Applicable from: 25 May 2018.

Predictpod services will publish all amendments or changes to the privacy policy on their respective websites; we reserve the right as a team to update this privacy policy at any time; we therefore advise you to review it frequently. Where significant amendments are made to this privacy policy, you will be informed via email or advice on the website before the changes come into force. Predictpod regularly updates their services in order to provide improvements, including improvements to privacy rights. If you do not wish to accept the terms of our new privacy policy, you will be able to request deletion or a restriction on our use of your personal data (via the page Manage account/Unsubscribe) as outlined in the relevant rules.

Scope of application

As stated, this Privacy policy applies to all websites and any Predictpod application, service or instrument (collectively the “Websites”) where there is reference to the Privacy policy, independently of the mode of access and use, for example on mobile devices.

Personal data collected by Predictpod

Firstly, what constitutes personal data?
Personal data is information on an identified or identifiable individual. An individual is a person who can be identified directly or indirectly by reference to identifiers such as an email address, for example.
Data which has been anonymised or aggregated such as no longer to allow a specific individual to be identified (not even in combination with other information available to the data controller) is not considered as personal data.
In order to benefit from certain subscription services on the websites (such as the daily newsletter via email: the “Services”), Predictpod requests that you register and provide certain personal data such as first name and email address. Additional data collected in order to provide the Services are: gender, date of birth, place of residence, profession, qualifications, interests, children and pets.
For increased privacy protection, the surname of users is not requested by the website.
Personal data which is automatically collected when you use our websites or Services:

• Statistics on pages viewed and IP address.
• Personal Data collected by us via cookies and similar technologies.

We use cookies, unique identifiers and other similar technologies to collect data on the web pages and links visited and other actions carried out by you when you use our Services, either within publicity content or emails.
For further information on the use of these technologies and how to manage preferences, see Cookies and similar technologies.
The Data Controller does not collect the personal data of users who simply navigate in the public areas of the website. However, the Data Controller will be able automatically to collect information on visits by users, for example browsing patterns. Information collected in this way does not show the contact details of users nor any kind of personal data. This anonymous information is used only in aggregate form in order to analyse, manage and develop websites and is not linked to any individual.
Personal data of European Union users will be processed by the Data Controller and saved on servers located in Europe. Users who send their personal data give their consent to their personal data being stored and processed as set out in this document.

How to access, control and modify your personal data

You may access, correct or delete your personal data at any time.
When you access your account via Manage Account, you can view, control and modify your personal data. Update your personal data immediately where there are changes or errors!
We fully respect your rights under the regulations in force to access, modify or delete your personal data. In certain cases, under the regulations in force (for example a Court order), notwithstanding any right of yours to request access to, modification or deletion of your personal data, we might however deny such access or refuse to modify or delete your personal data.
If you ask us to stop processing some or all of your personal data, or you withdraw your consent to us using it for the purposes described in this Privacy policy, we may not be able to provide you with all the Services and customer support provided to our users and authorised under this Privacy policy.
Upon request by you, we will close the account as soon as possible and remove your personal data depending on your account activity and in accordance with the regulations in force.

How we use your personal data

The information gathered is used to: provide and improve our Services, provide you with a personalised experience on the websites and in the emails you receive, contact you with regards to your account and our Services, provide you with customer service and personalised publicity and marketing material.
Your personal data is processed specifically for the purposes of:
1. fulfilling your request sent via the website and/or registration with the website and receipt of various Services. In particular, the processing of personal data allows: (i) users to participate actively in the online communities of Predictpod, to manage a profile; (ii) the data handler to follow up requests and/or respond to users’ questions and/or periodically to send users information and communications (for example communications regarding horoscopes, biorhythms or other subscription services) depending on the pre-selected Service; (iii) user profile management for the purpose of personalising Services; (iv) personalising the content and information received by the user and communications between the Data Controller and the user;
2. profiling and periodic emailing of users for the purpose of direct marketing for products or services provided by the Data controller and/or other companies operating in various sectors, or invitations to participate in marketing surveys on the Services provided by the Data Controller or other services provided by other companies.
3. compliance with the requirements as set out in the laws and regulations, as well as requests by the relevant authorities/monitoring bodies, including police and governmental authorities;
We use your personal data to pursue our legitimate interests in such a way as not to undermine your rights and fundamental freedoms. We have implemented checks to balance fairly our interests and your rights. They include the following:
Improving our services, for example, by examining data relating to blocked or non-functioning pages visited by users in order to identify and resolve the problems and give you a better experience.
Personalising, measuring and improving publicity on the basis of personalisation preferences.
Contacting you via email to offer you coupons, discounts and special promotions and to inform you about our services as permitted by the regulations in force.
Sending you targeted marketing campaigns, updates on services and promotional offers on the basis of notification preferences.
Measuring the performance of our email marketing campaigns (e.g. by analysing the percentages of emails opened and number of clicks).
We may, with your consent, use your personal data to conduct marketing via email.
We may use automated technologies for decision-making purposes and profiling.
You may withdraw your consent at any time.

