Privacy & Cookie Policy
Privacy Policy
Last updated: 12 June 20160. Data ownership and treatment responsibilityMoffu Labs S.r.l., having its headqurters in Milan, Via Merano 16, is the only responsible for treating any data collected on this website according to the European Data Privacy laws and the Italian laws on the subject matter.Specifically, transparently we inform you that the methods, tools and reasons for treating your data are conforming to article 13 of European General Data Protection Regulation (GDPR) 679/2016.1. Introduction and General TermsMoffu Labs is committed to protecting your and your family’s personal information when you are using Moffu Labs services. We want our services to be safe and enjoyable environments for our users and partners. This Privacy & Cookie Policy relates to our use of any personal information we collect from you via the following online services:any Moffu Labs website that links to this Privacy Policysocial media or official Moffu Labs content on other websitesmobile device, PCs, and TV Applications (“Apps”)It also relates to our use of any personal information you provide to us by phone, SMS,email, in letters and other correspondence and in person.In order to provide you with the full range of Moffu Labs services and contact options, we sometimes need to collect information about you.This Privacy and Cookies Policy explains the following:what information Moffu Labs may collect about youhow Moffu Labs will use information we collect about youwhen Moffu Labs may use your details to contact youwhether the Moffu Labs will disclose your details to anyone elseyour choices regarding the personal information you provide to usthe use of cookies on Moffu Labs websites and how you can reject cookies.Moffu Labs is committed to safeguarding your personal information. Whenever you provide such information, we are legally obliged to use your information in line with applicable laws concerning the protection of personal information, including relevant laws other than GDPR (these laws are referred to collectively in this Privacy and Cookies Policy as the “data protection laws”). No website can be completely secure; if you have any concerns that your data at Moffu Labs could have been compromised e.g. someone could have discovered through our websites any of the data you shared with us, please get in touch straight away.Moffu Labs websites contain hyperlinks to websites or functional services (e.g. SEO optimization) owned and operated by third parties. These third party websites have their own privacy policies, and are also likely to use cookies, and we therefore urge you to review them. They will govern the use of personal information you submit when visiting these websites, which may also be collected by cookies. We only allow them to use technical cookies absolutely required to implement their functionalities but enable no profiling ones. As such, we do not accept any responsibility or liability for the privacy practices of such third party websites and your use of such websites is at your own risk.2. Who are we?The Moffu Labs S.r.l. (Moffu Labs) is an Italian innovative startup acting both as an innovator and an incubation environment for other innovative startups to join. We are officially listed in the ranks of Italian Innovative Startups, established in Milan and operating on a national and international base.The www.moffulabs.com website acts as our main website and is operated from Italy in both national and international (English) versions.Moffu Labs’ activities are only covered by this Privacy and Cookies Policy in relation to its use of data collected via moffulabs.com. Other companies might expose Moffu Labs operated services under licence or by means of a partnership with Moffu Labs. These companies must operate to Moffu Labs standards but please make sure you always check the privacy policy of the websites you use so you know who runs the website and how they will use your data.When we refer to ‘’we’’ or ‘’our’’ or ‘’Moffu Labs’’ we are referring to Moffu Labs.3. What information will Moffu Labs collect about me?When you participate in, access or sign up to any of the Moffu Labs’ services, activities or online content, such as newsletters, forms, live chats, message boards, web and mobile notifications, telephone or text Moffu Labs,send your request for being considered or pitched using the Moffu Labs online registration & contact system we may receive personal information about you. This can consist of information such as your name, email address, postal address, telephone or mobile number or date of birth, as well as information collected about your use of Moffu Labs services (such as what you read or watch on Moffu Labs website and items you have “added” when signed in to your Moffu Labs account if you are a partner).Please note that sometimes we will require you to provide additional personal information, and sometimes sensitive personal information (e.g. if you’re sending in an application to be a startupper financed by us we may need to know your financial tenure). When we do this we will provide further information about why we are collecting your information and how we will use it and will notify Authorities about our need.Where we provide personalised services, we may ask your permission to review third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation. Some of our services may enable you to sign-in via a third-party service, such as Facebook. If you choose to sign-in via a third party app, you will be presented with a dialog box which