Gnammus Privacy Policy

Last updated: 21 October 2026

Preamble

This Privacy Policy ("Policy") constitutes an Appendix to the Gnammus Terms and Conditions, hereinafter the "General Terms", and explains how RTLP S.r.l. ("RTLP") collects, uses, shares, retains and transfers the personal information of Users of the Platform, as well as the User's rights in that regard.

Matters not expressly governed by this Policy are governed by the General Terms.

Gnammus is a service of:

RTLP S.r.l. — Corte dei Mesagnesi 30 — 73100 Lecce (LE) — Italia

VAT number and tax code: 02683850743 — REA: LE-361688

Art. 1 — Definitions

1.1. For the purposes of this Policy, the definitions set out in Art. 1 of the General Terms apply. In addition, the following definitions apply.

a. Personal Data (or "Data"). Personal data means any information which, directly or indirectly, including in connection with any other information, including a personal identification number, renders a natural person identified or identifiable.

b. Usage Data. The information collected automatically through the Platform (including by third-party applications integrated into the Platform), including: the IP addresses or domain names of the computers used by the User connecting to the Platform, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's response (successful outcome, error, etc.), the country of origin, the features of the browser and operating system used by the visitor, the various time-related details of the visit (for example, the time spent on each page) and the details of the path followed within the Platform, with particular reference to the sequence of pages visited and to the parameters relating to the User's operating system and IT environment.

c. Data Subject. The natural person to whom the Personal Data relate.

d. Data Processor (or "Processor"). The natural or legal person, public administration or any other body which processes personal data on behalf of the Data Controller, as set out in this Policy.

e. Data Controller (or "Controller"). The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures relating to the operation and use of the Platform. Unless otherwise specified, the Data Controller is RTLP.

f. Protected Information. The optional information that the User may indicate among their dietary preferences and that reveals their religious beliefs (religion-based dietary rules) or concerns their health (food allergies and intolerances). It constitutes special categories of personal data within the meaning of Article 9 of Regulation (EU) 2016/679 and is processed as provided for in Art. 4.

g. Private Content. The Data, information and content that the User has uploaded to the Platform but for which the User has not requested publication (or for which publication cannot be requested), as further specified in Art. 7.2.

h. Restricted Access Content. The Data, information and content that the User has uploaded to the Platform and for which a restriction of access has been set (explicitly or implicitly), as further specified in Art. 7.3.

i. Public Content. The content that the User has published without specifying access restrictions (or for which access cannot be restricted), as further specified in Art. 7.4.

Art. 2 — Data Controller

2.1. The Data Controller of the Personal Data is RTLP S.r.l., against which the User may exercise the rights provided for by applicable law.

2.2. For requests, questions or reports concerning privacy or data processing, the User is invited to use one of the following communication channels:

Ordinary or registered post: RTLP S.r.l. — Corte dei Mesagnesi 30 — 73100 Lecce (LE) — Italia
Email: [email protected]
Certified email (PEC): [email protected]

Art. 3 — Data collected

3.1. Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during use of the Platform.

3.2. Unless otherwise specified, all Data requested by the Platform are necessary for the proper use of the Service. If the User refuses to provide them, RTLP may be unable to provide the Service.

3.3. Where the Platform indicates certain Data as optional, Users are free not to provide them, without this having any consequence on the availability of the Service; in that case, some functions of the Platform may provide results of lower relevance or quality for the User.

3.4. Users who are unsure which Data are mandatory are invited to contact RTLP at the contact details indicated in Art. 2.

3.5. Cookies and other tools that store information on the User's device or access it, used by the Platform or by the providers of the third-party services it uses, are described in the Cookie Policy, which distinguishes those strictly necessary for the operation of the Platform, those used for aggregate statistical measurement and the tool activated only with the User's consent.

3.6. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through the Platform.

3.7. Data collection activities may include:

personal data provided at registration, such as: name, nickname, profile photo, registration email address, preferences;
where the User chooses to sign in through a third-party authentication service offered on the login screen, the email address, basic profile data and account identifier received from that service, in accordance with the settings chosen by the User with that service; authentication takes place on the provider's pages, and the provider manages it as an independent controller in accordance with its own privacy policy;
date of birth and country of residence, provided at registration and processed for the purposes set out in Arts. 6.3 and 6.4;
data relating to purchases of and subscriptions to paid services, such as transaction identifier, amount, date, renewal status and billing data;
data connected with the verification of Business Profiles, such as VAT number or equivalent tax identifier, the official name and contact details of the business, company documents and the identity document of the legal representative, processed as provided for in Art. 14;
content created by the User, such as recipes, reels, posts, comments or audio and video content;
connections to users of the Platform, pages, groups, followers and modes of interaction through the Platform;
content provided by the User through camera functions, gallery settings or voice functions;
messages sent and received and their content;
data relating to location or to the use of connection networks, such as, by way of example: IP address, IPv6 availability, proxy use, upload/download bandwidth, time zone, connecting ISP;
eating habits or preferences, such as, by way of example: a liking for particular diets (vegetarian, high-protein, low-calorie), occasions of consumption (restaurant, home, street food), beverages (wine products, spirits, etc.);
any Protected Information indicated by the User, processed exclusively on the basis of explicit consent and as provided for in Art. 4;
views of and interaction with content (such as, for example, likes, follows, subscriptions, etc.);
time, frequency and duration of activities on the Platform;
type of device used (web browser, tablet, smartphone, etc.) and related details such as, for example, operating system version, screen resolution, system language;
the promotional campaign from which the app installation originates, recorded in aggregate form as provided for in Art. 5.2 of the Cookie Policy;
where the User has consented, the device's advertising identifier and installation, app-opening and registration events, as provided for in Art. 9, point (a);
information shared by the device through the permissions granted by the User, as specified in Art. 3.8;
ongoing activity on the device, such as, for example: foreground/background, mouse movements or actions that make it possible to distinguish fraudulent use or use by bots;
information obtained from third-party providers, such as connectivity or distribution providers (CDN, IP transit, network peering, etc.), including in connection with traffic analysis and optimisation or fraud prevention;
any information or data provided by the User in order to receive support.

