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

This Policy describes which of your personal data is collected by KuriU S.r.l., for what purposes and how it is processed. Below you will also find the information you need to exercise your rights under the GDPR.

In general, we collect your data when you browse on the website www.cicerome.kuriu.it (hereinafter, “Platform“), when you subscribe to the relevant services provided via Whatsapp (“Services”) and/or when you buy them. Please note that the personal data collected during these processes will be processed in order to enable you to enjoy the services offered by the Platform, as outlined below.

1. Who processes your data: the data controller

KuriU S.r.l., Italian tax registration and VAT number 16956811000, with registered office in Rome, viale Bruno Buozzi n. 60, privacy@kuriu.it (hereinafter “KuriU” or “Data Controller”) is the controller of your personal data.

2. What data we process – Type of data processed

Your contact and purchase data. We will process the details you provide us with (e.g., name, e-mail address, telephone number and all the information provided during the use of the service) when you subscribe on the Platform to receive the relevant Services.

Your payment and invoicing data. We will retain the payment and invoicing data that you provide to us with (e.g., your credit card number, contact and personal data) when you purchase a Service, in order to process your order and provide you with this.

Information on the use of the Platform and on your activities on the Platform. Your use of the Platform implies the processing of the browsing data and the device that you are using and your IP address (i.e. the number that identifies a specific device connected to the internet and is required in order for your device to communicate with websites). We may analyze the website you browsed from, what you did and what you did not do on our Platform.

3. Where we get your data – Method of data collection:

Directly from you. For example, if you subscribe for a Service, ask us a question by e-mail.

Through your use of the Site’s features. We use cookies and other technologies, such as pixel tags on our Platform, in order to collect data about your usage. To learn more, please review our Cookie Policy.

4. Why and for how long we process your data – Purpose and legal basis for data processing; retention period
5. a) To provide you with services on the Platform. We will use your data to provide you with the Service available on the Platform and, where applicable, to process your order, to confirm your purchase and to manage any Service related to it. Without your data, we cannot provide you with the Service and manage and process your order.

The legal basis of such data processing is the performance of your request, according to the general terms and conditions of sale that you have accepted. The data retention period of your data is equal to the period required to process the order and to the period necessary to provide you with the Service requested (provided that if other processing activities, such as management of the administrative position, are applicable, the retention period shall be the one indicated in this notice in relation to such processing). Thereafter, the data will be anonymized and used only for statistical and analytical purposes.

1. b) To manage your administrative status correctly. We will process your data for accounting, administrative and tax purposes, directly connected to our business activities as required by the applicable legislation.

The legal basis of such data processing is compliance with the legal obligations. The data retention period is equal to that required by law (specifically, civil, tax, anti-money laundering, banking and public security law).

1. c) To request your feedback. After the use of the service, we may ask you via WhatsApp to provide us with your feedback with your opinion concerning the service provided.

The legal basis of such processing is our legitimate interest in improving our Services. The retention period is equal to the time required to process your feedback, thereafter, the data will be anonymized and used for statistical and analytical purposes.

1. d) To prevent or control unlawful conduct or to protect and enforce rights. For example, we may use your data to prevent or prosecute torts, violations of our own or third parties’ intellectual/industrial property rights or computer crimes or crimes committed through telematic networks. The legal basis for such processing is our legitimate interest in protecting our rights and preventing wrongdoing. The data retention period for your data is equal to the time reasonably necessary to enforce our rights from the time we learn of the wrongdoing or its potential commission: in particular, since the free trial of the Service is available only once, we may store your phone number for at least 5 years from when it has been collected.
2. Nature of provision of personal data

For the purposes (a) to (d) in the previous paragraph, the provision of data is necessary to enable you to use the services on the Platform.

6. Where your data is processed – data transfer

The data will be processed and stored at KuriU’s offices and at KuriU’s suppliers, with whom KuriU has entered into agreements for the processing of personal data in accordance with Article 28 GDPR, within the European Union.

7. Who we share your data with – recipients of personal data

Provided that, where required by law, we will obtain your prior consent and complete any formalities required by law, we may share your data with the following third parties.

With service providers. KuriU uses third-party services (service providers, payment gateways and other entities that provide banking services, IT providers) which may act as autonomous data controllers or as data processors: in this second scenario we will enter into a data processing in accordance with Article 28 GDPR. The updated list of third-party providers, operating as data processors under Art. 28 GDPR, is available by writing to KuriU’s addresses above.

With judicial or administrative authorities. Where we believe we must do so in order to comply with a court order or authority, or to fulfil legal obligations or in order to judicially protect KuriU, or third parties, we may disclose your data to the Judicial Authority or an Administrative Authority.

8. Minors

Our Platform and our Services are not intended for children under the age of 18, but are intended for an adult audience. If you are a parent or guardian and you think your child has submitted data to us, you can contact us at the addresses above.

9. Your rights

You can contact KuriU to request access to your personal data, rectification, erasure or restriction of processing, to object to processing and to request the portabilitỳ of your data; you can also withdraw your consent at any time (this will not affect the lawfulness̀ of processing based on the consent given before withdrawal).

When you exercise your right of access, you have the right to know whether your data are being processed, what the purpose of the processing is, what categories of data are being processed, who the recipients or categories of recipients are to whom your data are disclosed (and, if they reside in a third country on the basis of what guarantees), the retention period of your data (or the criteria for determining the retention period), whether any automated processing is taking place (e.g. by profiling) and what the logic of such processing is, the origin of the data (if not initially collected by KuriU). You can exercise your rights by contacting KuriU at the above addresses.

You have the right to lodge a complaint with the competent supervisory authority pursuant to and within the limits of Article 77 GDPR.

You can control and disable cookies and other profiling tools. To find out how we use cookies and other profiling tools, go the Cookie Policy section avalaible by clicking on the relevant widget in homepage (cicerome.kuriu.it).

10. What do we do if we change this policy

We may make changes to our privacy policy. We will notify you in connection with such changes as required by law. We will also post an updated version on our Platform. It will have a different date than the one shown below. Please check the Platform periodically for updates.

Updated version as of 18th April 2025.