will ask your permission to allow Moffu Labs to access your personal information (e.g. your full name, date of birth, email address and any other information you have made publicly accessible). Please note that any information that is not required by the particular service you have opted to use will not be retained by Moffu Labs.Moffu Labs also uses cookies and similar technologies (see section 15 below for details) and collects IP addresses (an IP address is a number that can uniquely identify a specific computer or other network device on the internet) and other information about devices from visitors to Moffu Labs websites, users of its mobile device and TV Apps, and through other Moffu Labs content online. Please see section 17below for more information about mobile devices and TVs. We hereby state that Moffu Labs doesn’t collect full IP addresses but just the first three numbers (octects) so that it is allowed to identify the region 4. How will Moffu Labs use the information it collects about me?Moffu Labs will use your personal information for a number of purposes including the following:to provide our services, activities or online content, to provide you with information about them and to deal with your requests and enquiriesfor “service administration purposes”, which means that Moffu Labs may contact you for reasons related to the service, activity or online content you have signed up for, as set out in section 5 below (e.g. to provide you with password reminders, to notify you that a particular service, activity or online content has been suspended for maintenance, to notify you of updates to our Privacy and Cookies Policy or Terms of Use, to let you know if your Moffu Labs account has become dormant and to ask if you would like to use it again before we close it)to ensure the startups owner and contact database is accurate and kept up to datewhere we provide personalised services, we may need to analyse the information you supply, as well as your activity on our services, so that we can offer you a better personalisation service (e.g. use your viewing history on moffulabs.com to provide personalised recommendations or if the first thing you look at every day on Moffu Labs online is the Financial startups we have in portfolio we may present this information or a link to it on your homepage). If you are signed-in or subscribed to email newsletters, you will receive a personalised service. If you do not wish to continue to receive these services then you can disable personalization or unsubscribe from the newsletters, please visit your account settings to find out more or contact privacy@moffulabs.comto contact you about a submission you have made, including any content you provideto use partial IP addresses and device identifiers to identify the coarse location of users, to block disruptive use, to establish the number of visits from different countries and to determine whether you are accessing the services from Italy or not. If not, you may be re-directed to the international version of the Moffu Labs website (moffulabs.com)for analysis and research purposes so that we may improve the services offered by Moffu Labsto provide you with the most user-friendly navigation experience.Moffu Labs may also use and disclose information in aggregate (so that no individuals are identified) for marketing and strategic development purposes, provided you explicitly allowed us to do sowhen you access a Moffu Labswebsite from outside Italy, you will see the international version, moffulabs.com, which may feature specific contents for an international audience. A certain amount of this contents are tailored to one individual, a common practice known as online behavioural taregting. Find out more in the next paragraphs of this Policy. Where Moffu Labs proposes using your personal information for any other uses we will ensure that we notify you first. Please see section 18 below for details.5. Your Moffu Labs Account If you are a partner or relate to Moffu Labs such as you have registered for a Moffu Labs account this will also allow you to login to the Moffu Labs website [for your location] and some other Moffu Labs websites and apps. These services might be run by the Italian chapter of Moffu Labs or they could be run by international chapters (e.g. Moffu Labs offices in Los Angeles) or a combination of the two. To provide you with a seamless experience, it may be necessary to share your personal information between the different chapters being a single legal entity. We will only share what we need to in order to provide the service you are using – we will never routinely share all of the data we each hold about you.You might be asked to use your Moffu Labs account on other Moffu Labs services to enable you to sign in and seamlessly enjoy Moffu Labs services. For example, you need a Moffu Labs account to be able to create and use an account with Moffu Labs Newsletters, which may be run by Moffu Labs offices in the US. This gives you a better experience by enabling you to access to any Moffu Labs service by means of single sign-on credentials.To enable this functionality, some information needs to be shared between the different parts of Moffu Labs that are providing you with a service. Your Moffu Labs account will always be covered by the policies of this website. But, please be aware that additional policies may apply if your Moffu Labs account is linked to another account for any current or future service having its own local policies.6. When will Moffu Labs contact me?Moffu Labs may contact you:in