VGen LAB cares about your privacy!

VGen LAB processes your personal data in compliance with the applicable data protection legislation and, in particular, with Regulation (EU) 2016/679 ("GDPR"), Legislative Decree no. 196 of 30 June 2003 ("Codice Privacy”).

Through this Privacy Policy, we would therefore like to inform you how we will treat your personal data that we collect and/or that you confer through our website www.vgen.it (hereinafter "Site") in order to take advantage of the services available there.

Before you give us your information, use the Site, and access related services, please review this Privacy Policy.

Who processes your personal data?

The Data Controller is VGen LAB S.r.l., located in Rome (RM), Piazzale di Porta Pia, 116, 00198. You may contact us at any time by writing to info@vgen.it.

Purpose and legal basis of processing

Navigation on the Site is free.

You may purchase our products and/or services even without registering on the Site. For this purpose, we may use and/or collect your personal data for the purposes and according to the legal bases below:

1. Execution of the contract and taking pre-contractual measures at your request

In order to purchase our products and/or use the services made available on the Site, or to enable us to take all pre-contractual measures requested by you or necessary for the conclusion of the purchase process and/or execute the contract we have entered into and to fulfill the obligations strictly related to the same, we will process your data to:

• manage your application for membership in the Site and activate your Personal Area, in order to enable you to purchase or access the services available therein, as well as register for the Challenges rendered from time to time in the section dedicated to them on the Site in accordance with the Terms of Services;
• allow you to submit a request to join one or more of the initiatives, free and/or paid, on the Site (such as, for example, physical presence events, hackathons, business games, innovation ground, training courses, etc.) and receive all necessary information related to the Challenges you have signed up for through the means of communication you have indicated to us when registering on the Site;
• allow you to interact with other Solvers, members of your team, Mentors, Partners, and any other individuals who have organized and/or are otherwise involved in the Challenge in which you have enrolled, in accordance with the Terms of Services;
• manage the sales process of the products and/or services you requested (receipt and processing of the purchase order, activation of the purchased service, etc., etc.) in accordance with the provisions of our General Terms and Conditions of Sale the you can access BY CLICKING HERE.
• handle payment for the products and/or services you have purchased;
• handle any requests you may have for assistance and/or support in using the Site or complaints about the products and/or services you have purchased or intend to purchase.
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1. Compliance with legal or regulatory requirements

To fulfill the obligations to which we are subject, we will process your personal data for:

• fulfilling a legal obligation or, upon request, an order of the Authority.
• to inform or respond to any requests from the competent Authorities for the assessment of liability in case of damage to our Site, as well as for the prevention of crimes;
• fulfill accounting, tax and administrative obligations related to the purchase of products and/or services available on the Site.
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1. Pursuit of our legitimate interests

Based on our legitimate interest coinciding with our need to improve our Site, we will process your personal data to:

• send you notices, to the email address you may have provided to us, regarding similar products/services in accordance with applicable law;
• gestire le tue richieste di contatto in caso di malfunzionamenti e/o chiarimenti in merito all’uso del Sito, delle Challenge o rispetto ai prodotti e/o servizi da te acquisitati;
• improve our Site and related services to enable you to use them in the best way possible;
• prevent fraud of any kind from being committed through your use of the Site;
• ascertain, exercise or defend a right of ours in pre-litigation or judicial proceedings.
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1. Consent

Subject to obtaining your express and specific consent, we will process your data to:

• send you communications of an informative and/or promotional nature, including through our newsletter, relating to updates on initiatives, activities or events planned and/or promoted by VGen and/or for inclusion in distribution lists for sending communications relating to such activities;
• publish on our communication channels your photo, first name and last name in compliance with what is indicated in the Terms of Services;
• subscribe and add you to the communication channels reserved for members of our community (e.g. on Telegram);

Please note that our newsletter is free of charge. You may unsubscribe from the newsletter at any time by simply clicking on the "unsubscribe" button in each newsletter, or by exercising any of the rights set forth in the "What are and how can you exercise your rights" section of this Privacy Policy.