3.8. Device permissions. The mobile app requests certain permissions from the operating system. Each of them is used exclusively for the function indicated and only when the User activates that function:

camera and audio recording: to take photographs and record videos with their sound, when the User chooses to create content;
media gallery: to enable the User to select photographs and videos already on the device and upload them to the Platform; access is limited to the files selected by the User;
precise location and approximate location: for the function for searching content and businesses near the User, which could not be provided without knowing where the User is;
network state and wireless connection state: to adapt the playback and upload quality of content to the connection conditions and to avoid large transfers on metered networks.

The processing of the data so collected is necessary for the performance of the functions requested by the User and is based on the legal basis set out in Art. 11.2, point (a). The User may revoke each permission at any time through their device settings; revocation makes only the corresponding function unavailable and does not affect access to the rest of the Service.

Art. 4 — Data not collected

4.1. In general, RTLP does not automatically collect or infer data unrelated to the field of food and wine or to the preparation or consumption of food and beverages. Purely by way of example, the following data are not collected: gender and sexual orientation, political or philosophical beliefs, national, ethnic or racial origin, membership of trade unions, social bodies and organisations, groups and associations.

4.2. Protected Information. The User may choose to indicate, on an optional basis, among their dietary preferences, information revealing their religious beliefs (religion-based dietary rules, such as halal or kosher) or concerning their health (food allergies and intolerances). Such information constitutes Protected Information.

4.3. Unprotected information. Dietary preferences and habits that reveal neither the religious beliefs nor the health of the User, such as, by way of example, a preference for vegetarian, high-protein or low-calorie diets, occasions of consumption or preferred product categories, do not constitute Protected Information. Such information is processed as Personal Data as provided for in Art. 3.7.

4.4. Explicit consent. Protected Information is processed exclusively on the basis of the User's explicit consent, given pursuant to Article 9(2)(a) of Regulation (EU) 2016/679. Such consent is collected separately from any other acceptance, at the time the User indicates the information, and is specific to the purposes set out in Art. 4.5 only.

4.5. Purposes. Protected Information is used exclusively for the following purposes:

providing the User with a more personalised experience, by flagging or excluding content, recipes and ingredients according to what the User has indicated;
calculating aggregate statistics on the appreciation of content, recipes and ingredients by all Users who have declared the same information, in order to make the flagging and exclusions referred to in the previous point more accurate.

The statistics referred to in the second point are calculated exclusively on groups of declaring Users whose size exceeds a minimum threshold predetermined by RTLP, below which no statistics are calculated or used. They do not produce any result referring to the individual User and are applied only to Users who have themselves declared the same information. RTLP does not use such statistics, or any other tool, to infer the Protected Information of Users who have not declared it.

4.6. Withdrawal of consent. The User may withdraw consent at any time, as easily as it was given, through the privacy settings of their account. Withdrawal results in the cessation of processing and the erasure of the Protected Information, and does not affect the lawfulness of processing carried out before withdrawal.

4.7. Optional nature. The provision of Protected Information is entirely optional. Refusal to give consent, or its subsequent withdrawal, has no consequence on the availability of the Service, as provided for in Art. 3.3.

4.8. Limits on processing. Under no circumstances is Protected Information shown to third parties on the User's profile or elsewhere, nor is it disclosed to third parties (including data processing or storage subcontractors). It contributes to the datasets used to train the algorithms referred to in Art. 6.1 only within the limits and in the manner provided for in Art. 4.5, and is not used to take the decisions indicated in Art. 15.5. Protected Information is never used to display advertisements or sponsored content, not even as partial, aggregated or derived data.

Art. 5 — Methods and place of processing

5.1. RTLP adopts all appropriate security measures to prevent unauthorised access to, or disclosure, modification or destruction of, Personal Data.