Your choices as to how we use your personal data

• Marketing

If you do not wish to receive marketing messages, you may cancel your registration using the link in the email you have received, to unsubscribe from Predictpod services; alternatively, you may contact us as indicated in the Contacts section below. It should be noted that we do not sell, nor do we access for payment or communicate in other ways your personal data to third parties for marketing purposes without your consent.

• Maintaining live access

When you access your account online, you may choose to continue live access for a fixed period of time. If you use a public or shared computer, it is, however, not advised that you maintain access: during the period in which access is maintained: any person using the computer you have used will be able to see most of the information in your account and carry out specific actions without the need for further authorisation.

• Viewing your user profile page

If attempts are made to change the password or other data, to update the account information or to carry out particular activities on the account apart from those listed above, you may be asked to enter the password.
In order to terminate the session, it is not sufficient to exit and/or cancel the cookies. If certain privacy settings are not set up in the browser, when you close page, the session may nevertheless be terminated. We advise you, however, to exit and/or cancel the cookies after using our Services.

Specific information on your rights

You have a number of rights in place to protect you. You may decide to exercise them at any time.

• Right of access (Article 15 of the GDPR): you may request confirmation of whether your personal data is subject to processing and, if so, to access that data and information such as the purpose of the processing or categories of personal data involved.
• Right to Rectification (Article 16 of the GDPR): you are entitled to request rectification of incorrect personal data.
• Right to erasure (Article 17 of the GDPR): you are entitled to request the erasure of personal data without undue delay in particular circumstances, for example if your personal data is no longer necessary for the purposes for which it was collected under Article 6(1)(a) of the GDPR and where there is no other legal basis for the processing.
• Right to restriction of processing (Article 18 of the GDPR): you are entitled to request Predictpod to restriction on the processing of your personal data in specific circumstances, for example, if you believe that the personal data processed is incorrect or unlawful.
• Right to data portability (Article 20 of the GDPR): in some cases, you are entitled to receive personal data you have provided, in a structured, commonly used and machine-readable format, and entitled to transmit that information to another data controller without hindrance and to request Predictpod to do so.
• Right to object (Article 21 of the GDPR):
  you are entitled to object to the processing of personal data in specific circumstances and specifically if that data is used for marketing purposes

Please note that it is possible to exercise these rights at any time by accessing your Predictpod account and going to Manage Account/Unsubscribe. It is also possible to send an email to rectify or modify any information or ask which personal data (for example name and address) have been stored or to enforce any other rights mentioned above by sending an email.

How long can we keep your personal data?

Predictpod deletes and anonymises your personal data as soon as possible once they are no longer needed for the purposes for which they were collected, as set out in this privacy policy, as long as it is not necessary to carry out further processing or storing of your personal data to meet a legal requirement.
The period of time for which we store personal data is set out in our data storage registers. The length of time may vary according to the context of the services we provide and our legal obligations. Length of storage normally depends on the following factors:
We are subject to legal, contractual or similar restrictions relating to the storage of your personal data. These depend on the regulations on storing data in the relevant jurisdiction, orders by Authorities relating to the storage of data following a survey, or on the storage of personal data where needed for reasons linked to a dispute.
Where is no longer necessary to store personal data, it will be removed securely in accordance with our rules on the storage and deletion of data.

In what exceptional cases might we share your personal data?

In application of the law, legal proceedings and procedures authorised by the law:
Authorities or police forces or third parties authorised in response to a verified request or other procedure provided for by the law in connection with a criminal investigation or an illegal activity or any alleged activity or other activity exposing one of our companies, you or any other user to some form of legal liability. We will provide the information we believe to be relevant to the purposes of the investigation or applications.

Change of ownership

In the case of a merger or acquisition with another company, we may share your data with that company and in that case would ask the new company arising out of the merger or acquisition to observe this Privacy policy relating to your personal data. If we wanted to process your personal data for purposes not listed in this Privacy policy, you would first receive notification about the processing of your personal data for new purposes.

Controller and Data Protection Officer (DPO)

For EU residents, the contracting party is Keyman Technologies Srl, Via degli Olivetani 10/12, 20123 Milano.
The company named as contracting party is the Data Controller and responsible for the acquisition, use, storage and protection of personal data in accordance with this privacy policy and, naturally, with the regulations in force.
In countries where it is required, we have named a Data Protection Officer, DPO, who is responsible for the privacy programme for the data controller. You may contact the DPO via the email address below in the Privacy policy.

Further information

If you wish to receive further information on this subject, send an email. Predictpod will respond to every request as soon as possible and at the latest within 30 days.