Privacy Policy
Last Updated: November 20, 2018

1. WHAT IS IDIFIER?
IDifier operates a platform that helps you make sure that people you meet online are who they claim to be. You can use this platform whether through our website or our mobile application. This Privacy Policy is intended to inform you about how we treat Personal Information that we process about you. If you do not agree to any part of this Privacy Policy, then we cannot provide the Platform to you, and you should stop accessing the Platform and deactivate your IDifier account using the Delete Account option in the right side of the top bar.

2. DATA CONTROLLER AND DATA PROTECTION OFFICER
IDifier, in its capacity as Data Controller according to EU Regulation 679/2016 (hereinafter referred to as "Regulation"), is fully committed to protecting the privacy of the personal information that you share with us. Therefore, in this Privacy Policy we provide you with information regarding the collection, processing, use and sharing of personal information through our website https://www.idifier.com (hereinafter referred to as the "Site"). By "personal information", we mean information that identifies you or can reasonably be used to identify you. You can contact ReCRED and our data protection officer at contactus@idifier.com for any request relating to the processing of your personal information or to exercise your privacy rights (see point 8 below).
3. CATEGORIES OF PERSONAL INFORMATION COLLECTED
IDifier collects information from you when you browse our Site in order to provide you with a better browsing experience. The following personal information is processed through the Site:
a. Web browsing data
In the course of your browsing activity, the systems we use to operate the Site acquire certain type of personal information about you. This information is not collected with the intent of associating it with identified users but, by its very nature, it could lead to the identification of users through processing. This category of data includes browser type and settings, device type and settings, operating system, location data, IP address or domain name of the device used by users who connect to the Site, the URL (Uniform Resource Identifier) addresses of requested resources, the time of the request, the method used to submit the request to the server, the size of the file received in reply and other parameters regarding your operating system. This data is used for the sole purpose of obtaining anonymous statistical information on the use of the Site to check its correct functioning, to identify anomalies or misuses; in any event, they are deleted immediately after processing. This information could be used to ascertain responsibility in the event of computer crimes against the Site or third parties.
b. Data voluntarily provided by the user
IDifier also processes personal information you voluntary provide us when filling out the form contained on the Site in order to ask for information. Such personal information includes your name and surname, e-mail address and telephone number. Providing your personal information is necessary to fill the “Contact Us” form and denial thereof will prevent us from answering your question.
c. Data collected through cookies
This cookie policy refers exclusively to the Site. Cookies are small text files that the websites visited by the user send and record on user’s personal computer or mobile device, these cookies are then re-transmitted to the same websites upon the user's subsequent visit. Because of cookies, a website remembers the user's actions and preferences (such as login data, chosen language, font size, other display settings, etc.) in such a way that they do not have to be newly indicated when the user returns to visit the above-mentioned website or browse from one page to another. Therefore, cookies are used to perform computer authentications, to monitor sessions and store information concerning the activities of the users who access a website. Cookies may also contain a unique identification code that enables a user's browsing within the website to be tracked for statistical or advertising purposes. While browsing a website, the user may also receive cookies from websites or web servers other than the one the user is visiting (so-called third-party cookies) on user’s computer or mobile device. Some operations may not be able to be performed without the use of cookies, which in some cases are, therefore, technically necessary for the functioning of the above-mentioned website. There are various types of cookies, according to their characteristics and functions, and these can remain on the user's computer or mobile device for different periods of time: so-called session cookies, which are automatically deleted when the browser is closed; so-called persistent cookies, which remain on the user's devices until a predetermined deadline. The user's express consent is not required for the use of "technical cookies", namely cookies used for the sole purpose of transmitting a communication over an electronic communications network, or used to the extent strictly necessary to provide a service explicitly requested by the user. These are cookies are indeed necessary for the operation of the website or to perform activities requested by the user. By contrast, for "profiling cookies" designed to create user profiles and used to send advertising messages in line with the preferences expressed by the same user in the context of web-browsing, the user's prior consent is required.
4. PURPOSE OF PROCESSING
Your personal information will be processed for the following purposes:

1. to allow your browsing of the Site;
2. to maintain and improve the Site (for instance, IDifier uses your information to ensure the website is running as intended); and
3. to respond to your questions sent through the “Contact Us” form.

5. PROCESSING LEGAL BASIS
IDifier processes your personal information on different legal bases, specifically:

1. the legal basis for data processing for the purposes set out in letters i) and ii) of section 4 is the legitimate interest pursued by ReCRED to run the Site and constantly improve it; and
2. the legal basis for data processing for the purposes set out in letter iii) is the necessity to reply to your questions.

6. DATA RETENTION
It is our policy not to keep your personal information for longer than is strictly necessary to achieve the purposes mentioned above. Data shall be deleted as soon as the service requested will be provided.
7. DATA COMMUNICATION
Your personal data will be processed only by ReCRED and, for reason strictly necessary to provide the services, the following categories of external subjects: service providers of ReCRED (professional and technical) properly appointed as data processors and legitimate recipients pursuant to law. The data recipients act as data controllers, data processors or persons in charge of the processing in accordance with applicable law.
8. DATA SUBJECT'S RIGHTS
Pursuant to the Regulation, you have the right to obtain from us confirmation as to whether or not personal information concerning you is processed and, if it is, to request access to that personal information including the categories of personal information processed, the purpose of the processing and the recipients or categories of recipients; you may have the right to obtain from us the rectification of inaccurate personal information concerning you. You have also the right to have incomplete personal information completed, including by means of providing a supplementary statement; under certain circumstances, you may have the right to obtain from us the erasure of personal information concerning you and we may be obliged to erase such personal information; under certain circumstances, you may have the right to request the restriction of processing. You may have the right to receive personal information concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to another entity. Under certain circumstances you may have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal information by us and we can be required to no longer process your personal information. You also have the right to lodge a complaint with the competent supervisory authority.
9. CHANGES TO PRIVACY POLICY
We may change or update this Privacy Policy from time to time. Therefore, we invite you to regularly check this policy before browsing our Site.