The document you are about to read has a simple but fundamental purpose: to inform you about what happens to your Personal Data (hereinafter also "Data") when you decide to use Weople.

A - Data Controller and Data Protection Officer

The Data Controller is the entity that determines the purposes and means of the processing. If you decide to use Weople, the Data Controller is Hoda S.r.l., based in Via Giovanni Enrico Pestalozzi, 10 int. 14/1 – 20143 Milan (MI). You can contact the Data Controller at the following email address: support@weople.space.

We are available to clarify any doubts you may have regarding this document and, more generally, about the actual processing of Data and the parties involved.

We have appointed a Data Protection Officer (DPO), whom you can contact at: dpo@hoda.digital for any information regarding the processing of personal data.

B - What Data We Use and Why

To provide our services, we use a significant amount of personal data. Not all data are necessary, and you will decide whether and which data to provide to us.

1. Account Creation

To use our services, you must create an account on Weople.
Why do we use your data? To create your account.
What data do we use? We collect your identifying and contact details and personal characteristics, such as name, surname, address, country, nationality, phone number, email address, date of birth, and gender (the latter is optional).
Why can we use them? Because processing is necessary for the performance of a contract or pre-contractual measures.
Are you required to provide the data? Yes, if you do not create an account with the required data, we will not be able to provide our services. Optional data can be omitted, and you can still create your account.
How long do we use the data? We retain the information provided during account creation for 10 years after account closure.

2. Data Acquisition for the Creation of Probabilistic Models and Enrichment

Weople is designed to allow you to invest your personal data in a controlled and protected manner. The goal of Weople is to enhance the personal data you store in the safes to redistribute the proceeds from investment activities, as explained in the Terms & Conditions of Service. Hoda aggregates and processes user data using analytical tools and profiling algorithms to derive anonymous statistical samples for commercial purposes. Starting from personal data, these are de-identified— meaning identifying data that could associate the information with you are removed—then summarized into homogeneous classes or cohorts. In essence, we create profiles from your information and consumption habits, but then combine them with those of other people with similar characteristics, so as to obtain a typical user model that no longer has the information of a single person, but those statistically most probable of a group of people. This process allows us to create valuable models for companies without providing them with personal data or unique individual profiles. We protect your privacy by creating a high-value product for companies.

Why do we use your data? We acquire your data to create anonymous statistical samples to generate economic returns.
What data do we use? We collect personal characteristics (city, country, nationality, age, gender) and consumption and preference information that you choose to share by inserting them into the safes available to you.
Attention: We are not interested in special categories of data, such as information about your health, racial or ethnic origin, religion, philosophical beliefs, trade union membership, political opinions, or information about your sex life. We therefore ask you not to insert this information into the safes. In any case, our system is calibrated to use only information relevant to the profiling purpose, and therefore we may not be able to control the data of all users and may end up retaining special data, even if unintended. For this reason, we ask for your prior consent to store any special data you voluntarily choose to share. Security procedures are in place to protect the confidentiality of your data, and we use encryption to protect your information, regardless of the type of data processed.
Why can we use them? We can do so only if you provide your consent. For special data, we can do so if you provide consent for storage purposes.
Are you required to provide the data? You are not required to provide the data, but if you do not activate the safes by giving consent for profiling, we will not be able to enhance your data and provide you with the economic return that the Weople service aims to offer its users.
How long do we use the data? We retain identifying information for this purpose for up to 12 months from the time of provision.

3. Data Storage

When you revoke consent for processing for enrichment purposes, for the data contained in all or some safes, Hoda allows you to leave your data in Weople, offering a mere information storage service.

Why do we use your data? To store your data.
What data do we use? The data you have deposited in the safes.
Why can we do this? We can do this only if you provide your consent.
Are you required to provide the data? You are not required to leave the data stored in Weople when you revoke consent for profiling; if you wish, you can delete them all by following the instructions in the App.
How long do we use the data? We retain the information for this purpose until you revoke consent or decide to delete your account.