relation to any service, activity or online content you have signed up for in order to ensure that Moffu Labs can deliver the services to you, e.g. to verify your email when you sign up for a Moffu Labs account, or to help you reset your password or to check if you still want to use the service (if your account is dormant)in relation to any correspondence we receive from you or any comment or complaint you make about Moffu Labs products or servicesin relation to any personalised services you are usingin relation to any contribution you have submitted to Moffu Labs, e.g. on the Moffu Labs message boards or via text or voicemail messageto invite you to participate in surveys about Moffu Labs services (participation is always voluntary)for marketing purposes, where you have agreed to this.Local pages will give you detailed information about how Moffu Labs will contact you in relation to specific services, activities or online content.We will never contact you to ask for your Moffu Labs account password, or other login information. Please be cautious if you receive any emails or calls from people asking for this information and claiming to be from Moffu Labs. 7. Will I be contacted for marketing purposes?Moffu Labs will only send you emails or otherwise contact you for marketing purposes, or to promote new services, activities or content where you have agreed to this. Where you have agreed to receive these communications, we may personalise the message content based upon any information you have provided to us and your use of Moffu Labs websites, applications and services.8. Will Moffu Labs share my personal information with anyone else?We will keep your information within Moffu Labs except where disclosure is required or permitted by law (for example to government bodies and law enforcement agencies, including for child protection reasons) or as described in this section and section 9 below.We may share your information across the Moffu Labs network of backed startups, services and its commercial subsidiaries, such as Pricebox S.r.l., where this is necessary to provide you with a service you have requested, for example, when you register outside Italy or where you register to being pitched as a Startup by Moffu Labs.Generally, we will use your information within Moffu Labs and will only share it outside Moffu Labs where you have requested it or given your consent, for example if you choose to share content via social media. However, sometimes Moffu Labs uses third parties to process your information on our behalf, for example to provide services or analysis. Moffu Labs requires these third parties to comply strictly with its instructions and Moffu Labs requires that they do not use your personal information for their own business purposes, unless you have explicitly consented to the use of your personal information in this way.We may share your personal information internally (i.e. with other Moffu Labs divisions) for example, to check your details against the National Innovative Startups database. Please see section 4 above for more details.9. Offensive or inappropriate content on Moffu Labs websitesIf you post or send offensive, inappropriate or objectionable content anywhere on or to Moffu Labs websites or otherwise engage in any disruptive behaviour on any Moffu Labs service, Moffu Labs may use your personal information to stop such behaviour.Where Moffu Labs reasonably believes that you are or may be in breach of any applicable laws (e.g. because content you have posted may be defamatory), Moffu Labs may use your personal information to inform relevant third parties such as your employer, school email/internet provider or law enforcement agencies about the content and your behaviour.10. What if I am a user aged under 18?If you are aged 18 or under, please get your parent/guardian’s permission before you provide any personal information to Moffu Labs.If you are under 18 and want to register for a Moffu Labs account then you will need to provide your date of birth to make sure you can use the parts of Moffu Labs that are meant for you and for younger visitors. If you are under 16 then we will need consent from your parent/guardian before you can use some of our services. Outside Italy a Moffu Labs Account will not provide access to the child specific content available in Italy. Please do not create a Moffu Labs Account if you are outside Italy and under 18 as your account may be removed.11. How long will Moffu Labs keep my information?We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with Moffu Labs. If you delete your Moffu Labs account then your personal information is deleted immediately, and the remaining information is anonymised for analytical purposes. For further information about deleting your Moffu Labs account, please see section 12 below.Where you contribute content together with your personal information (User Generated Content or UGC) please refer to our Terms of Use for further information about how long we may store such material.If you have not used your Moffu Labs account in the last two years then your account may be classed as dormant or may even have been deleted in line with our privacy policy. We will email to remind you before deletion so please check your inbox regularly to see if we have sent you any emails about this.12. Can I delete my data?The Controllers hereby guarantee to you that you may exercise, at any time, the rights specified by Article 12 of the GDPR. In particular, you have the right:to know whether the Controllers hold and/or process personal data