Privacy Policy

POLICY ON THE PROCESSING OF PERSONAL DATA

This policy describes the processing of personal data belonging to visitors of H-FARM S.p.A.’s website www.whaiwhai.com (the “Website”), as well as to those who, having used a WHAIWHAI guide, have sent an SMS to the number indicated in the guide to start playing (collectively, “Users“).

H-FARM S.p.A. may alter this policy to adapt it to future expansions or future alterations made to the Website or to the services offered. In the event of substantial alterations, H-FARM S.p.A. will publish a notification on the Website and/or send a notification via SMS to communicate the changes and gather any requests to exercise the rights granted by the legislation on the protection of personal data.

1.   DATA CONTROLLER

The data controller is H-FARM S.p.A., with headquarters in Via Sile 41, Roncade (TV), tax and VAT no. IT 03944860265 (“H-FARM”).

2.   DATA PROTECTION OFFICER

The Data Protection Officer (DPO) appointed by H-FARM is LCA Servizi S.r.l. They can be reached at the following address: Via della Moscova 18, 20121 Milano; via e-mail: dpo@lcalex.it; or via certified electronic mail (PEC): lcaservizi@pec.lcaservizi.it.

3.   DATA COLLECTED

3.1.   Data communicated by Users

a)   Data communicated by using a WHAIWHAI guide

  • “Standard” mode

By using the game service offered through one of the WHAIWHAI guides, the data collected are those communicated by the Users themselves when they send the first SMS to begin the game, and while using the service itself.

The data collected include the User’s identifying data and contact details, in particular their phone number and the username chosen by themselves. They also include data relating to the game session (e.g. date, length of game, game code, distance travelled, geolocation data, and, in particular, places visited).

  • “Sofà” mode

By using the game service offered through one of the WHAIWHAI guides, the data collected are those communicated by the Users themselves when they send the first SMS to begin the game, and while using the service itself.

The data collected include the User’s identifying data and contact details, in particular their phone number and username. They also include data relating to the game session (e.g. date, length of game and game code).

In this mode, no geolocation data is gathered for the User.

b)   Data communicated through the Website

The “My path” area of the Website, which allows the User to review the data relating to the game played, requires the User to communicate some personal data, such as the phone number used to play the game and the game code.

H-FARM will also process personal data shared by the User to send a communication or request using the e-mail addresses in the “Contacts” section of the Website. The data collected include Users’ contact details (e-mail address), personal data included in the communications and requests made to H-FARM, as well as other data that are needed to reply and carry out specific User requests.

We would suggest that Users only communicate data that is up to date, relevant and does not exceed the specific purposes of processing. We would also ask Users to avoid communicating third-party personal data unless necessary (e.g. because you do not have your own e-mail address and do not have any other direct contact details). Should third-party data be communicated, we would like to remind you that it is the User’s duty to fulfil the legal obligations on the protection of personal data and, in particular, to inform third parties of the communication of their data.

Any unnecessary data will immediately be deleted or made anonymous.

3.2.   Navigation data

With each access to the Website, the systems automatically record and analyse the access data (e.g. information on the browser used, screen resolution and size of the browser window, pages visited, and date, time and duration of each visit). This information is automatically collected by the Website and does not require any action by the User.

The data collected are anonymised and aggregated data only, and they cannot, therefore, lead to the identification of the User. The information collected simply allows for any technical problems to be identified and solved.

4.   PURPOSES OF PROCESSING

Users’ personal data and the data relating to the game that has been started by using a WHAIWHAI guide (“Data”) may be processed for the following purposes.

4.1.   To play the game

The Data will only be processed by H-FARM to allow the User to benefit from the game service offered by a WHAIWHAI guide. In the “My path” area, the User can also review and relive the game played with the WHAIWHAI guide, alongside the data relating to the game itself (duration, questions asked, mistakes made and, when using the game’s “standard” mode, the places visited too). Data is communicated on a voluntary basis and is necessary to be able to take part in the game and access the data relating to the game played; any refusal will result in the User being unable to take part in the game and benefit from the service offered through the WHAIWHAI guide.

The legal basis for this processing is H-FARM’s legitimate interest to provide its services, offering the User a complete gaming experience, and to allow the User to take advantage of these services when they ask to do so, enabling them to take part in the game and consult their results, as well as see the places they have visited. H-FARM’s interest has been weighed against that of the User. It is reasonable to believe that a User who has purchased a WHAIWHAI guide intends to make use of the game service, which entails the processing of Data by H-FARM. This intention is then confirmed by the User upon their request to start a game.

Nevertheless, at any time, the User may object to processing by writing to H-FARM at the addresses indicated in point 7 below or by contacting the Data Protection Officer at the addresses mentioned in point 2 above. From that moment on, Users will no longer be able to take part in the game or review their game in the “My path” section. In any case, any objection shall not affect the lawfulness of the processing carried out by H-FARM up until that moment.

4.2.   To respond to User requests

Data will also be processed to respond to requests that Users may make via the contact details available in the “Contacts” section of the Website..

Data is communicated on a voluntary basis but is necessary; any refusal will result in H-FARM being unable to respond to requests received and provide Users with information.

The legal basis for this processing is:

  1. in the event of requests sent by Users to plan an event, the need to take steps at the request of the User prior to entering into a contract and, where necessary, to fulfil the relevant legal obligations;
  2. in the event of requests sent by Users to obtain information, H-FARM’s legitimate interest to reply to Users in order to provide its services and give Users information relating to these services. H-FARM’s interest has been weighed against that of the User and is compatible with the User’s reasonable expectation to receive a response to requests sent to H-FARM.

