, browsing functionality and use of the App and Site) that operate as data processors under agreements in accordance with Article 28 GDPR. The updated list of third-party providers, operating as data processors under Art. 28 GDPR, is available by writing to KuriU's addresses above.
With judicial or administrative authorities. Where we believe we must do so in order to comply with a court order or authority, or to fulfil legal obligations or in order to judicially protect KuriU, or third parties, we may disclose your data to the Judicial Authority or an Administrative Authority.
Lastly, in case of extraordinary operations that the Data Controller may undertake as part of its business choices, it could happen that the data controller of your personal data may change: we will inform you in case such a scenario happens, in order to provide you with all the necessary information to contact the new data controller.
8. Minors
Our App and Site are not intended for children under the age of 18, but are intended for an adult audience. If you are a parent or guardian and you think your child has submitted data to us, you can contact us at the addresses above.
9. Your rights
You can contact KuriU to request access to your personal data, rectification, erasure or restriction of processing, to object to processing and to request the portabilitỳ of your data; you can also withdraw your consent at any time (this will not affect the lawfulness̀ of processing based on the consent given before withdrawal).
When you exercise your right of access, you have the right to know whether your data are being processed, what the purpose of the processing is, what categories of data are being processed, who the recipients or categories of recipients are to whom your data are disclosed (and, if they reside in a third country on the basis of what guarantees), the retention period of your data (or the criteria for determining the retention period), whether any automated processing is taking place (e.g. by profiling) and what the logic of such processing is, the origin of the data (if not initially collected by KuriU).
You have the right to lodge a complaint with the competent supervisory authority pursuant to and within the limits of Article 77 GDPR and to request from KuriU, at any time, information about the data processors and the authorized persons that process your data. You can exercise your rights by contacting KuriU at the above addresses.
In any case, you can change or withdraw your consents through the features of the App and the Site via your personal area, "Privacy Management”.
Limited to the Site, you can control and disable cookies and other profiling tools. To find out how we use cookies and other profiling tools, click here.
(https://www.kuriu.it/cookie-policy/cookie_policy.pdf).
Regarding the App, you can withdraw your consent to the tracking of your activity and location, as outlined in paragraph 3(i) and (j) above, by accessing your device's system settings by selecting the KuriU App and then changing your preferences.
You can also exercise your rights, in relation to the processing of personal data carried out through our Social Pages, by contacting them directly in accordance with their respective privacy policies.
10. What do we do if we change this policy
We may make changes to our privacy policy. We will notify you in connection with such changes as required by law. We will also post an updated version on our App and Site. It will have a different date than the one shown below. Please check the App and Site periodically for updates.
Updated version as of May 1, 2024.