OFF

Off - A better you collects some Personal Data from its Users.

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Owner and Data Controller

Rue Srl

Via Enrico Mattei 106

Bologna, Italy

Owner contact email: support@rue.xyz

Types of Data collected

Among the types of Personal Data that Off - A better you collects, by itself or through third parties, there are: email address;

Usage Data; session duration; Application opens; Application updates; Trackers; number of Users; session statistics; gender; date

of birth; general activity data; movement activity; body measurements & indexes; food related activity ; sleeping activity; heart

rate and other vital data; blood type.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by

specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using Off - A better

you.

Unless specified otherwise, all Data requested by Off - A better you is mandatory and failure to provide this Data may make it

impossible for Off - A better you to provide its services. In cases where Off - A better you specifically states that some Data is not

mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the

Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools — by Off - A better you or by the owners of third-party services used by Off - A

better you serves the purpose of providing the Service required by the User, in addition to any other purposes described in the

present document and in the Cookie Policy.

Users are responsible for any third-party Personal Data obtained, published or shared through Off - A better you.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised

destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes

strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of

persons in charge, involved with the operation of Off - A better you (administration, sales, marketing, legal, system

administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies,

communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be

requested from the Owner at any time.

Place

The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are

located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To

find out more about the place of processing of such transferred Data, Users can check the section containing details about the

processing of Personal Data.

Retention timeUnless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose

they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to

enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent

activity, as well as the following: Registration and authentication, Analytics, Handling activity data, Platform services and

hosting and Handling payments.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information

on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Analytics

The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User

behaviour.

Google Analytics for Firebase (for apps) (Google Ireland Limited)

Google Analytics for Firebase (for apps) or Firebase Analytics is an analytics service provided by Google Ireland Limited.

In order to understand Google's use of Data, consult Google's partner policy.

Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote

Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the

Owner.

Off - A better you uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service.

Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for

mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.

Personal Data processed: Application opens; Application updates; session duration; Usage Data.

Place of processing: Ireland – Privacy Policy.

Google Analytics 4 (Google Ireland Limited)

Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected

to track and examine the use of Off - A better you, to prepare reports on its activities and share them with other Google services.

Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or

server. Users can learn more by consulting Google’s official documentation.

Personal Data processed: number of Users; session statistics; Trackers; Usage Data.

Place of processing: Ireland – Privacy Policy – Opt Out.

Handling activity data

This type of service allows the Owner to use the activity or biometric data collected by your device in order for Off - A better you

to operate or to provide specific features. This may include movements, heartbeat, change in altitude or data about the

surroundings.

Depending on what is described below, third parties may be involved in the activity tracking.

Most devices allow for the User to control which Data is accessed or stored.

Apple HealthKit (Apple Inc.)

HealthKit is an activity data handling service provided by Apple Inc. that enables the Owner to access or store activity data.

Personal Data processed: blood type; body measurements & indexes; date of birth; food related activity ; gender; general activity

data; heart rate and other vital data; movement activity; sleeping activity.Place of processing: United States – Privacy Policy.

Handling payments

Unless otherwise specified, Off - A better you processes any payments by credit card, bank transfer or other means via external

payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and

personal information directly to such payment service providers. Off - A better you isn't involved in the collection and processing

of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment

has been successfully completed.

Payments processed via the Apple App Store (Apple Inc.)

Off - A better you uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or

in-app purchases.

Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.

Personal Data processed: email address.

Place of processing: United States – Privacy Policy.

Platform services and hosting

These services have the purpose of hosting and running key components of Off - A better you, therefore allowing the provision of

Off - A better you from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics,

user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling

of Personal Data.

Some of these services work through geographically distributed servers, making it difficult to determine the actual location where

the Personal Data are stored.

App Store Connect (Apple Inc.)

Off - A better you is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.

App Store Connect enables the Owner to manage Off - A better you on Apple's App Store. Depending on the configuration, App

Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app

purchases, and payments to measure the performance of Off - A better you. App Store Connect only collects such data from

Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device

settings here.

Personal Data processed: Trackers.

Place of processing: United States – Privacy Policy.

Registration and authentication

By registering or authenticating, Users allow Off - A better you to identify them and give them access to dedicated services.

Depending on what is described below, third parties may provide registration and authentication services. In this case, Off - A

better you will be able to access some Data, stored by these third-party services, for registration or identification purposes.

Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please

refer to the description of each service.

Firebase Authentication (Google Ireland Limited)

Firebase Authentication is a registration and authentication service provided by Google Ireland Limited. To simplify the

registration and authentication process, Firebase Authentication can make use of third-party identity providers and save the

information on its platform.

Personal Data processed: email address.

Place of processing: Netherlands – Privacy Policy.

Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to

provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically

forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.Personal Data processed: email address.

Place of processing: United States – Privacy Policy.

Cookie Policy

Off - A better you uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

Users have given their consent for one or more specific purposes.

provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual

obligations thereof;

processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the

Owner;

processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether

the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose

they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be

retained until such contract has been fully performed.

Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill

such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the

relevant sections of this document or by contacting the Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing,

as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period

whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to

rectification and the right to data portability cannot be enforced after expiration of the retention period.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their

consent to the processing of their Personal Data.

Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is

carried out on a legal basis other than consent.

Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding

certain aspects of the processing and obtain a copy of the Data undergoing processing.

Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or

corrected.

Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner

will not process their Data for any purpose other than storing it.

Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from

the Owner.

Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a

structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another

controller without any hindrance.

Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization

governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken

by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for

the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground

related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to

that processing at any time, free of charge and without providing any justification. Where the User objects to processing

for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the

Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this

document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such

requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users

with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be

communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves

impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action

arising from improper use of Off - A better you or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, Off - A better you may provide the User with additional and

contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, Off - A better you and any third-party services may collect files that record interaction

with Off - A better you (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see

the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly

within Off - A better you and/or - as far as technically and legally feasible - sending a notice to Users via any contact information

available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at

the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent

from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number

— allows for the identification or identifiability of a natural person.Usage Data

Information collected automatically through Off - A better you (or third-party services employed in Off - A better you), which can

include: the IP addresses or domain names of the computers utilised by the Users who use Off - A better you, the URI addresses

(Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file

received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country

of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the

time spent on each page within the Application) and the details about the path followed within the Application with special

reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT

environment.

User

The individual using Off - A better you who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as

described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes

and means of the processing of Personal Data, including the security measures concerning the operation and use of Off - A better

you. The Data Controller, unless otherwise specified, is the Owner of Off - A better you.

Off - A better you (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by Off - A better you as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to

the European Union and the European Economic Area.

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting -

that enables the tracking of Users, for example by accessing or storing information on the User’s device.

Legal information

This privacy policy relates solely to Off - A better you, if not stated otherwise within this document.

Latest update: 6 March 2024