Privacy Policy in App

CUSTOMER_PRIVACY

BAZR S.P.A.

PRIVACY POLICY

Last updated: 31/05/2024.

We at Bazr S.p.A. (hereinafter also referred to as “Bazr”, “we”, “us” or “our”) respect and protect the privacy of non-professional users who register on the platform (hereinafter referred to as “Users”), of registered sellers who are acting through the platform in the exercise of an entrepreneurial, commercial, handicraft or professional activity (hereinafter referred to as “Vendors”) and of Users, natural and legal persons, who operate on the platform with a significant presence on social media or other online platforms (hereinafter referred to as “Creators”).

In accordance with the provisions of European Regulation 2016/679 (hereinafter “GDPR”) and the national harmonizing legislation, Legislative Decree 196 of 2003 as amended and supplemented (hereinafter referred to as the “Privacy Code” and, jointly with the GDPR, the “Privacy Statement”), this information notice on the processing of personal data (hereinafter referred to as the “Privacy Policy”) describes – pursuant to Art. 13 and 14 of the GDPR – how we collect, use and share personal data of Users when they register for, access or use our “Services” (further detailed and available in the terms and conditions of service accessible herein and hereinafter also referred to as the “T&Cs”), via the Bazr mobile app (hereinafter referred to as the “App”).

We consider it of central importance to inform you fully about the processing of your personal data and, therefore, we invite you to read this Privacy Policy in its entirety, the salient points of which and some useful links are given below for ease of reading:

• our aim is to create a virtual space where supply and demand of products and services, sharing of social experiences and opinions meet (hereinafter the “Marketplace” or “Platform”). If you do not wish for your personal data to be collected and processed as described in this Privacy Policy, or if you are under 16 years of age, please stop the registration process on the Platform or, if you are an already registered User, stop accessing and using our Services by requesting the deletion of your profile and personal data in the manner indicated in Section 6;
• we collect and process your personal data in order to provide and improve our Services and your experience on the Marketplace as well as to ensure the security and integrity of our Platform and to comply with our legal obligations. To find out more, please see Section 1. “What data we collect and why we process it”;
• we share your personal data with carefully selected third parties and suppliers in order to provide our Services and to comply with our legal obligations. To learn more, please explore Section 2. “How and Why We Share Your Data”;
• we have tools that enable you to exercise your rights under the Privacy Statement to request access, rectification, deletion, restriction and objection to the processing of your personal data in our possession. If you have any questions about this Privacy Policy or your rights, you can contact us at [email protected]. For more information, please see Sections 6. “Your rights and choices regarding privacy” and 7. “How to contact us”.

Index

1. WHAT DATA WE COLLECT AND WHY WE PROCESS IT
2. HOW AND WHY WE SHARE YOUR DATA
3. HOW LONG WE KEEP YPUR PERSONAL DATA
4. PERSONAL DATA OF MINORS
5. INTERNATIONAL TRANSFERS
6. YOUR PRIVACY RIGHTS AND CHOICES
7. HOW TO CONTACT US
8. COMPANY VICISSITUDES
9. THIRD-PARTY WEBSITES AND SERVICES
10. CHANGES TO THE PRIVACY POLICY

1. WHAT DATA WE COLLECT AND WHY WE PROCESS IT

We collect and process your personal data in order to create, provide, customise, manage, improve and develop our Services in order to offer you a safe, interactive, efficient and personalised experience. The following details the reasons for which we process personal data (i.e. the purpose of the processing), the legal grounds for such processing, the details of your personal data being processed and the origin of such personal data. 

1. Processing of personal data necessary for the performance of the contract to which the User is a party

The personal data processed for the purposes listed below are necessary for the proper provision and use of the Services, as governed by the T&Cs and accepted by the User at the time of registration. Failure to provide Bazr with such personal data would make it impossible for the User to use the Platform Services. Bazr has identified the legal basis of the processing in Article 6, paragraph (1), letter (b) of the GDPR.

Why we collect your personal data

What personal data we collect

Where we collect your personal data

Platform registration and account creation.