What data do we process?

Our Website allows us to collect the following categories of personal data:

Information we collect during your use of the Website

The Website allows us to acquire certain data whose transmission is implicit in the use of the web. We do not collect this information to identify you, but through processing and association with third party data we may be able to identify you. In particular, we may be able to collect:

• • the IP addresses of the devices you use to access the Website;
• • the URI/URL notation addresses of the requested resources;
• • the time of the request, the method used to submit it and the http response code;
• • other parameters related to your browser and/or operating system used by you.

These data will not be kept for longer than the time strictly necessary for the use of the Website, for the fulfilment of the obligations in force regarding public security and/or required by the control authorities and in any case no longer than 7 days.

Data collected through your application

If you intend to submit an application for membership in a Challenge on the Site, we may acquire the information contained in the application and, in particular:

• •  identifying data (e.g., first name, last name, place and date of birth);
• •  contact data (e.g., email, telephone);
• • Further information:

Data provided and/or acquired during the Challenge

The Site allows us to collect certain information necessary to enable you to participate in the Challenges from time to time posted on the Site in accordance with when indicated in our Terms of Services. To this end, we collect, for example, your membership and interest in individual Challenges and the information and content indicated in the Papers you upload as part of them, which will be shared with the Partners of the same.

Data collected when you purchase, on your part, products and/or services

Qualora intendessi acquistare prodotti e/o servizi disponibili sul Sito, potremmo raccogliere i seguenti dati:

• •  identifying data (e.g., first name, last name, place and date of birth, gender, permanent/temporary address);
• •  contact data (e.g., email, telephone);
• •  payment data (e.g. credit card data and/or other payment instrument used by you, IBAN, etc.) necessary to finalize the purchase process. Please note that such data will not be stored on our systems and must be entered into the secure payment system we use.
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VGen LAB Newsletter

Upon consent, you may receive periodically on your e-mail our newsletter containing communications of an informative and/or promotional nature about initiatives, activities or events planned or promoted by VGen LAB and/or for inclusion in distribution lists for sending communications related to such activities.

The newsletter is free of charge. You can unsubscribe from our newsletter at any time by simply clicking on the "unsubscribe" button in each newsletter or by contact us at help@vgen.it.

Data acquired through your registration through a social network

Where available, if you choose to log in or subscribe to our Site via social login systems (e.g., LinkedIn, Facebook), we may have access to the personal information associated with your account (e.g., first name, last name, email) solely to complete the registration process and allow you to access and/or use the services available on the Site.

What cookies are installed on our site?

We use cookies to improve your experience using the Site and allow us to monitor usage. You will find all information about the use of cookies and related features in our "Cookie Policy" that you can find BY CLICKING HERE.

Are you obliged to give us your personal data?

You are not obliged to give us your personal data, although failure to provide it, partial or incorrectly, may not allow you to submit - and us to evaluate - your application to join the Site or the available Challenges, or to purchase and/or access restricted areas and/or services made available on our Site, if any.

Withdrawal and/or failure to give your consent for the conduct of marketing activities does not entail any consequences for you, although, in that case, you will not be able to stay updated on our activities and initiatives.

To whom can we communicate your data?

Limited to the purposes indicated in this Privacy Policy, we may communicate your data to the following categories of subjects:

• Solvers, Mentors, other Users, Challenge Promoters Partners and/or sponsors of any Challenge uploaded to the Website to which you have subscribed;
• external vendors who perform activities on our behalf, including but not limited to maintenance and support service of our information systems, printing services, news agencies, management of payment services, etc;
• natural persons, legal entities or professionals that perform, on our behalf, any paid services and/or the management of events promoted by us and/or accessible through the Website;
• freelancers, firms or professional associations appointed to assume our defense in litigation proceedings of any nature;
• Public security authorities, judicial authorities, persons or entities to whom it is obligatory to communicate your personal data under the provisions of the law or orders of the competent authorities.

The data to be communicated will concern only the data necessary to achieve the specific purposes for which they have been provided or collected. You can request a list of these subjects by writing to info@vgen.it.

