Privacy Policy of the Playvivi Mobile App
Last updated: [insert date]

This notice describes how the personal data of users who use the Playvivi mobile app are processed.
This notice is provided pursuant to Regulation (EU) 2016/679 (GDPR) and European legislation on the protection of personal data.

1. Data Controller
   The Data Controller is:
   IMMERSO S.R.L.
   VAT No.: IT06207030658
   Tax Code: 06207030658
   Registered office:
   Strada Comunale dello Statuto
   84090 Montecorvino Pugliano (SA) – Italy
   PEC: immersosrl@pec.it
   The Controller determines the purposes and means of the processing of personal data connected with the use of the Playvivi app.

2. Type of data processed
   The Playvivi app is designed to minimise the collection of personal data.
   During use of the app, the following categories of data may be processed.
   Technical device data
   The app may automatically detect certain technical information about the device used, including:
   • operating system of the device
   • device language
   These data are used solely to ensure the correct functioning of the application.
   Geolocation data
   The app may use the geographical location of the device exclusively in the following cases:
   • when the user explicitly enables the location function
   • when the user uses navigation or map display functions
   Geolocation:
   • is optional
   • is enabled only at the user's request
   • works only while the app is open
   • can be disabled at any time in the device settings.
   Use of the camera
   The app may use the device camera for:
   • augmented reality (AR) features
   • creating photos with AR elements
   The images taken:
   • are saved exclusively on the user's device
   • are not transmitted to Immerso's servers
   • are not stored by the Data Controller

3. Purposes of processing
   The data collected through the app are processed exclusively for the following purposes:
   • to ensure the correct functioning of the application
   • to provide navigation and map viewing functions
   • to allow the use of augmented reality features
   • to improve the technical compatibility of the app with the devices used
   Processing of data takes place on the basis of the following legal grounds:
   • performance of a service requested by the user
   • user's consent to the use of geolocation or the camera.

4. Third-party services
   The Playvivi app integrates services provided by third parties that may process personal data in accordance with their own privacy policies.
   Google Maps
   The app uses the Google Maps service for map display and navigation functions.
   The service is provided by:
   Google Ireland Limited
   Gordon House, Barrow Street
   Dublin 4, Ireland
   The use of Google Maps may entail the processing of technical and geolocation data by Google.
   For more information, you can consult Google's privacy policy:
   https://policies.google.com/privacy

5. Processing method
   Data are processed using computerised and telematic tools in compliance with the principles of:
   • lawfulness
   • fairness
   • transparency
   • data minimisation
   • security.
   Appropriate technical and organisational measures are in place to protect the data from unauthorised access, loss or disclosure.

6. Data retention
   The Playvivi app does not involve the creation of user accounts and does not store identifying personal data on the Controller's servers.
   Any technical data processed are used exclusively for the operation of the app and are not retained longer than is strictly necessary for the technical purposes of the service.
   Images created through AR features remain exclusively on the user's device.

7. Data transfer
   The technological services used by the app may be hosted on cloud infrastructures located in the European Economic Area (EEA) or in countries that guarantee an adequate level of data protection.
   If transfer to non-EU countries becomes necessary, it will take place in compliance with the safeguards provided for by the GDPR.

8. User rights
   Users may exercise at any time the rights provided for in Articles 15–22 of the GDPR, including:
   • right of access to data
   • right to rectification
   • right to erasure
   • right to restriction of processing
   • right to object to processing
   • right to data portability
   Requests may be sent to the Data Controller at the address:
   immersosrl@pec.it
   Users also have the right to lodge a complaint with the Italian Data Protection Authority.

9. Minors
   The Playvivi app is intended for users aged 14 and over.
   Users under this age must use the app under the supervision of a parent or legal guardian.

10. Changes to this notice
    The Data Controller reserves the right to amend this Privacy Policy at any time.
    Any updates will be published within the app and, where necessary, the user's acceptance will be requested again.