5.2. Processing is carried out using IT and/or telematic tools, with organisational methods and logic strictly related to the purposes indicated. In addition to RTLP, in some cases the Data may be accessed by other persons involved in the organisation of the Platform (administrative, sales, marketing and legal staff, system administrators) or by external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies), also appointed, where necessary, as Data Processors by RTLP. The updated list of Processors may be requested from RTLP at any time.

5.3. RTLP shares with any third-party providers the data strictly necessary for performing the activities entrusted to them, removing unnecessary data and, where possible, in anonymised or aggregated form or without personally identifying elements.

5.4. The Data are processed at RTLP's operating offices and in any other place where the parties involved in the processing are located. The User's Personal Data may be transferred to a country other than the one in which the User is located. For further information on the place of processing, the User may refer to the section on third-party providers (Art. 9).

5.5. Unless otherwise indicated in this Policy, Personal Data are processed and stored for as long as required by the purpose for which they were collected and may be retained for a longer period owing to any legal obligations or on the basis of Users' consent.

5.6. Anonymised, statistical or aggregated data, or data that cannot be traced back to a specific User, may be processed and retained indefinitely.

5.7. Whenever possible, the information and Data collected are processed automatically by RTLP's systems. However, in some cases, manual processing by staff authorised for that purpose may also be used.

Art. 6 — Purposes of processing

6.1. The User's Data are collected to enable RTLP to provide the Service and to offer a rewarding and personalised experience. The purposes of processing may include:

offering the User a personalised experience, including through content suggestion tools (sponsored and non-sponsored);
personalising the content displayed to the User (feed, collections, user interface, etc.);
translating content into different languages;
verifying that the Platform works properly and that the user experience is rewarding;
training and improving the proprietary algorithms used for the purposes indicated above — such as recommendation, machine translation and content moderation systems — as provided for in Art. 11.2, point (i);
providing measurements, services and statistical data (for example: popularity of content, list of followers, number of views), including in aggregate form;
measuring, in aggregate form, the effectiveness of promotional campaigns that generate new app installations and new registrations, as provided for in Art. 5.2 of the Cookie Policy;
subject to the User's consent, measuring promotional campaigns per device, optimising them and showing Gnammus advertisements to the User and to people with similar interests on third-party platforms, as provided for in Art. 9, points (a) and (m);
communicating with Users through the Platform (activity notifications or alerts) and through the contact details provided;
market, scientific or innovation research (only in anonymous, aggregated or statistical form).

6.2. Further purposes concern the need to comply with legal obligations, respond to requests or enforcement actions, protect rights and interests (of RTLP, of Users or of third parties) and detect any malicious or fraudulent activity.

6.3. Date of birth. The date of birth is processed exclusively for the following purposes:

verifying compliance with the minimum age for access to the Platform set out in Art. 3.1 of the General Terms;
applying the age-based visibility restrictions provided for in Art. 10 of the Moderation Policy, including the restriction concerning content on alcoholic beverages;
carrying out the checks referred to in Art. 13;
excluding Users under 18 years of age from the consent request referred to in Art. 6.5 of the Cookie Policy.

The date of birth is not shown on the User's profile or elsewhere on the Platform and falls within the Private Content referred to in Art. 7.2.

6.4. Country of residence. The country of residence is processed to determine the applicable minimum age under Art. 13 and the age required to access content relating to alcoholic beverages under Art. 10.6 of the Moderation Policy, as well as for further purposes connected with the operation of the Service, including the application of the geographical restrictions provided for in Art. 10 of the same Policy, determining the availability of paid services in the User's country, applying the campaign measurement rules referred to in Art. 5.2 of the Cookie Policy and fulfilling applicable tax obligations.

7.1. The sharing by RTLP with third parties of data collected or provided by the User is governed differently depending on the category to which the content belongs.

7.2. Private Content

These are the Data, information and content that the User has uploaded to the Platform but for which the User has not requested publication (or for which publication cannot be requested, such as the Protected Information referred to in Art. 4).

These Data are not disclosed to third parties, are not published on the Platform and are not stored or processed outside the IT platforms of RTLP and of any of its providers.

This category of data includes all information and data collected automatically, except for those which, with the User's consent, are disclosed to the advertising networks referred to in Art. 9, point (m).

7.3. Restricted Access Content

These are the Data, information and content that the User has uploaded to the Platform and for which a restriction of access has been set (explicitly or implicitly).

Examples of explicit access restriction are content that the User decides to make available to particular users or categories (recipes available only to followers or to specific groups). Some content is implicitly marked as restricted access: an example is messages between users or between a User and the Platform (for example reports, requests for help, etc.), to which the Platform automatically restricts access.

These data will be processed with the same tools and methods reserved for Public Content, but their visibility will be limited to the senders/recipients of the content itself (by means of ACL — Access Control List — mechanisms).

The User acknowledges that RTLP has no control over any disclosure of Restricted Access Content by its legitimate recipients, including outside the Platform. The User further acknowledges that any deletion of Restricted Access Content (or its transformation into Private Content) or any change to the persons authorised to view it may require technical time to implement and that, in any event, it cannot affect any copies, shares or disclosures already made.

