YEPPIK™ PRIVACY POLICY

1. SOME BASIC INFORMATION

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The applicable legislation, with particular reference to Regulation (EU) No. 2016/679 (General Data Protection Regulation, 'GDPR'), Legislative Decree. 196/2003 (the 'Privacy Code') and the relevant measures, decisions and guidelines issued by the Italian Data Protection Authority (collectively, the 'Privacy Legislation'), identify various figures who must - or sometimes simply may - come into the picture, taking part in data processing operations, with different roles and responsibilities based on the degree of involvement and discretionary power they may exercise with respect to how and why they process your data.

Other actors can also come into play with a supporting - albeit fundamental - role vis-à-vis the data controller. The Privacy Law in fact allows the latter to delegate one or more specific processing activities to external service providers, provided that they are reliable, called 'data processors', who may act exclusively on behalf of the data controller and within the limits of the written instructions provided by the latter.
Please note that by 'personal data' we do not mean only those that allow your immediate identification (e.g. first and last name), but also those that, in combination with other information available to us or to third parties, would allow us to recognize you (e.g. your social security number or the IP address of the device you used to access the Application).

2. What personal data we process and how we collect it

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The use of our Application and Services involves the collection and processing of personal data.
The categories of personal data collected are indicated in the following paragraphs. Some information is necessary to register you with the Application (your telephone number, date of birth and personal password), other information is only requested if you decide to use certain additional Services or to activate certain advanced features. Finally, there are data that you can freely choose to provide us, without this being necessary to use the Services offered by the Application (for example, the photo to associate with your account).
As for the sources of your personal data, some information is provided directly by you (for example, in order to create a YEPPIK account and use the related Services, you must necessarily provide us with your phone number and date of birth and set a password). Other personal data is automatically collected when you interact with us through the Application (for example, your device's IP address or personal data collected through cookies and other processing technologies).

2.1 Data provided directly by the user

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Some personal data is provided to us directly by you. With the exception of your telephone number and date of birth, which are essential for the creation of a YEPPIK account, the type of personal data you choose to share with us depends on the way you intend to use the Application and the features you decide to activate.
Such data include:

Account information

In order to use YEPPIK, you must create your own personal account ('User ID'). When registering, you will only be asked to provide us with your mobile phone number and date of birth and to create your own personal password. These are the only details that are essential for us to allow you to interact with us through the Application. Once you have entered this information, we will immediately send you a security code via SMS to verify your phone number and ensure that it was you who requested the account to be created.
In order to create your User ID, we do not need any other information from you. For example, you do not need to provide us with your email address, your first and last name, or your residential address. You decide whether you want to share this information with us, either during registration or while using the Application and Services. You may update and customize your profile at any time directly from your account by accessing the 'Personal Information' section.
For example, you will be able to enrich your profile with a photo, a nickname, or a brief description of yourself, other than to show when you are active in the app.

Gallery and contacts

You can choose to give us permission to access the contacts in the address book of your personal device to connect more easily with your YEPPIK friends.
Similarly, you are free to choose whether or not to give us permission to access media content in your device's gallery, for example if you want to select a photo to associate with your account.

Conversation data

While using the Application, we will collect data from conversations you have with other YEPPIK users. These include, but are not limited to, text messages, photos, PDFs, documents, audio, video or other media content, even included in the same text message.
The conversations will be temporarily stored in our databases, but always under the supervision of technical and organizational measures to ensure the security and confidentiality of data, especially in order to reduce the risk of destruction or loss, even accidental, of the data, unauthorized access, or processing not allowed or not in accordance with the purposes of collection, but also in order to allow you to view them when logging in from another device.
When you type a message in a chat with another YEPPIK user, we will use the preview of the unsent message to suggest you yeppiks from our Store: they are simple tags appearing on the virtual keyboard of your device in the form of stickers, while you are typing text, according to the meaning of the words you are typing in the text box.
You decide whether to share other personal information with us, depending on the features you choose to enable, or through our customer support contact form.

Microphone and voice messages

You can choose to give us permission to access your personal device microphone, in order to send voice messages during your conversations with other YEPPIK users.
Voice messages are stored in our databases, but always under the supervision of technical and organizational measures to ensure the security and confidentiality of data, like any other conversation data.

Notifications

You can receive push notifications from the Application related to our Services, for example, we could send you notifications in case system updates become available, or in case our General Terms and the present Privacy Policy receive any update, other than notifications triggered by our core functionalities.

Service and support

You can contact us at any time using the Contact form at www.yeppik.com.
When you contact us for assistance or to receive information about the operation of our Services, we will collect your email address and other details, including personal information, that you choose to share to help us respond to your requests.
Please do not send us any personal information through this channel that is not strictly necessary to fulfill your request. It is understood that, in this case, any processing of such personal data will be the exclusive consequence of your choice to share them with us within the above mentioned conversation.

