Developer Module Privacy Policy

Italian version

Updated on: 10 September 2019

We take your privacy seriously. We respect your right to privacy, and we are committed to protecting all personal information we collect.

This document describes the information collected by the Developer Module (available on Google Play and on the Apple Store), and how these are used, disclosed, transferred, and stored. By using the services made available by the Developer Module, you accept the terms and conditions of this privacy policy. By the same token, if you do not wish for the Developer Module to gather, store, use, or share your information in the manner described in this policy, you may be restricted from accessing our services.

Affidaty S.p.A. collects, stores, and utilises user data as a data controller for the purpose of supplying and developing games, applications, and services designed and sold directly by Affidaty in accordance with this privacy policy. To view Affidaty S.p.A.’s privacy practices, click here.

1. How are Data Collected?

The Developer Module collects Developer user data when the user (a) creates an account; (b) uses services connected to the module; (c) generates content; (d) views the utilities within our services; (e) contacts Affidaty customer service; (f) shares information or participates on any of our channels, social-media platforms, or other community websites; (g) subscribes to a newsletter.

2. What Types of Data are Collected?

The Developer Module collects only a sufficient amount of relevant data limited to the following purposes:

  1. data supplied by the Developer user: username and password, age, profile-related data (e.g. a profile picture), data supplied during interactions with customer service, contact information (such as a name, email address, and phone number), other data supplied by the Developer user (including data utilised to identify a lost account).
  2. data collected directly from the Developer user during their use of services: data relating to their progress and activities on the modules, and the services available on the Developer platform, IP address and device identifiers, device information (e.g. device name and operating system), data collected using cookies and similar technologies (for more details on this, please review our cookie policy), generic location data, accurate geolocalisation data (GPS), player ID;
  3. data obtained by our partners: data that the Developer Module receives when the user connects to a third-party social media site like Facebook, data collected for purposes of advertising and analysis, and to improve service quality.

3. How are the Collected Data Utilised?

The Developer Module uses collected data mainly to offer the Developer user a better experience. The collected data are used, both individually and cumulatively, for purposes including (a) providing the user services that comply with applicable law in the user’s country of residence; (b) to protect against crimes, cheating, fraud, or for other security-related purposes; (c) to identify and fix any bugs or service errors; (d) to compile statistics; (e) to discharge any statutory or regulatory duty, and to respond to any request by the data-protection or any other public authority; (f) to provide technical support, communicate with users, and reply to any questions or requests forwarded by the customer-service team.

In some of the foregoing cases, Affidaty S.p.A. may utilise and perform analysis. This information, indeed, may be used to support company processes, to facilitate product development, improve products and services, and finally to conduct statistical analysis.

The Developer Module collects personal information from Developer users only when (a) it has the user’s consent to do so; (b) it needs personal information to perform under a contract with the Developer itself and to provide services; (c) processing is done in Affidaty S.p.A.’s legitimate interest and without infringing upon user rights.

4. Data Storage Period

The Developer Module retains, uses, and stores Developer user data when the user utilises a module designed in-house by Affidaty S.p.A., or uses an application sold by Affidaty S.p.A., or when the user accesses any integration and development services for the smart contracts offered by Affidaty S.p.A. on the Developer platform, and only for so long as needed to fulfil those purposes described herein, in accordance with the European General Data Protection Regulation (GDPR). The data may be stored for a longer time for purposes of dispute resolution, or to respond to any request by the courts. In such cases, the collected data shall be utilised and stored until the request is fulfilled.

Personal data may be retained for statistical purposes beyond the time period required to pursue those purposes for which they were collected and thereafter processed, as permitted under the code of professional ethics and code of conduct established for the collection of personal data for statistical and scientific-research related purposes deemed to be GDPR-compliant by the Data Protection Authority in December of 2018. In such cases, the item of personal information will be stored in an anonymous format.

5. Data Storage, Disclosure, and Transfer

The Developer Module may also use third-party services. These are permitted only with limited access to Developer user data for specific purposes such as analysis, optimisation, customer service, and data analysis. Affidaty S.p.A. shall, without exception, alert any impacted user in advance.

Affidaty S.p.A. shall take steps to ensure that user personal data is processed in a secure and lawful manner, within a structure that is suitably controlled and maintained, in accordance with ISO 27000 standards, and within those geographic areas identified in Independentchain Areas and Locations, and which receive adequate protection in the jurisdictions where they are processed.

