Privacy policy

PRIVACY POLICY - 01/02/2015

Under Article 13 of Legislative Decree no. 30 June 2003, n. 196 ( "Code regarding the protection of personal data"), we inform the user of the Service SOLO Virtual PoS (hereinafter "SOLO" or the "Service") that the owner of Use of Data is SOLO Srl (Hereinafter the "Company"), based  in Milan, Via Quaranta n. 40. The data may be treated, only and exclusively to provide services requested by Lemonway SAS - a French company based in Montreuil (France) - as external Data Processor. The SOLO service is provided for  the  technical- information part by SOLO srl  and  the financial transaction aspect by partner LemonWay SAS. The SOLO service, based on the Internet and accessible at solo.sh from any browser, can be used without distinction by fixed devices (eg. PC) and mobile (eg. Smartphones and tablets). This policy applies in all cases of use. This policy  is provided only for the site www.solo.sh and not to other Web sites accessed via links.

As part of this policy  "User" means the individual who uses the Service, including this website, the user  must corrispond  with the interested party or be approved by that State and whose Personal Data is being processed.

Registration

The registration of the User to the Site for the use of the Service is not mandatory. The user is informed that even in the absence of recording some data is still collected by the Service, and that such collection is essential for the use of the Service.  User registration is optional and allows access to dedicated services.

The registration and authentication services could be provided with the help of third parties. If this happens, this website will have access to some data kept by the third used for recording or identification.

Data collected

The service collects independently or through third-party different types of data:

  • Technical Data: data technically needed for the supply of the service, for the use of the features offered and session security. The computer systems and software procedures for running this web site acquire, during their normal operation and only for the duration of the connection, some personal data whose transmission is implicit in the communication protocols of the Internet. This policy is not collected to be associated with identified individuals, but by their very nature could, through processing and association with data held by third parties, to identify users. The data in this category is that essential to the Internet and mobile communication protocols, such as electronic markers and session identifiers (indicating the date and time of each transaction), and other parameters relating to the environment hardware and software user, which is stored by computer and telematic tools. These data may be used for statistical processing in anonymous form of corresponding accesses. The data could be used to ascertain responsibility in case of hypothetical computer crimes against the Service.

  • Personal details and contact: all other data provided by the User in accordance with the provisions of the Contract and the "Terms and Conditions" (T & C) of the Service. Among the Personal Information collected by the service on their own or through third parties, there are: First and Last Name, Contact information and email addresses, cookies and data usage. Any other data collected by the Service will be equated to previous and treated equally.
  • Localization data: data relating to the geographical location of the device used by the user to use or only interact with the service. In some cases, for the use of the features offered by the Service, you may be required to enable the location of your mobile device. The data will be stored and processed on Localization, among others, in order to improve the service and prevention of fraud.

The collection of such data can take place at any time there is an interaction of the user with the service, in particular can be contextually:

  • to navigation on the websites of the Company
  • to the supply of the Service
  • to the registration process for the Service
  • with any requests for information and / or assistance complementary and / or associated, even indirectly, to the supply of the Service.
Sensitive Data

The Service is not designed to collect or process data "that may reveal racial or ethnic origin, religious, philosophical or other beliefs, political opinions, membership of political parties, unions, associations or organizations of a religious, philosophical, political or trade union, as well as personal data disclosing health and sex life" of the User, or the personal data defined "sensitive data" like Article. 4, paragraph I, letter. d) of the "Privacy Code". If for specific requirements related exclusively to service delivery was required treatment data cd "Sensitive", the user will be asked explicit consent to the processing of them.

Purposes and methods of treatment

The data will be processed by the holder and / or the External Data Processor  according to competencies for the following purposes:

  1. 1. The completion of related activities and / or necessary for the Service
  2. 2. The fulfillment of obligations under applicable laws, regulations and legislation, and provisions issued by authorities to do so by law or by the vigilance and control, including  prevention and detection of computer crime
  3. 3. Sending of communications regarding the service and / or related to the use of the same
  4. 4. Any other purposes connected and / or necessary to the satisfaction of the demands made, from time to time, by you through the Site and / or other means of communication

With reference to the Contact data, the data may be processed by sending promotional communications and advertising relating to events and services / products similar sending newsletters and promotional material concerning; market research; economic and statistical analysis unless the user does not intend at any time object to the processing for such purposes by sending a notice to the address indicated in the "Correspondence".

In relation to the objectives stated above, the processing of Data is done using manual tools, computer and data, with logic strictly related to the purposes in question and for the time strictly necessary; and, in any case, in order to protect, as far as reason and the state of technology, the security and confidentiality of the same through appropriate procedures that avoid the risk of loss, unauthorized access, misuse and dissemination.

In particular, the data provided by the customer will be retained by the Owner and / or the  external Data Processor (according to purpose and skills) in spaces encrypted and subjected to security measures aimed at achieving, by analogy, and the state of technology, the inaccessibility by unauthorized third parties.

Bestowal obligatory – optional

The Owner and External Data Processor inform that the transfer Personal Information and contact, if collected,  is necessary for the purpose of service and that, consequently, a refusal of the User to such a transfer would make it impossible the use of the Service. Also, once you register, the processing of data is optional to the extent that the use of the Service is optional, however, that can only be done using them, so that the choice of using the Service can only imply consent to the above.

The treatment of the Technical Data and Data Localization also can be carried out exclusively by the Owner and on behalf of the latter, anonymously, to third parties who provide data processing services and / or perform activities complementary to or necessary for the management, maintenance and analysis of the Service.

The processing of data for promotional reasons and marketing is optional, and the User may oppose it by giving notice to the address shown in the "Correspondence".