Feedback

At any time, you can voluntarily send us your feedback on our Services. Simply access the 'Support' section of your account and fill out the form in the 'Contact us' sub-section. For example, you can send us reports about any bugs or technical problems you have encountered while using the Application. We will only collect the data that you choose to include in the report (including, for example, any screenshots), as well as your e-mail address and the phone number you used to register with YEPPIK. We will automatically collect some information about the type of device you are using and the operating system you are using. We will use this data exclusively to manage your report, including possibly making contact with you, and to improve our Services.

In app purchases

When you choose to acquire contents sold from the Store or from your contacts, you will need to purchase our coin packs from the Apple Store or the Google Play Store.
In order to complete the payment steps or to handle refunds, those platforms share data with us (e.g. transaction ID, purchase date and the amount you paid).
We will keep track of contents you are going to acquire as well, in order to guarantee that any functionality involving them will work correctly.

Rewards

In the Profile section of the Application, you can earn coins from selling your yeppiks. We will keep track of the coins you earn in order to carry out your reward requests. When you choose to redeem your earnings asking for a reward, you will have to provide us with a valid e-mail address, which we will use to contact you and ask you any necessary information to proceed with the payment.

2.2 Data acquired automatically when using YEPPIK

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We have designed and set up the Application and our Services in such a way as to minimize the collection of user data, minimizing the processing of personal data to what is strictly necessary to achieve our purposes. However, when you use our Services, we automatically collect certain information through your device.
This category of data includes:

Navigation data

The computer systems and software procedures in charge of operating the Application, during their normal operation, automatically acquire certain information from your device when you access YEPPIK or use the related Services via mobile (smartphone).
This data includes, for example: the internet protocol (IP) address when you connect to YEPPIK, the time of the request and the method used to submit the request to the server; the numerical code indicating the status of the response given by the server (e.g. successful, error, etc.); the country you connected from; the version of the Application; the country you are connecting from; the type of browser you are using and the name of your internet service provider (ISP); the type of device used to access the internet, the operating system (iOS, Android) and other parameters and information related to your device and computer environment; the various temporal connotations of the visit, such as the time spent on each page of the Application and details about the itinerary followed within the relevant pages.
This is information whose transmission is implicit in the use of communication protocols with YEPPIK, and which is automatically collected to manage and optimize the use of the Application and its Services. Therefore, this information is not collected in order to be associated with identified individuals, but by its very nature could, through processing and association with other information, also held by third parties (in particular, third party providers of Internet connectivity services), allow your identification.

Data collected through cookies

We use cookies and other similar tracking technologies ('Cookies') to enable you to login to the Application and use our Services.

Application Usage Information

We collect information about how you use our Application and Services, such as what type of content you view on your status, how long you stay on the Application and how often you use it, what time you send and receive messages.

2.3 Data collected through other sources

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Sometimes, YEPPIK users themselves may provide information about you. For example, we may receive reports from other users about your alleged unlawful use of the Application or our Services (for example, you may report to us that you are using the Application to find out against the law or our Terms of Service). Your report may also include screenshots of conversations you have had with you or any other information you feel you would like to share.
Similarly, by giving us permission to access the contacts in your address book, we may collect data from another YEPPIK user (such as the name and surname with which you registered him/her in your address book) in addition to the data that the latter has chosen to associate with his/her personal account, and vice versa.

3.0 For what purposes we process your data and what gives us the right to do so

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Control over what can be done with your data is and should remain solely in your hands.
For this reason it is our duty to provide you with all useful details to understand the processing that we may carry out in connection with the use of the Application and of our Services, indicating in particular both the specific purpose from time to time pursued and the assumption that justifies the processing, allowing us or not to perform the various activities described below.

A. Registration, creation and management of your personal account

In order to access the Application, regardless of which Services you decide to use, you must create a personal account. For this specific purpose, we only need your telephone number, your date of birth and a personal password. Without this information, we will not be able to process your request to register with YEPPIK and you will not be able to use the Application.
You decide whether you want to enrich your account by providing us with additional information about yourself, such as your first and last name, your home address, your online status, a nickname and a profile photo.
We will use your telephone number and your date of birth and, if you decide to share them with us, your personal and contact information, exclusively for purposes related and instrumental to the management of your account, as well as to carry out, via SMS or through the other addresses that you may have provided, the necessary service communications (e.g. sending the security code during the registration, availability of any updates).
We will also use this information to allow you to migrate your YEPPIK account and related conversations to another device.
The legal basis for the processing of your personal data for this purpose is the execution of pre-contractual measures taken at your request and the contract you have entered into with us.
Legal basis: Art. 6.1, b) of the GDPR.