7.4. Public Content

This is all content that does not fall within the preceding categories, i.e. content that the User has published without specifying access restrictions (or for which access cannot be restricted). Examples of content that cannot be restricted are the username or nickname, the profile or cover photo, the tagline, interactions such as likes or comments and, in general, all publishable fields for which no restriction can be set from the user interface.

Such content, once approved by the moderation services, may be made publicly available and will be visible to everyone within (and, in some cases, outside) the Platform, in certain cases even without an account.

The User acknowledges that the removal, restriction or deletion of public content may require technical time to implement and that, in any event, it cannot affect any copies, shares or disclosures already made, nor any disclosure by third parties.

Art. 8 — Cookies and tracking technologies

8.1. The Platform may use cookies, i.e. small pieces of data stored in the User's browser that may be used for various tracking or technical purposes.

8.2. For a detailed description of the use of cookies by RTLP and by third-party providers, the User is invited to consult the Cookie Policy.

Art. 9 — Third-party providers

9.1. Without prejudice to Art. 7, the list of third-party providers to which the User's Data or information may be transmitted, or which may process them, is set out below. RTLP selects its third-party providers with particular attention to privacy issues, favouring "privacy-first" policies that minimise the processing of Data or allow the anonymisation of the data collected.

9.2. Role of the parties indicated. The parties referred to in points (a) to (j) and point (l) process the Data as Data Processors, on the basis of an agreement entered into with RTLP pursuant to Article 28 of Regulation (EU) 2016/679. The party referred to in point (k) acts as an independent controller for the purposes and within the limits indicated in the relevant entry. The party referred to in point (f) also acts as an independent controller solely for the purposes indicated in the relevant entry. The parties referred to in point (m) act in the roles indicated in the relevant entry.

9.3. Transfers outside the European Economic Area. Where the place of processing indicated in the entries below is outside the European Economic Area, the transfer takes place on the basis of the instrument specified in each entry, namely the European Commission's adequacy decision of 10 July 2023 on the EU-U.S. Data Privacy Framework, for providers certified under it, the adequacy decision concerning Canada (Decision 2002/2/EC), the adequacy decision concerning Israel (Decision 2011/61/EU), or the Standard Contractual Clauses adopted by Implementing Decision (EU) 2021/914, supplemented by the supplementary measures deemed necessary following the transfer impact assessment. The User may request a copy of the safeguards adopted by writing to the contact details indicated in Art. 2.

a. AppsFlyer

Company: AppsFlyer Ltd. (Israel) — Place of processing: European Union — Basis for transfer: European Commission adequacy decision concerning Israel (Decision 2011/61/EU); Standard Contractual Clauses for support access from countries not covered by an adequacy decision

AppsFlyer is a promotional campaign measurement service. RTLP uses it, solely for Users who have reached the age of majority and have consented to it, to find out which campaigns generate installations, app openings and registrations, to optimise campaigns and to enable the advertising networks referred to in point (m) to show Gnammus advertisements to the User and to people with similar interests. The provider receives an app installation identifier, the device's advertising identifier, the IP address, certain technical characteristics of the device and the app, and the installation, app-opening and registration events, associated with the originating campaign, and discloses them to the advertising networks. On iOS devices the service operates only if the User also authorises the operating system's tracking request. No content or data entered or viewed on the Platform, nor the Protected Information referred to in Art. 4, are disclosed. The service is activated exclusively with the User's prior consent, as provided for in Art. 6.5 of the Cookie Policy, and the processing is based on the legal basis set out in Art. 11.2, point (b). The provider's representative in the European Union is AppsFlyer Germany GmbH. Further information is available in Art. 4 of the Cookie Policy.

b. AWS

Company: Amazon Web Services EMEA SARL (Luxembourg) — Place of processing: European Union

Amazon Rekognition is a tool for checking visual content offered by Amazon Web Services. RTLP uses this tool to assess some of the content for which the User has requested publication. The integration arrangements provide that the images and videos for which the User has requested publication are exchanged with the provider (stripped of any metadata or information relating to the author) in order to receive an assessment of the content (for example, regarding the possible presence of prohibited or restricted material such as violence, hate, alcoholic beverages, etc.). Any access by the provider from outside the European Economic Area is governed by the data processing agreement entered into with RTLP.

c. Bunny.net

Company: BunnyWay d.o.o. — Place of processing: European Union

Bunny.net is a traffic optimisation, protection and distribution service. RTLP uses Bunny.net for the storage and distribution of audio-video content published by Users. The integration arrangements with this provider provide that BunnyWay processes all or part of the audio/video content for which the User has requested publication and which is ready to be distributed to the public, and distributes such content in the manner established by RTLP.

d. Cloudflare

Company: Cloudflare, Inc. — Place of processing: United States of America — Basis for transfer: EU-U.S. Data Privacy Framework

Cloudflare is a traffic optimisation, protection and distribution service. RTLP uses Cloudflare to provide Users with a better user experience and to protect some of its IT systems. The integration arrangements provide that Cloudflare filters all traffic of the Platform, i.e. the communications between the Platform and the User's browser, also enabling statistical data on such traffic to be collected.

