Privacy Policy

This privacy notice regarding the processing of personal data is provided pursuant to Article 13 of Regulation (EU) 2016/679 concerning the protection of natural persons with regard to the processing of personal data, as well as the free movement of such data (hereinafter "Regulation") and the Personal Data Protection Code Legislative Decree 196/2003 as subsequently amended (hereinafter "Privacy Code"). It describes the methods by which Alobar Ltd UK (hereinafter, the "Provider" or "Controller") collects, uses, stores, and protects the personal data of users of the Imbued application (hereinafter, the "App").

In this notice, we will also explain what categories of data are processed, what rights data subjects have, and how those rights can be exercised. We invite you to read this notice before providing any personal information of any kind. If you are under 14 years old, pursuant to Article 2-quinquies of the Privacy Code, you must inform a parent or legal guardian of the content of this notice and obtain their documented consent if such consent is required for the processing of your data in the context of our Services. Unless otherwise specified, all terms herein with a capital letter, whether in singular or plural, are to be understood as defined in the General Terms and Conditions of the IMBUED App.

1 – Data Controller
The personal data provided by the User, as well as data collected during navigation on the IMBUED App, will be processed by Alobar Ltd UK, with registered office at 9 Sandys Row, London, England, E1 7HW, as Data Controller, for the purposes specified in this document.
2 – Types of Data Processed
The App offers informational, educational, and at times, interactive content. While browsing the App, information may be collected about the user in the following ways:

1. Navigation Data
The computer systems and software procedures used to operate the App acquire, during their normal operation, certain personal data whose transmission is implicit in the use of Internet communication protocols. This category of data includes: IP addresses, the type of browser used, the operating system, the domain name and the addresses of websites from which access was made to or exit from the App, information on the profiles visited by Users within the App, access times, internal navigation paths, and other parameters related to the User’s operating system and IT environment.

2. Data Provided by the User for Registration in the App This includes all personal data voluntarily provided by the User, for example, to register with the App or to communicate with other Users. You may be asked to provide your name, email address, and place of residence. If you provide personal data of third parties, you do so under your exclusive responsibility, and you guarantee that you have the right to communicate or disclose such data, thus releasing the Controller and its suppliers from any consequences and liability towards those third parties. The Controller does not collect sensitive data or data belonging to the special categories referred to in Article 9 of Regulation (EU) 2016/679, or data relating to criminal convictions or offenses.

3 – Data processing methods
The processing is carried out both manually and by means of IT and/or telematic tools, using organizational methods and logic strictly related to the purposes indicated. For the above-mentioned purposes only, your data may be disclosed to external consultants and other subcontracted service providers involved in performing the requested operations and managing the User relationship in all its phases, as well as for responding to technical support requests and improving the App's service. These companies will process your personal data on behalf of Alobar Ltd UK, as Data Processors pursuant to Article 28 of the Regulation. If you wish, the updated list of the Data Processors pursuant to Article 28 of the Regulation is available at the Data Controller’s registered office, and you may also request it by emailing info@AlobarLtdUK.com .

4 – Purpose and Legal Basis of Processing
The personal data collected through the Imbued App are processed for various purposes, all in compliance with the principles of lawfulness, fairness, and transparency as required by the GDPR.
Firstly, the data are processed to allow the User to register and create a personal profile, as well as to enable access to the services offered by the App, such as the publication of artistic content, interaction with other users, creation of collections, and participation in the creative community. In this case, the legal basis is the performance of the contract between the User and the Provider, that is, the provision of the services requested via the App.
Secondly, certain data may be used for technical communications, updates related to the functioning of the App, announcements about new features, or contractual changes. This processing is based on the legitimate interest of the Controller to ensure the proper use of the service and to keep users informed about relevant aspects of the contractual relationship. A fundamental aspect of the Imbued project is also its scientific purpose: the data collected through the use of the App (in particular interaction data, browsing data, artistic preferences) are processed in anonymous and aggregated form to support studies and scientific research on creative, cognitive, and emotional behaviours of users in digital contexts. This type of processing is carried out based on the legitimate interest of the Controller and, in some cases, in light of the public interest connected to research activities, in accordance with the principles of data minimization and anonymization as established by law. Finally, data may be processed to comply with legal obligations or to respond to requests from competent authorities, in accordance with applicable regulations. In these cases, the legal basis for the processing is the fulfilment of legal obligations to which the Controller is subject. Alobar Ltd UK may also provide aggregated statistics about user traffic patterns, the number of users who have created accounts (by account type), and information relating to the App to third parties. In such cases, the data will be anonymized and will not include any personally identifiable information.

