Personal data regulation - GDPR adaptation
Last modified: 2020, the 12th of March
Thebrickplay.com is a set of "Services" ( from now "Services of Thebrickplay" or simply "Services" ), provided exclusivly online, either through proprietary website, application for mobile devices, registered authorized and accessible at official stores. Thebrickplay.com is provisioned and managed by the italian non profit organization SmartianS Associazione Sportiva Dilettantistica ( from now "Provider" as italian "Ente del Terzo Settore" alias Institution of Third Sector ). The Provider provides and manages online features, additional services and other products, including third parties. When you use, visit or buy on Thebrickplay.com ( from now the "Site" ), or when you use services or products Thebrickplay, install and make use of Thebrickplay's mobile applications or other Thebrickplay's software, in connection with any of the previous activities ( "Services of Thebrickplay" or simply "Services" ), you are subject to the knowledge of this information and related national and international rules. Thebrickplay Services are provided in compliance with current regulations and according to the following terms and conditions. Thebrickplay is the official name of all the "Services" you access once your unique and personal account is registered and validated.
The current legislation describes how to process information for the functionalities of Thebrickplay and Thebrickplay Mobile App and of the other products and functions offered by Thebrickplay ("Thebrickplay Services" or "Services"). You can find more tools and information in your Account or Your Profile settings. European law about GDPR.
TYPE OF INFORMATION COLLECTED
To provide the Thebrickplay Services, we need to process information about you. The type of information we collect depends on how you use the Services. You can find out more about how to access the information we collect and delete it by accessing the settings of Thebrickplay and Thebrickplay Mobile App.
Actions you and others take and items you provide. Information and content you provide.
We collect the content, communications and other information you provide when you use the Services, even when you create an account, create or share content and send messages or communicate with other people. Those data can be information present in the content provided or related to it ( such as metadata ), such as the location of a photo or the date on which a file was created. This also includes the elements displayed through the functions we offer, which allow us to perform actions such as suggesting masks and filters that you may like or give you advice. the Systems automatically process content and communications that you or others provide to analyze their context and content for the purposes described below.
Find out more about how to control who can see shared content.
Data subject to special protection: you can choose to provide information in the profile fields or in other requests for data entry or opinions regarding religious orientation, political orientation, "I like" option or your personal health. This and other information is subject to special protections under EU law.
Networks and connections.
We collect information about the people, pages, accounts and groups you connect with and how you interact with them on the Services, such as the people you connect with most often or the groups you belong to. If you choose to upload, sync or import contact information from a device ( such as an address book or call log or SMS log history ), we can use them to help you find other people you may know and for other purposes listed below.
How you use Thebrickplay.
We collect information on how you use the Services, what types of content you view or interact with, functions used, actions taken, people or accounts with which you interact and time, frequency and duration of activities. For example, we record the time and duration of the last use of the Services, as well as posts, videos and other content displayed on them. We also collect information on the use of our functions, such as the camera.
Information about transactions made in Thebrickplay.
If you use the Services for purchases or other economic transactions ( for example, in-app purchase or donations ), we collect information relating to these operations. This may be payment information, such as a credit or debit card number and other card information, other authentication and account information, and contact, shipping and billing information.
Activities performed and information about you provided by other people.
We receive and analyze content, communications and information that other people provide when they use the Services. This may be information about you, such as sharing or commenting on a photo, sending a message, or uploading, syncing or importing your contact information.
As indicated below, we collect information from and related to computers, mobile phones, smart TVs and other web-connected devices and combine this information on the different devices in use. For example, we use the information collected about the use of the Services on mobile to better customize the content ( including advertisements ) or functions displayed when using the Services on other devices ( such as laptops or tablets ) or to detect if an action has been taken in response to an advertisement shown on your mobile phone or other device.
The information we can collect from these devices includes:
Device attributes: information such as operating system, hardware and software versions, battery level, signal strength, available storage space, browser type, plug-ins and names and types of files and apps.
Device operations: information on operations and behaviors performed on the device, for example if a window is in the foreground or in the background or mouse movements (which help us distinguish users from bots).
