Pursuant to art. 13 and art. 14 of the Regulation (EU) 2016/679 and pursuant to the Italian legislative decree 30th of June, no. 196, as emended by the legislative decree 10th August 2018, no. 101, and pursuant to the rulings of the Supervisory Authority (Garante per la protezione dei dati personali) where applicable.

Dear Mr., Dear Mrs.,

pursuant the provisions of the Regulation (EU) 2016/679 (hereinafter also “GDPR”) and pursuant to the provisions of the Italian legislative decree 20th June, no. 196 as emended by the legislative decree 10th August 2018, no. 101 (hereinafter “Privacy Law”) (together referred to as “Applicable Law”), THERE4 S.R.L. (hereinafter “There4”), with office in Modena (MO), via Fregni 198, VAT number 03835220363, in his capacity as data controller (hereinafter “Data Controller”), informs you of the processing of personal data (hereinafter “Data”), with regard to the use and management of There4’s apps (hereinafter “App”).

  1. Sources and nature of the Data

Data are collected and processed by There4, in his capacity as Data Controller, in compliance with the provision of the GDPR and of the Applicable Law.

Your personal Data will be collected either directly from you or obtained from other sources, such as LinkedIn.

The collected Data will relate to personal information as personal details, credit card details, email address, Ip address, LinkedIn profile image and details linked to your job.

In this respect, we kindly ask you to let us know should your personal Data be subject to any change, in order to enable the update and amendments of such Data.

  1. Purposes and collection of Data

The Data are collected and processed, in compliance with the GDPR provisions and with the Applicable Laws, with the support of computerized or telematics means, designed to store, manage and transmit the Data and, in any case, by means of instruments suitable for guaranteeing the security and confidentiality of the Data processed, for the following purposes:

  • management of There4’s Apps;

  • compliance with the duties arising on There4 as a result of the applicable law;

  • compliance with the obligations established by law or deriving from contractual agreements, regulations and EU law provisions;

  • compliance with the fiscal and accounting obligations;

  • management of any dispute that might arise under either civil law, criminal law, administrative law or tax law;

  • sending of push notifications/emails in order to promote events and/or advertising and promotional materials;

  • assign or communicate anonymous and aggregated personal data to the parties specified under paragraph 5 of the present notice, for the purpose of carrying out studies, research, market statistics

  1. Data storage and retention

The Data will be processed by the Data Controller for the duration of the costumer’s relationship with There4 and for a period of time thereafter to allow for the compliance to any legal obligations, linked or resulting from the termination of the relationship itself. In any case, the Data will be deleted without delay after the expiration of the abovementioned period of time, once the legal obligations have been complied with.

  1. Nature of the collection, consequences in case of refusal and legal basis of the processing

The transfer of the Data to the Data Controller is mandatory only in respect of the Data which impose such legal obligation. The refusal to provide such Data might force the Data Controller to collect it from other sources (if permitted by law) or might result in the failure to establish or implement the relationship.

The refusal to provide the Data which do not impose a legal obligation, but which are functional to the implementation of the relationship, does not result in the failure to establish or implement the relationship, except for the impossibility to implement the operations linked to such Data or the impossibility to use the There4 App.

The legal basis of the processing of Data referred to in paragraph 2 “Purposes and Collection of Data” lies in the consent of the Data Subject and in the compliance with the legal obligation according to article 6, lett. b) and c) of the GDPR

  1. Communication of the Data

In addition to the communications pursued in order to comply with the legal obligations, the collected and processed Data can be communicated, for the purposes mentioned above, to:

  • the users of There4 App;

  • public entities in order to comply with applicable laws and government or regulatory bodies’ requests for information;

  • credit institutions with regard to payments via credit card;

  • judicial authorities and administrative bodies with regard to the purposes abovementioned;

  • lawyers and legal consultant, for the purpose of studying and resolving any dispute that might arise with regard to the relationship;

  • third parties with whom the Data Controller might get in touch with during the implementation of the business activity;

  • professionals, services companies and consultants who provide services to the Data Controller such as information technology services and marketing services;

  • companies with whom There4 maintains a relationship.

In addition, the Data might be shared with the processors (pursuant to art. 28 of the GDPR) with regard to outsourcing activities, and to any third party authorized by the Data Controller .

The Data will not be disseminated.

  1. Transfer of right to third countries

Were There4 to transfer the Data outside of the EU and outside of the European Economic Area, the transfer will be made pursuant to the GDPR provisions and in compliance with the Applicable Law.

  1. Rights of the Data Subject

In relation to the processing of Data, the Data Subject is entitled to exercise the rights provided for in Articles 15 to 22 of the 2016/679 European Regulation, here reproduced in abbreviated form: the Data Subject has the right to access to a copy of the information comprised in their personal data, object to processing that is likely to cause or is causing damage or distress, object to decisions being taken by automated means, obtain the limitation of the process (in certain circumstances), have (in certain circumstances) his personal data rectified, integrated, blocked, erased or destroyed, obtain the portability of his personal data and the right to propose a claim before the Data protection Authority.

To enforce the rights mentioned, the Data Subject shall send a message via email to

  1. Data Controller

Data Controller is THERE4 S.r.l., with office in Modena (MO), Via Fregni 198, VAT number 03835220363.

Modena, 11.2.2019

THERE4 S.r.l