Privacy Policy – Waitlist

This English version is provided for convenience only. In the event of any dispute, misunderstanding or other conflict, the Italian text shall be deemed the definitive reference.

   

Last updated: 30 settembre 2025

In compliance with Article 13 of the European General Data Protection Regulation (EU Regulation 679/2016, “GDPR”), we inform you that:

 

1. Data Controller

Social Media Marketing SRLS, with registered office at Via Monti Iblei 12, 90146, Palermo (PA), Italia. MoodTo is a product of Social Media Marketing SRLS.

For any questions regarding privacy, you can contact us at: privacy@moodto.com.

This Privacy Notice applies exclusively to the form related to the waiting list (also referred to as the “waitlist”), and shall be considered as additional, not replacing, the general MoodTo Privacy Policy available at: moodto.com/privacy-policy

2. Purpose and Legal Basis

The data collected will be processed solely for the following purposes:

• to manage your subscription to the waitlist for early access to the MoodTo app;
• to send you one-time, non-commercial communications regarding the availability of the app on the stores;
• to comply with legal and audit obligations (e.g., consent record-keeping).

The legal basis for processing is your explicit consent provided by checking the relevant box (Art. 6.1.a GDPR). Providing your data and related consent is optional but necessary to join the waitlist. Without consent, you will not be included in the waitlist nor receive early access communications.

3. Data Processed

Through the form we collect and store the following data:

• Email address;
• Country indicated by the user as reference for early access;
• Any expressed interest in becoming a Mooder;
• Explicit consent to the use of personal data;
• IP address and user agent, recorded exclusively for security and legal audit purposes of the consent.

4. Processing Methods

Data are processed electronically, with appropriate technical and organizational security measures to ensure confidentiality, integrity, and availability.
Access to the data is restricted to authorized personnel and appointed data processors.

5. Recipients and Infrastructure

Data will not be sold or disclosed to third parties.
However, they are processed by service providers acting as Data Processors under Art. 28 GDPR, including:

• Vercel Inc.: hosting services (EU servers);
• Supabase: database hosting (EU servers);
• Cloudflare: network and security infrastructure services, which may involve extra-EU data processing in compliance with Articles 44 et seq. GDPR (extra-EU servers).

For more information, please refer to the general Privacy Policy at: moodto.com/privacy-policy

6. Extra-EU Transfers

Data are stored on servers located within the European Union. Should a transfer outside the EU be required, it will be carried out only where a European Commission adequacy decision is in place or subject to standard contractual clauses ensuring protection of your rights.

7. Data Retention

Data will be retained until the user withdraws consent. You may request deletion at any time by writing to privacy@moodto.com.
In any case, data will not be kept longer than strictly necessary to demonstrate the valid collection of consent and waitlist registration.

8. Data Subject Rights

You have the right to:

• access your data (Art. 15 GDPR);
• request rectification (Art. 16 GDPR) or deletion (Art. 17 GDPR);
• restrict processing (Art. 18 GDPR);
• object to processing (Art. 21 GDPR);
• withdraw consent at any time;
• lodge a complaint with the Data Protection Authority (www.garanteprivacy.it).

9. Profiling

No profiling or marketing activities are carried out based on the data collected through the waitlist.