Basic information required to register on the Platform and create an account: first and last name, date of birth, nationality, telephone number, e-mail address, username and password.

Information provided by you.

Collection of additional and optional information for customising the User’s profile.

Profile picture, home address.

Information provided by you.

Communication of data to the Vendor for the purpose of brokering the activity of buying and selling through the Platform (e.g. allowing the Vendor to manage the phases of invoicing for the product purchased by you, shipping, etc.) as well as the activities subsequent to the same (e.g. chargeback procedures, return, withdrawal and return of products under warranty) and the related issue of the receipt.

Information necessary for the intermediation of the buying and selling activity through the Marketplace as well as the activities following the same (e.g. return procedure, withdrawal procedure, etc.): first name, last name, residential address, payment card number, expiry date, CVC, billing address and bank account (the personal data listed will not be collected and processed by Bazr in the case of using third-party purchasing systems – e.g. Apple Pay). 

Information contained within your request for chargeback, return, withdrawal and return of products under warranty.

Information required for invoicing and dispatch of products by the Vendor: name and surname, residential address, any further information deemed necessary (delivery instructions etc.).

Information provided to us by you and third parties.

Publishing content on the Platform.

Publishable content: images and videos.

Information provided by you.

Interactions, live chat and comments to content on the Platform.

Live chat, comments and reviews: username, profile picture and information entered in the commentary.

Information provided by you.

Indexing of Platform content in relation to interactions and ways of using in-app Services.

Activity information, i.e. information about what you view, clicks, likes, follows of the user with the sole purpose of indexing content.

Automatically collected information.

Informative in-app warning regarding content or Creators that the User has requested to follow via the “notify me” function.

Information for sending e-mail notifications and in-app alerts (according to the settings and notification mode preferences indicated by the User in the profile section of the App): username, e-mail, first and last name.

Information provided by you.

In-app and/or e-mail notification regarding Vendor’s product and service purchase orders and their fulfilment status.

App registration and administrative notifications as well as announcements of changes to the App, the T&Cs, this Privacy Policy or other legal documentation by e-mail and/or in-app notification.

Management of customer care services and related notifications and alerts by e-mail.

Customer service management information: username, description of the problem encountered on the Platform, e-mail.

Information provided by you.

Handling of reports of violations of Bazr policies.

Information necessary for the handling of reports of policy violations published on Bazr’s website [●] (hereinafter, the “Website”) and accessible via the App, such as information relating to conduct in breach of the T&Cs and all Bazr policies, and in particular of (i) non-payment (ii) providing false data during the registration process; (iii) making the account available to unauthorized third parties; (iv) publishing commercial advertisements in breach of the T&Cs; (v) registering multiple accounts and using them in breach of the T&Cs; (vii) sending spam messages to other Users.

Information provided by you.

Checking for violations of Bazr policies and issuing possible measures (such as warnings or account suspensions).

Information we obtain from third parties.

1. Processing of personal data to fulfil legal obligations on Bazr

Bazr is subject to laws and regulations that require it to collect, use and store your personal data in certain ways. Failure to provide Bazr with such personal data would result in your inability to use the Platform Services. Pursuant to Article 6, paraghraph (1), letter (c), of the GDPR, the legal basis of the processing operations listed below is the performance of a legal obligation incumbent on Bazr.

Why we collect your personal data 

What personal data we collect 

Where we collect your personal data

Handling of reports of violations of applicable regulations.

Information necessary for the handling of cases of violations of applicable law (e.g. resulting from content monitoring carried out as required by law).

Information provided by you.

Checking for violations of legal and regulatory obligations and issuing possible measures (such as warnings or account suspensions).

Information we obtain from third parties or collected automatically

Fulfilment of legal obligations of an accounting and/or tax nature.

Information relating to tax and/or accounting obligations: any information necessary for Bazr to fulfil its legal and tax obligations.

Information provided by you.