about you and to access them in full, also obtaining copies thereof (Article 15 Right of access by the data subject), to the rectification of inaccurate personal data or to the completion of incomplete personal data (Article 16 Right to rectification);to the erasure of personal data in the Controllers’ possession if one of the reasons specified by the GDPR applies (Right to erasure, Article 17);to ask the Controllers to limit processing only to some personal data, if one of the reasons specified by the Regulation (Article 18 Right to restriction of processing); to request and receive all your personal data processed by the Controllers, in a structured, commonly used and machine-readable format or to request transmission to another controller without hindrance (Article 20, Right to data portability);to object to all or part of the data processing for the purposes of transmitting advertising material and market surveys (“Consent”) (Article 21 Right to object)to object to all or part of the data processing in automatic or semiautomatic mode for profiling purposes (“Consent”)These rights may be exercised by communication to the Data Controllers/Data Protection Officer whose addresses are indicated in the dedicated section of this disclosure.Moreover, you always have the right to file a complaint with the Italian Authority for the Protection of Personal Data, at the address garante@gpdp.itor through the Website http://www.gpdp.it.You can always delete your Moffu Labs account but there are a few implications you should consider.As explained in section 11 above, deleting your Moffu Labs account will erase any personal information in your account that we have about you and it will mean any data we hold about how you have used Moffu Labs will be made anonymous.Deleting your Moffu Labs account will not delete the data you shared with Moffu Labs for reasons that are not connected with your Moffu Labs account. For example, if you sent us and email to apply for a pitch, we will keep your data so that we can manage that service and tell you abotu time and venue for the pitch (if you have asked to be kept updated).Important: if you delete your Moffu Labs account then you will be unable to access any Moffu Labs account that is associated with it, as they share the same technology. So you may lose anything you have shared with your Moffu Labs account.13. Can I find out what personal information Moffu Labs holds about me?Under the Data Protection laws of the European Community and Italian regulation you have the right to request a copy of the personal information Moffu Labs holds about you and to have any inaccuracies corrected. (We require you to prove your identity with 2 pieces of approved identification). We will use reasonable efforts consistent with our legal duty to supply, correct or delete personal information about you on our files.If you are within Italy, please address requests and questions about this or any other question about this Privacy and Cookies Policy to the Privacy Office at Moffu Labs S.r.l, via Merano 16, 20134 Milano (Email:privacy@moffulabs.com).From outside Italy, please email privacy@moffulabs.com or write to Privacy Office at Moffu Labs S.r.l, via Merano 16, 20134 MilanoWe will need two copies of forms of identification, which can be:PassportPersonal Id cardDriving licenceBirth certificateUtility bill (from last 3 months)Bank statement (from last 3 months)14. What if I am accessing Moffu Labs websites outside Italy?The Moffu Labs website is published in Italy by Moffu Labs as www.moffulabs.com. The international version of the website, www.moffulabs.com/en/, is made available to international users accessing the website from outside Italy. All personal information submitted by users outside Italy will be processed in accordance with this Privacy and Cookies Policy (and any local terms that apply to certain areas of the site). Where there is a conflict, the local terms will apply.15. Web browser cookiesa) What is a Cookie?A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it. Many websites do this whenever a user visits their website in order to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the Moffu Labs website. However, you can change your cookie setting at any time.On Moffu Labs websites, cookies record information about your online preferences and allow us to tailor our websites to your interests.During the course of any visit to a Moffu Labs website, the pages you see, along with a cookie, are downloaded to your device. Many websites do this, because cookies enable website publishers to do useful things like find out whether the device (and probably its user) has visited the website before. This is done on a repeat visit by checking to see, and finding, the cookie left there on the last visit. b) How does Moffu Labs use cookies?Information supplied by cookies can help us to understand the profile of our visitors and help us to provide you with a better user experience. It also helps us recognise when you are signed in to your Moffu Labs account and to provide a more personalised experience.. For example, if on a previous visit you went to our financial boosting pages, we might find this out from your cookie and highlight our financial strategy information on your second and subsequent visits. Moffu Labs uses this type of information to help improve the services it provides to its users. Certain areas of Moffu Labs websites may use cookies for a specific reason – for example, to help an online questionnaire work effectively on your device.Additionally, Moffu Labs uses