e. DeepL

Company: DeepL SE — Place of processing: European Union

DeepL is a service for translation between different languages. RTLP uses DeepL to translate some of the content for which the User has requested publication, before it is made available globally. The integration arrangements provide that the texts to be translated (stripped of information relating to the author) are exchanged with DeepL in order to obtain the version in one or more languages.

f. Didit

Company: Didit Identity Spain, S.L. — Place of processing: European Union

Didit is an identity verification and document validation service. RTLP uses Didit for the identity and document checks provided for in this Policy, such as the manual verification referred to in Art. 14.4, solely in respect of the Users subject to them. The integration arrangements provide that the identity documents and, where required, the company documents uploaded by the User are transmitted to the provider for the extraction of the identifying fields, including by reading the document's NFC chip, and for checking the validity of the document itself. The provider may use pseudonymised data derived from the checks, as an independent controller, for the security of its own service and for fraud prevention.

g. Embrace

Company: Embrace Mobile, Inc. — Place of processing: European Union

Embrace is a system for detecting errors, crashes and performance issues in mobile applications. RTLP uses it to identify and fix technical, security or performance issues in the app. The provider receives data relating to the device and to app errors. Any access by the provider from outside the European Economic Area for support and maintenance purposes is governed by the Standard Contractual Clauses adopted by Implementing Decision (EU) 2021/914, provided for in the data processing agreement entered into with RTLP. Further information is available in Art. 4 of the Cookie Policy.

h. Fathom Analytics

Company: Conva Ventures Inc. (Canada) — Place of processing: European Union, for the data of visitors from the European Economic Area — Basis for transfer: European Commission adequacy decision concerning Canada (Decision 2002/2/EC)

Fathom Analytics is a service for the statistical measurement of website use. Further information is available in Art. 5 of the Cookie Policy.

i. Google Natural Language AI and Visual Moderation

Company: Google LLC — Place of processing: United States of America — Basis for transfer: EU-U.S. Data Privacy Framework

Google Natural Language AI and Google Visual Moderation are tools for checking text or visual content. RTLP uses these tools to assess some of the content for which the User has requested publication. The integration arrangements provide that the texts or the audio, video or image content for which the User has requested publication are exchanged with Google (stripped of any metadata or information relating to the author) in order to receive an assessment of the content (for example, regarding the possible presence of prohibited material such as violence, racial hatred, etc.).

j. Microsoft Azure AI Content Safety

Company: Microsoft Ireland Operations Limited (Ireland) — Place of processing: European Union

Azure AI Content Safety is a tool for checking text or visual content offered by Microsoft. RTLP uses this tool to assess some of the content for which the User has requested publication. The integration arrangements provide that the texts or images for which the User has requested publication are exchanged with the provider (stripped of any metadata or information relating to the author) in order to receive an assessment of the content (for example, regarding the possible presence of prohibited material such as violence, hate, etc.). Any access by the provider from outside the European Economic Area is governed by the data processing agreement entered into with RTLP.

k. Stripe

Company: Stripe Payments Europe, Limited and Stripe Technology Europe, Limited, parties to the service agreement, and Stripe Technology Company, Limited, the provider's main establishment in the European Union (a limited liability company incorporated under Irish law, with its registered office at One Wilton Park, Wilton Place, Dublin 2, D02 FX04, Ireland) — Place of processing: Ireland (European Union), with transfers to Stripe, LLC — United States of America — Basis for transfer: EU-U.S. Data Privacy Framework

Stripe is a payment management service. RTLP uses Stripe to obtain the authorisation to charge and to collect the fees for the paid services of the Platform, such as Gnammus Certified Business. The integration arrangements provide that the authorisation and payment are made by the User directly on a page managed by Stripe: payment card data do not pass through RTLP's systems and are not stored by RTLP. For services subject to verification, such as the verification referred to in Art. 14, the charge is made only upon successful completion of the verification; in the event of a negative outcome, no charge is made and the authorisation lapses.

Solely with regard to the processing of payment data, Stripe acts as an independent controller, independently determining the purposes and means, including in relation to its own obligations concerning fraud prevention and anti-money laundering legislation, and transmits the data necessary to execute the transaction to payment method providers and acquirers; Stripe's privacy policy applies to such processing. The updated list of sub-processors and group companies involved in providing the service, indicating the country of each, is published by the provider at https://stripe.com/legal/service-providers. RTLP remains the Data Controller of the data relating to the purchase and the subscription — such as transaction identifier, amount, date, renewal status and billing data — processed for the performance of the contract and for compliance with tax and accounting obligations.

l. WonderPush

Company: Wonder Push SAS (France) — Place of processing: European Union

WonderPush is a system for sending push notifications to mobile devices. RTLP uses this service to send notifications and alerts to Users who choose to receive them (for example, when a User receives a "like", gains a new follower or a piece of content has been published). The integration arrangements provide that the provider receives the identifier assigned by the operating system for receiving notifications, an app installation identifier, certain technical characteristics of the device — such as platform, operating system version, make and model, language, country, time zone and mobile network operator — the date the app was last opened and interactions with the notifications received, and delivers the message sent by RTLP. The service is activated exclusively if the User authorises the sending of notifications. The integration is configured so as to exclude the collection of the device's location; neither the Protected Information referred to in Art. 4 nor any other attributes of the User's profile are transmitted to the provider. Upon revocation of the authorisation, the identifiers are deleted by the provider.

