Privacy Policy

This document (hereinafter, the “Privacy Policy”) applies to the processing of personal data (hereinafter, the “Data”) of the users (hereinafter, the “User/s”) carried out by Claudio Cavallini, Tax Code CVLCLD71T28G702Q, email "" (hereinafter, the “Controller”) through the website “”  (hereinafter, the “Website”).

This Privacy Policy does not apply to the third-party online store and websites from which you install the Website or make payments, which may also collect and use data about you, unless specifically indicated in it. The data Controller has no control over, and is not responsible for, the actions and privacy policies of third parties and other websites and apps.

The Controller reserves the right to modify, integrate or update, in whole or in part, this Privacy Policy at any time and for any reason. Users will be promptly alerted about any changes by updating the “Last updated” date of this Privacy Policy. Users are encouraged to periodically review this Privacy Policy to stay informed of updates. In this regard, Users that do not accept it before continuing to use the App, may request and obtain removal of Personal Data.


1. Definitions

2. Types of Data collected

3. Purposes of processing

4. Methods of processing

5. Legal basis of processing

6. Place

7. Retention time

8. Cookie

9. The rights of Users

10. Data Controller

1. Definitions

For the purposes of this Privacy Policy, the following definitions are framed within Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“Regulation”):

a)- Personal Data: in accordance with article 4, n. (1), of the Regulation is meant “any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person”;

b)- Processing: in accordance with article 4, n. (2), of the Regulation is meant “any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction”;

c)- Controller: in accordance with article 4, n. (7), of the Regulation is meant “the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law”;

2. Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Cookies; Usage Data; email address; first name and last name, credit card data, address, 

Tax Code.

Personal Data may be freely given to this App by the User under his or her consent or, in the case of usage data, may be collected through automated process by using this App.

Unless specifically indicated, the provision of User’s Personal Data for the purposes referred to in this privacy Policy is mandatory. Any refusal to provide the requested data could make it impossible to create an account and to enjoy the App’s services. Whereas the provision of specific User’s Personal Data for the purposes referred to is optional, any refusal to provide such data will not result in any detrimental consequences within the use of the App.

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

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

Controller will collect, store and process the following information:

a)- Usage Data:The computer systems and software procedures used to operate this site during their normal operation acquire some personal data whose transmission is implicit in the use of Internet communication protocols.This information is not collected to be associated with identified data subjects, but by their very nature it could, through processing and association with data held by third parties, allow users to be identified.This category of data includes IP addresses or domain names of the computers used by Users connecting to the site, the addresses in the Uniform Resource Identifier (URI) notation of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, and other parameters relating to the operating system and the user's computer environment.

b)- Personal Data voluntarily provided by the User: Users may voluntarily provide Personal Data to this Website as the name, surname, email address, phone number, account information to enter services and products, personal interests, and other. The failure to provide mandatory required information will prevent the service requested by the User from being performed, in whole or in part. Users are responsible for any third-party Personal Data obtained, published or shared through this Website pursuant to art. 6 of the Regulatory.

c)- Data collected by third parties’ web sites or apps: this Website may collect Personal Data through third party platform and analyze it whenever it is related to an User account or a published content directly linked to this Website.

3. Purposes of processing

Personal Data may be processed for the purposes described in this Privacy Policy, for compliance with a legal obligation to which the Controller is subject, for the performance of a contract to which Controller and User are party, or when the Controller has assessed it is necessary for the following purposes:

a)- management of payments: financial information related to payment method (e.g. credit card number, expiration date) is stored by our payment processor PayPal and Stripe who acts as data controller and not by this App. Payment processor services may include programmed messages to the User as invoices or communication related to the payment.

b)- managing contact and sending messages. The user's email address is automatically entered in a list of contacts enabled to receive email messages containing information, even of a commercial and promotional nature, related to this App. User’s email address may also be added to this list as a result of registering with this App or after making a purchase within it.

c)- creating a public profile of the User that can be viewed by other Users. In addition to the Data provided, this profile may contain User interactions with this Website.

d)- interaction with third-party live chat platforms directly from the pages of this Website. If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service, and the Data communicated to ………….

e)- Tag management to manage the tags or scripts needed on this Website in a centralized fashion.

f)- different commercial communications in relation to the interests of the User. Some of the services may use Cookies to identify the User or use the behavioral retargeting technique, i.e. display advertisements tailored to User’s interests and behavior, also detected outside of this Website, communicating Data to ..................

h)- registration and authentication to allow the Website to identify the User and give him access. The registration and authentication services could be provided by third parties.

i)- providing legal, tax, accounting, electronic invoicing, communication to the Interchange and Electronic Invoice Retention System by communicating the Data to third part subject to appropriate information.

l)- commercial affiliation to allow the Website to display advertisements of products or services offered by third parties displayed both in the form of advertising links and in the form of banners, communicating the Data to third part subject to appropriate information.

m)- sending comments and feedback to this Website. The comment service can be managed directly or provided by third parties. In this last case it is possible that, even if the Users do not use the comment service, the same collects traffic data related to the pages where the comment service is installed, communicating the Data to third part subject to appropriate information.

n)- inviting and suggesting friends. This Website may use the Personal Data provided and access to authorized internal content to allow Users to invite their friends, suggest friends or connections within it.

o)- interaction with social networks and external platforms directly from the pages of this Website. Even if Users do not use the service, it may collect traffic data about the pages on which it is installed, communicating the Data to third part subject to appropriate information.

p)- remarketing  and  behavioral targeting to allow this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.

q)- statistics to allow the Controller to monitor and analyze traffic data and track the behavior of the User by communicating the Data to third part subject to appropriate information.

r)- viewing content hosted on external platforms directly from the pages of this Website and interacting 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 communicating Data to third part subject to appropriate information.