5 – Location of Data Processing
The Data is processed at the operational offices of the Data Controller and at any other location where the parties involved in the processing, such as data processors, are located within the European Economic Area (EEA). For further information, you may contact the Data Controller at info@imbued.art . Transfer of Data Outside the EU Pursuant to Article 44 of the Italian Privacy Code, and in order to allow you to navigate our web pages and register for or access a reserved area, Alobar Ltd UK may transfer your personal data to service providers located in countries outside the European Union or the European Economic Area, provided that the recipient country has received an adequacy decision under Article 45 of the GDPR, recognizing that it ensures an adequate level of protection. If it becomes necessary to transfer data to third countries that have not been granted an adequacy decision under Article 45 of the Regulation, Alobar Ltd UK ensures the adoption of appropriate safeguards, such as the use of Standard Contractual Clauses (SCCs) approved by the European Commission. These clauses guarantee a level of data protection equivalent to that required by EU law. For more information, contact the Data Controller at info@imbued.art.

6 – Data Retention Period
Personal data will be retained for the time necessary to fulfil the purposes for which they were collected, unless further legal obligations apply. Public content will remain visible until deleted by the User or upon account deletion. In any case, Alobar Ltd UK may continue to process and retain some of your personal data even after the above-mentioned periods, if necessary to defend or assert a right of its own, or to comply with a legal obligation (pursuant to Article 6(1)(f) of the GDPR). Data anonymized for scientific research purposes may be stored in aggregated form even after that, without any possibility of re-identification.

 7 – Data Subject Rights
We inform you that, in accordance with applicable legislation, you are entitled to: Right of access: to request and obtain information regarding the processing of your personal data and a copy of such personal data; Right to data portability: to request and obtain your personal data, provided by you and processed by automated means, in a structured, commonly used, and machine-readable format; you may also request that such data be transferred to another data controller; Right to rectification: to request and obtain the modification and/or correction of your personal data if you believe it is inaccurate or incomplete; Right to erasure and restriction: to request and obtain the erasure and/or restriction of processing of your personal data if such data are or become unnecessary for the purposes mentioned above; Right to object to processing and/or automated decision-making: to object at any time to the processing of your data, unless we have legitimate reasons to continue processing that prevail over your interests. Requests to exercise the above-mentioned rights should be addressed to Alobar Ltd UK at its registered office located at 9 Sandys Row, London, England, E1 7HW, or by email at info@imbued.art , attaching a digital copy of your valid ID document. Finally, we inform you that under current legislation you may lodge complaints regarding the processing of your personal data with the Italian Data Protection Authority (Garante per la protezione dei dati personali). More information is available on the website: http://www.garanteprivacy.it.

8 – Changes to this Privacy Policy
Alobar Ltd UK reserves the right, at its sole discretion, to modify and/or otherwise amend this Privacy Policy at any time. Such changes and/or additions will be published on the App and will become effective immediately upon publication. Therefore, we recommend reviewing this Privacy Policy periodically. Continued use of the App, completion of the online registration form, and any other interaction with the App or use of the Services after the publication of any changes and/or additions to this Policy will constitute acknowledgment and acceptance of the revised Privacy Policy.