Privacy Policy - SONIC EUROSPINBALL

Company: Promotica Spa
Version: 01
Confidentiality level: Public
Date: 30.01.2025

Promotica S.p.A. (hereinafter referred to as “Data Controller”), in its capacity as Personal Data hereby informs you that we collect, use and protect personal data when using the gaming app.

Data Controller and DPO

The Data Controller is Promotica S.p.A., headquartered at 111, Via Monte Baldo, 25015 Desenzano del Garda (BS). Mail address for communication purposes: info@promotica.it, PEC: promotica@pec.promotica.it.

The Data Protection Officer (DPO) can be contacted at the following e-mail address: dpo@promotica.it.

Type of data processed, purpose of data processing, legal basis for processing and consequences of failure to provide personal data, data retention.

Eurospinball does not collect personal data. However, we do collect anonymous usage data for technical analysis and performance purposes, in order to improve the user experience.

**Usage data**: The app allows you to use a pinball with various graphics. Some game features and graphics will only be accessible by scanning a QR code found on some of the products distributed by Eurospin.

While using the app, anonymous data regarding performance, errors and usage metrics will be collected in aggregate format. The data collected is used exclusively to:
- improve the app's performance and efficiency;
- analyse and resolve any technical issues;
- provide an optimal user experience.

Recipients of personal data

No data is shared with third parties. Anonymous usage data is only used internally for app analysis and improvement purposes.

Existence of automated decision-making and data dissemination

Anonymous personal data will not be disseminated and there is no automated decision-making.

Security measures

We use technical, organisational and IT security measures to protect the data collected.

Transfer of your data abroad

Anonymous Personal Data is processed and stored within the European Union.

Data subjects’ rights

You may contact the Data Controller at any time to exercise the following rights, in accordance with Articles 15 to 22 of EU Regulation 679/16, where applicable, namely to:

  1. obtain information on the processing carried out by the data controller (right to information);
  2. request and obtain the data held by the data controller in an intelligible form (right of access);
  3. obtain the updating or rectification of the data provided;
  4. obtain the cancellation of the data in the data controller’s possession (right to be forgotten);
  5. object to the processing in whole or in part;
  6. withdraw consent at any time (also by deactivating consent via the banner on the web page);
  7. object to automated processing and not to be subject to processing based solely on automated decisions, including profiling;
  8. request and obtain the transformation of data into anonymous form;
  9. request and obtain the blocking or limitation of data processed in violation of the law and data no longer required to be retained in relation to the purposes of the processing;
  10. obtain data portability;
  11. lodge a complaint with the personal data protection authority in accordance with Art. 77 of the GDPR;
  12. take the appropriate legal action pursuant to art. 79 of the GDPR.

The rights provided for in EU Regulation 2016/679 may be exercised by contacting the Data Controller by registered letter with return receipt, email or certified email at the addresses indicated.