m. Advertising networks

Companies: Meta Platforms Ireland Limited (Ireland); Google Ireland Limited (Ireland) — Onward transfers: to Meta Platforms, Inc. and Google LLC (United States), on the basis of the European Commission's adequacy decision of 10 July 2023 on the EU-U.S. Data Privacy Framework

Where the User has consented, the data indicated in point (a) are disclosed via AppsFlyer to Meta and Google, which use them to attribute installations and registrations to Gnammus campaigns, to optimise campaigns and to show Gnammus advertisements to the User and to people with similar interests on their own services.

Meta. For the collection of the data and their transmission to Meta Platforms Ireland Limited, RTLP and Meta are joint controllers pursuant to Article 26 of Regulation (EU) 2016/679, in accordance with Meta's Controller Addendum (https://www.facebook.com/legal/controller_addendum). For campaign measurement and reporting, Meta processes the data on behalf of RTLP as a Data Processor; for processing subsequent to the transmission, it acts as an independent controller. Information on the processing carried out by Meta, including the legal bases and how to exercise rights in respect of Meta, is contained in Meta's privacy policy (https://www.facebook.com/privacy/policy). For the collection and transmission of the data, the User may exercise their rights in respect of and against RTLP or Meta.

Google. Google Ireland Limited receives the data as an independent controller, under the Google Ads Controller-Controller Data Protection Terms, and processes them in accordance with its own privacy policy (https://policies.google.com/privacy).

Art. 10 — Further information on processing

10.1. For operational and maintenance needs, the Platform and any third-party services it uses may collect system logs, i.e. files that record interactions and that may also contain Personal Data, such as the User's IP address.

10.2. RTLP reserves the right to amend this Policy at any time, notifying Users on the Platform. The User is invited to consult this page frequently, referring to the date of last update indicated. Where the amendments concern processing whose legal basis is consent, RTLP will collect the User's consent again, where necessary, before carrying out such processing.

10.3. At the User's request, in addition to the information contained in this Policy, RTLP may provide additional and contextual privacy notices concerning specific Services or the collection and processing of Personal Data.

Art. 11 — Legal basis for processing

11.1. The terms of this Policy are governed by Italian law; in particular, the EU rules on the protection of personal data and Regulation (EU) 2016/679 (GDPR) apply.

11.2. The processing of the User's information in the manner and for the purposes described in this Policy is based on the following legal bases:

a. Performance of a contract. RTLP processes the information necessary to fulfil its contractual obligations towards the User, namely to provide the services indicated in the General Terms. This legal basis covers the personalised presentation of content — feed ranking, collections and suggestions — which is an essential function of the Service requested by the User and not an ancillary one: the Platform is designed to enable the User to discover content relevant to the food interests declared and shown by the User, and without such presentation the Service would not be the one that is the subject matter of the contract.

b. Consent. RTLP processes the information for which the User has given consent. When processing is based on consent, RTLP may retain the Personal Data until such consent is withdrawn. RTLP may also be required to retain the Personal Data for a longer period in order to comply with a legal obligation or by order of an authority. At the end of the retention period, the Personal Data will be erased. Until that period expires, the User has the right to withdraw consent.

c. Legitimate interests. RTLP processes the User's information as necessary for its own legitimate interests and those of other parties. These interests include: ensuring the security of the Platform and of Users; preventing fraud, abuse and automated use; protecting the reliability of the certification system; measuring, in aggregate form, the use of the Service and the effectiveness of the promotional campaigns that promote its uptake; developing and improving the Service. Any obligation to process or retain data in order to comply with legal requests constitutes a legitimate interest. RTLP has carried out and documented the balancing test between each of those interests and the rights of Users; the User may exercise the right to object as provided for in Art. 12.

d. Public interest. RTLP processes the User's information to the extent necessary in the public interest, for example by conducting research or promoting safety, security and integrity, or for the exercise of any official authority vested in it.

e. Vital interests. RTLP processes information to protect persons or prevent harm (for example, to save the life of, or protect the physical safety of, the User or other persons).

f. Legal obligations. RTLP processes the User's information as necessary to comply with obligations specifically laid down by law or in compliance with legally binding acts.

g. Consent of minor Users. RTLP does not allow registration by Users who have not reached the minimum age for information society services laid down by the law of their country of residence, as provided for in Art. 13. Consent to processing is therefore always given by Users who have reached the age required to give it validly under Article 8 of Regulation (EU) 2016/679 and, for Users resident in Italy, under Article 2-quinquies of Italian Legislative Decree No. 196/2003. It remains the case that, pursuant to Art. 3.2 of the General Terms, a User who is under 18 years of age accesses the Platform with the consent of the person exercising parental responsibility.

