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Privacy Notice

This English translation is provided for convenience only. The Italian version is the sole binding version and prevails in the event of any discrepancy.

Leggi l’originale italiano

Privacy Notice

"Ciakli" Platform

1. Data controller

The controller of personal data collected through the "Ciakli" platform is Gianmarco De Bernardinis, VAT number 02131400661, whose registered address is Via Jean Emile Baudot, 9, 00132 Rome (RM), Italy (the "Controller" or "Ciakli"). For any request concerning the processing of personal data, you may contact the Controller at privacy@ciakli.it.

2. Categories of data processed

Ciakli collects and processes the following categories of personal data, depending on whether the user is registered as a Viewer or an Author:

The terms "Viewer", "Author", "Short Film" and "Plan" have the meanings given to them in the Platform's Terms and Conditions of Service.

3. Purposes and legal bases of processing

3.1 Performance of the contract

Processing identification and payment data and data relating to uploaded Short Films is necessary to perform the contract between the user and Ciakli (Article 6(1)(b) GDPR). This includes creating and managing accounts, processing payments through Stripe, publishing and managing Short Films, and sending the service communications provided for in the Terms (such as advance notice before a charge, notifications of editorial review outcomes or the removal of a Short Film following cancellation).

3.2 Legal obligations

Certain data, in particular tax information and invoices, are processed and retained to comply with legal obligations, including tax, accounting and consumer protection requirements (Article 6(1)(c) GDPR).

3.3 Legitimate interests

Ciakli processes certain data, such as logs, IP addresses and consent records, on the basis of its legitimate interests (Article 6(1)(f) GDPR) in keeping the Platform secure, preventing fraud and abuse, and retaining documentary evidence of users' consent, including consent to waive the right of withdrawal referred to in the Terms.

3.4 Consent

Where Ciakli uses statistical analysis tools that are not strictly necessary (analytics), or sends promotional communications or newsletters, that processing is based on the user's specific consent (Article 6(1)(a) GDPR). Consent may be freely withdrawn at any time, without affecting the lawfulness of processing carried out before withdrawal.

4. Data recipients and third-party providers

To provide the service, Ciakli uses the following third-party providers, which process data as independent controllers or processors according to their respective roles:

  • • Stripe, Inc. — payment processing and management of tokenised payment methods; Stripe acts as an independent controller for payment processing purposes, under its own privacy notice.
  • • Cloudflare, Inc. — hosting and CDN (Content Delivery Network) services for distributing the Platform's content;
  • • Google Cloud (Google Ireland Limited, with infrastructure attributable to Google LLC) — archiving and storage of video files for Short Films uploaded by Authors;
  • • Iubenda S.r.l. — management of the cookie consent banner and retention of evidence of users' consent;
  • • the transactional email delivery provider, whose identifying details will be included in an update to this Notice once selected;
  • • Google Analytics (Google Ireland Limited) — statistical analysis of Platform use, activated only with the user's prior consent through the Iubenda banner.
  • • any email marketing or newsletter tool, if activated, whose identifying details will be included in an update to this Notice.

Data may also be disclosed to public or judicial authorities where required by law.

5. Transfers of data outside the EU

Some providers, in particular Stripe, Inc., Google Analytics and Google Cloud (both attributable to Google LLC), and Cloudflare, Inc., all companies based in the United States, may involve transfers of personal data outside the European Economic Area. In those cases, transfers take place on the basis of appropriate safeguards under the GDPR, such as the Standard Contractual Clauses approved by the European Commission, as described in each provider's privacy notice. Iubenda S.r.l., a company based in Italy, does not involve transfers of data outside the European Economic Area.

6. Retention periods

Personal data are retained for the following periods:

  • • account data (Viewer/Author): throughout the contractual relationship; following cancellation, the account is deactivated as provided in the Terms, without immediate deletion of personal identification and tax data;
  • • tax and accounting data (invoices): 10 years, under applicable tax legislation;
  • • logs and consent records: throughout the contractual relationship and for the subsequent period needed to defend rights in legal proceedings, within the ordinary limitation periods;
  • • data processed on the basis of consent, such as newsletter data: until the user withdraws consent.

7. Data subjects' rights

As a data subject, the user has the right to:

  • • access their personal data and obtain a copy (Article 15 GDPR);
  • • request rectification of inaccurate or incomplete data (Article 16 GDPR);
  • • request erasure of data, subject to legal retention obligations (Article 17 GDPR);
  • • request restriction of processing (Article 18 GDPR);
  • • request portability of the data provided (Article 20 GDPR);
  • • object to processing based on legitimate interests (Article 21 GDPR);
  • • withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;
  • • lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) if they consider that processing infringes applicable law.

These rights may be exercised by contacting the Controller at the address specified in Article 1.

8. Data security

Ciakli adopts appropriate technical and organisational measures to protect personal data from unauthorised access, loss, destruction or improper disclosure. These include encrypted connections, access to data restricted to authorised personnel, and entrusting payment processing to a specialist provider (Stripe) certified under PCI-DSS security standards.

9. Minors

Access to the Platform is restricted to adults, as stated in the Terms and Conditions of Service. Ciakli does not knowingly collect data relating to children under 18.

10. Changes to this Notice

Ciakli reserves the right to amend this Notice at any time. Users will receive adequate advance notice of material changes, using the same methods provided for in the Terms and Conditions of Service.

11. Cookies

The Platform may use technical cookies that are necessary for the service to function and, with the user's prior consent, statistical analysis cookies (currently Google Analytics). The use of cookies and the associated consent choices are governed by a separate Cookie Policy, generated and managed through the Iubenda consent platform. It is available on the Platform and accessible through the consent banner displayed on the first visit.