1. Processing of personal data for legitimate interests of Bazr

Following a careful balancing act, we have ascertained that your rights and freedoms are not overridden or in any way even potentially limited and/or adversely affected by the processing activities described below. In light of this, the legal basis on which we will base the processing of your personal data in the cases described below is the pursuit of our legitimate interest, pursuant to Article 6(1)(f) of the GDPR.

Why we collect your personal data 

What personal data we collect 

From whom/where we collect your personal data

Possible processing of personal data for purposes of legal defence.

Information concerning the protection of the right to legal defence: information necessary for the purpose of activating or permitting the defence of Bazr in the judicial and extrajudicial context.

Information provided by you.

Platform and Marketplace security maintenance and fraud prevention activities.

App and device information: information about the device and operating system you use; other device characteristics or identifiers (e.g., plugins, the network you connect to); IP address. Diagnostic and Troubleshooting Information: information about the performance of our Services when you use them, i.e. diagnostic and performance information about the Service, crash data, App performance logs, and error messages or reports.

Automatically collected information.

Analysis for the purpose of improving the Platform and Services.  

App and device information: information on the device and operating system used; other device characteristics or identifiers (e.g. plug-in, network connected to); IP address.

Automatically collected information.

1. Processing of personal data on the basis of your consent

Bazr will process your personal data for the purposes described below only and exclusively following your specific, free and informed consent. You may revoke your consent at any time in the manner described in Section 6 of this Privacy Policy. In light of the foregoing, the legal basis for the processing described below is your prior, specific and informed consent, pursuant to Article 6, paraghraph (1), letter (a) of the GDPR. The provision of your personal data for the purposes described below is optional and your refusal to provide it will make it impossible for Bazr to pursue these purposes but will not affect your ability to use our Services.

Why we collect your personal data 

What personal data we collect 

From whom/where we collect your personal data

Profiling aimed at proposing via e-mail and/or in-app content related to the interests and preferences expressed on the Platform by the User.

Information used for profiling the User: name and surname, date of birth, nationality, telephone number, e-mail address, username, home address, activity information, i.e. information on what you view, clicks, likes, follows of the User.

Information provided by you as well as automatically collected.

Request for in-app surveys and customer satisfaction feedback on the Platform and the products and/or services offered therein.

Information provided by the User in response to surveys and customer satisfaction feedback requests.

Information provided by you.

Transfer of your contact details to the Vendor so that the latter can contact you to promote its products and services.

Information given by Bazr to the Vendor, at the request of the User following expression of interest (i.e. consent) regarding a Vendor product, to enable the User to be contacted by the Vendor: username, first name, last name, e-mail, telephone number.

Information provided by you.

Geolocation of the device.

Location of the User’s device.

Information collected automatically after the user has enabled the relevant functionality on the device.

Commercial sponsorship through e-mail communication of content on Bazr (e.g. live) and/or Vendor products/services.

Information for sending e-mail notifications and in-app alerts: username, e-mail, first and last name.

Information provided by you.

1. Processing of anonymized data

Anonymized data is information that, through a data processing technique, is altered in such a way that it cannot be correlated with an identified or identifiable natural person. The GDPR does not apply with regard to the processing of such anonymized data.

Bazr may use anonymized or aggregated data for different purposes, such as for business purposes, including better understanding the needs and behavior of the User base, improving the Platform, conducting business intelligence and marketing activities and detecting security threats.

Please note that, with the exception of this Section, none of the other provisions of the Privacy Policy apply to anonymized and/or aggregated data.

• HOW AND WHY WE SHARE YOUR DATA

1. We communicate some of your personal data to Vendors

The personal data we process and collect may be transferred to third parties registered on our Platform with the Vendor account. In particular, Bazr will disclose your personal data to the Vendor:

• when purchasing a product and service so that the latter can carry out the necessary order management activities (e.g. invoicing, shipping, etc.).
• if you give your consent for the latter to contact you to promote its products and services. 

For such processing activities, the Vendors shall act as autonomous data controllers.  

