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The Validactor Privacy Policy



Last modified: 24 May, 2018



When you use Validactor services, you entrust us with your personal data and information. This Privacy Policy is meant to help you understand what data we collect, why we collect it, and what we do with it.
This document is extremely important; we hope you will take time to read it carefully before using the Validactor services. And remember, you can find controls to manage your information and protect your privacy and security in your personal area of the Validactor service you are registered to.

Privacy Policy


When you share information with us, for example by registering to one of the Validactor App or to the Social Pages Portal, we can make those services even better – to show you more customized services such as your preferred brands and products and the closest or less expensive shops or websites where to find them, to help you connect with other people, with purchasing groups, Preferred NGOs or Charities or make connections with other registered users. In this Privacy Policy we’d like to clarify how we’re using information and the ways in which you can protect your privacy.

Our Privacy Policy explains:
• What information we collect and why we collect it.
• How we use that information.
• The choices we offer, including how to access and update information.

We’ve tried to keep it as simple as possible, but if you’re not familiar with terms like cookies, IP addresses, geolocation and browsers, we suggest you get familiar with them. Your privacy matters to Validactor so whether you are new to Validactor or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us.

Information we collect



We collect information to provide better services to all of our users – from figuring out basic stuff like which language you speak, to more complex things like which products or brands you like most, any allergy you may have, which Points of sale or resellers you prefer, or which promotions you may be interested in.

How we collect information:
• Information you give us. For example, our basic services do not require you to register on Validactor; however but if you want to explore and use the full set of Validactor services you need to create your personal Validactor account. While you are doing it, we’ll ask for personal information, like your name, email address, telephone number, home or office address, your birthdate and sex (not all of this information are mandatory however).
• Information we get from your use of our services. We collect information about the services that you use and how you use them, like when you scan a product VACode, when you visit our Social Pages Portal, when you purchase a product or when you place an order. This information includes:

o Device information
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). Validactor may associate your device identifiers or phone number with your Validactor Account.

o Log information
When you use our services or view content provided by Validactor, we automatically collect and store certain information in server logs.

This includes:
Details of how you used our service, such as your product browsing or product scans.
Telephony log information like your phone number.
Internet protocol address (IP Address).
Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
Cookies that may uniquely identify your browser or your Validactor Account.

o Location information
When you use Validactor services, we collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Validactor with information on nearby devices, Wi-Fi access points and cell towers.

o Local storage
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

o Cookies and similar technologies

Validactor uses various technologies to collect and store information when you visit a Validactor service, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with Validactor features that may appear on other sites.

Information we collect when you are signed in to Validactor are treated as personal information.



How we use information we collect
We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect Validactor and our other users. We also use this information to offer you tailored services – like giving you more relevant purchase options and offers.

If you have a Validactor Account, we may display your personal data including Profile name, Profile photo, and other sensible information only by respecting the choices you make to limit visibility in your Validactor account.
When you contact Validactor, we keep a record of your communications to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements in the services we offer.
We use information collected from cookies and other technologies, to improve your user experience and the overall quality of our services.
One of the products we use to do this on our own services is Clicky to anonymously track the visits to our websites. By saving your language preferences, we’ll be able to have our services appear in the language you prefer. When showing you tailored offers, we will not associate an identifier from cookies or similar technologies with sensitive categories, such as those based on race, religion, sexual orientation or health; we will only base our tailored offers on the selections you will do in your Validactor Account.
Our automated systems analyze your actions within Validactor to provide you personally relevant product features, such as customized product offers and tailored services.
We may combine personal information from one service with information from other Validactor services - including personal information - for example to make it easier to share accumulated VAPoints with people you know.
We will always ask for your consent – in advance - before using information for a purpose other than those that are set out in this Privacy Policy.
Validactor processes personal information on AWS servers in many countries around the world. We may process your personal information on a server located outside the country where you live or outside the European Community.

Transparency and choice



People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:
• Review and update your Validactor functions to decide what types of data (such as data related to the products you have purchased) you would like get saved with your account when you use Validactor services.
• Review and control certain types of information tied to your Validactor Account by using the Validactor My profile area.
• View and edit your preferences about the Validactor products shown to you on any Validactor service, such as which categories might interest you most.
• Adjust how the Profile associated with your Validactor Account appears to others.
• Control who you share information with through your Validactor Account.
• Choose whether your Profile name and Profile photo appear in shared endorsements that appear in product pages.
You may also set your browser to block all cookies, including cookies associated with Validactor services, or to indicate when a cookie is being set by us. However, it’s important to remember that many of our services may not function properly if your cookies are disabled. For example, we may not remember your language preferences.