h. Explicit consent for Protected Information. The Protected Information referred to in Art. 4 constitutes special categories of personal data. Its processing is based on the explicit consent given by the User pursuant to Article 9(2)(a) of Regulation (EU) 2016/679, collected separately as provided for in Art. 4.4, in addition to the legal basis referred to in point (b).

i. Training and improvement of algorithms. The training of RTLP's proprietary algorithms does not constitute an autonomous purpose of processing, but is instrumental to the purposes indicated in Art. 6.1 and follows the legal basis of each of them. In particular:

the training of the recommendation and personalised content presentation systems is based on the performance of the contract referred to in point (a), as it adds no further processing to the personalisation already described in Art. 6.1;
the training of the machine translation and content moderation systems uses datasets built by aggregating or anonymising the source information, which do not make it possible to trace back to the individual User and therefore do not constitute personal data; the processing necessary to produce such datasets is based on the legitimate interest referred to in point (c).

Training uses the Protected Information referred to in Art. 4 only within the limits provided for in Art. 4.5, i.e. in the form of aggregate statistics relating to all declaring Users and calculated only above a minimum size threshold; for that part, the processing is based on the explicit consent referred to in point (h). RTLP refrains from any activity aimed at re-identifying Users from the datasets used and does not build, from content or behaviour, derived attributes revealing the health or religious beliefs of Users who have not declared them.

11.3. If the User has doubts about the lawfulness of the processing of specific data, or about the legal basis adopted for it, the User is invited to contact RTLP at the contact details indicated in Art. 2 for clarification.

Art. 12 — User's rights

12.1. The User's rights vary depending on the applicable legal basis. As a general rule, irrespective of the legal basis adopted, the User always has the right to request access to, and rectification and erasure of, the information concerning them.

12.2. Within the limits provided for by law, the User has the right to:

withdraw consent at any time;
object to the processing of their Data;
access their Data;
verify their Data and request rectification;
obtain restriction of processing;
obtain the erasure or removal of their Personal Data;
receive their Data or have them transmitted to another controller;
not be subject to decisions based solely on automated processing which produce legal effects concerning them or similarly significantly affect them, as provided for in Art. 15;
lodge a complaint with the competent supervisory authority.

12.3. The User's Personal Data may be used by RTLP in legal proceedings or in the stages preparatory to their possible commencement, in order to defend itself against abuse of the Platform or of the related Services by the User. The User declares that they are aware that RTLP may be required to disclose the Data by order of public authorities.

12.4. Further information regarding the processing of Personal Data may be requested from RTLP at any time using the contact details indicated in Art. 2. RTLP will make all reasonable efforts to settle any disputes through mediation tools and bodies.

12.5. Verification of the requester. RTLP acts on requests after ascertaining that they come from the account holder, normally through the account itself or the email address associated with it, and may request the additional information necessary for that purpose pursuant to Article 12(6) of Regulation (EU) 2016/679.

Art. 13 — Minors

13.1. Minimum age. Access to the Platform is reserved for Users who have reached the minimum age set out in Art. 3.1 of the General Terms, namely 14 years or any higher age laid down by the law of the User's country of residence. The thresholds applied reflect the legislation in force in each country and are subject to updating if that legislation changes.

13.2. Verification at registration. At registration, RTLP compares the date of birth and country of residence declared by the User with the applicable threshold and does not allow the account to be created if the age requirement is not met. This verification constitutes the reasonable effort made by RTLP within the meaning of Article 8(2) of Regulation (EU) 2016/679.

13.3. Suspected accounts. Where it emerges, or there are reasonable grounds to believe, that a User has not reached the required minimum age, RTLP suspends the account as a precautionary measure and asks the User for evidence capable of demonstrating that the age requirement is met, giving the User 14 days to respond. The account remains suspended for the entire period and until the verification is concluded. Any Data provided for this purpose are processed exclusively for the purposes of the verification and erased at the end of it.

13.4. Outcome of the verification. If no reply is received within the period referred to in Art. 13.3, or if it is confirmed that the minimum age has not been reached, RTLP deletes the account and erases the Personal Data associated with it, except for data whose retention is required by a legal obligation. RTLP may, at its discretion, grant the User a longer period where circumstances so justify.

13.5. Requests from parents and guardians. A parent or the person exercising parental responsibility may at any time request from RTLP information on the minor's Data, their rectification or erasure, as well as the deletion of the account, by writing to [email protected] as indicated in Art. 2. RTLP acts on the request after verifying the requester's parental responsibility and the link between the minor and the account, and may request the necessary evidence for that purpose.

Art. 14 — Identity verification for Gnammus Certified Business

14.1. Scope. This article governs the processing of Data connected with the verification process provided for in Art. 3 of the Gnammus Certified Business Terms of Use. Such processing concerns exclusively Users who purchase the paid services and does not concern other Users of the Platform.