1. We also disclose your personal data to other parties

Bazr cooperates with and uses carefully selected service providers, partners and other third parties who support us in providing our Services. For this reason, we may share certain information about you with such third parties.  In particular:

Privacy role of the subject

Types of third-party suppliers with whom we collaborate 

What data we share

We work with suppliers who support us in providing our Services. When we share information with such providers we ensure that they process your personal data in accordance with our instructions and terms.  These parties act in the role of data controllers within the meaning of Article 28 of the GDPR. To obtain a full list of data controllers you can write to [email protected].

• Marketing and promotion service providers.
• Suppliers of telecommunications technology.
• Security service providers (for investigation of fraud and security incidents).
• Providers of tracking and analysis services of in-app User behaviour (to understand how you use our Services).
• Document storage service providers.
• Providers of ticketing systems, chatbots and customer support.

Basic information about the User, additional identifying information, information about the use of the Platform, information about transactions, additional information provided by you.

Third parties acting in the role of autonomous data controllers.

• Payment processing service providers;
• Judicial and police authorities.

• HOW LONG WE KEEP YOUR PERSONAL DATA

We retain your personal data as necessary to provide our Services, comply with legal obligations or protect our interests or those of others. Bazr has adopted internal retention policies that set out the timing and method of retention for all processing of personal data, taking into account, for example, the need for processing to ensure your proper use of our Services, the fulfilment of any legal obligations requiring us to retain your personal data, or the need to retain your personal data to ensure the security, safety and integrity of our Services.

In line with these considerations, we set out below the retention period of personal data in relation to the purposes listed above: 

• for the purposes set out in Section 1.a, your personal data will be kept for as long as is necessary for the proper provision of the Services or until your account is deleted by you. If you do not access your account on the Platform for a continuous period of more than 24 months, Bazr will proceed to delete your profile;
• for the purposes set out in Section 1.b and 1.c, your personal data will be kept in accordance with the applicable regulations for a period of time not exceeding the time necessary to achieve the purposes for which they are processed;
• with reference to Section 1.d, your personal data will be stored for the purpose of:
  • “Profiling aimed at proposing via e-mail and/or in app content related to the interests and preferences expressed on the Platform by the User”, for a period of 12 months from the collection of consent;
  • “Request for in-app surveys and customer satisfaction feedback on the Platform and the products and/or services offered therein”, for the time required to process the User’s answers;
  • “Transfer of the User’s contact data to the Vendor so that the Vendor can contact you to promote its products and services”, for the time necessary for the transfer of the contact data to the Vendor;
  • “Geolocation of the device”, until the user deactivates this setting on the device;

• “Commercial sponsorship through e-mail communication of content on Bazr (e.g. live) and/or Vendor products/services”, 24 months after consent collection. 

1. PERSONAL DATA OF MINORS

Except for Services related to brokering the purchase and sale of products and/or services, which are aimed at persons under the age of 18, the App and Services are not aimed at persons under the age of 16 and we do not knowingly solicit or collect any information about persons under the age of 16. Despite Bazr’s efforts to monitor and prevent the registration of such Users, we cannot guarantee that there will be no registered Users under the age of 16. If we suspect that you are under 16 years of age, we will ask you for further proof of your age and, if you do not respond or if we determine that you are under 16 years of age, we will immediately suspend your account and subsequently terminate and delete your personal data.

If you are the exercising parental responsibility for a User under the age of 16 years registered on the Platform, please write to [●] so that we can immediately proceed with the suspension and subsequent closure of the account and the deletion of personal data.

1. INTERNATIONAL TRANSFERS

Bazr informs you that your personal data may also be transferred to countries outside the European Union or the European Economic Area (so-called Third Countries) recognised by the European Commission as having an adequate level of protection of personal data or, if not, only if an adequate level of protection of personal data with respect to that of the European Union is contractually guaranteed by all Bazr suppliers located in the Third Country (e.g. by signing standard contractual clauses provided by the European Commission) and that the exercise of your rights is always ensured.

