Last updated: July 15, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and disclosure of Your information when You use the Service and tells You about Your privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy. This Privacy Policy has been created with the help of the Privacy Policy Generator.

Interpretation and Definitions


The words of which the initial letter is capitalized have meanings defined under the following conditions. The following definitions shall have the same meaning regardless of whether they appear in singular or in plural.


For the purposes of this Privacy Policy:

  • Account means a unique account created for You to access our Service or parts of our Service.

  • Affiliate means an entity that controls, is controlled by or is under common control with a party, where “control” means ownership of 50% or more of the shares, equity interest or other securities entitled to vote for election of directors or other managing authority.

  • Application means the software program provided by the Company downloaded by You on any electronic device, named

  • Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to SiBot S.a.s. di Silletta Antonio & C., Viale Giacomo Mancini 156, Cosenza 87100.

  • Country refers to: Italy

  • Device means any device that can access the Service such as a computer, a cellphone or a digital tablet.

  • Personal Data is any information that relates to an identified or identifiable individual.

  • Service refers to the Application.

  • Service Provider means any natural or legal person who processes the data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the Service, to provide the Service on behalf of the Company, to perform services related to the Service or to assist the Company in analyzing how the Service is used.

  • Third-party Social Media Service refers to any website or any social network website through which a User can log in or create an account to use the Service.

  • Usage Data refers to data collected automatically, either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

  • You means the individual accessing or using the Service, or the company, or other legal entity on behalf of which such individual is accessing or using the Service, as applicable.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally identifiable information that can be used to contact or identify You. Personally identifiable information may include, but is not limited to:

  • Email address

  • First name and last name

  • Phone number

  • Address, State, Province, ZIP/Postal code, City

  • Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that You visit, the time and date of Your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect certain information automatically, including, but not limited to, the type of mobile device You use, Your mobile device unique ID, the IP address of Your mobile device, Your mobile operating system, the type of mobile Internet browser You use, unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through the following Third-party Social Media Services:

  • Google

  • Facebook

  • Twitter

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service’s account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service’s account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

Information Collected while Using the Application

While using Our Application, in order to provide features of Our Application, We may collect, with Your prior permission:

  • Information regarding your location

  • Information from your Device’s phone book (contacts list)

  • Pictures and other information from your Device’s camera and photo library

We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company’s servers and/or a Service Provider’s server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

  • To provide and maintain our Service, including to monitor the usage of our Service.

  • To manage Your Account: to manage Your registration as a user of the Service. The Personal Data You provide can give You access to different functionalities of the Service that are available to You as a registered user.

  • For the performance of a contract: the development, compliance and undertaking of the purchase contract for the products, items or services You have purchased or of any other contract with Us through the Service.

  • To contact You: To contact You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.

  • To provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless You have opted not to receive such information.

  • To manage Your requests: To attend and manage Your requests to Us.

  • For business transfers: We may use Your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Us about our Service users is among the assets transferred.

  • For other purposes: We may use Your information for other purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Service, products, services, marketing and your experience.

We may share Your personal information in the following situations:

  • With Service Providers: We may share Your personal information with Service Providers to monitor and analyze the use of our Service, to contact You.

  • For business transfers: We may share or transfer Your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of Our business to another company.

  • With Affiliates: We may share Your information with Our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include Our parent company and any other subsidiaries, joint venture partners or other companies that We control or that are under common control with Us.

  • With business partners: We may share Your information with Our business partners to offer You certain products, services or promotions.

  • With other users: when You share personal information or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If You interact with other users or register through a Third-Party Social Media Service, Your contacts on the Third-Party Social Media Service may see Your name, profile, pictures and description of Your activity. Similarly, other users will be able to view descriptions of Your activity, communicate with You and view Your profile.

  • With Your consent: We may disclose Your personal information for any other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use Your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

The Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of Our Service, or We are legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data is transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such action is necessary to:

  • Comply with a legal obligation

  • Protect and defend the rights or property of the Company

  • Prevent or investigate possible wrongdoing in connection with the Service

  • Protect the personal safety of Users of the Service or the public

  • Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While We strive to use commercially acceptable means to protect Your Personal Data, We cannot guarantee its absolute security.

Children’s Privacy

Our Service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If You are a parent or guardian and You are aware that Your child has provided Us with Personal Data, please contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without verification of parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information and Your country requires consent from a parent, We may require Your parent’s consent before We collect and use that information.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If You click on a third party link, You will be directed to that third party’s site. We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service, prior to the change becoming effective and update the “Last updated” date at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:


Who is the data controller of my personal data?

Data controllers pursuant to art. 4 (7) GDPR is:

• SIBOT S.a.s. DI SILLETTA ANTONIO & C , with registered office in Cosenza, viale Giacomo Mancini n ° 156, 87100

Data Protection Officer (“DPO”)

The Data Controller has appointed a person responsible for the protection of your data. You can contact the DPO at any time in the following ways:

What rights do I have with respect to my personal data?

