Privacy Policy

Policy Effective Date: December 1, 2020

1. General Information

QUA App is committed to protecting and respecting the privacy of users. This disclosure (“privacy policy”) is intended to inform you about our practices regarding the collection, use and disclosure of information that you may provide through our mobile applications (hereinafter referred to as the “Platforms”).
This Privacy Policy (together with our Terms and Conditions, and any other documents referred to in it) establishes the basis on which the personal data we collect from you or that you provide to us will be processed. Please read the following carefully to understand our considerations and practices regarding personal data and how it will be treated.

2. What information do we collect from you and for how long?

We may collect and process the following data:

2.1. Information You Provide

You may provide us with information, including personally identifiable information (“Personal Data”) when using our Platforms, when filling out forms on the Platforms (such as the registration form), when participating in any of our contests, promotions or surveys, when you communicate with us by phone, email or otherwise, and when you report a problem with our Platforms.
The information you provide may include:

• Mandatory information to register for the service we provide on our Platforms or to access other services provided by us, including your name, email address, date of birth, gender, mobile number and a password. All these fields are mandatory. QUA will not be able to provide the services offered on our Platforms if the requested information is not provided and, consequently, the user will not be able to register his user account on our Platforms;
• Picture profile;
• Details on organized events/experiences;
• Details on events/experiences in which he participated;
• A history of any correspondence between the user and us;
• A history of all events/experiences and requests for invitations;
• Details of visits to our Platforms and the resources accessed;
• The answers to any surveys or questionnaires, such as reviews on events/experiences with other users of our community. This information can be used for analysis and user understanding purposes;
• Information we may request from users when they report a problem with our Platforms or our service, such as the subject of the support equest;
• Real-time location information of the device. The App can collect precise information about the location of your mobile device to convert your geographic location into an address that could be the address of an Event you are organizing or to show you Events close to your geographic location on a map. Your location is stored exclusively on your device. You can choose not to enable localization but you won’t be able to use features based on that.
• Access to photos, media and files on your device. The App may require you to use photos, media and files on your device to complete your profile data or to attach a photo and/or video to your events. You can choose not to allow access to your device”s photos, media and files, but you won’t be able to use features based on this.
• Access to the camera. The App may require the use of the camera, built into your device, to scan the QR code corresponding to a guest’s virtual ticket. The captured images are stored exclusively on your device. You can choose not to allow the app to use the camera, but you won’t be able to use features based on that.

2.2. Information collected automatically

2.2.1. If the user signs up through the social media authentication methods, QUA will access certain Personal Data (e.g. name, surname, photo, e-mail) provided by the user’s social media account according to the terms of use applicable to those social media platforms. We may also collect some of your Personal Data when interacting with third party social media features.

2.2.2. With regard to each of the visits to our Platforms, we may collect, in accordance with applicable laws and if necessary with your consent, information relating to the devices in use and the networks to which you are connected when using our services. This may include the following information: IP address, login information, type and operating system and platform for and from our Platforms, products viewed or searched for, download errors, duration of visits to certain pages, interaction on the pages and any telephone number used to call our customer service number. We collect this information through the use of various technologies.

2.3. Data retention

2.3.1. Except for the categories of Personal Data indicated in the clauses below, Personal Data will be kept for the duration of the relationship with us and therefore no longer used:

• 3 years after the last use of our Platform, if the user does not close the account;
• 1 year after account closure, unless you have received a negative rating or report, in which case your Personal Data is kept for (i) a period of 2 years after the last rating or report negative, or (ii) 1 year after account closure, whichever is longer.

2.3.2. The following categories of Personal Data may be kept for different durations:

• All user-generated content (such as comments and ratings) are anonymized but remain available on our Platforms.

2.3.3. In the event that the account has been suspended or blocked, we will keep the data for a period of between 2 and 5 years, in order to prevent the user from circumventing the rules that apply to our Platforms.

3. Who are the recipients of the Information we collect from the user and for what purposes?

3.1.When using our services, some information about you is shared with users of our communities, both on your public profile and during the process of requesting an invitation.

3.2.We may receive and send information about you, including Personal Data, if you use any of the Platforms operated by us or by other entities affiliated with QUA, for the purposes set out in this Privacy Policy.