B. Using the Application

We will use any personal data you provided during the account registration or after it (e.g. messages, multimedia, conversations data, error logs, etc.) to allow you to get in touch with other YEPPIK users, to send, receive and/or forward text messages and other multimedia content, as well as for purposes related and/or instrumental to the functioning of the Application, including all technical and organizational activities aimed at enabling the execution of the contract you have entered into with us.
We will also use your information to process and handle your requests for information about our Services and to provide you with the assistance you need in connection with any problems you encounter while accessing or using the Application.
In relation to the purposes just mentioned, we will process your personal data in order to execute the contract to which you are a party.
Legal basis: Art. 6.1, b) of the GDPR.

C. Security

Your personal data may also be processed for the purpose of breach analysis. For example, we may process your data in order to prevent, detect, analyze and/or manage fraud and other illegal activities against the Company or users interacting with YEPPIK (such as malware attempts, spamming, abusive access to our computer systems), as well as to protect the rights and safety of our users, the Controller or third parties.
Legal basis: Art. 6.1, f) of the GDPR.

Further purposes

In addition to the above, your data may also be processed for the following additional purposes:
The purposes for which the Controller may process your personal data, with the relevant legal bases, are summarized in the table below.

	Purpose of the treatment	Legal basis
A	Registration, creation and management of your personal account	Performance of contractual obligations and pre-contractual measures (Art. 6.1(b) GDPR)
B	Using the Application	Performance of contractual obligations and pre-contractual measures (Art. 6.1(b) GDPR
C	Security	Legitimate interest of the Owner (art. 6.1, lett. f) GDPR)
D	Statistical and aggregate analysis	Legitimate interest of the Owner (art. 6.1, lett. f) GDPR)
E	Fulfilment of specific legal obligations applicable to the Owne	Fulfilment of a legal obligation to which the Controller is subject (art. 6.1, letter c) GDPR)
F	Fulfilment and execution of legal regulations or orders, decisions and measures of authorities	Fulfilment of a legal obligation to which the Controller is subject (art. 6.1, letter c) GDPR)
G	To establish, exercise or defend a right in court	Legitimate interest of the Owner (art. 6.1, lett. f) GDPR)

4.0 Method of processing and communication of your personal data

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The processing of your personal data may take place using both computerized and manual procedures, but always under the supervision of appropriate security measures to counter the risk of destruction, loss, modification or unauthorized disclosure of the same.
Under no circumstances will your personal data be subject to fully automated decision-making processes.
Your data may be made available to third party service providers, outsourcers and, more generally, external companies to which the Data Controller entrusts the performance of activities related to the development of the Application and related Services, where this is indispensable for the performance of the purposes described above (e.g. IT service providers, companies in charge of the development and/or technical maintenance of systems, databases and services of YEPPIK, professionals and legal and tax consultants, auditing and audit companies).
These entities, bodies, companies and professionals will process your data as autonomous data controllers or data processors, subject to verification by us of their level of competence and reliability and duly appointed through an appropriate agreement pursuant to Art. 28 of the GDPR, depending on the purpose and type of processing pursued.
Your data may also be disclosed:

5.0 Transfer of data to third countries

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Your data may also be processed outside the European Economic Area ('EEA').
Whenever the need arises to transfer your data to countries outside the EEA, it is our duty to ensure that those countries provide levels of protection and security at least equivalent to those required by the Privacy Policy and to impose the same data protection and security obligations on the recipient of the data as we do (e.g. by entering into Standard Terms of Business with the recipient of the data and by carrying out a risk assessment of the transfer when required).

6.0 How long we keep your data

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We will only retain your data for as long as is necessary to achieve the purposes described above.
In particular, also in accordance with the provisions of specific laws:

The retention times of your personal data are summarized in the table below.

	Category of personal data	Terms
A	Navigation data	For the duration of the relevant browsing session only, except for longer periods required for security reasons
B	Your personal account details	Until account deactivation
C	Conversation data	Until account deactivation
D	Data processed for security purposes	For as long as is strictly necessary for security checks, and in any case for no longer than one year from the date of collection
E	Support and Feedback	For the time strictly necessary to process the request or report
F	Transactions data	One year from the date of collection, except in case of litigations

After the expiration of the above mentioned terms, we may further store your data for anonymous aggregate statistical purposes, as specified above, as well as to comply with any requests, orders, decisions or orders issued by the Judicial Authority, Public Safety Authority or other competent authorities, as well as to ascertain, exercise or defend our legal rights.

7.0 Your rights

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As a data subject, you may at any time exercise your rights under the Privacy Policy, namely:

To exercise your rights and/or to ask for any information or clarification regarding the processing of your data by SME, you can write at any time to the following contacts:
E-mail: dpo@yeppik.com
PEC: socialmediaemotions@legalmail.it
Paper mail: SOCIAL MEDIA EMOTIONS S.r.l., Corso Antonio Fogazzaro, n. 234, Vicenza (VI).