Improve your Empowerment
Privacy Policy
In short. This site does two things: it shows you what EMPOKERMENT is, and it lets you leave your email address so we can tell you when the trial version opens. If you accept measurement cookies, we also count how many people visit. Nothing else. We sell your data to no one, and you can have yourself removed at any time with a single message.
1. Data controller
All In Channel Entertainment & Communication di Pietro Semeraro
Via Carnaga, 29 — 21100 Varese (VA), Italy
VAT number 03440510125 — ROC no. 25933
Email: infoprivacy.dpo@allinchannel.com
Certified email (PEC): allinchannel@pec.it
No Data Protection Officer has been appointed: the processing carried out at this stage does not fall within the cases in which appointment is mandatory.
2. What data we process, why, on what basis and for how long
| Data | Purpose | Legal basis | Retention |
|---|---|---|---|
| Email address | To send you updates on the project and to tell you when the trial version opens | Consent — Art. 6(1)(a) GDPR | Until you withdraw consent and in any case no longer than 24 months from the last meaningful contact |
| Proof of consent: date and time, IP address, wording accepted and version of this policy | To demonstrate that consent was validly given | Legal obligation — Art. 6(1)(c) and Art. 7(1) GDPR | For as long as you remain subscribed and for the following five years, for evidential purposes |
| Browsing data recorded by the server: IP address, date and time of the request, page requested, browser | To keep the site running, security, defence against abuse and attacks | Legitimate interest — Art. 6(1)(f) GDPR | For as long as strictly necessary for the security and diagnostics of the service, according to the hosting provider's policy and in any case no longer than 12 months |
| Data collected by the anti-spam system when the form is submitted: IP address, browser and device information, interactions with the page | To verify that the sign-up comes from a person and not from an automated program | Legitimate interest in the security of the service — Art. 6(1)(f) GDPR | According to Google's terms, as stated in its own policy; we keep only the outcome of the check |
| Cookies and measurement identifiers (Google Analytics 4) | To count visits, understand which channels they come from and how many people leave their email | Consent collected through the banner — Art. 122 of the Italian Privacy Code and Art. 6(1)(a) GDPR | As stated in the cookie policy; consent is requested again after six months |
Signing up is completed by a confirmation: after you submit the form you receive a message with a link to open. Until you open it, your address stays pending and receives nothing else. This verifies that the address really belongs to the person who entered it. When the trial version opens, anyone who has already confirmed will not have to verify their address again: they will only need to choose their player name.
At this stage we do not collect first name, surname, player name, date of birth, telephone number, payment data or game data: neither accounts nor games exist yet.
3. Providing your data is optional
You can read every page without giving us any data. Leaving your email address is your free choice: without it you will not receive the announcements, but nothing else is denied to you. Consent to communications is separate, optional and is not a condition for any other service.
4. Recipients and data processors
Your data is never sold, transferred or disclosed for third-party marketing. It is processed, besides by the controller, by the following providers, appointed as processors under Art. 28 GDPR:
| Provider | Role | Where it processes the data |
|---|---|---|
| MailUp S.p.A. (Growens group), Italy | Platform for sending communications and managing the list | Italy — European Union |
| A2 Hosting, LLC — Hosting.com (Delaware, United States). Representative in the Union under Art. 27 GDPR: Hosting Holding Germany BidCo GmbH, Kennedy-Ufer 11, 50679 Cologne, Germany | Website hosting and retention of server logs | European Union and United States, depending on the data centre assigned to the account |
| Google Ireland Ltd. | Visit measurement (Google Analytics 4), only after consent | European Union, with possible transfers to the United States |
| Google Ireland Ltd. | Anti-spam system for the form (reCAPTCHA), activated only when you start filling it in | European Union, with possible transfers to the United States |
Data may also be disclosed to professional advisers and public authorities where necessary to comply with legal obligations or to defend a legal claim.
5. Transfers outside the European Economic Area
The contact list is managed in Italy. Transfers to the United States may instead occur through the hosting service, when the assigned data centre is located outside the Union, and through the measurement service. In those cases the transfer relies on the European Commission's adequacy decision on the EU-US Data Privacy Framework and, in the alternative, on the Standard Contractual Clauses, together with the supplementary measures declared by the providers and the processing agreements signed with each of them.
6. How we protect your data
The sign-up form is protected by Google reCAPTCHA, which tells people apart from automated programs. The tool does not start when you simply read the page: it is activated only when you begin filling in the form, and from that moment Google's privacy policy and terms apply. We use the outcome of the check for no other purpose.
The site is served over an encrypted connection. Access to the contact list is limited to the people who actually need it, with individual credentials and, where available, two-factor authentication. We collect the minimum necessary for the stated purpose.
7. Your rights
You may exercise the rights set out in Articles 15 to 22 GDPR at any time:
- access: to know whether we process data concerning you and to obtain a copy of it;
- rectification: to correct inaccurate or incomplete data;
- erasure: to be removed from the list and from our records;
- restriction of and objection to processing;
- portability: to receive your data in a machine-readable format;
- withdrawal of consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.
To exercise them write to infoprivacy.dpo@allinchannel.com: we reply within one month, extendable by two further months in complex cases, of which we will inform you. Every message we send also carries a one-click unsubscribe link.
You have the right to lodge a complaint with the Italian Data Protection Authority, the Garante per la protezione dei dati personali (Piazza Venezia 11, 00187 Rome — garanteprivacy.it), or with the supervisory authority of the country where you live, or to bring proceedings before a court.
8. Automated decision-making and profiling
We do not carry out profiling and we take no automated decisions producing legal effects concerning you or similarly significantly affecting you.
9. Minors
The site and the project are addressed to adults. By leaving your address you declare that you are at least 18 years old. If we become aware that an address belongs to a minor, we delete it without delay. When the trial version opens, registration will require a date of birth and the specific rules will be stated in the Terms of Use then in force.
10. Cookies
The use of cookies and similar tools is described in the cookie policy, which states which tools we use, what they are for and how to withdraw consent.
11. Changes
This policy will be updated as the platform evolves: registration with a player name, game history and activity data will each require new sections. Every version is published here with its number and date of entry into force; we will notify subscribers by email of material changes before they take effect.