Privacy policy

A) Personal Data Protection

1. By registering, The User gives his/her express consent for the use and storage of the data for other purposes. Furthermore, The User gives his/her consent for the change of all no-personal data. The Advisor shall comply with the respective statutory provisions governing the protection of personal User data.

Personal User data shall be processed and applicable on INVICTUS web site and INVICTUSApp by The Advisor to fulfil General Terms and Conditions accepted during registration and specific requirement of the User before the subscription. Unless a specific and facultative consent of the User to data processing for commercial purposes pursuant to paragraph 2, The Advisor shall use personal data (name, surname, e-mail address, telephone number) for the sole purpose of verifying the identity of The User, in order to avoid possible abuses and swindles. The User shall be also contact for service requirements only (i.e. communication about changes in General Terms and Conditions; notification about services provided by INVICTUS web site and INVICTUSApp).

2. Furthermore, with The User's voluntary and optional permission, The Advisor shall process some User’s personal data (i.e. name, surname, e-mail address and telephone number) for commercial purpose (sending of advertising material, marketing communication and direct sales), or to contact the User through mail or e-mail to the purchase of products and services provided by The Advisor and/or by third parties. Even if consent is achieved, The User should remain at any time able to withdraw the grant to using his/her personal data making demanded to The Advisor with the modalities indicated at paragraph 6.

The User may object to additional promotional communications (through e-mail) clicking on the specific link in every promotional e-mail to express his/her cancellation of consent. After receiving the revocation of consent, The Advisor shall send a confirmation e-mail to The User.

The Advisor informs that, subsequent to the exercise of the right to object promotional e-mails, The User may receive further promotional communications for technical reasons (i.e. creation of clients’ packing lists before User’s request of object). If the User shall receive promotional communications after 24 hours from the exercise of the right of object, The User should inform The Advisor, using contacts indicated in paragraph 6.

3. The processing of User’s personal data will be performed using manual and computerized tool, with logic strictly related to the purposes and in any event to ensure the security and confidentiality of data.

4. All employees and collaborators of the INVICTUS web site and INVICTUSApp who may be aware of The User’s personal information. Those subjects, who are expressly nominated "processors of personal data", shall process User’s personal data solely for the abovementioned purposes and in compliance with the Italian Privacy Code.

Third parties may learn User's personal data as “external processors of personal data” such as service providers and system suppliers of INVICTUS web site and/or INVICTUSApp, outsourcing service providers or cloud computing service responsibles. professionals and consultants, companies involved in advertising services. The User shall request a list of all prosessors of personal data nominated by The Advisor using modalities indicated in paragraph 6.

5. Furthermore, with The User's voluntary and optional permission, The Advisor shall communicate User's personal data (name, surname, e-mail address and telephone number) to trade partners (“The Partners”). The Partners, as the independent data processing functions, shall process User’s personal data for their commercial purposes: direct sales, sending of commercial and advertising material. In case of lack of consent, The User's subscription to INVICTUS web site and/or INVICTUSApp shall not be compromised. The Advisor informs that User’s personal data shall be process by The Partners as independent holders of treatment on the basis of specific information sending to The User by The Partners. Possible further requests for rejection of personal data processing should be direct directly to The Partners.

6. Pursuant to Art. 7 of the Privacy Code, The Advisor informs that The User has the right to obtain an indication (i) of the origins of the personal data; (ii) the purposes and methods of processing; (iii) the method applied in the case of processing carried out with the aid of electronic means; (iv) the identifying details of the Data Controller and Data Processor: (v) the subjects or the subject categories to whom the personal data may be disclosed or who may become aware of them in the performance of their duties as Data Processing Managers.

The User shall have the right to obtain:

1. the updating, correction or, when they are interested, additions to the data

2. the cancellation, transformation into anonymous form, or blocking of data processed in violation of law, including those that need not be retained for the purposes for which the data were collected or subsequently processed

3. certification that the parties to which the data have been transferred or disseminated have been notified of the operations specified in points a) and b), also regarding their content, except for the case where notification proves impossible or requires the use of means clearly disproportionate to the right being protected.

The User has the right to oppose, the total or partial processing of his/her data: 6.1) for legitimate reasons, the handling of the personal information concerning him/her even if it is pertinent to the purpose of its collection; 6.2) the handling of personal data which pertains to him/her for the purpose of sending advertising materials or direct sales materials, for the completion of market research or for commercial communication. The User may exercise his/her rights with the following modalities: (i) by sending them by registered mail to The Advisor’s Registered office (ii) by sending an e-mail.

7. The Advisor reserves the right to store data link, source and destination IP details and all other log files to protect its and third parties’ computers. The Advisor shall also exercise the right to compiling User reports not directly referred and by registering, The User gives his/her explicit content, for the purpose.

8. In order to adapt develop and optimize constantly INVICTUS web site and INVICTUSApp and their design and quality to User’s individual need, The Advisor shall use cookies, retargeting cookies and tracking tools.

