Privacy Policy

Last updated: August 14, 2025
‍This Privacy Policy ("Policy") explains the information collection, use, and sharing practices of Byte-Code SpA, with registered office in Italy — Via Vittor Pisani 10, 20124 Milan ("we", "our", "Byte-Code").Unless otherwise specified, this Policy describes and governs the collection, use, and sharing practices of Byte-Code SpA in relation to the use of our website and applications ("Apps") that we provide and/or host on our servers.
Before using or submitting any information through or in connection with the Apps, please carefully review this Privacy Policy. By using any part of the website, you understand that your information will be collected, used, and disclosed as described here. If you do not agree with this Privacy Policy, please do not use our Apps.

Our principles

• Privacy policies should be understandable and easy to find.
• Data collection, storage, and processing should be simplified to improve security and consistency and to be easy to understand.
• Data practices should meet users' reasonable expectations.

Information we collect

We collect information in several ways, including when you provide information directly to us; when we passively collect information from you (e.g., from your browser or device); and from third parties.

Information you provide directly

We collect any information you provide. This may occur when you: (a) install the app, (b) contact support, (c) subscribe to a newsletter flow, (d) download one of our apps. Such information may include, without limitation, your name, email address, phone number, mailing address, payment information, and geographic location.

Information collected automatically

Device/Usage Information
We may automatically collect certain information about the computers or devices (including mobile or tablet devices) you use to access the Apps. We may collect and analyze (a) device information such as IP addresses, location information (by country and city), unique device identifiers, IMEI and TCP/IP address, browser types, browser language, operating system, mobile carrier information; and (b) information on how you interact with the Apps, such as referring and exit webpages and URLs, platform type, number of clicks, domain names, landing pages, pages and content viewed and their order, statistical information about your use of the Apps, time spent on particular pages, the date and time you used the Apps, the frequency of your use, error logs, and other similar information.

Cookies and Other Tracking Technologies
We also collect data about your use of the Apps through Internet server logs and online tracking technologies such as cookies and/or tracking pixels. A web server log is a file in which website activity is stored. A cookie is a small text file placed on your computer when you visit a website, allowing us to:
• recognize your computer;
• store your preferences and settings;
• understand which app webpages you have visited and the referring sites that led you to our apps;
• enhance your user experience by delivering content tailored to your inferred interests;
• conduct research and analytics;
• assist with security administrative functions.

How we use your information

• Fulfill the purposes for which you provided it.
• Provide and improve the Apps, including developing new features or services, protecting App data collection, and providing technical and customer support.
• Send you information about your interactions or transactions with us, account alerts, or other communications such as newsletters you subscribed to.
• Process and respond to your requests or solicit your feedback.
• Conduct analysis, research, and reporting, including summarizing and deriving insights from your use of our Apps.
• Comply with law and protect the security, rights, property, or safety of Byte-Code SpA, the Apps, our users, and the general public.
• Enforce our Terms of Use, including investigating potential violations.
We may combine information collected from and about you (including automatically collected information) with information we obtain about you from our affiliates and/or unaffiliated third parties, and use such combined information in accordance with this Privacy Policy.

When we disclose your information

Service Providers
We may disclose your information to third parties that perform services on our behalf, including but not limited to event management, marketing, customer support, data storage, analytics and data processing, and legal services.

Legal Compliance and Protection
We may disclose your information if required by law or in good faith that such disclosure is permitted by this Privacy Policy or reasonably necessary or appropriate to: (a) comply with legal process; (b) enforce our Terms of Use and this Privacy Policy, or other agreements with you; (c) respond to your customer service requests; and/or (d) protect the rights, property, or personal safety of Byte-Code SpA, our agents and affiliates, our users, and the public.

Business Transfers
As we continue to develop our business, we may engage in certain business transactions, such as the transfer or sale of our assets. In such transactions, your information may be disclosed. If any of our assets are sold or transferred to a third party, customer information (including your email address) would likely be one of the transferred business assets.

Consent
We may disclose your information to third parties based on your consent.

Legal Basis for Processing Personal Data

Where applicable laws require, we inform you of the legal grounds on which we rely to use or disclose information that can be directly linked to or used to identify you. Our legal bases are:

To Honor Our Contractual Commitments

Much of our processing is to fulfill our contractual obligations to provide services to our users.

Legitimate Interests

In many cases, we handle information based on our legitimate interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals. These include:
• Customer service;
• Marketing, advertising, and fundraising;
• Protecting our users, staff, and property;
• Managing user accounts;
• Organizing and running events and programs;
• Analyzing and improving our business;
• Managing legal issues.

Legal Compliance

We may need to use and disclose information in certain ways to comply with our legal obligations.

Consent

Where required by law, and in some other cases where legally permissible, we process information based on consent. Where we process your information based on consent, you have the right to withdraw your consent in accordance with applicable law.

Your Rights

Data Subject Rights in the EU

Individuals in the European Economic Area ("EEA") and other jurisdictions have certain legal rights (subject to applicable exceptions and limitations) to obtain confirmation of whether we hold certain information about them, to access such information, and to have it corrected or deleted where appropriate. You may also have the right to object to our handling of your information, restrict our processing, and withdraw any consent you have provided.

International transfers

As described above, we may share your information with trusted service providers or business partners in countries other than your country of residence, in accordance with applicable law.

Security measures

We implement technical, physical, and organizational security measures to protect against the loss, misuse, and/or alteration of your information. However, we cannot and do not guarantee that these measures will prevent every unauthorized attempt to access, use, or disclose your information.

Data retention

We retain the information we collect for as long as necessary to fulfill the purposes outlined in this Privacy Policy or for as long as we are legally required or permitted to do so.

Changes to this Privacy Policy

We will continue to evaluate this Privacy Policy as we update and expand our Services and may make changes accordingly. We will post any changes here and update the "last updated" date above.

Questions about this Privacy Policy

If you have questions about this Privacy Policy or our privacy practices, you may contact us at: app-privacy@byte-code.com