4. Methods of processing

The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly suitable to ensure the security and confidentiality of the Data, and the compliance of the Treatment to the relevant regulations.

All data collected will not be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning the User or similarly significantly affects him or her.

In addition to the Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (staff management, business area staff, system administration, etc.) or external parties (such as IT companies, third-party technical service providers, mail carriers, hosting providers, etc.) appointed, if necessary, as Data Processors by the Controller. They may also have access to the Data whenever necessary and are contractually obliged to keep the Data confidential.

The updated list of these parties may be requested at any time addressing to contact details provided in this document.

5. Legal basis of processing

This Privacy Policy is issued under art. 13 of the Regulation (EU) 2016/679 of the European Parliament and the Council of 27 April 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data ("Regulation"), of Legislative Decree 196/2003 (as amended by Legislative Decree 101/2018) and other applicable local laws on the matter of protection of personal data.

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

a)- Users have given their consent for one or more specific purposes;

b)- Processing is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;

c)- Processing is necessary for compliance with a legal obligation to which the Controller is subject;

d)- Processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party.

6. Place

The Data is processed at the Controller's operating offices and in any other places where the parties involved in the processing are located. To find out more about the place of processing of such transferred Data, Users can inquire with the Controller using the contact details provided in this document.

7. Retention time

Data shall be processed and stored for as long as required by the purpose they have been collected for.

Therefore, Data collected for purposes related to the performance of a contract between the Controller and the User shall be retained until such contract has been fully performed.

Data collected for the purposes of the Controller’s legitimate interests shall be retained as long as needed to fulfill such purposes or User and third party’s legal defensive purposes.

Whenever the Processing is based on User’s consent, as long as such consent is not withdrawn the Controller may be allowed to retain Data. 

The Controller may be obliged to retain Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, 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.

8. Cookie

This Cookie Policy applies exclusively to the Website MaxiTicTacToe and shall be considered as an integral part of this Privacy Policy. This Website uses Trackers to provide a more efficient user experience.

1. Definition

Cookies are text strings sent to the User device during Website usage and then sent back to the Website each time the User log in it to allow automatic authentications, tracking sessions and saving specific information regarding users activities into the Website. They can contain a unique identification code tracking User activities for statistic or advertising purposes. During the Website experience, the User may be subject to third party’s cookies.

2. Collected cookies and purposes of the processing

a)- Session and permanent cookies: cookies can be stored throughout the session or for a longer period. A session cookie contains information that is stored in a temporary memory location and then subsequently deleted after the session is completed. This cookie will not store Personal Data to identify User.

b)- Technical cookies: are essential for the functionality of the Website and for the performance of activities requested by the User. Technical cookies allow to use the service more efficiently by identifying a session, accessing restricted areas, storing previously saved game levels. User consent is not requested to use technical cookies, but User can block or remove them by changing the options configuration. However, doing this may not guarantee some of the services offered by this Website.

c)- Analytics cookies: the Website or third parties can place analytics cookies on a User's device by collecting anonymous information about how Users interact with the Website and its features, generating statistics without personal identification of individual visitors. The information collected can be used to personalize User online experience and show specific content. Analytics cookies do not collect personal information.

d)- Profiling cookies: the Controller or third-party service providers may install profiling cookies to store User choices and provide targeted or optimized features such as online services, advertisements that take into account User interests or to prevent Users from being offered services that they have refused in the past. Advertisers or third parties may be allowed to place their profiling cookies on Users devices and use them, as the Controller can do, in order to provide custom functionality and optimize User experience. The Website currently uses cookies for profiling purposes.

3. Cookie Controller

For the purpose of this Cookie Policy, the Controller is Claudio Cavallini, Tax Code CVLCLD71T28G702Q, email ""

4. The rights of Users

Users are entitled at any time to obtain confirmation of the existence of the Data concerning them and to know its content and origin, to verify its accuracy or to request its integration or update, or to rectify, delete, anonymously transform or block the Data processed in violation of the law, and to oppose for legitimate reasons the processing of data concerning it by written request to be addressed in this document using the contact details provided in it.

5. Purpose of processing

Cookies are used by Controller to generate statistics and to assess correct usage of the Website and to improve its efficiency.

6. Enable / Disable cookies

The User can change the default configuration of the Website and enable or disable cookies or allow to be subjected to a confirmation message before accepting cookies. User must be aware that by permanently blocking or disabling cookies, may make it impossible for this Website to provide its fully operating or interactive services.

9. The rights of Users

Pursuant to the Regulation art. 15 and following provisions, User may exercise the following rights in any moment:

a)- withdraw the consent at any time;

b)- object to processing of their Data;

c)- access their Data;

d)- verify and seek rectification;

e)- restrict the processing of their Data;

f)- have their Personal Data deleted or otherwise removed;

g)- receive their Data and have it transferred to another controller;

h)- lodge a complaint.

Any requests to exercise User rights can be directed to the Controller through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

10. Data Controller

For the purpose of this Privacy Policy, the Data Controller is Claudio Cavallini, Tax Code CVLCLD71T28G702Q, email address ""

Last update: September 14, 2020