To whom do we transfer your data abroad?

Within the European Union, we may transfer the data collected through our Website in order to comply with legal, regulatory or regulatory obligations. Your data is stored on the servers of our hosting service provider Serverplan, whose servers reside in Italy.

However, it is possible that some cloud services and/or additional services offered by our providers may be provided by companies whose governance is located in countries located outside the European Union, and if this is the case, we are committed to:

• ensure that the country to which your personal data will be sent guarantees an adequate level of protection as required by Article 45 of the GDPR; or
• use the Standard Data Protection Contractual Clauses approved by the European Commission under Article 46(2) GDPR. For more information on the Standard Contractual Clauses click here.

Please also note that, such a transfer, is necessary for the performance of a contract concluded between the data subject and the data controller, or for the performance of services you have requested (e.g., the newsletter service).

For further clarification regarding transfers or guarantees taken write to us at info@vgen.it.

How long do we keep your personal data?

Your data are stored for a period of time not exceeding the time necessary for the purposes for which they were collected, conferred or subsequently processed in accordance with the provisions of the law.

In particular, the data provided for registration on the Website will be stored until your request for cancellation and/or deactivation of your account and, subsequently, only for the time necessary to fulfill the related legal obligations.

We inform you that the data of your credit card or payment systems that you have used and that may be available on the Website will not be stored, even temporarily, in our systems.

With reference, on the other hand, to the performance of the marketing activities indicated in this Privacy Policy, we inform you that we will process your data until you revoke your consent by writing to us at info@vgen.it, i.e., for 24 months after its acquisition, after which your data will be deleted and/or anonymized.

What are they and how can you exercise your rights?

You will be able to have clarity on the processing we carry out on your personal data or exercise the rights recognized by articles 15 and following of GDPR at any time. As example, you may exercise the following rights:

• Right of access: you can ask us for confirmation and which treatments we carry out on your personal data. You may also ask us to provide you with a copy of your data by e-mail and verify the data in our possession.
• Right of rectification: you will be able to modify your data where it is incorrect (for example, because it is different from the data you provided to us at the time you submitted your application) or complete incomplete data. You will also be able to modify and/or update your data or revoke the consents you have given via your Personal Area.
• Right to cancellation: you may ask us to delete all or part of the data you have provided us with.
• Right of limitation: you can ask us to limit the processing of your personal data to the use of the hypotheses provided for by law.
• Right to portability: you can obtain, in a structured format, in common use and readable by automatic device, the data you have provided us with and transmit them to another data controller.
• Revocation of consent: if the processing is legitimated by the consent you have given us, we inform you that you may revoke it at any time, without prejudice to the lawfulness of the processing carried out by us before said revocation.
• Right to lodge a complaint with the Guarantor: without prejudice to any other administrative or jurisdictional recourse, you may lodge a complaint with the Guarantor Authority for the protection of personal data in the event that you believe that the processing operations carried out by us are in conflict with or violate current legislation on data protection.

You may send us any request and/or exercise the above rights by writing to info@vgen.it.

Other websites

The Site may contain links to other websites (e.g., Twitter, Facebook, LinkedIn), which can be accessed by selecting appropriate links made directly accessible by it.

However, accessing and consulting such sites remains outside the scope of the activities, controls and/or security measures we take to protect your personal data. In such cases, we assume no responsibility in relation to the data processing performed by operators of other sites and/or applications. To this end, please carefully read their terms of use and privacy policies to understand how your personal data will be used.

Updates

We may amend this policy to comply with any changes in data protection legislation or as may be required by the relevant authorities. To this end, please check this page periodically to stay informed about how we process your data.

We will publish any new version of this policy and will notify you by e-mail. Any new version of the policy will be considered binding as soon as it is made known. If you do not wish to accept said changes, you may exercise any of the above rights within 7 days of receiving our email summarizing the changes to the Privacy Policy, otherwise it will be deemed accepted by you and, therefore, valid and binding.

Version updated as of December 22, 2021.