Privacy Policy of the Application

This Application collects some Personal Data from its Users.

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Owner and Data Controller

MediaEngine Srl

Via Quadrio, 20 – 20154 Milano Italy

Owner contact email: info@retlay.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: name; email address; profile picture; username; geographic position; device information; Usage Data; session statistics; photos; videos; audio recordings; documents; chat messages; push notification tokens; biometric enrollment status.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Some deployments of this Application include a server endpoint for users in China. Data processed through that endpoint is subject to Chinese data protection laws (PIPL) in addition to this policy.

Retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

The purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: authentication and account management; work data synchronisation and collaboration; push notifications; location-based store selection; in-app translation; analytics and performance monitoring; error tracking and crash reporting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

Authentication and account management

The Application uses an enterprise Single Sign-On (SSO) provider for authentication and identity management. Personal Data processed: login credentials and identity tokens.

Work data synchronisation and collaboration

Work-related content — including photos, videos, documents, and chat messages — is synchronised across the User’s devices and made accessible to authorised members of the User’s organisation according to their role and permissions. Personal Data processed: name, email address, profile picture, role, assigned area, photos, videos, documents, chat messages, message metadata.

Location services

If the User grants permission, the Application collects geographic location while the Application is in use (foreground only) to suggest nearby stores and speed up store selection. Location is not tracked in the background or used for advertising. Personal Data processed: geographic position.

Biometric authentication

The Application offers optional Face ID / Touch ID login. iOS handles all biometric verification locally; the Application only receives a success or failure signal. A locally generated token is registered with the server to confirm biometric enrolment — no biometric templates or raw biometric data are ever transmitted or stored by the Owner. Personal Data processed: biometric enrolment status.

Push notifications

The Application sends push notifications for work events and updates via a third-party push notification service. Personal Data processed: device push notification token, notification delivery events.

In-app translation

When a User explicitly requests translation of a chat message, the message text is sent to a third-party translation API for processing. Personal Data processed: chat message text.

Analytics and performance monitoring

Microsoft Application Insights (Microsoft Corporation)

Microsoft Application Insights is an analytics service. Personal Data processed: User ID, device type, app version, screen views, feature interaction events, session duration.

Privacy Policy: https://privacy.microsoft.com/privacystatement

Session recording — Smartlook (Smartlook s.r.o.)

Smartlook is a session recording and user behaviour analytics service. This service is enabled only in production environments. Personal Data processed: User ID, session interactions, screen content recordings.

Privacy Policy: https://www.smartlook.com/privacy/

Error tracking — Sentry (Functional Software, Inc.)

Sentry is an error tracking service. Data is stored in the EU. Personal Data processed: error logs, stack traces, session identifiers.

Privacy Policy: https://sentry.io/privacy/

Push notification delivery — Pushwoosh (Pushwoosh, Inc.)

Pushwoosh is a push notification delivery service. Personal Data processed: device push tokens, notification delivery metadata.

Privacy Policy: https://www.pushwoosh.com/privacy-policy/

Translation — Google Translate API (Google LLC)

Google Translate API is used to translate chat messages at the User’s request. Personal Data processed: message text submitted for translation.

Privacy Policy: https://policies.google.com/privacy

Further Information for Users

Legal basis of processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof.
• Processing is necessary for compliance with a legal obligation to which the Owner is subject.
• Processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner.
• Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Further information about retention time

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

Therefore:

• Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
• Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfil such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
• The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Device permissions for Personal Data access

This Application requests certain permissions from Users that allow it to access the User’s device Data as described below. All permissions are optional; denying a permission may limit certain features but will not prevent core use of the Application. Permissions can be managed at any time via My Account > Settings > Permissions or via the device’s system settings.

• Camera — used to capture in-store photos and videos for work tasks.
• Photo Library — used to select and upload existing photos from the device.
• Microphone — used to record and send voice messages in chat.
• Location (When In Use) — used to suggest nearby stores for faster selection.
• Face ID / Touch ID — used for biometric authentication as an alternative to a password.
• Push Notifications — used to receive real-time alerts for work activities.

The rights of Users based on the General Data Protection Regulation (GDPR)

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following, to the extent permitted by law:

• Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
• Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
• Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
• Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
• Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
• Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
• Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.

Security measures

The Owner takes appropriate security measures to protect Personal Data against unauthorised access, disclosure, modification or destruction. These include HTTPS with a minimum of TLS 1.2 for all communications, hardware-backed encrypted storage on-device, token-based API authentication with short-lived session tokens, and role-based access controls. Biometric templates never leave the User’s device. Despite these measures, no data transmission or storage system can be guaranteed to be 100% secure. In the event of a data breach, the Owner will notify affected individuals and relevant supervisory authorities as required by applicable law.

International data transfers

The Data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States, where the Owner’s third-party service providers operate. In such cases, the Owner ensures appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) approved by the European Commission and Data Processing Agreements with all sub-processors.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Children’s privacy

This Application is designed for professional enterprise use only and is not directed at children under the age of 18. The Owner does not knowingly collect Personal Data from minors. If you believe a minor has provided Personal Data, contact the Owner immediately.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page.