Information you share


Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines, including Google.
Accessing and updating your personal information
Whenever you use Validactor services, you can access to your personal information at any time. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes.
We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

Information we share


We do not share personal information with companies, organizations and individuals outside of Validactor unless one of the following circumstances applies:
• With your consent
We will share personal information with companies, organizations or individuals outside of Validactor when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
• With AWS Servers Administrators
Your Validactor Account can be accessed in very special circumstances by AWS Servers and Platform Administrators who may be able to:
o View statistics regarding your account, like statistics regarding applications you install.
o Modify your account password.
o Suspend or terminate your account access.
o Access or retain information stored as part of your account.
o Receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request.
o Restrict your ability to delete or edit information or privacy settings.
• For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.
• For legal reasons

We will share personal information with companies, organizations or individuals outside of Validactor if we have a good-faith belief that access, use, preservation or disclosure of this information is reasonably necessary to:
o Meet any applicable law, regulation, legal process or enforceable governmental request.
o Enforce applicable Validactor Terms of Service, including investigation of potential violations.
o Detect, prevent, or otherwise address fraud, security or technical issues.
o Protect against harm to the rights, property or safety of Validactor, our users or the public as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.
If Validactor is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.
Information security
We work hard to protect Validactor and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold.

In particular:
• We encrypt many of our services using SSL.
• We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to personal information to Validactor employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

When this Privacy Policy applies



This Validactor Privacy Policy applies to all of the services offered by Validactor SRL and its affiliates, and services offered on other sites (such as our corporate website), but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you in our Social Pages Portal, sites that may include Validactor services, or other sites linked from our services. Our Privacy Policy does not cover the information practices of other companies and organizations who purchase and use our services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
Compliance and cooperation with regulatory authorities

We regularly review our compliance with our Privacy Policy.
We also adhere to several self-regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

Changes



Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of this privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

Validactor always keeps your personal information private and safe, and you are in control.



Validactor Terms of Service



Last modified: 24 May, 2018



Thanks for using our products and services (Services).
By using our Services you are agreeing to these terms. Please read them carefully.
Additional terms will be available with the relevant Services, and those additional terms become part of your agreement with us if you use those Services.

Using our Services


You must follow any policies made available to you within the Services.
Don’t misuse our Services. For example, don’t interfere with our Services or try to access them using a method other than the Web interface or the Apps and the instructions that we provide. You may use our Services only as permitted by law, including applicable export and re-export control laws and regulations. We may suspend or stop providing our Services to you if you do not comply with our terms or policies or if we are investigating suspected misconduct.
Using our Services does not give you ownership of any intellectual property rights in our Services or the content you access. You may not use content from our Services unless you obtain permission from its legitimate owner or are otherwise permitted by law. These terms do not grant you the right to use any branding or logos used in our Services. Don’t remove, obscure, or alter any legal notices displayed in or along with our Services.
Our Services display content that is not Validactor’s. This content is the sole responsibility of the entity that makes it available. We may review content to determine whether it is illegal or violates our policies, and we may remove or refuse to display content that we reasonably believe violates our policies or the law. But that does not necessarily mean that we review content, so please don’t assume that we do.
In connection with your use of the Services, we may send you service announcements, administrative messages, and other information. You may opt out of some of those communications.
Some of our Services are available on mobile devices. Do not use such Services in a way that distracts you and prevents you from obeying traffic or safety laws.

Your Validactor Account


You may need a Validactor Account in order to use some of our Services. You may create your own Validactor Account, or your Validactor Account may be assigned to you by an administrator, such as your employer. If you are using a Validactor Account assigned to you by an administrator, different or additional terms may apply and your administrator may be able to access or disable your account.
To protect your Validactor Account, keep your password confidential. You are responsible for the activity that happens on or through your Validactor Account. Try not to reuse your Validactor Account password on third-party applications. If you learn of any unauthorized use of your password or Validactor Account, immediately access your Validactor Account and change your password.

Privacy and Copyright Protection


Validactor’s privacy policies explain how we treat your personal data and protect your privacy when you use our Services. By using our Services, you agree that Validactor can use such data in accordance with our privacy policies.
We respond to notices of alleged copyright infringement and terminate accounts of repeat infringers according to the process set out in the EU General Data Protection Regulation (GDPR) and in the U.S. Digital Millennium Copyright Act.
If you think somebody is violating your copyrights and want to notify us, send a mail to privacy@validactor.com

Your Content in our Services


Some of our Services allow you to upload, submit, store, send or receive content. You retain ownership of any intellectual property rights that you hold in that content.
In short, what belongs to you stays yours.
When you upload, submit, store, send or receive content to or through our Services, you give Validactor (and those we work with) a worldwide license to use, host, store, reproduce, modify, create derivative works (such as those resulting from translations, adaptations or other changes we make so that your content works better with our Services), communicate, publish, publicly perform, publicly display and distribute such content. The rights you grant in this license are for the limited purpose of operating, promoting, and improving our Services, and to develop new ones. This license continues even if you stop using our Services (for example, for a comment on a product you have added to a product page in the Validactor Social Portal). Some Services may offer you ways to access and remove content that has been provided to that Service. Also, in some of our Services, there are terms or settings that narrow the scope of our use of the content submitted in those Services.
Make sure you have the necessary rights to grant us this license for any content that you submit to our Services.
Our automated systems analyze your content (excluding emails) to provide you personally relevant product features, such as customized product offers. This analysis occurs as the content is sent, received, and when it is stored.
If you have a Validactor Account, we may display your Profile name, Profile photo, and actions you take on Validactor or on third-party applications connected to your Validactor Account in our Services, including displaying in ads and other commercial contexts.
We will respect the choices you make to limit sharing or visibility settings in your Validactor Account. For example, you can choose your settings so your name and photo do not appear in an ad.

