Privacy Policy

Last updated: 13th December 2024

Brief summary for if you’re short on time
I. For User, Registered User or Private Advertiser that uses our Services
Dario Sangiovanni, with registered office at Via Castagnevizza 192, Fiumicino, Rome, 00054 Italy, VAT and tax code no. IT13120271005, C.F. SNGDRA83E19H501U, (hereinafter, "10 Under Tiber Studio") is the data controller for processing the personal data you provide us with via the Website, its relative subdomains or the Apps, in order to provide to you our services.
At the time you request a service, you register in our Services, this becomes a contractual relationship that is the legal basis to be able to process your personal data.
We may also send you commercial messages when you have accepted them.
If you have authorised the assignment of your data or you have requested us for a service rendered by other companies, the latter may need to have access to your data in order to be able to render the service.
You can, at any time, access, rectify or cancel your data, as well as exercise other rights, as explained below.
II. For Professional Advertiser or company or representative thereof that uses our Services for Business Profiles
10 Under Tiber Studio is the data controller for processing the personal data you provide. We will process them in order to be able to render the services you request based on the agreement signed with the company you represent, this being the legal basis to be able to process them in the legitimate interest of 10 Under Tiber Studio.
Your data may be shared with 10 Under Tiber Studio's service providers that must access them in order to render the service.
You can, at any time, access, rectify or cancel your data, as well as exercise other rights, as explained below.
You should know:
We always recommend that you fully read the privacy policy that we provide below to be able to know in-depth which data we use from each service you request and for how long we need to keep them.
This privacy policy may be modified by a unilateral decision by 10 Under Tiber Studio, so we recommend that you review it regularly.
When you click the "Ok, let’s go" button or equivalent, you state you know and understand 10 Under Tiber Studio's privacy policy.
Now we get down to the nitty-gritty of the legal text, so that you can have the peace of mind to know everything we do (and don’t do) with your data. Go pop the kettle on and put on your favourite song to make the reading just a little lighter.

Index
  1. Data controller: who is the data controller for processing your data?
  2. Purpose of the processing: what can we do with your data?
  3. Legal basis: why can we process them?
  4. Recipients: to whom can we disclose your data?
  5. International data transfers: where can we send them?
  6. Period for storing your data: how long will we process them?
  7. Required updated information
  8. Rights of data subjects
  9. Confidentiality and security
  10. Additional information about certain functions of the Services
  11. Types of data collected
  12. Third party services involved in the processing of your data
1. Data controller: who is the data controller for processing your data?
Dario Sangiovanni, with registered office at Via Castagnevizza 192, Fiumicino, Rome, 00054 Italy, VAT and tax code no. IT13120271005, C.F. SNGDRA83E19H501U, (hereinafter, "10 Under Tiber Studio") is the data controller for the processing of personal data sent through our website and its subdomains or our mobile applications or our tools (hereinafter, the "Services").
We provide information in the following sections about the rights you (hereinafter referred to as the "User" or "Registered User") hold as well as how we use your personal data, whether you use our Services to search for information about professionals or businesses advertised (hereinafter referred to as the "Business Profiles") or if you post a professional or business profile as an individual (hereinafter referred to as the "Private Advertiser" or "Advertiser") or as a representative of a Professional Advertiser (hereinafter referred to as the "Professional Advertiser" or "Advertiser") by virtue of the EU General Data Protection Regulations 2016/679 (hereinafter referred to as the "GDPR").
If you have any queries related to the processing of your personal data, you can contact us at the following email address: privacy(at)doctful.com
2. Purpose of the processing: what can we do with your data?
  1. We manage your personal data to render the services you have requested through the Services. The list of services includes the following:
    1. Signing-up as a user
    2. Saving and managing your searches for Business Profiles
    3. Contacting advertisers
    4. Publication of listings on the website doctful.com and/or on the websites of other companies belonging to the 10 Under Tiber Studio group, branding and extra visibility.
    5. Posting advertisements
    6. Contact chat
    7. Business Profiles valuation service
    8. Multimedia services that help you to improve your listing (including photo book, professional video, text and image enhancements, etc.)
    9. Sending information about Business Profiles that may interest you.

    Please note that, if you have requested any of the above services, we may contact you by phone, SMS or email (if you have provided any of these data), for the provision of the same.