Nevertheless, in the event of letter b., the User may object to processing, at any time, by writing to H-FARM at the addresses indicated in point 7 below or by contacting the Data Protection Officer at the addresses mentioned in point 2 above. In any case, any objection shall not affect the lawfulness of the processing carried out by H-FARM up until that moment. Instead, it will lead to the cancellation of all the User’s Data and will make it impossible for H-FARM to follow up on any outstanding requests.

5.   METHODS OF PROCESSING AND RECIPIENTS OF THE DATA

The Data will be processed by H-FARM’s staff and partners using manual and computerised tools. H-FARM has provided its staff and partners with detailed operating instructions, with particular reference to the adoption of adequate technical and organisational security measures.

6.   STORAGE PERIOD

The personal data collected and processed by H-FARM, for the purposes identified in point 4 above, may be stored in a form that allows the User to be identified for the period of time necessary to achieve the purposes of the processing. Specifically:

  • for the processing defined in point 4.1, or rather, to play the game, for a period of 2 years from the last game played;
  • for the processing defined in point 4.2, or rather, to respond to User requests, for a period of 12 months from the last contact.

The Data may be kept for longer periods of time where necessary to fulfil legal obligations, or to protect H-FARM’s rights, until the relevant limitation period expires.

7.   USER RIGHTS AND CONTACT DETAILS

At any time and in so far as the rights are applicable, the User may:

  1. obtain access to their Data;
  2. request the rectification, erasure and restriction of processing of their Data;
  3. object to processing, in accordance with the procedures described in article 4 above, without prejudice to the lawfulness of the processing carried out before the objection was made;
  4. lodge a complaint with the competent supervisory authority for the protection of personal data, or appeal to the competent judicial authority.

Requests to exercise the above rights must be sent to the Data Protection Officer, at the addresses mentioned in point 2 above, or to H-FARM at one of the following addresses:

  • via e-mail, to the address legal@h-farm.com;
  • via registered letter with return receipt, to H-FARM S.p.A., Via Sile 41, 31056 – Roncade (TV).

Requests for clarifications regarding this policy may also be sent to these addresses.

8.   LINKS TO OTHER WEBSITES

This policy on the processing of personal data is provided only in relation to the Data collected through the Website and with reference to the purposes identified in point 4. It does not relate to any other websites consulted and/or that can be consulted through links and/or widgets (e.g. social networks). These other websites will process Data as independent controllers and in compliance with their respective policies. Users are explicitly advised to consult these policies.

9.   COOKIE POLICY

Cookies are small text strings that the websites visited by the user send to the browser of the user’s terminal. Here, they are stored to then be retransmitted to the same websites when the user visits them again. While browsing a website, the user’s terminal may receive “first-party” cookies, where they are managed directly by the owner and/or manager of the website, as well as cookies that are sent from different websites or web servers (i.e. “third parties”). This happens because there may be elements on the website visited that reside on servers other than the one where the website is located. In other words, they are those cookies that are set by a different website to the one you are currently visiting.

With regard to the purposes pursued, cookies may be technical, analytical and profiling.

The Website uses the following cookies for the purposes indicated below.

Analytics cookies

Analytical cookies are used to collect information, in an aggregate form, regarding the number of Users and how they visit the Website.

It should be noted that the Website uses the following third-party analytical cookies:

Cookie/Provider Domani Purpose Duration Means of removal
Google Analytics *.whaiwhai.com Anonymous collection of website access and navigation data in order to draw up usage statistics through aggregate data. 2 years To remove the cookies installed on your device, you need to change your preferences by specifically configuring your browser (see section on “Options regarding the use of cookies”).

Should the User wish to remove their data from the Google Analytics database, they must contact H-FARM via the e-mail address legal@h-farm.com. H-FARM will give the User indications on how to locate their Analytics identification code, which H-FARM will then use to request the removal of the corresponding data from the third-party system.

Provision of data by Users

By continuing to browse the Website after having read the banner, the User authorises the use of cookies. The provision of data is optional.

You can change your cookie preferences at any time by specifically configuring your browser, according to the specific procedure described below. Through your browser preferences, you can also remove previously installed cookies, including the cookie where any consent for the Website to install cookies is saved.

The User may consent to the use of the Website’s cookies. You can accept all cookies, just some cookies, or you can refuse them all. Should the User decide to disable cookies (including the technical ones), they will not be able to access many of the features that make this Website more efficient, and some of our services will not work properly.

As far as third-party cookies are concerned, the User may also exercise their right to object to processing by consulting the privacy policy of the third party, and using the opt-out link if explicitly provided in the aforementioned privacy policy or cookie policy, or by contacting the third party directly.

Options regarding the use of cookies

You can manage cookies in the settings of the browser you are using. Since each browser has slightly different functions, the User should check their browser’s “help” menu to understand how to correctly change the settings relating to cookies.

The User can then change the browser settings so that cookies are removed and are not saved to the computer or mobile device without their explicit consent. At the following links, Users can better understand how to set their browsers:

Internet Explorer: https://support.microsoft.com/en-en/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox: http://support.mozilla.com/en-US/kb/Cookies

Google Chrome: https://support.google.com/chrome/answer/95647?hl=en

Safari: https://support.apple.com/en-en/guide/safari/sfri11471/mac

Opera: https://help.opera.com/en/latest/web-preferences/

If you disable cookies, you will not be able to access some of the features that make this Website more efficient (e.g. settings regarding the “language” chosen for browsing), and some of our services may not work correctly