Data Controller and Owner
Sokhrates S.r.l. SB– Via Molino delle Armi n. 11, Milano.
Data Protection Officer
Data protection officer
Aleksei Antonovitch Gandini
Types of Data collected
When an user uses Sokhrates, even if they are just looking at posts, Sokhrates receive some personal information like the type of device they are using and their IP address. User can choose to share additional information like their email address, phone number, address book contacts
Among the types of Personal Data that Sokhrates collects, by itself or through third parties, there are: Cookies, Usage data, email address, first name and last name.
Sokhrates does not automatically collect data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade-union membership, and the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person's sex life or sexual orientation. However, users should be aware that, by sharing their contents on the social network, they might publicly disclose some of these data, making them public and hence collectable.
Here a list of data Sokhrates might collect:
Information provided by User while using Sokhrates´s Services, including when signing up for an account, creating or sharing contents, messages or communication with others, locations and date of any material that is posted in the social network. Sokhrates also collect information about how users use its Services, such as the types of content they view or engage with or the frequency and duration of their activities.
Information provided by Other users
Sokhrates also collect content and information that other people provide when they use its Services, including information about the user, such as when they share a photo of the user, contact them.
User’s networks and connections.
Sokhrates collect information about the people and groups users are connected to and how they interact with each other, such as the people they communicate with the most or the groups they like to share with. Sokhrates also collect contact information user provide if they upload, sync or import their information (such as an address book) from a device.
Sokhrates collect information from or about the computers, phones, or other devices that the user use while they install or access Sokhrates’ Services, depending on the permissions granted.
Sokhrates share the content of user's Direct Messages with the recipient; these data do not use to serve ads.
User may provide Sokhrates with payment information, including credit or debit card number, card expiration date, CVV code, and billing address, in order to purchase advertising or other offerings provided as part of Sokhrates services.
Sokhrates keep track of how users interact with links across Sokhrates’ services. This includes links in emails sent to the user in Tweets that appear on other websites or mobile applications.
If the user click on an external link or ad on Sokhrates services, that advertiser or website operator might figure out that the user came from Sokhrates, along with other information associated with the ad clicked such as characteristics of the audience it was intended to reach. Advertisers may also collect other personal data, such as cookie identifiers or your IP address.
Sokhrates share or disclose non-personal data, such as aggregated information like the total number of times people engaged with a post, the number of people who clicked on a particular link, the topics that people are engaging about in a particular location, or reports to advertisers about how many people saw or clicked on their ads.
The Personal Data may be freely provided by the User, or collected automatically when using Sokhrates.
Failure to provide certain Personal Data may make it impossible for Sokhrates to provide its services.
Users are responsible for any Personal Data of third parties obtained, published or shared through Sokhrates and confirm that they have the third party's consent to provide the Data to the Owner.
Sokhrates give users control through their settings to limit the data collected and their use, and to control things like account security, marketing preferences, apps that can access their account, and address book contacts.
Mode and place of processing the Data
Methods of processing
The Data Controller processes the Data of Users in a proper manner and shall take 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. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
The Data is processed at the Data Controller's operating offices and in any other places where the parties involved with the processing are located. For further information, please contact the Data Controller.
The Data is kept for the time necessary to provide the service requested by the User or stated by the purposes outlined in this document. Normally, data are collected as long as the user is registered as an user of the Sokhrates social network and does not notify their intention to eliminate their account, unless Sokhrates no longer need the data to provide products and services.
Sokhrates may also access, preserve and share information when it has a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity.
These Information may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of Sokhrates terms or policies, or otherwise to prevent harm.
User can always request the controller to access, rectify or erase or restrict the collection of their personal data, as well as make them portable to other data collector, through the following link contact. The user can withdraw their consent at any time and ask for the suspension or elimination of all personal data collected just by clicking at the following link contact.
User can also ask confirmation as to whether or not personal data concerning him or her are being processed at the following link contact. .
Users should keep in mind that search engines and other third parties may still retain copies of their public information, like their profile information and public posts, even after the users have deleted the information from Sokhrates services or deactivated their account.
User has the right to lodge a complaint about use of their information (and without prejudice to any other rights they may have), with their local supervisory authority or Sokhrates supervisory authority, the Italian “Garante della Privacy”.
Profiling and Direct Marketing Objections
User have the right to consent or not to the fact that their data might be used to categorize their interests and interactions in an automated way through measures that safeguard the user’s rights and freedoms and legitimate interests, also for direct marketing purposes. User has the right to express their consent at any time, expressly when registering at Sokhrates or through the modalities described under "User rights”.
Sokhrates services are not directed to children. Users under the age of 16 needs their parent or guardian consent in order to activate an account. Parent or guardians can give their consent only if they create an account on Sokhrates as well.
The use of the collected Data
The Data concerning the User is collected to allow Sokhrates to provide its services, as well as for the following purposes: Access to third party services' accounts, Analytics, Interaction with external social networks and platforms, Managing contacts and sending messages, Contacting the User, Displaying content from external platforms, Infrastructure monitoring, Registration and authentication and Traffic optimization and distribution.
The Personal Data used for each purpose is outlined in the specific sections of this document.
Data collection is not a statutory requirement, but it is necessary to access Sokhrates’ services.
Sokhrates might also use contact information to market to user as their country’s laws allow, and to help others find user's account if their settings permit, including through third-party services and client applications.