  2. In the case of a claim or query, we will process your data in order to manage them.
  3. If you are a User or a Private Advertiser, we may send you commercial messages, if you have accepted them, for the following purposes:
    1. To send you information about Business Profiles, news and other promotional messages related to 10 Under Tiber Studio or its partners
    2. To send you special offers of companies that will help you in the sale process of your Business Profiles related services
    3. To invite you to participate in satisfaction surveys
  4. If you are a User or Registered User, a profile may be created that will include information about the searches you have launched, the Business Profiles you have saved as favourites or the contacts you have made with advertisers for the purpose of showing you similar Business Profiles through messages that could be of interest to you.
  5. If you are a representative or contact person of a Professional Advertiser, we manage your personal data to keep in contact and develop the business relationship with the companies you represent. Moreover, we may send you messages for the following purposes:
    1. To invite you to events and workshops held by 10 Under Tiber Studio or by its partners
    2. To send you information about Business Profiles, news and other promotional messages related to 10 Under Tiber Studio or by its partners
    3. To invite you to participate in satisfaction surveys
  6. If you have purchased a paid service, are a Private Advertiser or a representative or contact person of a Professional Advertiser, we process your personal data to manage any claims for payment for our services.
3. Legal basis: why can we process them?
The legal basis that allows us to process your data for each of the purposes specified in section 2 above are:
  1. Contractual relationship: applicable when you request one of our services specified in paragraph 2.I above, even if such services are free of charge.
  2. Legitimate interest: to handle the queries and claims you send us (paragraph 2.II) and manage claims for payments of due amounts (paragraph 2.VI). If you are a representative or contact person of a Professional Advertiser, we have a legitimate interest to remain in contact with the company to which we render services and that you represent, also to invite you to our events and workshops (paragraph 2.V)
  3. Your consent:
    1. If you are a Registered User or a Private Advertiser, by checking the box included in the sign-up form or in the user profile menu, you have authorised us to send you the messages referred to in section 2.III above
    2. If you are a representative or contact person of a Professional Advertiser, by checking the box included in the contact form or when contracting any of our services, you have authorised us to send you the messages referred to in section 2.V above
4. Recipients: To whom can we disclose your data?
The legal basis that allows us to process your data for each of the purposes specified in section 2 above are:
In relation to paragraph 2.I above (services requested)
  1. To the advertisers that you have contacted to handle your request.
  2. Courts or Tribunals or Public Authorities to fulfil any legal requirement.
In relation to paragraph 2.III above, (if you are a User, Registered User or a Private Advertiser)
  1. Third parties in the business sector, consultants and other companies of 10 Under Tiber Studio when you have accepted this and for the purpose of sending you direct marketing messages.
For the remaining purposes
Your data will not be disclosed to third parties unless we need to fulfil any legal requirement.
To enable the publication of listings and the management of business between brands belonging to the same group, your personal data may be communicated to other services in the group to which 10 Under Tiber Studio belongs.
10 Under Tiber Studio's data processors may access your personal data, in other words, 10 Under Tiber Studio's service providers that must access your data in order to perform their duties, including technology service providers, documentation tools and support tools in order to assess the functioning of the Services and the use of certain functions by the users.
You can request further information about the use of your data by sending an email to the email address privacy(at)doctful.com specifying the specific processing or use for which you require information about the recipients.
5. International data transfers: where can we send them?
We will as a rule, your personal data are stored in computer/paper resources in countries within the European Union; in case, for organisational reasons/business choices of 10 Under Tiber Studio or the relevant group, it becomes necessary to transfer them to countries outside the European Union, the measures provided for by European Regulation 2016/679 in Paragraphs 44-49 will be adopted, as from time to time most appropriate to the specific case of transfer your personal data internationally for any of the purposes listed above.
6. Period for storing your data: how long will we process them?
Depending on each processing purpose, the period for storing your data may be:
  1. During the whole contractual relationship, in other words while you are using our services or while we or the supplier is handling your requests (applicable to paragraphs 2.I above).
  2. Until the query or claim has been settled (paragraphs 2.II and 2.VI).
  3. Until you revoke your consent (paragraphs 2.III and 2.V).
  4. If you are a representative or contact person of a Professional Advertiser, during the contractual relationship with the company you represent or until you notify us that you are no longer its contact person (paragraph 2.V).
  5. Until you request its cancellation (applies to all purposes under section 2).
In addition, we hereby inform you that your data will remain blocked after the end of the processing for which they are intended and during the time-barring (prescription) periods of obligations for each purpose stated in section 2.