Subjects

Given the instrumental nature and characteristics of the service, and in particular the technological interface to allow the transfer of electronic money, the processing of data can be made:

  • by the Owner and External data processor;
  • by entities external to them, as owners and / or processors;
  • by independent Owner of treatment, including merchants, whose data will be communicated to fulfill the above purposes.

The data can then be communicated to other persons and in particular:

  • employees and / or associates of the owner, the external data processor, appointed as managers and / or agents, by virtue of their duties / responsibilities within the limits of the treatments respectively allowed;
  • to banks, institutions and financial intermediaries, interbank institutions treated by them subject to the activities necessary to implement the provisions of, or banking and financial transactions, management of payment services, fraud control and debt collection, as well as activities internal audit and consulting;
User Rights

Those interested can write to the adress of the Owner or the External Data Processor listed in the section “correspondence”or  check your personal data and add to, update or correct and / or to exercise any other rights under Art. 7 of the Code, the text of which is transcribed below:

Correspondence

The owner of the data, within their respective jurisdiction, are:

  • SOLO  Srl, with registered office in Milan, Via Quaranta 40, in the person of its legal representative.
  • Lemonway SAS, a French company, with headquarters in Montreuil (France), 14 rue de Beaune - 93100, in the person of its legal representative;

The complete and updated list of those responsible and in charge of processing pro-tempore appointed is available on the website of LemonWay SAS, headquartered in Montreuil (France), 14 rue de Beaune - 93100 and, by analogy, at the headquarters of SOLO Srl.

Anyone interested in more information, to contribute with their own suggestions or complaints or claims regarding this policy, please write to the following e-mail:

  • if addressed to Solo Srl at: info@solo.sh
  • where addressed to LemonWay: reclamation@lemonway.fr
Mailing list

The Users are informed that their email address is automatically added to a list of contacts that can be transmitted email messages containing information, including commercial and promotional Related Service, subject to the right of requesting exclusion notifying  the Holder in the manner specified in the "Correspondence".

Social network

The user is informed that through the Service it is possible that interactions occur with social networks, or other external platforms directly from the web pages of the Service. Interactions and information obtained from the Service are in any case subject to the user's privacy settings related to each social network. If  a service interaction with social networks  is installed, it is possible that, even if the users do not use the service, the same collects traffic data about the pages in which it is installed.

Members residing in the European Union

This policy is prepared in fulfillment of the obligations under Art. 10 of the Directive n. 95/46 / CE and to the provisions of Directive 2002/58 / CE, as updated by Directive 2009/136 / CE, concerning Cookies.

Duration and changes to the privacy policy

The Owner reserves the right to make changes to this policy at any time by giving notice to the Users on this page.

Users are invited, therefore, periodically visit this page, by reference to the date of the last modification listed at the top. In case of rejection of the changes made to this privacy policy, the User must cease use of this Site and to refrain from accessing the Service and may require the Owner to delete your Personal Data.

Unless otherwise specified, the previous privacy policy will continue to apply to data collected until then.

Extended Cookie Information

The service owner SOLO S.r.l., innovative start-up under Italian right, with legal residence in Milan (MI), Via Quaranta 40, Tax and Vat Identification Number n. IT08790780962, registered at the Registro delle Imprese in Milan, in addiction of it is defined in the Privacy,  want to describe specifically and detailed way, the characteristics of the cookies installed in the Internet site www.solo.sh (“Site”).

A cookie is a small data file made up of letters which is placed by a website on the device you use to access the internet. Cookies are then sent back to the originating website on each subsequent visit.

This website uses technical cookies which are those used for the sole purpose of "transmitting information through an electronic communications network, or which are strictly necessary for the provision of an information service as explicitly requested by the subscriber or user "(see Art 122, paragraph 1, of the Code).

Among them, this website uses:

  • Analytics cookies are used in order to collect information in aggregated form of the number of users and how the site itself is visited. These anonymous cookies gather information concerning website use and allow the website owner to gain improved user knowledge and to improve site design.
  • Navigation or session cookies: they are strictly necessary to allow specific required functions guaranteeing normal navigation and use of the website.

They are:

  • language – technical cookies, used to allow the language selection by the user;
  • c_notice – technical cookies, used to enable access to the EU Cookies Law;
  • solosh – session technical cookies;
  • wwwsolosh - session technical cookies.

www.solo.sh also allows to send the so-called ‘’third-party’’ cookies, which are the cookies used by Google Analytics, the web analytics tool provided by Google, Inc. (‘’Google’’).

The information created by the cookie on the website use (including the IP address) will be sent to and stored by Google servers in the United States. Google uses the information collected to analyze the website usage, to report on the website activities for www.solo.sh and to provide additional services concerning web utilities as a whole. Furthermore, Google can transfer these details to third parties if required by law or in case such parties process the information by themselves on behalf of Google.

Further information about the privacy policy of Google Analytics can be found at this link. Google Analytics cookies can be easily disabled or enabled in any moment here.

Cookies can be disabled or enabled via your own browser. By accepting cookies, information will be preserved and restored in the subsequent navigations. They can be blocked entirely or only for some specific websites, for which you do not want to provide and then store certain information. All recent browsers allow you to modify cookies settings, which can be usually found in the ‘‘Tools’’ or ‘‘Preferences’’ browser menu. For more information about cookies settings, you can see the following link:

For information on how to manage cookies through other browsers, it can be useful to read the online help file. For further details, please check the browser ‘’Help’’.

Note that disabling technical cookies could affect the normal functioning of the webpage.

For further information, please refer to the privacy policy.