About Software in our Services


When a Service requires or includes downloadable software, this software may update automatically on your device once a new version or feature is available. Some Services may let you adjust your automatic update settings.
Validactor gives you a personal, worldwide, royalty-free, non-assignable and non-exclusive license to use the Apps provided to you by Validactor as part of the Services. This license is for the sole purpose of enabling you to use and enjoy the benefit of the Services as provided by Validactor, in the manner permitted by these terms. You may not copy, modify, distribute, sell, or lease any part of our Services or included software, nor may you decompile or disassemble or attempt to extract the source code of that software, unless laws prohibit those restrictions or you have our written permission.
Open source software is important to us. Some software used in our Services may be offered under an open source license that we will make available to you. There may be provisions in the open source license that expressly override some of these terms.

Modifying and Terminating our Services
We are constantly changing and improving our Services. We may add or remove functionalities or features, and we may suspend or stop a Service altogether.
You can stop using our Services at any time, although we’ll be sorry to see you go. Validactor may also stop providing Services to you, or add or create new limits to our Services at any time.
We believe that you own your data and preserving your access to such data is important. If we discontinue a Service, where reasonably possible, we will give you reasonable advance notice and a chance to get information out of that Service.

Our Warranties and Disclaimers


We provide our Services using a commercially reasonable level of skill and care and we hope that you will enjoy using them. But there are certain things that we don’t promise about our Services.
Other than as expressly set out in these terms or additional terms, neither Validactor nor its suppliers or distributors make any specific promises about the Services. For example, we don’t make any commitments about the content within the Services, the specific functions of the Services, or their reliability, availability, or ability to meet your needs. We provide the Services “as is”.
Some jurisdictions provide for certain warranties, like the implied warranty of merchantability, fitness for a particular purpose and non-infringement.
To the extent permitted by law, we exclude all warranties.

Liability for our Services


When permitted by law, Validactor, and Validactor’s suppliers and distributors, will not be responsible for lost profits, revenues, or data, financial losses or indirect, special, consequential, exemplary, or punitive damages.
To the extent permitted by law, the total liability of Validactor, and its suppliers and distributors, for any claims under these terms, including for any implied warranties, is limited to the amount you paid us to use the Services (or, if we choose, to supplying you the Services again).
In all cases, Validactor, and its suppliers and distributors, will not be liable for any loss or damage that is not reasonably foreseeable.

We recognize that in some countries, you might have legal rights as a consumer. If you are using the Services for a personal purpose, then nothing in these terms or any additional terms limits any consumer legal rights which may not be waived by contract.
Business uses of our Services
If you are using our Services on behalf of a business, that business accepts these terms. It will hold harmless and indemnify Validactor and its affiliates, officers, agents, and employees from any claim, suit or action arising from or related to the use of the Services or violation of these terms, including any liability or expense arising from claims, losses, damages, suits, judgments, litigation costs and attorneys’ fees.

About these Terms


We may modify these terms or any additional terms that apply to a Service to, for example, reflect changes to the law or changes to our Services. You should look at the terms regularly. We’ll post notice of modifications to these terms on this page. We’ll post notice of modified additional terms in the applicable Service. Changes will not apply retroactively and will become effective no sooner than fourteen days after they are posted. However, changes addressing new functions for a Service or changes made for legal reasons will be effective immediately. If you do not agree to the modified terms for a Service, you should discontinue your use of that Service.
If there is a conflict between these terms and the additional terms, the additional terms will control for that conflict.
These terms control the relationship between Validactor and you. They do not create any third-party beneficiary rights.
If you do not comply with these terms, and we don’t take action right away, this doesn’t mean that we are giving up any rights that we may have (such as taking action in the future).
If it turns out that a particular term is not enforceable, this will not affect any other terms.

The courts in some countries will not apply EU law to some types of disputes. If you reside in one of those countries, then where EU law is excluded from applying, your country’s laws will apply to such disputes related to these terms. Otherwise, you agree that the laws of EU, ITALY, will apply to any disputes arising out of or relating to these terms or the Services. All claims arising out of or relating to these terms or the services will be litigated exclusively in the Italian court of Lucca (LU), ITALY, and you and Validactor consent to personal jurisdiction in this court.

The Services are provided by Validactor SRL (“Validactor”), headquartered in Lucca (LU) 55100, ITALY.

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