Any different or further use of collected data will be notified to User prior to the further processing with information on that other purpose and with any relevant further information.
All information used by Sokhrates are aimed to provide, improve a develop its Services.
Data collection is used, specifically, to:
personalize content, and make suggestions for users by using their information and interaction with the Services and the people or things they are connected to and interested in on and off Sokhrates’ Services; provide shortcuts and suggestions, such as possible friend, tags, events of interest,
conduct surveys and research, test features in development
communicate with the user
send marketing communications,
verify accounts and activity, promote safety and security, investigate suspicious activity and violations.
The use of the collected Data with Others
Sokhrates social network is based on sharing information by the users.
Sokhrates shares information according to the level of privacy chosen by the User.
Public information is those shares with every possible user, as well as information from Public Profiles or content shared as public. Users that registers as Sponsors understand that their accounts will be automatically followed, hence be visible, to all Sokhrates' users. These information are available to anyone and can be seen or accessed through online search engines, APIs, and offline media, such as on TV. These contents might also be re-shared.
Users might share contents about other users with their privacy settings such as sharing a photo of them or tagging them. If the user does not want this information to be share, they can report the post to the Data Controller and Owner.
Sokhrates might also share information with third party companies who help provide and improve its Services or who use advertising or related products, which makes it possible to operate Sokhrates’ companies and provide free services to people around the world.
Here are the types of third parties Sokhrates can share information with about user:
Advertising, Measurement and Analytics Services (Non-Personally Identifiable Information Only).
When advertising on Sokhrates will start, Sokhrates will be able to use information from the user to show them relevant ads. However, in this case Sokhrates will not share information that personally identifies the user with advertising, measurement or analytics partners unless permission is given.
Sokhrates also share information with vendors, service providers, and other partners who globally support its business, such as providing technical infrastructure services, analyzing how Services are used, measuring the effectiveness of ads and services, providing customer service, facilitating payments, or conducting academic research and surveys. These partners must adhere to strict confidentiality obligations in a way that is consistent with this Data Policy and the agreements Sokhrates enter into with them.
Sokhrates may share information internally within their companies or with third parties for purposes described in this policy. Information collected within the European Economic Area (“EEA”) may, in the future, be transferred to countries outside of the EEA for the purposes as described in this policy. Sokhrates utilize standard contract clauses approved by the European Commission, adopt other means under European Union law, and will obtain user's consent to legitimize data transfers from the EEA to the United States and other countries.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Access to third party services' accounts
This type of services allows Sokhrates to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically but require explicit authorization by the User.
Facebook permissions asked by Sokhrates
This service allows Sokhrates to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Sokhrates may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it.
The permissions asked are the following:
By default, this includes certain User’s Data such as id, name, picture, gender, and their geo-localization. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Provides access to the birthday.
Provides access to the User's primary email address.
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of Sokhrates, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage data.
Contacting the User
By filling in the contact form with their Data, the User authorizes Sokhrates to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email address, first name and last name.
Displaying content from external platforms
This type of services allows you to view content hosted on external platforms directly from the pages of Sokhrates and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows Sokhrates to incorporate content of this kind on its pages.
Personal Data collected: Cookies and Usage data.
Interaction with external social networks and platforms
This type of services allow interaction with social networks or other external platforms directly from the pages of Sokhrates.
The interaction and information obtained through Sokhrates are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage data.
Registration and authentication
By registering or authenticating, Users allow Sokhrates to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, Sokhrates will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Additional information about Data collection and processing
The User's Personal Data may be used for legal purposes by the Data Controller, in Court or in the stages leading to possible legal action arising from improper use of Sokhrates or the related services. The User declares to be aware that the Data Controller may be required to reveal personal data upon request of public authorities or if Sokhrates have a good faith belief that the law requires it to do so and the law is consistent with internationally recognized standards.
Additional information about User's Personal Data
System logs and maintenance
For operation and maintenance purposes, Sokhrates and any third-party services may collect files that record interaction with Sokhrates (System logs) or use for this purpose other Personal Data (such as IP Address).
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from the Data Controller at any time. Please see the contact information at the beginning of this document.
The rights of Users
Users have the right, at any time, to know whether their Personal Data has been stored and can consult the Data Controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the Data Controller at the contact information set out above.
Definitions and legal references
Personal Data (or Data)
Any information regarding a natural person, a legal person, an institution or an association, which is, or can be, identified, even indirectly, by reference to any other information, including a personal identification number.
Information collected automatically from Sokhrates (or third party services employed in Sokhrates), which can include: the IP addresses or domain names of the computers utilized by the Users who use Sokhrates, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within Sokhrates) and the details about the path followed within Sokhrates with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
The individual using Sokhrates, which must coincide with or be authorized by the Data Subject, to whom the Personal Data refers.
The legal or natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
Data Controller (or Owner)
The natural person, legal person, public administration or any other body, association or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes, and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Sokhrates. The Data Controller, unless otherwise specified, is the Owner of Sokhrates. Sokhrates
The hardware or software tool by which the Personal Data of the User is collected.
Small piece of data stored in the User's device.
Notice to European Users: this privacy statement has been prepared in fulfillment of the obligations under EU Regulation 679/2016 and the relevant European and Italian legislation.
Effective: May 25, 2018