Right to object – Art. 21 GDPR.

You have the right to object to the processing of your personal data where the Data Controller processes such data on the basis of a legitimate interest (Article 6.1 (f) GDPR) or for profiling or direct marketing purposes. If your opposition is compatible with the applicable law, the Data Controller will cease the related processing.

Right of access – Art. 15 GDPR.

You have the right to obtain from the Data Controller a confirmation as to whether or not your data is being processed. To provide you with this confirmation without violating the rights of others, the Data Controller may ask you for additional information in order to verify your identity. By exercising this right you can:

access your personal data;

receive information on the purposes of the processing, on the categories of data processed, the recipients or categories of recipients of such data, the data retention period envisaged or the criteria used to determine this period, the existence of the other rights granted to you by GDPR and the right to lodge a complaint with the competent supervisory authority, the source of any data collected from sources other than the interested party, the existence of automated decision-making processes, including profiling, the existence of adequate guarantees in relation to any transfer of data outside the European Union.

Furthermore, you will be able to obtain a copy of your personal data subject to processing by the Data Controller.

Right of rectification – Art. 16 GDPR.

You have the right to obtain from the Data Controller the correction of inaccurate personal data concerning you. Taking into account the purposes of the processing, you have the right to obtain the integration of incomplete personal data, also by providing an additional declaration.

Right to cancellation – Art. 17 GDPR.

You have the right to obtain the cancellation of all or part of your personal data if one of the following reasons exists:

• your consent has been revoked (where the consent itself constitutes the only basis for the relative processing);

• the personal data are no longer necessary with respect to the purposes for which they were collected or otherwise processed;

• You objected to the processing pursuant to Art. 21 GDPR and there is no legitimate overriding reason to proceed with the processing;

• the personal data have been unlawfully processed; or

• personal data must be deleted to fulfill an obligation under applicable law.

1 Despite the exercise of the right to cancel, the Data Controller may continue to process your personal data where this is necessary to observe laws to which the Data Controller is subject (for example of a fiscal nature) or to exercise the right of defense in court or right to freedom of expression or information.

Right to limitation of processing – Art. 18 GDPR

You have the right to obtain from the Data Controller the limitation of the processing. If you exercise this right, you will only be able to access those features of the PASS Services that do not require processing of your data.

The right to limit the processing can be exercised when one of the following hypotheses occurs:

• You dispute the accuracy of your personal data; in this case the Data Controller will limit the processing for the period necessary to verify the accuracy of such personal data;

• the processing is unlawful and you request that the use of personal data be limited instead of requesting its cancellation;

• the Data Controller no longer needs the personal data for the purposes of the processing, but they are necessary for you to ascertain, exercise or defend a right in court;

• You objected to the processing pursuant to Article 21 paragraph 1 of the GDPR pending verification of the possible prevalence of the Data Controller’s legitimate reasons with respect to your interests.

Right to data portability – Art. 20 GDPR.

You have the right to receive from the Data Controller in a structured format, commonly used and readable by an automatic device, the personal data concerning you and you have the right to transmit such data to another data controller. Alternatively, you have the right to obtain the direct transmission of personal data from one data controller to another, if technically possible.

Do I have the possibility to report problems related to the processing of my personal data?

Yes, you have the right to send reports to the Personal Data Protection Authority, Piazza di Montecitorio, 121, 00186 Rome, Italy –

How is my personal data protected?

The Data Controller does everything in its power to ensure that your personal data are kept secure. To this end technical and organizational measures have been implemented designed to best protect your personal data. These measures include in particular:

• periodic tests on the security of the IT infrastructure;

• access control within the organization and the IT systems of the Data Controller; is

• the use of cryptographic techniques.


How do we use cookies?

We use cookies for a variety of reasons described below. To make the best use of our website, we recommend that you set your device to accept all cookies. However, by using your device settings, you may disable or limit some types of cookies.

• Provide you with a better user experience: Cookies are used for a number of things that help improve your online experience. They can help in several ways, including: ensuring faster loading of our websites, keeping you connected even on different devices, making logins faster and more accessible by remembering your customer details, remembering how you used ours service earlier, allowing you to book a visit with a doctor faster and more accessible, or making sure our pages are optimized for your browser or device.

• Adapt our services to your preferences: Cookies can help us present you with content that meets your interests and preferences. Cookies also help us personalize our website for you.

• Improve security: We use some cookies to ensure the security of our websites.

• Improving our websites: We use cookies to improve our services, predict how users use our websites and to make websites better for our users.

• Marketing: We use some cookies to provide you with advertisements about our services. We use these cookies in cooperation with our marketing partners (Google and Facebook).

Third party cookies

We use third party cookies to pursue our legitimate interests and to improve our websites for our users.