3.3. We also work closely with third parties who may be the recipients of your Personal Data, such as:

• our business partners who are social media platforms and who may offer linking services, such as linking information the profile, from their social media platforms to our Platforms;
• our business partners who may advertise their services on our Platforms and to which the user may decide to subscribe: these services may be services related to our services.
• our business partners who may advertise our services on their websites;

3.4. We do not disclose the information provided, including your Personal Data, with any of these third parties, except in cases where: It is

• necessary to involve a third-party service provider, for the fulfillment of any contract entered into with the user to in order to facilitate or extend our services;
• It is provided as part of the booking process and in order to provide the requested services, information such as name, profile picture, mobile phone number and/or e-mail address may be displayed on the Platforms and/or transmitted to the organizer;
• As part of our rating system, reviews written by you will be posted on the Platforms. The reviews, including the abbreviated name and the photograph, are visible to all visitors to the Platforms;
• We use analytics and search engine providers to support the improvement and optimization of our Platforms;
• It is explicitly requested by the user (for example, when using social media authentication methods);
• We may distribute portions of our Platforms (including user-posted events) for display on the websites of our business partners through APIs or widgets. In these cases, some information of the user’s public profile may be displayed on these websites;
• QUA may also disclose the information if required by law or if, in good faith, it believes that such access, storage or disclosure is reasonably necessary to (i) respond to complaints filed against QUA, (ii) comply with any legal process, (iii) enforce any agreements with our users, such as the General Terms of Use, the Privacy Policy, (iv) in the event of an emergency involving a danger to public health, the death or physical injury of a subject (v) as part of an investigation or (vi) to protect the rights, property or personal safety of QUA, its users or others;
• In the event that we were to sell or buy any business or assets, in which case we may disclose the Personal Data to the prospective seller or buyer of such business or assets;
• If QUA or all or part of its assets are acquired by third parties, in which case the Personal Data in its possession relating to its users will be one of the transferred assets.

3.5. In accordance with applicable laws and, if necessary with your consent, we may combine information relating to you, including Personal Data, that we send and receive from our business partners. We may use this information and the combined information for the above purposes.

3.6. Attention is also drawn to the fact that if the user decides to share information with us, including Personal Data, through the connection services of our business partners, in addition to this Privacy Policy, any privacy policies and/or notices of our business partners. We do not control the collection and/or processing of information that may be performed by our business partners on their platforms.

4. How do we use and moderate messages?

4.1. We may review, scan or analyze the messages exchanged with other users of our community through our Platforms for the prevention of fraud, the improvement of the service, for the purposes of customer support, for the application of contracts entered into with our users (such as the General Terms of Use). For example, in order to avoid bypassing our online booking system, we may scan and analyze messages sent through our Platforms to check that they do not include any contact details or references to other websites.

4.2. We will never scan or analyze user messages with other users in our community for commercial and advertising purposes. We may use automated methods to moderate these messages.

5. Targeted advertisements on social media platforms and on our communications sent by e-mail and SMS

In accordance with applicable laws and, if necessary with your consent, we may use the information provided on our Platforms for electronic direct marketing purposes (for example, (i) receiving our newsletters, invitations to our events, or other communications that we believe may be of interest to you or (ii) provide targeted advertising based upon your interest through social media platforms or third party websites).
For electronic marketing communications: you can withdraw your consent at any time (i) by clicking on the unsubscribe link provided in any QUA communication sent to your attention or (ii) by contacting us using the contact details provided in section 10 below.
For targeted ads and contents on social media: you can object at any time by configuring the ad settings via your social media account.

6. What are your rights regarding your personal data?

6.1 Where permitted by law, you may have the right to obtain a copy of your Personal Data in our possession. Before responding to the request, we may ask you to (i) verify your identity and (ii) provide further details so that we can better respond to your request. We will try to respond within an appropriate period of time and, in any case, within the time period required by law. If you wish to exercise this right, you must contact us using the contact details provided in section 10 below.

6.2.As a user of our Platforms, you can access the Personal Data we hold about you through your account to correct, modify, or delete any inaccurate information. You can also update or delete your Personal Data by contacting us, using the contact details provided in section 10 below. You can close your online account at any time and you have the right to object to the processing of your Personal Data.
In some cases, we may retain certain information about you as required by law or for legitimate purposes. For example, if we believe that you have committed fraud or violated our General Conditions of Use, we may decide to keep some of the information to avoid bypassing the rules applicable to our Platforms.

6.3. You also have the right to receive the Personal Data concerning you and provided by you to us, in a structured, commonly used, and machine-readable format, as well as to transmit such Personal Data to another data controller.

7. Password confidentiality

In cases where the user has chosen a password that allows access to certain parts of our Platforms, he is responsible for keeping this password confidential. We ask the user not to share the password with anyone.

8. Links to other websites and social media

Our Platforms may, from time to time, contain links to and from websites of our networks or our advertisers and affiliate partners. If you follow a link to any of these websites, you should remember that these websites have their own privacy practices and that we accept no responsibility for those policies. Please review these policies before submitting Personal Data to these websites.

9. Changes to the Privacy

Any changes to our Privacy in the future will be posted on this page. If appropriate, we will notify users or ask them to provide consent. Please check this page often for any updates or changes to our Privacy Policy.

10. Contact details and Data Protection Officer

If at any time a user wishes to contact us to exercise their rights or for any requests relating to Personal Data, they can do so by contacting our Data Protection Officer at info@qua-app.com