Information Notes on Privacy Protection of Personal Data and request for Consent to Processing

The present information notes document is provided in accordance with Article 13 of Legislative Decree No. 196/2003.

01. Data processing controller- Definition

01.01. Processing controller

Sooeasy S.r.l. with registered offices in Milan, Via Santa Tecla 4, 20122, PIVA [VAT] 0886100962, (hereinafter referred to as the "COMPANY"), as Data Processing Controller; collects and processes for purposes related to the provision to USERS of the PLATFORM: and the APPs: "PENGUINPASS" and "CHECK IN" (the "DIGITAL PLATFORMS"), of its own services offered on the DIGITAL PLATFORMS, some personal information (the "PERSONAL DATA").

01.02. Definitions

APPs: free mobile applications, called "PENGUINPASS" and "CHECK IN" on which the COMPANY has full disposition and commercial exploitation rights, made available in key "Stores" of the respective operating systems (with particular reference to iOS and Android's world);

EVENT: a cultural or entertainment event, free or on payment, exempt or subject to SIAE;

ORGANIZER: the user of the PLATFORM and of the APP "CHECK IN" that organizes and manages the free or paid entry, exempt or subject to SIAE, to an EVENT within a public or private space;

PLATFORM: the online platform,, designed for the creation and management of EVENTS;

PRODUCT: the set of the PLATFORM, the APPs and the SERVICES;

SERVICES: the integrated and intelligent solutions for the geolocation of mobile payments and wireless recognition of mobile devices (including tablets and smartphones) that the ticketing and access reserved and directed to structures and cultural and entertainment events are done through the DIGITAL PLATFORMS;


USER: the subject, generic user of the PRODUCT, regardless of its CONSUMER USER or ORGANIZER USER nature.

02.Purpose of processing

The Personal Data collected are instrumental for the following purposes:
a. to allow the Company to:
- provide geo-location services;
- provide search engine services for events and private and/or cultural initiatives;
- provide service through the aid of an external Supplier of the COMPANY, to purchase tickets of a cultural or entertainment nature.
b. to guarantee registration on the PLATFORM and the APPs as well as for the proper provision of the SERVICES offered;
c. to fulfil its obligations under the law or regulations in force, in particular, in tax and public security matters;
d. to fulfil current administrative and accounting obligations, including any e-mail transmission of commercial invoices by the COMPANY and/or of the Supplier(s);
e. to process the business profile of the USER (through analysis of consumption habits).

The registration of the PRODUCT and the simultaneous use of the same is only permitted to adult USERS according to the law governing them.

The PERSONAL DATA may be used by the COMPANY for sending newsletters and other promotional material: from the moment of registration or at the time of acquiring a SERVICE, the USER is able to decide to give its express consent to receive business communications of the COMPANY or the Supplier, or to permit market research through the PERSONAL DATA, in order to send personalised information.

03.Optional or compulsory nature of providing data

The provision to the COMPANY of PERSONAL DATA that are requested may be necessary to achieve the purposes specified in the particular information notes, or are optional.
The obligatory or optional nature is specified from time to time, with reference to the single data requested, at the time of the single data collection.
Any refusal to communicate to the COMPANY the information marked as obligatory makes it impossible to provide the SERVICES offered by the same.

The PERSONAL DATA are also derived from third parties: these include access to third-party platforms, such as Facebook.

04.Processing procedures and security measures adopted

The PERSONAL DATA stored on the servers of the COMPANY are processed exclusively by managers appointed by the COMPANY, by its employees and/or collaborators.

The COMPANY has adopted security measures in order to minimize the risks related to the loss, damage (even accidental), unauthorized access and the unlawful processing of PERSONAL DATA.
The processing of PERSONAL DATA is performed mainly by electronic and automated means and with the appropriate instruments to ensure security and confidentiality in accordance with the Privacy Code.
However, the COMPANY cannot guarantee the USER that the measures taken for the security, the transmission of data and of the information on the PRODUCT, limit or exclude any risk of unauthorized access or loss of PERSONAL DATA by devices pertinent to the USER.

