INFORMATION PURSUANT TO ARTICLE 13 OF EU REG. NO. 2016/679 (“GDPR”)

This Privacy Policy describes what personal data is collected by KuriU S.r.l. (“KuriU”), for what purposes, and how it is processed. Below, you will also find the information needed to exercise your rights under the GDPR.

1. WHO PROCESSES YOUR DATA – DATA CONTROLLER

KuriU S.r.l., with registered office in Rome (Italy), Viale Bruno Buozzi n. 60, VAT no. 16956811000, email: privacy@kuriu.it (hereinafter “KuriU” or the “Data Controller”), is the controller of your personal data.

2. WHAT DATA WE PROCESS – TYPE OF DATA PROCESSED

We may process the following types of personal data:

• Contact data: such as your phone number and name (if provided), collected when you interact with the Cicerome service via WhatsApp, Telegram, or iMessage.
• Voluntary information: such as messages you send to us while using the service.
• Usage data: such as IP address, device type, and browsing behavior on www.cicerome.kuriu.it.
• Feedback: if you voluntarily provide feedback on the service.

We do not collect or process payment or billing data, as the service is completely free of charge.

3. HOW WE COLLECT YOUR DATA – METHOD OF DATA COLLECTION

• Directly from you, when you send us a message to use the service or when you interact with the Platform.
• Automatically, through cookies and similar technologies when you visit the Platform. Please refer to our Cookie Policy for details.
  
  

4. WHY AND FOR HOW LONG WE PROCESS YOUR DATA – PURPOSE AND LEGAL BASIS FOR DATA PROCESSING

a) To provide the Cicerone service
We process your data to deliver the requested information and personalized suggestions via messaging platforms.

• Legal basis: performance of a service requested by the data subject (Art. 6.1.b GDPR)
• Retention period: for the duration necessary to provide the service. Data may be anonymized and stored for statistical purposes thereafter.

b) To request feedback
We may contact you via the same platform (WhatsApp, Telegram, iMessage) to ask for your opinion.

• Legal basis: legitimate interest (Art. 6.1.f GDPR) in improving our services
• Retention period: until the feedback is processed and then anonymized.

c) To protect rights and prevent abuse
We may retain certain identifiers (e.g., phone number) to prevent misuse (e.g., repeated free trials).

• Legal basis: legitimate interest (Art. 6.1.f GDPR)
• Retention period: up to 5 years, only if necessary to prevent abuse or protect rights.
  
  

5. NATURE OF THE DATA PROVISION

Providing your data is necessary to access and use the service. Without it, we cannot respond to your requests.

6. WHERE YOUR DATA IS PROCESSED – DATA TRANSFER

Data is processed at KuriU’s offices and by selected suppliers operating within the European Union. All suppliers have signed agreements pursuant to Art. 28 GDPR where applicable.

7. WHO WE SHARE YOUR DATA WITH – RECIPIENTS

• Service providers: who support us in operating the service (e.g., hosting, analytics), bound by data processing agreements under Art. 28 GDPR.
• Authorities: only when required by law or to protect our rights.

A full list of data processors is available upon request at privacy@kuriu.it.

8. MINORS

The Platform and Services are intended for users aged 18 and over. If you believe a minor has shared data with us, please contact us to request its removal.

9. YOUR RIGHTS

At any time, you may request:

• Access to your personal data
• Rectification or erasure
• Restriction or objection to processing
• Data portability
• Withdrawal of any consent (if applicable)

To exercise your rights, contact us at privacy@kuriu.it.
You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali), pursuant to Art. 77 GDPR.

10. COOKIES AND TRACKING TECHNOLOGIES

We use cookies and similar tools on the Platform. For more information, please refer to the Cookie Policy available via the widget on the homepage.

11. CHANGES TO THIS POLICY

We may update this Privacy Policy. Any substantial changes will be communicated through the Platform. Please refer to the latest version published online.

Updated version as of: 14th May 2025