4. Exercise of Your Rights

For the safes indicated in the app, you can, if you wish, ask Hoda to exercise the right to data portability on your behalf. To do this, you must delegate Hoda within the Application, as indicated in the Terms and Conditions of Service. For this purpose, in some circumstances, Weople may need to request further identification details, such as a photograph and/or scan of your identity document, as well as the use of identity verification procedures.

Why do we use your data? To allow the exercise of your rights through delegation.
What data do we use? The data required to exercise the right to portability.
Why can we do this? We can do this only if you provide your consent.
Are you required to provide the data? You are not required to delegate Hoda to exercise the right to portability. However, if you use the delegation, you must provide the requested data to obtain the data from the relevant data controllers.
How long do we use the data? We retain the information necessary for the delegation for the time needed to exercise it. The uploaded identity document may be retained for an additional 2 months after the delegation expires, to facilitate the generation of new delegations. In the absence of new delegations, this document will also be permanently deleted.

5. Sending Promotional and Commercial Communications Within the Application Based on Profiling

Within Weople (in the "Gain&Relax" area), you can decide to receive communications and/or promotional material tailored to your interests or based on profiling activities carried out by Hoda.

Why do we use your data? To send you advertising or promotional communications.
What data do we use? The data you have deposited in the safes.
Why can we use them? We can do this only with your consent, which you will provide before accessing the "Gain&Relax" area.
Are you required to provide the data? No, you are not required. Without it, you can still use the App, but you will not receive the economic return linked to participation in this activity, as indicated in the Terms and Conditions of Service.
How long do we use the data? For 24 months from the granting of consent. Upon expiration, we will ask if you intend to renew your consent for this processing.

6. Responding to Requests Within Weople

If you contact us or request assistance to resolve problems or for any need, we will use your data to fulfill your requests.

Why do we use your data? To respond to and fulfill your requests.
What data do we use? Your account data and data related to the requests you make.
Why can we use them? To perform the contract or pre-contractual measures.
Are you required to provide the data? Yes, otherwise we will not be able to respond to and fulfill your requests.
How long do we retain the data? We retain the data for the time necessary to fulfill the requests, and in any case no longer than 24 months, unless specific needs are communicated to users from time to time.

7. Managing Navigation and Use of Weople

When you use Weople, we directly collect some information for the correct use of the Application.

Why do we use your data? For the correct use of the Application.
What data do we use? This includes information such as: IP addresses (both static and dynamic) or domain names of the devices used by those who connect, URI ("Uniform Resource Identifier") addresses, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the server response (success, error, etc.), the country of origin, the characteristics of the browser and operating system used, etc.
Why can we use them? To perform the contract or contractual measures.
Are you required to provide the data? The data is collected directly through the use of the Application.
How long do we use the data? Until your account is closed.

8. Communicating Service Updates or Community Activities to Registered Users

In short, we can use your contact data to communicate service updates or information about the application and the community.

Why do we use your data? To communicate with registered users who have chosen to use the email communication channel for service updates or information about the application and the community.
What data do we use? Your contact and registration data.
Why can we use them? Because it is in Hoda's legitimate interest to update the user on improvements or changes to the services offered in order to retain them.
Are you required to provide the data? The data is already present within the Application. At any time, you can choose to opt out of receiving such communications by unsubscribing directly from the service via a request to the address indicated in all communications sent.
How long do we use the data? Until your account is closed.

9. Processing Statistical Data in Anonymous and Aggregated Form

These are analyses carried out on data to obtain completely anonymous results that allow us to understand, for example, the modes of use of the application, the most viewed content, and to conduct market research and statistical surveys.

