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Privacy Policy

📅 Last updated: 07/10/2026

This Privacy Policy describes how SmartChain S.r.l. ("we", "our", or "the Company") collects, uses, stores, and shares the personal data of users ("User" or "you") who use the FreeTime mobile application (the "Application").

1. Data Controller

The Data Controller for personal data collected through the Application is:

  • Company Name: SmartChain S.r.l.
  • Registered Office: Discesa Zeusi, 1 - Crotone, Italy
  • VAT / Tax Code: 03607620782
  • Contact Email: info@smart-chain.it

2. Types of Data Collected and Processing Methods

Depending on how you use the Application, we may collect the following data categories:

  • Registration and Profile Data: Name, username, email address, profile avatar, and credentials. When signing in via Google or Apple, we collect public identity data authorized during the OAuth consent screen.
  • Calendar and Event Data: Custom events, dates, times, descriptions, locations, and personal notes created or synchronized inside the app.
  • Voice Notes and Audio Recordings: Temporary voice recordings submitted via the voice input interface. Audio files are processed by AI models (Speech-to-Text and NLP) solely to extract event metadata and are deleted immediately after transcription.
  • Images and Posters (OCR): Flyers, photos, or screenshots uploaded to automatically schedule events. Images are analyzed and permanently deleted immediately after text extraction.
  • Location Data (Optional): GPS coordinates or approximate city location, subject to explicit user consent, to recommend events matching your location and radius preferences.
  • Social Listening Channels: Public channel links and event portals configured by the user for automatic event discovery.
  • Push Notifications (Optional): Device push token for event reminders and service notifications.
  • Technical and Usage Data: IP address, device identifiers (IDFA for iOS, GAID for Android), crash logs, and aggregated app performance statistics.

3. Advertising and Tracking (Ads)

We do not sell your personal data to third parties in any way.

The Application may display advertisements served by trusted third-party providers (such as Google AdMob). These networks may use anonymous device identifiers solely for ad delivery, analytics, or personalization in compliance with your permissions.

4. Purposes and Legal Basis for Processing (GDPR)

We process your personal data only when at least one of the following conditions is met:

  • Performance of a contract: To ensure the proper functioning and delivery of the Application's services (account management, calendar sync).
  • User consent: For audio/OCR processing, geolocation access, and personalized advertisements. Consent can be revoked at any time.
  • Legal obligation: To comply with legal requirements and regulatory frameworks.
  • Legitimate interest: To evaluate app performance, prevent fraud, and ensure platform security in aggregated, anonymized form.

5. Data Retention (Data Minimization)

Personal data is retained only for the duration strictly necessary for the intended purposes:

  • Audio recordings and temporary images are erased immediately after NLP/OCR processing.
  • User account and calendar entries remain active until account closure or deletion request.
  • Expired authentication tokens and system logs are systematically removed by automated cleanup jobs.

6. Sharing Data with Third Parties

Your data is never sold. It is shared strictly with:

  • Cloud hosting, backend processing, and AI infrastructure partners operating in full compliance with European GDPR standards.
  • Third-party ad networks for delivering in-app advertising.
  • Law enforcement or public authorities when strictly required by law.

7. User Rights (GDPR)

In accordance with the European General Data Protection Regulation, you are entitled to:

  • Access your personal data and receive a structured copy (via "Export My Data" in the app).
  • Rectification or Erasure of your data ("right to be forgotten"), accessible directly in the app Settings or on our web page: FreeTime Account Deletion.
  • Restriction or Objection to data processing, as well as data portability.
  • Withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
  • Lodge a complaint with your competent Data Protection Supervisory Authority (in Italy: Garante per la Protezione dei Dati Personali - www.garanteprivacy.it).

To exercise any of these rights, contact us at: info@smart-chain.it

8. Changes to this Privacy Policy

We reserve the right to revise this Policy periodically. Notice of material updates will be posted inside the Application or indicated by the revised date at the top of this document.