For a user to be able to use the Developer Module, your personal information may be transferred to other entities, subsidiaries, processors, or third parties located outside the user’s country of residence, and indeed anywhere Affidaty S.p.A. has operations. If you are located within the European Economic Area (EEA), Affidaty S.p.A. shall provide adequate protection for the transfer of personal information outside the EEA pursuant to standard contract language authorised by the European Commission, or other reasonable security measures as defined in Art. 46 of EU Regulation no. 2016/679 (GDPR).

6. Data Security and Confidentiality

Affidaty S.p.A. has implemented security measures to safeguard, prevent unauthorised access to, and to maintain the security of the data, and to ensure personal data collected through the services are correctly used. Affidaty S.p.A. takes all reasonable precautions to protect user personal data from loss, improper use, unauthorised disclosure, alteration, and destruction, and when possible obliges third parties to do so. However, one must bear in mind that no data transmission over the internet or through a wireless network is 100% secure. Therefore, even if Affidaty S.p.A. makes a concerted effort to protect user data, it cannot guarantee the security of such data, and does not assume any liability for any unauthorised access or use of any data under its control where the user has failed to take proper precautions when using an unsecured network.

Should any third party be assisting in the processing of personal data, Affidaty S.p.A. shall take all reasonable steps to demand that such third parties consent to its privacy policies, and to otherwise protect user personal data.

Affidaty S.p.A. shall immediately alert users to any data breach within our services.

7. Minors

For purposes of digital-service delivery, a minor under European law is anyone under sixteen (16) years of age. That age limit may be lower under national laws: indeed, under Italian law, the age limit is fourteen (14). Therefore, minor users, meaning those under fourteen (14) years of age, may legally use the Developer module and related developments/integrations for the smart contract, and may further promote and sell the technologies available to the Developer end-users, provided they are in the company of, and supervised by, a parent or legal guardian.

8. User Rights

The Developer user warrants all tendered data to be correct, truthful, and referring only to the user and not to any other person.

The Developer user may exercise his or her rights at any time. For more information on the rights enjoyed by the user, and how to exercise them, please read Affidaty S.p.A.’s policy by clicking here.

If you have previously consented to any marketing emails from Affidaty S.p.A., or if you have signed up for our newsletter, you can unsubscribe from these by clicking on the link included with each notice or newsletter sent by Affidaty S.p.A..

If you wish to reject all cookies and the use of any other tracking technology, please review our cookie policy available on the Affidaty website.

User conduct may impact Developer Module functionality, its services, and its various functions. Consequently, certain conduct on the part of a user may oblige Affidaty S.p.A. to interrupt service. For example (a) requests to modify mandatory data; (b) requests to limit processing on data required for the Developer Module, or refusals to permit processing on the same; (c) revocation of consent, or any request to delete personal data.

Should the Developer user revoke his or her consent or request the data be deleted, Affidaty S.p.A. shall not use or process such data any further; instead, they will be archived in case any request therefor is made by any court or public authority.

9. Third-Party Services

The Developer Module may contain links to external sites, which are outside Affidaty S.p.A.’s control. This Developer Module privacy policy only applies to Affidaty S.p.A.’s processing of personal and other data collected through the Developer Module. When a Developer user accesses any external site, he or she accepts the privacy policy for that site. Please note, however, that those external sites may have different policies with respect to the collection, use, and disclosure of personal data. Therefore, Affidaty S.p.A. shall not be responsible for any third-party privacy practices, and has no control over the same; for this reason, we recommend consulting the privacy policies for all third-party services. Affidaty S.p.A. shall not be liable for any act, omission, or policy issued by any external service provider.

10. Changes to this Privacy Policy

Affidaty S.p.A. reserves the right to modify this policy at any time. Should any substantive changes be made to this privacy policy, they will be posted to the privacy section on our websites and apps. These sections will always include the date of the most recent version. Therefore, the user is advised to check this privacy policy periodically in order to be apprised of any changes. Continuing to use services once such changes have taken effect shall be deemed acceptance of the changes. Should you choose to reject the changes, you may then elect to refrain from further use of the services by sending Affidaty S.p.A. proper notice of the same.

11. Legal Notices

Affidaty S.p.A. neither represents nor warrants that the services offered on the Developer Module will be available at all times, or that the services will never be subject to interruptions or other technical issues. Affidaty S.p.A. shall not be liable for the user’s ability to access the services, nor for any other issue outside its control. This privacy policy shall be governed by the law in the user’s country of residence. Should any dispute arise regarding the use of services, the matter shall be heard exclusively by the Court of Milan.

Should you have any questions, comments, or concerns regarding the privacy policies in effect at Affidaty S.p.A., please send us an email to or write to us at:

Affidaty S.p.A.

Viale Giovanni Milton n.53

50129 Florence (FI)