The purpose of this document is to inform the natural person (hereinafter “Data Subject”) regarding the processing of their personal data (hereinafter “Personal Data”) collected by the data controller, amuseapp srl, with registered office at via della Rivetta 32B, 32100 Belluno, Italy, tax code/VAT number IT01302450257, e-mail address help@amuseapp.it, (hereinafter the “Controller”), through the amuseapp application for iOS and Android and the web app web.amuseapp.art (hereinafter the “Application”).
Changes and updates will be binding as soon as they are published on the Application. In the event of non-acceptance of the changes made to the Privacy Policy, the Data Subject must cease using this Application and may request that the Controller delete their Personal Data.
- Categories of Personal Data processed The Controller processes the following types of Personal Data voluntarily provided by the Data Subject: The Controller processes the following types of Personal Data collected automatically: Failure by the Data Subject to provide Personal Data for which there is a legal or contractual obligation, or which constitutes a necessary requirement for the conclusion of the contract with the Controller, will make it impossible for the Controller to establish or continue the relationship with the Data Subject. A Data Subject who provides the Controller with Personal Data of third parties is directly and solely responsible for their origin, collection, processing, communication, or disclosure.
- Contact data: first name, last name, address, e-mail, phone number, images, authentication credentials, any further information sent by the Data Subject, etc.
- E-mail address and city to receive communications from the venue: on some routes the Data Subject may leave their e-mail address and, if requested, their city, to receive communications or benefits from the venue visited. Together with the consent, the date, the text of the consent shown, the venue, the route, the language, the installation identifier and the IP address are recorded, so that the consent can be demonstrated. The subscription is active as soon as the form is submitted, without a confirmation e-mail. The venue's privacy notice is shown next to the form.
- E-mail address linked to an access: after activating an access, the Data Subject may link an e-mail address to it in order to recover it on another device. The Controller sends a confirmation e-mail to that address via SendGrid (Twilio Inc.), appointed as data processor. This address is not used for marketing communications without a separate consent.
- Messages to the AI assistant: if the Data Subject uses the venue's AI assistant, the Application sends the text of the messages and the current conversation, the language, the venue and a random conversation identifier, which is not linked to the Application's other identifiers. Together with the conversation, the date, the browser or device type and the sources used for the answer are recorded; the IP address is used only in irreversibly encrypted form, to limit the number of requests. The Data Subject is advised not to enter personal data in the messages. Answers are generated automatically and may contain errors.
- Group visit: to join a guided group visit, the Data Subject enters the group code and, if they wish, a name to be shown to the guide. The name, the language and the profile chosen are visible to the guide for the duration of the visit.
- Tax and payment data: tax code, VAT number, credit card details, bank account details, etc.
- Data relating to the employment relationship: data entered in the curriculum vitae, data relating to spouse or children, social security data, etc.
- Technical data: Personal Data produced by the devices, applications, tools, and protocols used, such as, for example, information about the device used, IP addresses, browser type, Internet Service Provider (ISP) type. Such Personal Data may leave traces that, particularly when combined with unique identifiers and other information received from servers, may be used to create profiles of natural persons
- Application identifiers: on first launch, the mobile application generates some random identifiers, stored on the device: a guest user identifier, an installation identifier and an identifier for statistics. They do not contain the name, e-mail address or phone number of the Data Subject and are not advertising identifiers: the Application does not access the device's advertising identifier (IDFA or Advertising ID). They are used to recognise the access activated on that device, to count activations, to link quiz answers and badges earned, and to diagnose errors. If the Data Subject links an e-mail address to their access, or leaves it to receive communications, the address remains linked to the guest user identifier or to the installation identifier.
- Browsing and Application usage data: such as, for example, pages visited, number of clicks, actions taken, session duration, etc. In the mobile application, for statistical purposes, the following are recorded: which venues, routes and stops are opened and for how long, the progress of audio listening, the outcome of access activation and of QR code scanning, the language chosen, the device model and operating system, and the Application version. This data is associated with a random identifier generated by the Application, is not linked to the e-mail address or other data of the Data Subject, and is not used for advertising.
- Location data: with the Data Subject's permission, the Application uses the device's GPS location to show nearby venues and the position on the map and to start outdoor stops. The GPS location is used only on the device and is not sent to the Controller. To display the map, the Application downloads images of the area from OpenStreetMap, which receives the IP address and the area displayed.
- Bluetooth beacon data: in venues equipped with beacons, the Application periodically sends the Controller the list of beacons received (identifier, signal strength, battery level), the venue, the route and the device model, without any identifier of the Data Subject, in order to check that the beacons are working.
- Indoor positioning data: in venues where the positioning data collection service is active (currently La Pedrera), during the visit the Application also records the strength of the beacon signals, the atmospheric pressure measured by the barometer, motion sensor data (accelerometer, gyroscope and magnetometer), the step count provided by the device's system, the stops recognised and the start of audio tracks, the device model and the Application version. The data is associated with a random session identifier. In the diagnostic data described below, this identifier appears together with the guest user identifier: the data is therefore pseudonymous, not anonymous. It does not contain GPS location or contact data.