1. YOUR PRIVACY RIGHTS AND CHOICES

In relation to the processing of personal data, you are entitled to exercise your rights under Articles 15 to 22 of the GDPR. In particular, you have the right, where applicable and under the conditions and in the manner provided by the GDPR, to exercise: 

• the right of access, i.e. the right to request access to one’s personal data and to information on the purpose of the processing, the categories of personal data processed, the subjects or categories of subjects to whom the personal data are or could be communicated, when possible, the storage period of the personal data, or, the criteria used to determine this period, the existence of the right to rectification and/or erasure of personal data, to restriction of processing and to object to processing, the right to lodge a complaint with the supervisory authority, the origin of the data, the existence of an automated decision-making process. Should you exercise this right, Bazr will provide an electronic copy of your personal data (Art. 15 GDPR); 
• the right to rectification of personal data where these are incomplete or inaccurate (Art. 16 of the GDPR); 
• the right to erasure where one of the following conditions exists: (i) personal data are no longer necessary for the purposes for which they were collected, (ii) revocation of consent – where this is the legal basis for the processing, (iii) objection to processing without a legitimate interest of Bazr prevailing, (iv) unlawful processing of personal data and (v) obligation to erase in order to comply with a legal obligation under Union or national law (Article 17 GDPR); 
• the right to restriction of the processing of personal data when: (i) the accuracy of your personal data is contested, for the time necessary for Bazr to verify that accuracy, (ii) the processing is unlawful and, instead of erasure, restriction of the processing is requested, (iii) when Bazr no longer needs to process your personal data but you yourself need it for the exercise or defence of a legal claim, and (iv) you have objected to the processing pending verification of whether Bazr’s legitimate grounds prevail over your fundamental rights and freedoms (Art. 18 of the GDPR); 
• the right to the portability of personal data and, therefore, to receive personal data in a commonly used, machine-readable and interoperable format, including for the purpose of transmitting them to another data controller, where the processing is based on consent or is carried out by automated means (Art. 20 GDPR); 
• the right to object to the processing of personal data where such processing is carried out pursuant to Article 6, paragraph (1), letter (e) (performance of a public task entrusted to Bazr) or Article 6, paragraph (1), letter (f). (legitimate interest of Bazr) of the GDPR unless Bazr is able to demonstrate compelling legitimate grounds for processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims (Art. 21 of the GDPR).

If you consider that the processing of personal data concerning you is in breach of the GDPR, you also have the right to lodge a complaint with the Data Protection Authority pursuant to Article 77 of the GDPR, following the instructions that are published on the official website of the Data Protection Authority (www.garanteprivacy.it). 

1. HOW TO CONTACT US  

The data controller is Bazr S.p.A. (Vat Number 17122741006), with registered office in Viale Bruno Buozzi, 64, 00197, Rome, Italy.

If you have any questions or concerns regarding this Privacy Policy, or wish to exercise any of the rights described above, or if you have a complaint, please contact us at [email protected].

1. CORPORATE VICISSITUDES

In the event that Bazr is acquired by or merged with another company, transfers some or all of its assets to a third party, or in the event of bankruptcy or dissolution of the business, your personal information may be transferred to an acquiring company or third party, including in anticipation of or in connection with the due diligence required for such business transactions, subject to the limitations and safeguards of applicable law. In any event, you will be promptly informed of any business disruption so that you can decide whether to proceed with the termination of your profile or to continue using the Services.

1.  THIRD-PARTY WEBSITES AND SERVICES

While using the Platform you may come across links to third-party websites and services. This Privacy Policy does not refer to any processing of personal data carried out by such third parties. Bazr has no control and responsibility over the processing of personal data that may be carried out by third parties through their websites and/or services. For more information on the processing carried out by third parties, please refer to their privacy policy.

1. CHANGES TO THE PRIVACY POLICY

We are constantly trying to improve our Services, so we may also need to change this Privacy Policy from time to time by posting any changes on this page and, where appropriate, we will provide you with reasonable notice of any material changes before they become effective or as otherwise required by law. The date this Privacy Policy was last updated is indicated at the top of this page.