cookies to serve some targeted content publishing on moffulabs.com/en/ to non-Italian-resident users.c) Third party cookies in embedded content on Moffu Labs pagesPlease note that during your visits to Moffu Labs websites you may notice some cookies that are not related to Moffu Labs or the Moffu Labs’ contractors.To support our vision and communication needs, we sometimes embed content from social media and other third party websites. These may include YouTube, Twitter, Facebook, Soundcloud, Vine, Instagram, Pinterest and Flickr. As a result, when you visit a page containing such content, you may be presented with cookies from these websites and these third party cookies may track your use of the Moffu Labs website. Moffu Labs does not control the dissemination of these cookies and you should check the relevant third party’s website for more information. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the Moffu Labs website. However, you can find out about changing your cookie settings here.Where Moffu Labs embeds content from social media and other third party websites, some websites may use Google Analytics to collect data about user behaviour for their own purposes. Moffu Labs does not control this and for more information see GA’s site ‘How Google Uses Data’ .Moffu Labs Sharing ToolsYou will also see embedded ‘share’ buttons on Moffu Labs web pages; these enable users to easily share content with their friends through a number of popular social networks. When you click on one of these buttons, a cookie may be set by the service you have chosen to share content through. Again, Moffu Labs does not control the dissemination of these cookies. If you continue without changing your settings, we’ll assume that you are happy to receive all cookies on the Moffu Labs website. However, you can change your cookie settings at any time.d) Moffu Labs cookies and how to reject cookiesFull information about how Moffu Labs uses cookies can be found in the Cookie section of this Privacy & Cookie Policy.If you wish to control what cookies are set on your device through the Moffu Labs website then you can find out how to do this in the Cookies settings section of this Privacy & Cookie Policy. It is important to note that if you change your settings and block certain cookies, this means that certain features which you have chosen cannot be provided and you will not be able to take full advantage of some of the websites’ features.e) Other information collected from web browsersYour web browser may also provide Moffu Labs with information about your device, such as an IP address and details about the browser that you are using. Where requesting a list of Moffu Labs services near your location, it may be possible for you to choose to provide Moffu Labs with access to your device’s location through the web-browser. We use information provided by your browser or by the link that you have clicked to understand the webpage that directed you to Moffu Labs and this may be captured by performance cookies.If you have any concerns about the way that we use cookies or respect your settings, then please contact us at privacy@moffulabs.com.16. Do Not Track (DNT) browser settingDNT is a feature offered by some browsers which, when enabled, sends a signal to websites to request that your browsing is not tracked, such as by third party ad networks, social networks and analytic companies. This website does not currently respond to DNT requests.17. Apps, Devices and TVsWhen you download or use Moffu Labs apps on your mobile device or TV, information may be accessed from or stored to your device. Most often this is used in a similar way to a web browser cookie, such as by enabling the app to ‘remember’ you or provide you with the content you have requested.Your web browser or device may also provide Moffu Labs with information about your device, such as a device identifier or IP address. Device identifiers may be collected automatically, such as the device ID, IP address (only the first three octets), MAC address, IMEI number and app ID (a unique identifier relating to the particular copy of the app you are running).If you have any concerns about the information which might be accessed from or stored to your device by Moffu Labs, you may wish to only access Moffu Labs content through a web browser and to alter your settings as discussed above in “Web browser cookies” section of this Privacy and Cookie Policy18. Changes to Moffu Labs’ Privacy and Cookies PolicyThis Privacy and Cookies Policy may be updated from time to time so you may wish to check it each time you submit personal information to Moffu Labs. The date of the most recent revisions will appear on this page. If you do not agree to these changes, please do not continue to use Moffu Labs websites to submit personal information to Moffu Labs.You can also delete your Moffu Labs at any time – please see section 12 for details. If material changes are made to the Privacy and Cookies Policy, for instance affecting how we would like to use your personal information, we will notify you by placing a prominent notice on the website.19. Contacting Moffu Labs about this Privacy and Cookies PolicyIf you any questions or comments about this Privacy and Cookies Policy please contact: Data Privacy Officer c/o Moffu Labs S.r.l.Via Merano, 16 – 20134 Milano(Email: privacy@moffulabs.com)If you are viewing the international version of this website, moffulabs.com/en/, and you have any questions or comments about the Privacy Policy, please contact Moffu Labs via email: privacy@moffulabs.com