Last updated: 07/10/2026

This Privacy Policy describes how SmartChain S.r.l. ("we", "our", or "the Company") collects, uses,  stores, and shares the personal data of users ("User" or "you") who use the FreeTime mobile application (the "Application").

1. Data Controller

The Data Controller for personal data collected through the Application is:

• Company Name: SmartChain S.r.l. 

• Registered Office: Discesa Zeusi, 1 

• VAT / Tax Code: 03607620782

• Contact Email: info@smart-chain.it

2. Types of Data Collected and Processing Methods

Depending on how you use the Application, we may collect the following categories of data:

• Data voluntarily provided by the user: First name, last name, email address, and login  credentials provided during registration for account creation and management, as well as saved  calendar event data (titles, dates, notes).

• Voice Notes (Speech-To-Text): Audio files sent to create events via voice notes. The audio is processed for text transcription and deleted after processing.

• Image and Flyer Processing (OCR): Images of posters or flyers uploaded for event data extraction  using artificial intelligence algorithms. Images are deleted after processing.

• Geolocation (Optional): Geographic location of the device (subject to explicit consent) to suggest local events. Location permissions can be disabled at any time in the device settings.

• Push Notifications (Optional): Device token for sending event reminders or service-related  notifications and technical updates.

• Technical and usage data: IP address, device identifiers (IDFA for iOS, GAID for Android), usage  data, crash logs, and app performance statistics.

3. Advertising and Tracking (Ads)

We do not sell your personal data to third parties in any way.

The Application may display advertisements served by third-party service providers (e.g., ad  networks such as Google AdMob). These third parties may collect or use anonymous device identifiers  or cookies solely for delivering, analyzing, or personalizing advertisements, always in compliance  with the consents granted by the user.

4. Purposes and Legal Basis for Processing (for EU Users - GDPR)

We process your personal data only when at least one of the following conditions is met:

• Performance of a contract: To ensure the proper functioning, maintenance, and delivery of the Application's services (e.g., account management, calendar synchronization).

• User consent: For audio/OCR processing, access to geolocation, and displaying personalized  advertisements. Consent can be revoked at any time.

• Compliance with a legal obligation: To comply with legal obligations to which the Data Controller is subject.

• Legitimate interest: To analyze app usage in an aggregated and anonymous form to improve functionality, prevent unlawful use, and ensure system security.

5. Data Retention (Data Minimization)

Personal data will be kept only for the time strictly necessary to achieve the purposes for which  it was collected, or as provided by law:

• Audio files and temporary images are deleted immediately after processing.

• User account and calendar data will be retained until application utility ceases or until a deletion request is submitted.

• Expired session tokens and temporary logs are automatically deleted through periodic cleanup routines.

6. Sharing Data with Third Parties

Your data will not be sold to third parties. It may be shared solely for functional application purposes with:

• Third-party service providers that support the Company in managing and operating the app (e.g., cloud hosting services, analytics tools, and artificial intelligence services).

• Third-party ad networks for delivering in-app advertisements.

• Public authorities, where legally required.

7. User Rights (GDPR)

In accordance with the European General Data Protection Regulation (GDPR), you have the right to:

• Access your personal data in our possession and obtain a structured copy (available via the  "Export My Data" feature in the app).

• Request the rectification or erasure of your data ("right to be forgotten"), available  independently via the "Delete Account and Data" option in the app Settings.

• Request restriction of processing or object to it. Request data portability. Revoke consent at any time.

• Lodge a complaint with the Italian Data Protection Authority (Garante per la Protezione dei Dati Personali). To exercise your rights, you can send a written request to the email address: info@smart-chain.it

8. Changes to this Privacy Policy

We reserve the right to amend this Policy at any time. Any material changes will be notified to users directly within the Application or by updating the date at the top of this page.