14.2. Standard verification. Verification is normally carried out by sending a one-time code to an official contact address of the business, such as its certified electronic mail (PEC) address or an equivalent tool in its country. The Data processed for this purpose include the VAT number or equivalent tax identifier, the name of the business and its official contact details.

14.3. Data from public registers. RTLP may obtain the official contact details and identifying data of the business from public registers, such as the registers kept by chambers of commerce or equivalent bodies. Pursuant to Article 14(3)(c) of Regulation (EU) 2016/679, the information relating to such Data — including an indication of the source — is provided to the data subject at the latest at the time of the first communication, i.e. in the message by which the one-time code is sent.

14.4. Manual verification. Where the verification referred to in Art. 14.2 is not possible, RTLP carries out a manual verification, directly or through the provider indicated in Art. 9, point (f). RTLP chooses, on a case-by-case basis, the most appropriate method among those listed in Art. 3.2 of the Gnammus Certified Business Terms of Use. Depending on the method used, the verification may involve the processing of the following Data:

company documents, such as an extract from the companies register kept by the Chamber of Commerce or the VAT registration certificate;
identity document of the legal representative, including by reading the NFC chip;
image of the User and of the document shown, where verification is carried out by video identification conducted by an operator; the session may be recorded and the recording is deleted as provided for in Art. 14.5;
domain name indicated by the User and the outcome of the technical check carried out on the related public records, where verification is carried out by domain verification.

14.5. Retention. The company and identity documents and the recordings acquired for verification purposes are deleted within 30 days of the notification of its outcome. RTLP retains only the outcome of the verification, the VAT number or equivalent tax identifier and the activation date of the current certification, for the duration of the certification service and for any further period required by legal obligations. Where the negative outcome is due to the falsity of a document, RTLP also retains the finding of the discrepancy identified — and not the document — for as long as necessary to exercise or defend legal claims, on the basis of the legitimate interest referred to in Art. 14.7.

14.6. Publication of certification details. The certification details shown on the Business Profile include an indication that certification has been granted, the legal name of the business, the VAT number or equivalent tax identifier and the activation date of the current certification, which remains unchanged upon renewal. Such information constitutes Public Content within the meaning of Art. 7.4 and is visible to anyone viewing the Business Profile, even without an account. Publication is the very subject matter of the service purchased and ceases when the certification service ends.

14.7. Legal basis. The processing referred to in this article, including the publication referred to in Art. 14.6, is based on the performance of the contract under Art. 11.2, point (a), and on RTLP's legitimate interest in preventing fraud and protecting the reliability of the certification system under Art. 11.2, point (c). The User's consent is not required.

Art. 15 — Automated decision-making

15.1. Automated processing. In providing the Service, RTLP uses automated systems for: the moderation of content for which the User requests publication; the application of the geographical and age-based restrictions provided for in Art. 10 of the Moderation Policy; the detection of fraudulent, abusive or automated activity; the ranking and personalisation of the content shown to the User.

15.2. Logic involved. The moderation systems compare content with the rules of the Moderation Policy and assign it a compliance assessment on the basis of models trained as provided for in Art. 11.2, point (i), also making use of the analysis tools indicated in Art. 9, points (b), (i) and (j). The restriction systems apply to the content the restrictions provided for the jurisdiction and age group of the recipient User. The content ranking systems use the User's interactions within the Platform and the preferences indicated by the User.

15.3. Consequences. Automated decisions may result in the refusal to publish content, its subsequent removal or the restriction of its visibility. The ranking and personalisation of content affect only the order in which content is presented to the User and do not produce legal effects concerning the User or similarly significantly affect the User.

15.4. Human intervention and review. A User who is the subject of a decision referred to in Art. 15.3 receives a statement of reasons and may request its review in accordance with the procedure provided for in Art. 14 of the Moderation Policy. The review is carried out by RTLP staff and is not entrusted to automated systems. The User's right to express their point of view and to contest the decision pursuant to Article 22(3) of Regulation (EU) 2016/679 remains unaffected.

15.5. Special categories of data. Decisions that may result in the refusal to publish content, its removal, the restriction of its visibility or the suspension of the account are under no circumstances based on special categories of personal data within the meaning of Article 9 of Regulation (EU) 2016/679, including the Protected Information referred to in Art. 4. The ranking and personalisation of content, which under Art. 15.3 do not produce legal effects concerning the User or similarly significantly affect the User, take into account the Protected Information that the User has chosen to declare, on the basis of the explicit consent referred to in Art. 4.4 and only within the limits provided for in Art. 4.5.

15.6. Advertising on third-party platforms. Where the User has consented, the advertising networks referred to in Art. 9, point (m), use the data received to select the Gnammus advertisements to be shown to the User and to identify people with similar interests. Such processing does not produce legal effects concerning the User or similarly significantly affect the User. Withdrawal of consent, as provided for in Art. 6.5 of the Cookie Policy, stops the disclosure of the data to the networks.

Art. 16 — Reference to the General Terms

16.1. Matters not expressly governed by this Policy are governed by the General Terms, including — by way of example — the provisions on governing law, jurisdiction, limitation of liability, the severability clause and jurisdiction-specific provisions.