If you are Private Advertiser (whether you have used the free or the paid service), we hereby inform you that if you request to delete your Doctful account, we will keep your telephone number and email address in a blocked state from the deactivation date of the last of your listings up to the legal time-barring period. During this period, we retain the right to carry out security checks to ensure the correct working of our services.
7. Required updated information
There are fields in the forms that are for mandatory completion, without which we will be unable to render you the services you request. When you click on the "Ok, let’s go" button (or equivalent) included in the aforementioned forms, you state that the information and the data that you provide are correct and true.
In order for the information provided to always be up to date and so that it does not contain any errors, please remember to inform us as soon as possible of any changes and rectifications of your personal data that occur by using the following email address: privacy(at)doctful.com. You can also update your personal data through your private area on the Services.
8. Rights of data subjects
We hereby inform you that you can exercise the following rights:
  1. The right to access your personal data to know which ones are subject to processing and the data processing operations carried out with them
  2. The right to rectify any inaccurate personal data
  3. The right to cancel your personal data, whenever this is possible (for example, by a legal order)
  4. The right to request the restriction of your personal data processing when the accuracy, legality or need for the data processing is in doubt, in such case, we can keep them to file or defend any claims.
  5. The right to oppose processing of your personal data, when the legal basis that authorises us to process them in our legitimate interest allows this. 10 Under Tiber Studio will stop processing your data unless it has a legitimate interest or it is necessary to defend claims.
  6. The right to the portability of your data, when the legal basis that authorises us to process them is the existence of a contractual relationship or your consent has been granted.
  7. The right to revoke the consent granted to 10 Under Tiber Studio.
You can exercise your rights at any time free of charge in the following ways:
  1. From the private area on the Services, you can unsubscribe to the commercial messages previously accepted. Through this section you can select and customise the kind of messages you wish to receive from 10 Under Tiber Studio.
  2. If you are unable to access the Services, you can send an email to privacy(at)doctful.com specifying the right that you wish to exercise and your identifying data.
We also inform you that you are entitled to submit a claim to the Italian authority "Garante per la protezione dei dati personali" if you consider an infringement has been committed of the data protection laws when processing your personal data.
9. Confidentiality and security
At Doctful, we make all reasonable efforts to keep the personal information confidential that is processed through the Services and if need be, other 10 Under Tiber Studio tools. We will apply strict security levels to protect the personal data we process to avoid accidental loss and unauthorised access, processing or disclosure, bearing in mind the state of the art, the nature and risks to which the data are exposed. However, we cannot be held responsible for your use of the data (including the username and password) at Doctful that is not through our Services.
10. Additional information about certain functions of the Services
Use of the message archive and internal chat messaging
For the purpose of improving your experience, Doctful will make a message archive service (sent or received) and internal messaging (chat) available to you on the Services through which Users, Registered Users and Advertisers can begin to make contact or continue their chats. By accepting this Privacy Policy, you expressly consent to 10 Under Tiber Studio storing such chats; accessing them and using automatic systems to check them to ensure fulfilment of the general terms and conditions for using the service, developing and improving our services and for the other purposes outlined in this policy.
We reserve the right to block access to the messaging service if, at our discretion, we consider that the chats could contain malicious content, spam or imply any risk for Users, Registered Users or Advertisers. Since 10 Under Tiber Studio provides various forms of contact, Users or Advertisers can choose to directly contact you using the email address, your telephone number provided or by other communication channels not under the control of 10 Under Tiber Studio.
Registering a username and password
When signing up on the Services, you must specify a username and password that will allow you to start a session at any time as a "Registered User" and therefore manage your relationship with 10 Under Tiber Studio. The password can be changed.
It is indispensable that you store and keep the password secret at all times and that you do not provide it to any third parties. It is advisable not to use the same password for all your personal accounts so that, if any third party accesses them without your consent, such person will not be able to access the different accounts that you have on different websites.
Passively collected information
When rendering our Services we will use software and/or services of third parties to passively, without your knowledge, collect data, while you are browsing or interacting with the content of our Services or that of the subsidiaries or investee brands of 10 Under Tiber Studio, as well as information about the device you use.
The sole purpose of passively collecting this information is to learn more about how you use and interact with the Services in order to improve your experience while using our services and detect possible errors in the implementation of our Services. The information collected will include the following, among others:
  1. The IP address of your device
  2. The screen size and resolution of the device you use
  3. Type of device (unique device identifier) and information about the browser
  4. Geographic location
  5. Preferred language used on our Services
  6. Web pages visited
  7. Date and time of the visits to the Services
For more information on passively collected information, please review our Cookies Policy.
