Privacy Policy

Blinkoo srl acts as the Data Controller of personal data when Users navigate its online platform “blinkoo,” accessible via browser or app (hereinafter, the “Platform”). The term “User” also refers to individuals who publish and share their own content (including “Creators”) after registering and creating a profile.

Please note that this Privacy Policy applies solely to Blinkoo srl’s Platform and does not concern other websites or apps, even if potentially referenced via links.

This privacy policy applies exclusively to the blinkoo Platform and does not extend to other websites or apps, even if referenced through links.

For any requests, communications, or to exercise your rights as a data subject, you may write to: privacy@blinkoo.com.

What types of data do we process?

We process personal data collected during registration on the Website/App, data entered for the purchase of products/services, and any subsequent data (personal details, company name, contact information, banking data, information regarding your social media profiles, websites, and online resources, tax data) that you provide to us either via the Platform’s features or through direct communications with our staff (via email, phone, chat, or messaging apps).

We also process data relating to navigation behavior on the Platform and other websites, including purchasing habits, geographic location, and the device used to access the Website/App, as well as the IP address. When you browse our Platform, you agree that our company may collect certain personal data such as technical data (e.g., IP address, browser type, computer information, data concerning the device you are using) and data collected via cookies or similar technologies (for more information, please refer to our Cookie Policy).

Why do we process your data?

1. To fulfill your request to activate the service and to perform it once established.

We process your data, at the time of your initial registration, to carry out pre-contractual measures at your request, and after your registration is complete, to perform the service agreement. In providing the service, your data will also be processed to verify its completeness, validity, and accuracy, to respond to inquiries and requests, and to send reminders, technical notices, updates, notifications, and administrative and support messages. Should you be a Creator, your data may also be shared with banks and payment institutions to process the fees provided for, as well as to fulfill legal, administrative, accounting, and tax obligations.

The legal basis for processing is therefore the performance of contractual services and compliance with a legal obligation.

2. To disclose your data to third parties that provide activities necessary for our company to deliver the service.

We need to share your data with third parties, both with professionals providing commercial and accounting consulting services to our company and with companies offering services related to the maintenance and use of the Platform (bodies coordinating, supervising, and managing national and international Internet networks, as well as hosting and storage service providers).

These processing activities may involve transferring data to non-EU countries. In such cases, Blinkoo srl adopts safeguards such as the execution of Standard Contractual Clauses.

The legal basis for these processing activities is the Data Controller’s legitimate interest in properly fulfilling its legal obligations and in providing the service correctly and on an ongoing basis.

3. To improve service delivery

We also process your data to ensure a better service and to enhance it through activities such as support, aggregated data analysis, fraud prevention, administrative, financial, or accounting tasks, surveys, and user satisfaction research. These processing activities are based on the Data Controller’s legitimate interest in improving and developing the service, and in cases provided for by law, you may object at any time.

4. For commercial offers and personalized services.

We process your data to enable us to send advertising, informational, promotional material, and exclusive offers (via email, SMS, mail, telephone) relating also to products or services other than those on the Website, including those offered by third parties, and to conduct market research. This objective is pursued:

• through direct marketing activities;
• through marketing activities that also use profiling data.

The legal basis for such processing is your consent, and for direct marketing for promoting similar products or services, the legitimate interest of the Data Controller in offering these types of products and services to its users.

Is it mandatory to provide data?

Providing data is optional but necessary for the requirements related to concluding and executing the contract. If the data subject refuses to provide the data, it will be impossible to proceed with the relationship and its proper performance.

Providing data for additional purposes is optional, and any refusal will not affect or prejudice the main processing but will simply make it impossible to carry out the additional activities mentioned therein.

Who are the parties involved in the processing

The data controller is blinkoo srl, headquartered at Via Pozzone n.5, Milan, Italy, VAT 10938230967. The company also appoints data processors and a Data Protection Officer (DPO) to oversee data security.

For any inquiries regarding your personal data, see the next section.

Contact information

Please remember that you can contact the DPO at any time and submit any question or request relating to your personal data and the protection of your privacy by writing to: privacy@blinkoo.com.

Parties to Whom Personal Data May Be Disclosed

The data collected in the context of providing the service may be disclosed to:

• Companies that perform tasks strictly related or instrumental — including technically — to the services, such as providers that supply services for carrying out advertising campaigns or that provide technical components for delivering some of the service’s functionalities;
• Administrative and judicial authorities and entities, as required by law;
• Other bodies and companies with which the Controller has entered into specific agreements to conduct some of the processing activities necessary to achieve the purposes set out above.

How is your data processed?

Data is processed in compliance with the security measures required by the GDPR (Art. 32), by means of IT, manual, and automated tools, and with procedures strictly related to the purposes.

Personal data is not used for the purpose of automated decision-making processes.

Your rights

Any individual who uses our service may:

• Obtain, at any time, from the Data Controller, information regarding the existence of their personal data, its origin, the purposes and methods of processing, and, if present, obtain access to the personal data and the information referred to in Article 15 of the GDPR;
• Request the update, rectification, or integration of the data, and its erasure or restricted processing under the conditions provided for in Article 18 of the GDPR, as well as its anonymization or blocking if processed unlawfully. This also includes data that does not need to be retained for the purposes for which it was collected and/or subsequently processed. Such requests may be made in writing to: privacy@blinkoo.com
• Object, wholly or in part, on legitimate grounds, to the processing of data, even if pertinent to the purpose of collection, and to the processing of personal data for purposes of commercial information, or for sending advertising materials, direct sales, market research, or commercial communications. Each data subject also has the right to withdraw consent at any time without prejudice to the lawfulness of processing based on consent prior to its withdrawal;
• Lodge a complaint with the Data Protection Authority in Italy (Garante per la protezione dei dati personali).

We remind you that for any questions or requests relating to your personal data and the exercise of your rights, you can write to the dedicated address indicated above.

Retention period

Data will be retained for the entire duration of the Service and/or contract. Subsequently, we will retain data required under civil and tax regulations for a period of ten years.

For direct marketing and profiling purposes, we will process your data — according to the consent you have provided — for no longer than the period allowed by applicable regulations (respectively, 24 months for direct marketing and 12 months for profiling). For the purpose of developing and improving the service and its functionalities, the personal data of active users may be analyzed and retained in aggregated and pseudonymized form for up to 36 months. Such data is confidential and for internal use only or in response to requests by judicial authorities.

Changes

It may be necessary to periodically update this Notice in light of ongoing changes affecting the technological environment.

We will inform you of any significant changes to the processing of data by providing notice on our Platform or through our usual communication channels.

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