1. Cookies and retargeting cookies

Cookies are text files placed on User's computer hard disk or mobile while he/she is browsing on INVICTUS web site or INVICTUSApp. Retargeting cookies collect data (on personal use of INVICTUS web site and INVICTUSApp and on socio-demographic factors). Cookies detect what are User’s favourite games, his/her frequency (time of the day and days of the week) and how long INVICTUS web site and INVICTUSApp are used. The Advisor analyzes and uses data collected by cookies in order to adapt INVICTUS web site and INVICTUSApp to the specific needs and interests of The User and to establish statistics and user groups. Furthermore, data are also used specifically for the choice of advertisement by third parties. The stored data are updated constantly depending on User behavior.

The User accepts the use of cookies and retargeting cookies by The Advisor. He/she also accept expressly that his/her personal data (i.e. User gender) shall be processed by automatic supports (i.e. electronic means).

2. Traking tools

Tracking tools are services provided by third parties that support The Advisor during the analysis and statistical evaluation of User behavior. The Advisor uses acquired data to optimize and develop INVICTUS web site and INVICTUSApp. Tracking tools that The Advisor used are: Mixpanel, Google Analytics, Facebookanalytics, Clickmeter, Hotjar.

9. The Advisor shall take all reasonable steps to achieve the best possible results in terms of User data protection. However The Advisor is not liable for conseguences of data amendment or treatment by third parties. A mutual agreement between The User and The Advisor stipulates that The Advisor is not responsible for such damages to The User or third parties.

10. The User may view his/her personal data stored by The Advisor at any time accessing to User settings of INVICTUS web site or INVICTUSApp

11. The User reserves the right to modify or delete his/her personal data any time with a direct request to The Advisor. The Advisor agrees to User’s request of deleting data concretely. By cancelling all required registration data, The Advisor shall automatically cancel User account.

12. The Advisor assures that processing of data during payment transactions shall be in accordance with Directives PCI DSS (Payment Card Industry Data Security Standard).

B) Responsibility and Warranty

1. Liability claims against The Advisor, its employees, collaborators and consultants for accidents with services, advices and subscriptions provided by INVICTUS web site and INVICTUSApp are excluded only insofar as the damage was not due to The Advisor own fault or privity. The exclusion of liability herein agreed does not apply to cases of personal injury.

2. The Advisor and its employees, collaborators, consultants, trade partners remain outside the scope of the product liability law within the framework of legislations.

3. The Advisor waives all responsibility for damage of any nature to The User that might be due to the illicit use of services, advices, subscriptions of INVICTUS web site and INVICTUSApp by third parties (meaning persons other than The Advisor, its employees, collaborators and consultants), except in cases of gross negligence or wilful misconduct caused by The Advisor.

4. The Advisor waives all responsibility for damage due to force majeure or other circumstances beyond The Advisor’s control.

5. The Advisor assumes no liability for User’s Content but reserves the right to delete those contents that infringe conditions of use and legal provisions when they are detected as well as they are transmitted to law enforcement authorities on the instruction of the court.

6. In case of violation of these Terms and Conditions, The User in required to inform The Advisor immediately. In case of violation of these Terms and Conditions, The User guarantees to maintain indemnify and hold harmless The Advisor from all damages and rights of third parties caused by this violation. Furthermore, The User covers the losses or costs incurred by this violation. The obligation to compensation for damages by The Advisor are not subject to restrictions.

7. The Advisor may in no event be held liable for any loss or damage to The User and The User acknowledges and agrees that advices provided by The Advisor do not guarantee winning of any kind. Therefore The User do not hold The Advisor, its employees, collaborators and consultants for received information. The User shall be the solely responsible for received advices and information.

8. The Advisor may not be held liable if the e-mail with the advices sent by The Advisor should arrive to The User late or never.

9. The Advisor could generate links to other web sites. By clicking on the external links, The User will leave INVICTUS web site or INVICTUSApp and, consequently, The Advisor shall not be considered responsible for the User’s use of that links outside the platform.

C) Final provisions

1. The Advisor reserves the right to widen or modify the offer of services constantly.

2. Any modifications to the General Conditions of contract will be communicated to The User through e-mail. If The User does not oppose within two weeks since the message has been received, these changes will be considered accepted.

3. All communication and explanations of this General Terms and Conditions shall be considered valid in writing through e-mail or on INVICTUS website and INVICTUSApp only.

4. The User shall immediately inform The Advisor any changes to his/her personal data on INVICTUS web site and INVICTUSApp. If The User will not communicate these changes promptly, he/she should not receive important legal declarations transmitted by The Advisor and they shall be considered as delivered.

5. After registration to INVICTUS web site and INVICTUSApp, every User expressly recognises all intellectual ownership rights of this General Conditions to The Advisor.

6. Even if any single provision of the Contract become invalid, this agreement shall remain valid in all the other parts.

7. These Terms and Condition represent the entire agreement between The User and The Advisor regarding the service provided by The Advisor to Users in order to allow them to use it with their own Account. These Terms and Conditions replace all contracts and agreements previously stipulated by the parties.