11. Types of data collected
We have collected the following categories of personal data from or about consumers within the last 12 months:
Personal Data CategoryPersonal Data we collect in this CategorySources of Personal Data
Identifiers
  1. First name
  2. Last name
  3. Password (encrypted)
  4. Profile picture
  5. Internet Protocol address(es)
  6. Email address
  7. Account name (username), or other similar identifier
  8. Telephone number
  9. Mobile push tokens
  10. Specific third-party identifiers relating to payment services (VAT, Tax Identification Number) may be collected for some accounts
  1. Information you provide us
  2. Information we collect from you automatically
  3. 3rd Party Service Provider
Geolocation Data
  1. IP address data
  2. Location
  3. Physical address
  4. Country
  5. Postal code/Zipcode
  6. Timezone
  1. Information you provide us
  2. Information we collect from you automatically
User profile
  1. Gender
  2. Age
  3. Language
  4. Content Language
  5. Other information the User chooses to share in the private section of the profile
  1. Information you provide us
  2. Information we collect from you automatically
  3. 3rd Party Service Provider
User activities
  1. Favorites
  2. Chat messages
  3. Appointment details (location, time, status)
  4. Appointments history
  1. Information you provide us
  2. Information we collect from you automatically
Advertiser profile
  1. Business Profiles name
  2. Business Profiles phone number
  3. Business Profiles location (address, location, country)
  4. Business Profiles hours
  5. Business Profiles services (name, duration, price, availability)
  6. Other information the Advertiser chooses to share in the private section of the Business Profile
  7. Other information the Advertiser chooses to share in the private section of the Advertiser Profile
  1. Information you provide us
  2. Information we collect from you automatically
  3. 3rd Party Service Provider
Payments
  1. First name
  2. Last name
  3. Account ID
  4. Email address
  5. Transaction ID
  6. Transaction timestamps
  7. Transaction amount
  8. Transaction status
  1. Information you provide us
  2. Information we collect from you automatically
  3. 3rd Party Service Provider
Internet or other similar network activity
  1. Browsing history
  2. Information on a User’s interaction with the Services
  3. Information regarding your operating system and device
  1. Information we collect from you automatically
  2. 3rd Party Service Provider
For more information on passively collected information, please review our Cookies Policy.
12. Third party services involved in the processing of your data
Hosting and backend infrastructure
NameTypes of data
OVH (OVH Groupe SA)platform code and data
Place of processing
France
Description
OVH is a cloud computing company which offers VPS, dedicated servers and other web services. Privacy Policy
Platform services and hosting
NameTypes of data
Cloudflare (Cloudflare Inc.)Trackers; various types of data as specified in the privacy policy of the service
Place of processing
Worldwide
Description
Cloudflare, Inc. is an American company that provides content delivery network services, cloud cybersecurity, DDoS mitigation, and domain registration services. Privacy Policy
Payments and billing
NameTypes of data
Stripe (Stripe Inc.)Billing address; email address; first name; last name; payment info; Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing
Worldwide
Description
Stripe is a payment processing platform that allows businesses to accept payments from customers through their website, e-commerce platform, app, or pretty much anywhere else on the internet. Privacy Policy
Infrastructure monitoring
NameTypes of data
Bugsnag (SmartBear Software Inc.)Trackers; various types of data as specified in the privacy policy of the service
Place of processing
United States
Description
Bugsnag is an app monitoring and stability tool that helps teams build better software. It can help you debug issues that impact user experience. Privacy Policy
Platform services and hosting
NameTypes of data
Githubplatform data backups (encrypted)
Place of processing
United States
Description
GitHub is a website and cloud-based service that helps developers store and manage their code, as well as track and control changes to their code. Privacy Policy
Managing apps and sending messages
NameTypes of data
OneSignal (OneSignal Inc.)email, first name, last name, phone number, chat messages, appointment details
Place of processing
United States
Description
OneSignal is a customer engagement solution for Push Notifications, Email, SMS, In-App Messaging, and Live Activities. Privacy Policy
Collect feedbacks
NameTypes of data
Feedback Fish (Maximilian Stoiber e.U.)email, first name, last name, phone number, chat messages, feedback data
Place of processing
United States
Description
Feedback Fish is a simple widget for collecting website feedback from users: problems, suggestions or anything else. Privacy Policy
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