Privacy Policy

Last update: v.1, October 19th, 2021

This privacy policy applies to the processing of your personal data (hereinafter, “Personal

Data”), as user (hereinafter, the “User” or “Data Subject”) of the Rosarium Pro App (hereinafter, “Rosarium Pro” or the “App”) carried out by the Data Controller, in accordance with Regulation (EU) 2016/679 (the “General Data Protection Regulation” or the “GDPR” – as well as the Italian Legislative Decree 196/2003 (as amended) and other applicable local laws, as amended or replaced (jointly, the “Applicable Privacy Laws”).

1) Data controller

The Data Controller (hereinafter the “Controller” or the “Data Controller”), pursuant to art. 4(7) GDPR, is Carlo Sacchetti. The Data Controller can be contacted at info@rosariumpro.com.

2) Personal Data

The Personal Data processed by Data Controller for the purpose below may include by way of example, identification and contact details such as name, surname and email adress and payment details in order to proceed to in-app purchases.

3) Purpose of processing

Your Personal Data are processed by the Data Controller for the purpose of managing any aspect of your registration within the Rosarium Pro App, including, but not limited to: (i) registration for the initial free plan; (ii) subscribing to pro plans. However, please note that the Data Controller is in no case able to view the personal data used for Subscription Purposes (every subscription is automatically transferred in an anonymous ID)

4) Legal basis for the processing

The Legal Basis for the Processing of your personal data is art. 6, para. 1, lett. b GDPR (Execution of a Contract). As a matter of fact, processing for the purpose mentioned in paragraph 3) of this policy is necessary for the Controller in order to manage and fulfil your request to use the Rosarium Pro App and enter into a valid contract..

5) Nature of processing

The use of the Rosarium Pro App is entirely optional and the provision of your Personal Data for registering and subscribing to Rosarium Pro is voluntary. However, failure to provide such Personal Data may make it impossible for the Controller to manage and fulfil your request of registration and further subscriptions. You may revoke your registration at any time by writing at info@rosariumpro.com.

6) Retention period

Your Personal Data will be retained for the time strictly necessary to pursue the purpose of Managing your Registration. Once the App will be uninstalled, the Data Controller undertakes to delete your personal data without delay.

7) Recipients of Personal Data

Your Personal Data may be shared with the following subjects, on a need-to-know basis and

in accordance with Applicable Privacy Laws: (i) Internet service providers and platforms used by the Data Controller as organisational or necessary tools for the development of this app (such as, for example, https://developers.apple.com and https://www.revenuecat.com/) (the “Recipients“).

For efficiency or convenience reasons, some of the providers or organizations mentioned may be located in territories outside the European Economic Area that do not provide a level of data protection comparable to that of the European Union, such as the United States. In such cases, we inform you that we transfer your data with adequate guarantees and always keep your data safe. Should the transfer be based in any other legal ground, when required it shall be informed to you before performing such an international transfer.

8) Your privacy rights

To the extent provided by Applicable Privacy Laws, you can send an email to info@rosarioumpro.com in order to exercise, at any moment and for free, the following rights: (i) access to your Personal Data, as well as further information on the processing carried out on them; (ii) the rectification or updating of your Personal Data processed by the Controller, where they are incomplete or out of date; (iii) the cancellation of your Personal Data from the Rosarium Pro App and/or archives; (iv) the limitation of the processing of your Personal Data by the Controller; v) to obtain the Personal Data relating to it in a structured, commonly used and automatically readable form by automatic device; (vi) object to the processing of your Personal Data by the Data Controller; (vii) withdraw your consent.

In any case, you are always entitled to lodge a complaint with the competent Personal Data

Protection Authority if you believe that the processing of your Personal Data is contrary to

Applicable Privacy Laws.