Identifiers: unique identifiers, device IDs and other identifiers, such as those from games, apps, accounts used and possibly associated devices
Device signals: Bluetooth signals and information about nearby Wi-Fi access points, beacons and cells.
Data from device settings: information you allow us to receive via enabled device settings, such as access to GPS location, camera or photos.
Network and connections: information such as the name of the mobile operator or ISP, language, time zone, mobile number, IP address, connection speed and, in some cases, information on other devices nearby or on your network, to help you, example, to stream a video from mobile to TV.
Thebrickplay partner information.
Advertisers, app developers and publishers can send us information through types of tools such as, social plug-ins (eg the "Like" button), Mobile App, API and SDK or the Thebrickplay pixel. These partners provide information about your activities outside of Thebrickplay, including information about the device, websites you access, purchases made, advertisements displayed and how to use their services, whether you have an Thebrickplay account or not or who has whether or not you logged in to Thebrickplay. We also receive information about your actions and your online and offline purchases from third party data providers who have the right to provide us with your information. Partners receive your data when you visit or use their services or through third parties with whom they collaborate. Each of these partners is required to hold the legal rights to collect, use and share your data before providing us with any data. Find out more about the types of partners from whom we receive data.
How does Thebrickplay use the collected data?
We use the information in our possession ( subject to your choices and permissions ) in the ways described below and to provide and support the Services.
Supply, customization and improvement of the Services.
We use the information in our possession to offer the Services, for example to customize the functions and contents ( including the news stream, the announcements and the publication of events ) and to provide you with suggestions ( e.g. groups or events that could interest or topics you may want to follow ) inside and outside of the Services. To create personalized, exclusive and relevant services for you, we use connections, preferences, interests and activities based on the data collected and provided by you and other people ( including any data subject to special protection that you choose to provide in cases in which you have given us your explicit consent ), the way you use and interact with the Services and the people, places or elements with which you connect or that interest you, inside and outside of the Services.
Information on Services and devices: we connect information on the activities carried out on various Services and devices to provide a more personalized and consistent experience on all the Services in use, wherever you are. For example, we may suggest you join a group or report events. We can also make the experience more fluid, for example, by automatically filling in the registration information ( such as phone number ) from one of the Services when you register an account on any other Service.
Location information: we use location information, such as your current location, your place of residence, the places you love to visit and nearby businesses and people to provide, customize and improve the Services, including listings, to you and other people. Location-based information may be based on elements such as the exact location of the device ( if you allow us to obtain it ), IP addresses and information resulting from the use that you and other people make of the Services ( e.g. registrations or events you participate in ).
Research and development of the functionalities: we use the information in our possession to develop, test and improve the Services, carrying out surveys and researches and testing and solving the problems of new products and new functionalities.
Advertisements and other sponsored content: we use the information in our possession, including that relating to interests, actions and connections, to select and personalize advertisements, offers and other sponsored content to be shown to you. Provision of measurements, statistical data and other aggregate services.
We use the information in our possession ( including activities outside the Services, such as websites you access and displayed news ) to help our partners measure the effectiveness and distribution of their services and their advertisements and to understand the the type of people who use their services and how people interact with their websites, apps and services.
Promotion of security, integrity and protection.
We use the information in our possession to verify accounts and activities, combat harmful conduct, detect and prevent spam and other negative experiences, maintain the integrity of the Services and promote security and protection inside and outside the Services. For example, we use the data we have to investigate suspicious activities or violations of our regulations or conditions or to identify cases where people need help. To get more information, contact the support service.
Communication with you.
We use the information in our possession to send marketing communications, to provide information about the Services and our regulations and conditions. The information is also used to provide an answer when you contact us.
Research and innovation for the good of society.
We use the information we hold ( including information from the research partners we work with ) to carry out and support research and innovation on topics related to general social well-being, technological advances, public interest, health and well-being. .
How is information shared?
We share your information with others in the following ways:
Sharing within the Services.