At any time, the USER may exercise its legal right to be informed of the existence, content, source, purposes and methods of processing of the PERSONAL DATA provided to the COMPANY.
Furthermore, the USER may exercise the right to request the updating, correction, addition or cancellation of its PERSONAL DATA.
These rights may be exercised by contacting the COMPANY as well as the Data Processing Holder at the e-mail address:

The COMPANY neither controls nor effects monitoring operations of third party web sites which may be connected to its PRODUCT.
The COMPANY, therefore, cannot be held responsible for the content of such sites and the regulations adopted by them, even with regard to the processing of PERSONAL DATA during the operations carried out on the same.

05.Duration of processing

The PERSONAL DATA will be stored for the time necessary to provide the SERVICES requested by the USER, or the time required for the purposes described in this document.
The USER may always request that the COMPANY discontinue processing and/or the cancellation of PERSONAL DATA in the cases provided for by law.

In case of cancellation, exclusion or disabling of unused USER accounts, the PERSONAL DATA will be stored for administrative purposes for a period not exceeding one quarter, subject to any specific legal obligations on the conservation of accounting documentation or for purposes of public security. In such cases, the automatic deletion of such data will be guaranteed including those of third parties to which they may have been communicated.

In any case, it is understood that the PERSONAL DATA, will be stored and processed for the purposes of verification of consumption and marketing habits for the period of time allowed by law and the prescriptions of the Competent Authority on Personal Data Processing.
After this period, the PERSONAL DATA will be transformed into anonymous form, so as not to allow, even indirectly, the identification of the persons concerned.

06.Communication of Personal Data

In order to provide the SERVICES, the COMPANY may communicate to the Supplier(s)/third party(ies) (for examples ticketing partner services, museums, etc) the PERSONAL DATA, that is strictly necessary to ensure the provision of the SERVICES of the same, both in Italy and abroad, or the USER’s name, its e-mail address, if necessary to complete the SERVICE of the Supplier, and any other information of relevant utility.
The Supplier acts as an independent holder in relation to the PERSONAL DATA and can have its own privacy policy that you are invited to carefully read and note that it applies to purchases of CONSUMER USERS.
The Supplier may reserve the right to contact the USER for more information in order to facilitate the use of their SERVICE.

Furthermore, collected PERSONAL DATA could be transmitted:
a. to all those subjects (including public authorities) that have access to personal data under legislation or administrative regulations;
b. to third party companies whose services are offered or sold through the PRODUCT (and, in particular, to companies or organizers of EVENTS for which tickets are sold through the DIGITAL PLATFORMS);
c. to the banks and companies that manage national or international payment circuits through which payments are made online for the products purchased through the DIGITAL PLATFORMS;
d. to companies, consultants or professionals eventually charged with the installation, maintenance, updating and, in general, the management of the hardware and software of the COMPANY or of others which serve the COMPANY for the provision of its SERVICES;
e. to a company or Internet provider in charge of sending documentation and/or information materials;
f. a company responsible for processing and/or the sending of advertising and information material on behalf of the COMPANY;
g. to third parties that perform outside consulting services for the COMPANY, both in Italy and abroad: such subjects, also the Processing Holders, have access to PERSONAL DATA necessary to carry out their duties and they may not use them for other purposes; therefore, they are required to process the data in accordance with the reference law and will be responsible for processing delegated by the COMPANY;
h. to all those public and/or private, physical and/or legal persons (offices of consultants, legal, administrative and fiscal, Judicial Offices, Chambers of Commerce, Chambers and Labor Offices, etc.), if such disclosure becomes necessary or appropriate to the proper fulfilment of its contractual obligations, as well as obligations under the law.

The PERSONAL DATA will not be disseminated, except in a collective and anonymous manner, for statistical or research purposes.

07.Sharing of localization

The COMPANY allows CONSUMER USER geo-location; for proper provision of the SERVICE, it needs to know the location of the same. Thus, whenever the CONSUMER USER opens and uses/interacts with the "PENGUINPASS" APP, the data on the location of the device detected by its mobile is used to adjust the offered SERVICES to your current location.
The positioning data of the CONSUMER USER detected through geolocation are shared with the ORGANIZER at the time of access to the EVENT and with other CONSUMER USERS only if the CONSUMER USER itself decides proactively through association of the APP to its own social account.

08.Updates and/or modifications to the Privacy Policy

The COMPANY may update and/or modify, in whole or in part, the present PRIVACY POLICY taking into account changes in the law governing the matter.
The modifications and updates of the PRIVACY POLICY will be notified to USERS by means of the APP.


The modifications and updates of the PRIVACY POLICY will be notified to USERS by means of the APP.