We use Google Analytics. Google Analytics is widely used by many professional websites around the world. This tool helps us understand, predict and adapt our websites for our users and helps us manage our databases and improve our SEO.

We also use third party cookies to measure the use of our website; in particular, these cookies can record how much time you spend on our website, how you browse etc.

We also use third party cookies to test our new features and products. These cookies help us ensure that you receive a satisfying experience from our services.

We also use social media buttons and / or plugins on this site, which allow you to connect with your social network in various ways. In order for these to work, such social media sites, including Google and Facebook, will set cookies through our site which can be used to enhance your profile on their site or contribute to the data they hold for various purposes described in their respective privacy policies.

We use technical solutions provided by Facebook and Google to better adapt our services and to offer you a better user experience.

Third Party Tracking Tools

Traffic optimization and distribution through the Cloudflare service

This type of service allows this Application to distribute its contents through servers located throughout the territory and to optimize its performance.

The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter communications between this Application and the User’s browser.

Given the distributed nature of this system, it is difficult to determine the places where the contents are transferred, which may contain the User’s Personal Data.

Cloudflare (Cloudflare)

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

The methods of integration of Cloudflare provide that this filters all the traffic of this Application, that is the communications between this Application and the User’s browser, also allowing the collection of statistical data on it.

Personal Data processed: Cookies and various types of Data as specified in the privacy policy of the service.

Place of processing: USA – Privacy Policy.

Infrastructure monitoring via Pingdom

This type of service allows this Application to monitor the use and behavior of its components, to allow for the improvement of performance and functionality, maintenance or troubleshooting.

The Personal Data processed depend on the characteristics and methods of implementation of these services, which by their nature filter the activity of this Application.

Pingdom (Pingdom AB) is a monitoring service provided by Pingdom AB.

Personal Data processed: Cookies and Usage Data.

Place of processing: Sweden – Privacy Policy

Google analytics

We use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Website. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve our service. The reports disclose website trends without identifying individual visitors. For more information on Google Tag Manager, see here. For more information on Google Analytics, see here.

You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, see here.

Cookies help us run useful analytics.

If you don’t want Google Analytics to be used in your browser, you can also install the Google Analytics browser add-on.

Targeted advertising

Our advertising partners use device identifiers and other similar technologies to show you ads that are useful to you. We may share certain information such as your location, browser and cookie data and other data relating to your use of our Service with our business partners to deliver personalized advertisements (“ads”) that may be of interest to you. may allow third-party ad servers or ad networks to serve personalized advertisements either on the Service or on third party websites, including Facebook and Google. These third-party ad servers or ad networks use technology to send, directly to your browser or mobile device, these personalized ads and ad links, and will automatically receive your IP address when they do so. They may also use other technologies (such as cookies, JavaScript, device identifiers, location data, and clear gifs, see above) to compile information about your browser’s or device’s visits and usage patterns on the Service, and to measure the effectiveness of their ads and to personalize the advertising content. does not sell, rent, or share the information we collect directly from you or about you from third parties with these third-party ad servers or ad networks for such parties’ own marketing purposes.

Please note that an advertiser may ask to show an ad to a certain audience of users (e.g., based on demographics or other interests). In that situation, determines the target audience and serves the advertising to that audience and only provides anonymous aggregated data to the advertiser. If you respond to such an ad, the advertiser or ad server may conclude that you fit the description of the audience they are trying to reach.

Facebook: We use the pixel function of Facebook Custom Audiences to identify users who have landed on certain pages for the purposes of target group-orientated remarketing and advertising. The Facebook pixel stores a cookie, which means that information about your visit to our Website will be shared with Facebook. Also, as part of the “advanced matching” undertaken by Facebook, other information (such as telephone number, email address, Facebook ID) may be shared with Facebook in a hashed form. These cookies, and the information collected, are used to help Facebook deliver advertising on our behalf to users who have previously visited our Website when they are on Facebook or another platform powered by Facebook Advertising, and to track advertising success. You can modify your Facebook Ad settings to restrict these advertisements. Learn more about the different types of Facebook cookies here:

How long do we keep cookies?

Depending on the type of cookie, some of them are stored for a short period of time, while others are stored for longer periods. Below you will find more detailed information.

Session cookies: these cookies only last for a given session you have with us and are automatically deleted when you close your browser.

Persistent cookies: these cookies last even if the browser has been closed or the device has been turned off and are active for a period of time defined in the cookie. We use persistent cookies when we need to know who you are for longer than necessary for a single browsing session. For example, we use them to remember your preferences for the next time you visit our site.

Disabling cookies

You can prevent the setting of cookies by changing your browser settings. Please note that disabling cookies will affect the functionality of this and many other websites you visit. Disabling cookies usually also involves disabling some features and features of our services. Therefore it is recommended not to disable cookies.