People and accounts you share and communicate with.
When you share content and communicate using the Services, you are the one who chooses the audience for the elements you share. For example, by publishing items, you select the audience of the post, for example a group, all friends, all or a personalized list of people. Your network can also view the actions you take on the Services, including interactions with adverts and sponsored content.
Public information can be viewed by everyone, inside and outside of the Services, even if you don't have an account. This includes user name, publicly shared information, public profile information about Thebrickplay and content shared on an Thebrickplay Page, such as Thebrickplay Marketplace. You, other members, and we may provide access to or send public information to anyone within or outside of the Services, including search results or through tools and APIs. You can also view, access, reshare or download public information through third party services such as search engines and APIs, offline media such as TV and through apps, websites and other services integrated with the Services.
Content that people share or re-share about you.
You must evaluate the people you choose to share content with because those who can see your activities on the Services can also share them with others inside and outside the Services, including people and companies outside the public with whom you shared the content. For example, by sharing a post or sending a message to specific friends or accounts, they can download, take a screenshot or share that content with others inside or outside of the Services, personally or through avatars or automatic programs. Additionally, post comments and reactions added to others' content are visible to anyone who can view the other person's content, who can subsequently change the audience.
People can also use the Services to create and share content about you with an audience of their choice. For example, people can share a photo of you in a story, mention or tag you in a place within a post, or share information about you in their posts or messages. If you feel uncomfortable with the elements that concern you shared by others on the Services, you can report the contents and subjects involved.
Information on active status or presence on the Services.
People in your networks can view signs indicating your activity on the Services, including your current activity or the last use of the Services.
Apps, websites and third party integrations on the Services or that make use of them.
When you choose to use apps, websites or other third party services that use or are integrated with the Services, they may receive information on what you publish or share. For example, when you play or use the Comment or Share button on a website, the game developer or website may get information about your activities within the game or receive a comment or link that you have shared from the website. Furthermore, when you download or use these third party services, they can access your public profile on Thebrickplay and the information you share with them. The apps and websites you use may receive your friends list on Thebrickplay if you choose to share it with them. However, the apps and websites you use will not be able to receive any other information about your friends from you ( although your friends and followers may, of course, choose to share this information yourself ). The information collected by these third party services is subject to their conditions and regulations, not ours.
The devices and operating systems that provide any native versions of Thebrickplay ( for which we have not developed our own apps ) will have access to all the information you choose to share with them, including the information that your friends share with you, so we can provide you with our main features.
Note: since your approval is always necessary, we advise you to check what you share and what you approve in case you have the doubt of not being within our authorized services. To request other data, our approval will be mandatory. For example for requests related to investigations of any kind as long as any type of request is received officially and with an explicit judicial act.
If ownership or control of all or part of the Services or related resources changes, we may transfer your information to the new owner.
Sharing content with third party partners.
We collaborate with third party partners who help us provide and improve the Services or who use the tools of the Thebrickplay marketplace. It is understood and clear that your personal information is not sold to anyone, neither now nor in the future.
Examples of types of partners with whom we share information:
Partners who use the Statistical data collection services.
We provide aggregate statistical data that helps people and companies understand how people interact with their posts and other content, inside and outside the Services. For example, Page administrators receive information on the number of people or accounts that have viewed, added a reaction or commented on their posts, as well as aggregated demographics and other information that helps them understand interactions with their Pages or their accounts.
We provide advertisers with reports on the interactions with their activities within the Services, without allowing your identification, unless your authorization.
We share information with companies that aggregate it to provide statistical data and measurement reports to our partners.
Partners offering products / services / reservations within the Thebrickplay marketplace.
When you sign up to receive exclusive content or purchase a product / service / booking from a seller in the Services, the content creator or seller may receive your public information and other information you share with him, as well as the information necessary to complete the transaction, including payment details, possible shipment and contact.
Suppliers and service providers.
We provide information and content to suppliers and service providers that support our company, for example, by providing technical infrastructure services, analyzing how the Services are used, providing customer support, simplifying payments or conducting surveys.
