Information Sheet in Accordance with Articles 13 and 14 of Regulation UE 2016/679

Dear Client, in compliance with articles 13 and 14 of Regulation UE 2016/679 (hereinafter “the Regulation”), and in regard to your personal data which will be entrusted to Digital Fastlane GmbH (hereinafter “the Company”) during the course of any dealings between you and the company on the website https://www.secretwinks.com (hereinafter “the Website”) we wish to inform you of the following:

1. Purpose of Data Processing

Data will only be processed where necessary in order to provide the services supplied on the Platform. The Platform allows users (the “Users”) to exchange contents and/or personal and professional knowledge with other Users: in fact, each User may offer his/her knowledge (either professional or amateur) via live videochat, or by publicly uploading contents on the Platform (including, but not limited to, video, images, e-book, research papers; the “Content”), or also by exchanging Content privately with other Users. In order to access the Platform, Users are normally charged with a monthly subscription fee. Depending on the subscription, Users may also get monetary reward for sharing their Content and knowledge. Users’ personal data are therefore required for invoicing reasons.

2. Personal Data Communications

The name and family name, age (optional), profession (optional), location (optional) of each User will be made publicly available on the Platform to other registered Users. Personal data may be disclosed to the data processing managers and may be disclosed for the purposes indicated under item 1 to legal authorities, counterparties and their counsel, to arbitration boards and, in general, to all public and private entities for which disclosure is necessary for the proper fulfilment of the activities listed under item 1.

3. How Data is Processed

Processing of data is performed as follows: collection, recording, organisation, storage, consulting, development, modification, selection, extraction, comparison, use, interconnection, blocking, communication, cancellation and destruction of data. The processing operations may be performed with or without the aid of electronic or other automated tools. In order to ensure the maximum level of security in the Users’ data treatment, the collected data are protected by a latest generation encrypting protocol. Processing is carried out by the data controller. Pursuant to Article 28 of GDPR, the subjects appointed as external processors by Digital Fastlane GmbH process data useful for carrying out all the activities of the platform.

4. Data Transfer and Data Communication Refusal

The provision of personal data is strictly necessary for the purposes of the activities indicated under item 1. Refusal of the User to provide personal data will result in the inability to carry out the activities indicated under item 1, and therefore in the impossibility to use the Platform.

5. Data Diffusion

Personal data will not be subject to circulation, apart from the disclosure as defined above in item 2.

6. Transferring of Data Abroad

Personal data may be transferred to other EU countries where necessary in order to carry out the activities under item 1.

7. Rights of the Party Concerned

The Regulation grants specific rights to the party concerned. In particular, the party concerned may: obtain confirmation of the existence or not of his or her own personal data (art. 15 of the Regulation); obtain rectification of inaccurate personal data concerning him or her (art. 16 of the Regulation); obtain the cancellation of any personal data concerning him or her, according to the data subject’s right to be forgotten (art. 17 of the Regulation), by sending a request from your registration email to info@secretwinks.com Following the cancellation, an email notification is sent at the same time. By deleting the account, all content published on the platform will be removed, such as photos, videos and status updates and all other information or content entered by the user, with the exception of the data necessary to fulfill tax obligations (as reported in point 8 of this document); obtain the restriction of processing from the controller (art. 18 of the Regulation); obtain personal data concerning him or her in a structured, commonly used, and machine-readable format (art. 20 of the Regulation); object the processing of personal data concerning him or her (art. 21 of the Regulation). The party concerned may anytime revoke the consent to the personal data given to the Data Controller, while such revocation will not affect the data treatment performed by the Data Controller on the basis of the User’s consent until the revocation.

8. Duration of Data Processing

The personal collected by the Data Controller at the purposes stated above in item 1 will be conserved from the moment the User will activate his/her subscription, until up to 3 (three) months after the expiry of such subscription. The Data Controller will not cancel the Users’ personal data that must be kept for fiscal reasons.

9. Right to File a Petition to a Supervising Authority

Users have the right to file a petition to a Supervising Authority in any moment, if they think the Data Controller is not acting in compliance to the Regulation.

10. Data Controller

The Data Controller is Digital Fastlane GmbH, with elected domicile in Hans-Gasser-Platz 9/3/20 - 9500 Villach (AT)