- Camera: with the Data Subject's permission, the Application uses the camera only to read QR codes and barcodes (tickets, artworks, venues). Images are neither saved nor sent: the Controller receives only the code read, in order to activate the access or open the content. The Application does not use the microphone.
- Diagnostic data and recordings of usage sessions: the Application records errors and freezes, a share of response times, and the sequence of screens and actions performed during use. In the mobile application, recording currently covers all usage sessions. In the recording, text and images are masked: for example, messages written to the AI assistant or the e-mail address entered are not visible. Technical events are also recorded (for example the addresses of requests to the server, which may contain the text of a search, the network status and the start of audio tracks), as well as information about the device and the Application version, the venue and route opened, and the guest user identifier. The IP address is not stored. The service is provided by Functional Software, Inc. (Sentry), appointed as data processor, with data stored in the European Union for up to 90 days.
- Cookies and similar technologies The Application uses cookies, web beacons, unique identifiers, and other similar technologies to collect the Data Subject's Personal Data regarding pages, links visited, and other actions carried out when the Data Subject uses the Application. These are stored so that they can be transmitted upon the Data Subject's next visit. The full Cookie Policy can be viewed at the following address: https://amuseapp.art/en/cookie-policy The mobile application does not use cookies: the identifiers used are those described above.
- Legal basis and purposes of processing The processing of Personal Data is necessary: On the basis of the Controller's legitimate interest, the Application allows interactions with external platforms or social networks whose processing of Personal Data is governed by their respective privacy policies, to which reference should be made. The interactions and information acquired through this Application are in any case subject to the privacy settings that the Data Subject has chosen on such platforms or social networks. This information – in the absence of specific consent to processing for further purposes – is used solely to enable use of the Application and to provide the information and services requested. The Data Subject's Personal Data may also be used by the Controller to defend itself in legal proceedings before the competent courts.
- for the performance of the contract with the Data Subject, and specifically:
- fulfillment of any obligation arising from the pre-contractual or contractual relationship with the Data Subject
- registration and authentication of the Data Subject: to allow the Data Subject to register on the Application, log in, and be identified, including via external platforms
- support and contact with the Data Subject: to respond to the Data Subject's requests
- AI assistant: to answer the Data Subject's questions about the venue and the artworks and to check the quality of the answers. Messages are processed by Anthropic Claude and Cohere models through the Amazon Bedrock service of Amazon Web Services EMEA SARL, appointed as data processor. The answer is generated in data centres in the European Union; a preliminary step, which rephrases the question to search for relevant information, uses Amazon Bedrock's global routing and may therefore take place in data centres outside the European Union. Model providers do not receive the messages, and the messages are not used to train the models. Conversations are stored on servers of Supabase Inc., appointed as data processor, in the European Union (Sweden).
- payment management: tickets and donations are paid for on the web app, not in the mobile application. Payment is handled by Stripe Payments Europe, Ltd. (Ireland), which processes card data as an independent controller under its own privacy policy (https://stripe.com/privacy). The Controller does not receive card data: it receives the e-mail address, the amount, the date and the outcome of the payment, in order to send the access and comply with tax obligations.
- for compliance with a legal obligation, and specifically:
- fulfillment of any obligation set out in current regulations, laws, and regulations, in particular regarding tax matters
- on the basis of the Controller's legitimate interest, for:
- email marketing purposes for the Controller's products and/or services to directly sell the Controller's products or services using the e-mail address provided by the Data Subject in the context of the sale of a product or service similar to the one that was the subject of the sale
- management, optimization, and monitoring of the technical infrastructure: to identify and resolve any technical issues, to improve the Application's performance, to manage and organize information within an IT system (e.g., servers, databases, etc.)
- security and fraud prevention: to ensure the security of the Controller's assets, infrastructure, and networks
- usage statistics: to measure, in pseudonymous form, how the Application is used (for example how many visitors complete a route or listen to an audio track to the end) and to improve it. The service is provided by Google Ireland Limited (Google Analytics 4), appointed as data processor. Data may be transferred to the United States on the basis of the EU-U.S. Data Privacy Framework and the standard contractual clauses, and is retained by Google Analytics for up to 14 months.