We also provide information and content to search partners to conduct research designed to study improvements and the addition or modification of functionality within the Services.
What are our legal bases for data processing?
We collect, use and share the data we hold in the manner described above:
in a manner consistent with the consent granted, which can be revoked at any time through the settings from the page of your profile or account;
as necessary to comply with our legal obligations;
to protect your vital interests or those of others;
as necessary for the public interest;
as necessary for legitimate interests ( commercial or disclosure ), unless the interests or fundamental rights and freedoms of the data subject that require the protection of personal data prevail over these interests.
How to exercise the rights provided by the GDPR?
The General Data Protection Regulation recognizes the right to access, correct, transfer and delete your data. The right to oppose and limit certain processing of their data is also recognized. This includes:
the right to object to the processing of your data for direct marketing, which can be exercised through the unsubscribe link contained in these marketing communications;
the right to object to the processing of your data when we carry out an activity in the public interest or in the pursuit of the legitimate interests of Thebrickplay or third parties.
Data retention, deactivation and deletion of the account.
We store data as long as it is necessary to provide the Services or until the account is deleted, whichever occurs first. This is a case-by-case determination that varies based on elements such as the nature of the data, why it is collected and processed and relevant legal or operational retention needs. For example, when you search for something, you can access and delete that request from ythe Search history at any time, but the log of this search will be deleted at different time intervals. If you send a copy of an official ID for account verification, the copy will be deleted after 30 days of submission.
When you delete your account, we delete items you have published, such as photos and status updates, and you will no longer be able to recover this information. The information that other people have shared about you is not part of your account and will not be deleted. To delete your account at any time, proceed with the settings from your profile page.
How do we fulfill legal requests or avoid damages?
We access, store and share information with regulatory bodies, law enforcement agencies or other entities in these cases:
In response to a legal request if we believe in good faith that the law requires us to do so. We can also respond to legal requests if we believe in good faith that what is made mandatory by the law of the jurisdiction in question, concerns users who respond to that jurisdiction and that it complies with internationally recognized standards
If we have reason to believe that it is necessary to detect, prevent and resolve unauthorized use of the Services, violations of our terms or regulations or other harmful or illegal activities, to protect ourselves (including our rights, properties or Licenses), you or others, also in the context of investigations or regulatory requests or to prevent death or imminent physical injury. For example, if relevant, we provide information to third party partners and receive it from them regarding account reliability to prevent fraud, abuse or other harmful activity inside and outside of the Services.
The information we receive ( including financial transaction data ) may be consulted and stored for an extended period of time when it is the subject of a proceeding or legal obligation, a government investigation or investigation into possible violations of our terms or regulations or to avoid damage.
How do we manage and transfer data within our global services?
We share information worldwide, with our partners and with the people you connect with and share content all over the world, in compliance with this regulation. The information controlled by Thebrickplay could be transferred or transmitted or stored and processed in Italy or in other countries outside the one where you reside for the purposes described in this regulation. The transferred data are necessary to provide the services described in the Thebrickplay Terms & Conditions and to manage and offer the Services globally. We use standard contractual clauses approved by the European Commission and based on the adequacy decisions of the European Commission for some countries, as appropriate, for data transfers from the EEA to the United States and other countries.
How will we inform you in case of changes to this regulation?
We will notify you before making changes to this policy and will allow you to read the amended policy before choosing whether to continue using the Services.
How to contact Thebrickplay with any questions
You can get more information on how privacy works on Thebrickplay. If you have questions about this regulation, contact us in the manner described below. We can resolve disputes that arise in connection with our privacy practices and regulations through the Support service.
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Our contacts : SmartianS Associazione Sportiva Dilettantistica - Non-profit Organization. (“SASD-npo”), President Mr Angioni Roberto. VAT n.: IT10955390017
For any information refer to the official website www.smartians.org
Legal and administrative residence
Verolengo (TO), vicolo San Rocco 3, 10038, Italy, Europe
Imperia (IM), vico Castello 4, 18100, Italy, Europe