Policy on mobile device identifiers

TooA S.p.A., in its capacity as Data Controller (hereinafter referred to as ‘TooA’ or ‘Data Controller’) pursuant to Art. 13 of the Regulation (EU) 2016/679 (General Data Protection Regulation, hereinafter the ‘Regulation’) provides you with the following information regarding the mobile device identifiers used in the TooA App (hereinafter the ‘App’).

What are 'mobile device identifiers'?

In order to provide you with an optimal experience through the App, TooA uses various mobile device identifiers, which may also involve tracking your activities in the App. ‘Mobile device identifiers’ are, by extension, all technologies that contribute to the achievement of specific purposes related to the App, such as App operation, performance analysis. In particular, these purposes can be achieved through a code executed within the App at server level and through related technologies (e.g. Software Development Kit - SDK, device identifiers). Cookies cannot be used in the App (as on websites), so, depending on the purpose, specific mobile device identifiers can be used instead of cookies, e.g. device or installation identifiers can be used to track your activity while using the App or to send you personalised messages.

What mobile device identifiers are used?

Strictly necessary mobile device identifiers are used to allow the App to function properly, so that you can easily enjoy the content and features offered. These mobile device identifiers cannot be deactivated and do not require your consent to be used.

Performance analytics identifiers are used to measure some of your actions while using the App. These mobile device identifiers are very useful for statistically analysing your accesses and activities in the App, in order to optimise its structure, navigation patterns and contents. These mobile device identifiers are not necessary for the operation of the App, so your consent is required for their use.

Below is a table containing all the information about the mobile device identifiers for performance analysis used in the app:

Mobile device identifiers for behavioural advertising (targeting identifiers) are used to track your navigation on the App, to analyse your behaviour for marketing purposes and to create a profile of your preferences, habits and choices. In this way TooA can deliver targeted advertising messages in relation to your interests and in line with your browsing preferences. These mobile device identifiers are not necessary for the operation of the App, so your consent is required for their use.

Below is a table containing all the information about the mobile device identifiers for behavioural advertising used in the app:

How do you manage preferences?

When accessing the App for the first time, you can decide which mobile device identifiers to enable. You can access your Account at any time and easily provide or withhold consent for the above purposes.

In addition to this, you can also change the settings on mobile device identifiers for advertising purposes via the device settings:

for iOS (Apple): select Settings > Privacy > Advertising > Restrict data collection. If you change any of the above information, you can consult the following information page: https://support.apple.com/it-it/HT205223.
for Android (Google): select Settings > Account or Sync or Google (depending on device) > Privacy or Advertising or Ads (depending on device) > Turn off Ad customisation. If you change any of the above information, you can consult the following information page: https://support.google.com/googleplay/android-developer/answer/6048248?hl=it.

How data may be communicated

The data collected using the aforementioned mobile device identifiers may be processed by employees and collaborators of the company departments responsible for pursuing the aforementioned purposes, who have been expressly authorised to do so and have received adequate operating instructions. This data may also be processed by trusted companies that carry out technical and organisational tasks on TooA's behalf. These companies act as Data Controllers.

Furthermore, data may be processed by external parties acting as autonomous controllers such as, for example, authorities and supervisory and control bodies. The data collected will not be transferred outside the territory of the EU.

Your rights

Using the contact data in the 'Contact us' section of this App you can contact TooA and ask to access your personal data, delete them, limit their processing in the cases provided for by art. 18 of the GDPR, and oppose their processing in the case of automated processing.

If the processing is based on consent or on contract and is carried out by automated means, you have the right to receive the data in a structured, commonly used and machine-readable format and, if technically feasible, to transmit it to another data controller without hindrance.

You also have the right to revoke the consent previously given to the mobile device identifiers mentioned above and this will not affect the operation and functionality of the App. Finally, you have the right to lodge a complaint with the Data Protection Authority (Garante per la protezione dei dati personali).

Personal Data Controller

The Data Controller is TOOA S.p.A., Reg. No. 02823780420, which can be contacted at the address of the head office: Via Giovanni Pascoli, 2, Fabriano (AN) Italy, or by e-mail: tooaspa@legalmail.it