- improvement of indoor positioning: to analyze, in pseudonymous form, how beacon signals are received in venues equipped with the service, and to improve the accuracy with which the Application recognizes the stop on the route where the Data Subject is located
- diagnostics of Application errors: to reconstruct, in pseudonymous form and with text and images masked, what happened in the Application when a feature did not behave as expected, and to fix it
- on the basis of the Data Subject's consent, for:
- profiling of the Data Subject for marketing purposes: to provide the Data Subject with information about the Controller's products and/or services through automated processing aimed at collecting personal information for the purpose of predicting or evaluating their preferences or behavior
- retargeting and remarketing: to reach, with a personalized advertisement, the Data Subject who has already visited or has shown interest in the products and/or services offered by the Application, using their Personal Data. The Data Subject may opt out by visiting the page of the Network Advertising Initiative
- marketing purposes for the Controller's products and/or services: to send commercial and/or promotional information or materials, to carry out direct sales activities for the Controller's products and/or services, or to conduct market research using automated and traditional means
- marketing purposes for third-party products and/or services: to send third parties' commercial and/or promotional information or materials, to carry out direct sales activities, or to conduct market research on their products and/or services using automated and traditional means
- disclosure of Personal Data for third-party marketing purposes: to disclose Personal Data to third parties operating in the marketing and advertising sector so that they may use it to send commercial and/or promotional information or materials, to carry out direct sales activities for their products and/or services, or to conduct market research using automated and traditional means
- communications from the venue visited: if the Data Subject leaves their e-mail address in the form on the route, the e-mail address and city are disclosed to the venue visited, which processes them in the role stated in the privacy notice shown next to the form, and are entered, together with the consent data, into the GetResponse e-mail marketing service (GetResponse S.A.). Consent may be withdrawn at any time via the link in the e-mails received or by writing to help@amuseapp.it.
- for the performance of the contract with the Data Subject, and specifically:
- Methods of processing and recipients of Personal Data The processing of Personal Data is carried out using paper-based and IT tools, with organizational procedures and logic strictly related to the purposes indicated, and through the adoption of appropriate security measures. Personal Data are processed exclusively by: The parties listed above are required to use appropriate safeguards to protect the Personal Data and may access only the data necessary to carry out the tasks assigned to them. Personal Data will not be disseminated indiscriminately in any way.
- persons authorized by the Controller to process Personal Data who have committed to confidentiality or are subject to an appropriate legal obligation of confidentiality;
- parties who act autonomously as separate data controllers, or parties appointed as data processors by the Controller in order to carry out all the processing activities necessary to pursue the purposes set out in this notice (for example, business partners, consultants, IT companies, service providers, hosting providers);
- parties or entities to which Personal Data must be disclosed by legal obligation or by order of the authorities.
- Updates to the mobile application are distributed through Expo (650 Industries, Inc., United States), which receives the IP address, the operating system, the Application version and a random installation identifier.
- Location If necessary, Personal Data may be transferred to parties located outside the territory of the European Economic Area (EEA). Whenever Personal Data is transferred outside the EEA, the Controller will adopt every contractual measure suitable and necessary to ensure an adequate level of protection of Personal Data, including – among others – agreements based on the standard contractual clauses for the transfer of data outside the EEA, approved by the European Commission. In particular, the following providers are based in the United States or belong to groups based in the United States and may process Personal Data outside the EEA as well: Google (Google Analytics), Functional Software, Inc. (Sentry), Amazon Web Services (Amazon Bedrock), Supabase Inc., Xano (the Application's server infrastructure), 650 Industries, Inc. (Expo), Twilio Inc. (SendGrid) and Stripe. For these transfers the Controller relies on the EU-U.S. Data Privacy Framework, for providers that participate in it, or on the standard contractual clauses. To request information on the specific safeguards adopted, the Data Subject may contact the Controller at the following e-mail address: help@amuseapp.it.
- Retention period of Personal Data Personal Data will be retained for the period of time necessary to fulfill the purposes for which it was collected, in particular: At the end of the retention period, all Personal Data will be deleted or retained in a form that does not allow identification of the Data Subject.
- for purposes relating to the performance of the contract between the Controller and the Data Subject, it will be retained for the entire duration of the contractual relationship and, after termination, for the ordinary limitation period of 10 years. In the event of legal proceedings, for their entire duration, until the deadlines for bringing appeals have expired
- for purposes relating to the Controller's legitimate interest, it will be retained until that interest has been fulfilled
- for the fulfillment of a legal obligation, by order of an authority, and for defense in legal proceedings, it will be retained in accordance with the timeframes set out by such obligations and regulations, and in any case until the expiry of the limitation period provided for by applicable law
- for purposes based on the Data Subject's consent, it will be retained until consent is withdrawn. For marketing purposes, for a period not exceeding 24 months.
- conversations with the AI assistant are retained for as long as necessary to check and improve the quality of the answers; the Data Subject may request their deletion by writing to help@amuseapp.it.
- Rights of the Data Subject Data Subjects may exercise certain rights with regard to the Personal Data processed by the Controller. In particular, the Data Subject has the right to: To exercise their rights, Data Subjects may send a request to the following e-mail address: help@amuseapp.it. Requests will be taken in charge by the Controller immediately and handled as quickly as possible, and in any case within 30 days.
- be informed about the processing of their Personal Data
- withdraw consent at any time
- restrict the processing of their Personal Data
- object to the processing of their Personal Data
- access their Personal Data
- verify and request rectification of their Personal Data
- obtain the restriction of processing of their Personal Data
- obtain the erasure of their Personal Data
- transfer their Personal Data to another controller
- lodge a complaint with the supervisory authority for the protection of their Personal Data and/or take legal action.