Why do we use your data? To process statistical data in anonymous and aggregated form.
What data do we use? The data comes from registration and that contained in the safes but, before being used, it is made totally anonymous so that it cannot be subsequently attributed to you.
Why can we use them? Because it is in Hoda's legitimate interest to acquire information on the use of the Application to improve it.
Are you required to provide the data? The data is already present within the Application. You can object to the use of this data, for reasons related to your particular situation, from the beginning or later by contacting Hoda at the DPO's address.
How long do we use the data? Until your account is closed.

10. Fulfilling Legal Obligations

We use your data because we are required to do so to fulfill the obligations provided by current legislation.

What data do we use? The data comes from registration and that contained in the safes.
Why can we use them? Because it is necessary to fulfill legal obligations.
Are you required to provide the data? The data is already present within the Application.
How long do we use the data? For 10 years after account closure.

11. Protecting Our Rights

We may use the data you have provided to protect our rights in case of disputes.

What data do we use? We may use any data entered within the Application.
Why can we use them? Because it is in Hoda's legitimate interest to exercise, ascertain, or defend a right.
Are you required to provide the data? The data is already present within the Application.
How long do we use the data? For 10 years after account closure.

12. Meeting Organizational and Security Needs

To ensure the security of our systems, we must ensure that the activities carried out by users are lawful and correct.

What data do we use? We use registration data and data acquired during the use of the Application (log-in, log-out, IP address).
Why can we use them? Because it is in Hoda's legitimate interest to ensure the security of its systems.
Are you required to provide the data? The data is acquired directly through the use of the Application. You can object to the use of this data, for reasons related to your particular situation, from the beginning or later by contacting Hoda at the DPO's address.
How long do we use the data? For 10 years after account closure.

Details of data collected by category:

C - To Whom We Disclose the Data

The processing is carried out directly by the Data Controller, through expressly authorized personnel, and/or by external parties to its organization, who are in any case bound to it as Data Processors by virtue of a specific data processing agreement (e.g., service companies, professionals, and consultants). You can request the list of all parties involved in the processing at any time. We may also disclose data to third parties, public or private, if we are required to do so by laws or orders from authorities.

D - Where Your Data Is Located

To carry out our activities, we also use suppliers located outside the European Union or who access data from countries outside the European Union, such as the email provider. In these cases, the transfer of data takes place in the presence of the guarantees required by current legislation, i.e., to countries for which an adequacy decision exists or based on the standard contractual clauses ("SCCs") approved by the European Commission. If you wish to know more about the transfers, you can contact our DPO at dpo@hoda.digital.

E - Rights of the Data Subject

We remind you that you have the right to:

1. obtain access and rectification of inaccurate data, as well as the integration of incomplete personal data;
2. obtain the erasure of processed data in the cases provided for by the legislation;
3. obtain the restriction of data processing if the circumstances indicated by the current legislation occur;
4. request and obtain that the personal data held by Weople be communicated in a commonly used format ("data portability") or transmitted directly to another controller, when the processing is based on consent or contract and is automated;
5. revoke at any time the consent previously given, without affecting the lawfulness of the processing carried out before the revocation;
6. lodge a complaint with the supervisory authority or take legal action to protect your rights.

You also have the right to object, for reasons related to your particular situation, to the processing of data necessary for the pursuit of the legitimate interest of the Company or third parties. The Company may continue to process the data if it demonstrates the existence of compelling legitimate reasons for the processing that override the rights, interests, and freedoms of the data subject or for the establishment, exercise, or defense of legal claims. The data subject may also object to the processing of data for direct marketing purposes, including profiling insofar as it is related to such direct marketing.

All requests from the data subject can be addressed to Hoda at support@weople.space or to the DPO at dpo@hoda.digital.

F - Changes to This Privacy Policy

Hoda reserves the right to make changes to this privacy policy through direct communication to the data subject using the available means of communication (email, regular mail, telephone, etc.).

In the event that the changes concern activities carried out on the basis of consent, before proceeding with any further form of processing, Hoda S.r.l. will request new consent from the data subject.