Data controller
Meeters SRL
Registered Office: Ripa di Porta Ticinese, 39 — 20143 Milano
Operational Office: Via Antonio Pacinotti, 25 — 37135 Verona
VAT Number: 10802670967
REA Number: MI - 2558973
Share Capital: €36,701.39
Email: privacy@gengle.it
Data Protection Officer (DPO)
As of the last update of this Policy, Meeters SRL has not appointed a Data Protection Officer, as the conditions set out in Art. 37 GDPR do not apply. For any privacy request please write to privacy@gengle.it.
Data collected
When using the Platform, the following categories of personal data may be processed:
- Identity data: first name, last name, date of birth, gender
- Contact data: email, phone, city, province
- Children's data: name, date of birth, gender (entered by the parent or person exercising parental responsibility)
- Geolocation data: approximate location for searching events and nearby users
- Messages and content: private conversations, event chats, channel messages and content published in the community
- Usage data: event registrations and participation, forum posts, preferences, interactions
- Event data: registrations, participant lists, role as organizer or co-organizer, invited guests, event chat, event-related preferences
- Data of external guests: when a registered user invites a non-registered guest to an event, the Platform may process the guest's first name, last name and, where provided, year of birth and information about accompanying minors. The user entering guest data declares to have informed the guest and, where necessary, obtained consent to share such data with the Platform.
- Safety, reliability and moderation data: reports sent or received, blocks, warnings, suspensions, removed content, actual event participation, late cancellations, no-shows, reliability score (Karma) and other information necessary to prevent abuse and keep the community safe
- Reviews and feedback: reviews, ratings and content voluntarily published by the user, including in forums, chats and events
- Photos, videos and images: profile pictures, photographic content and videos uploaded by the user or published in the context of community events and activities
- Notification data: tokens and technical identifiers required to deliver push notifications, where enabled
- Payment and subscription data: where paid services are available, the Platform may process the purchased plan, subscription status, transactions, receipts, renewals and cancellations. Full payment details (card numbers or payment credentials) are processed by payment providers or digital stores under their respective policies
- Technical data: IP address, technical logs, device type, operating system, session identifiers and data necessary for IT security
Special categories and sensitive content
The Platform does not require users to provide special categories of personal data under Art. 9 GDPR, except where strictly necessary for specific features. Users are invited not to share sensitive data about themselves or third parties, including data on health, personal beliefs, detailed family situation, minors or other information not necessary to participate in the community.
Should the user voluntarily share such information in posts, messages, comments or other content, this data will be processed within the limits necessary to provide the service and manage the community.
Purposes of processing
- Account: registration, login, profile management and authentication
- Events: creation, registration, participation, event chat, participant list management
- Guests: management of external guests invited by users and accompanying minors
- Community communications: private messaging, event chats, channels and forums
- Forums, posts, comments, reviews and user-generated content
- Community safety: reports, blocks, moderation, abuse prevention
- Reliability: Karma calculation, management of late cancellations and no-shows, community quality
- Personalization: event and content suggestions, matching with other users, ordering of displayed content
- Service communications: transactional emails, service notifications and push notifications
- Marketing: newsletters and promotional communications, only with the user's optional consent (Art. 6(1)(a) GDPR)
- Payments: management of subscriptions, in-app purchases, receipts and administration, where paid services are active
- Legal obligations: accounting, tax, response to authority requests, defense of the Controller's rights
- Analytics: aggregated or anonymized statistics and, where required, analyses subject to cookie consent
- Advertising: measuring Meta campaigns and creating ad audiences through Meta Pixel on public information pages, only with optional consent.
Legal basis
The legal bases for processing are identified per purpose, as follows:
| Purpose | Legal basis |
|---|
| Registration, account, profile, use of the Platform | Performance of the service contract — Art. 6(1)(b) GDPR |
| Events, event chats, participation | Performance of the service — Art. 6(1)(b) GDPR |
| External guests invited by users | Performance of the service and legitimate interest in safe event management — Art. 6(1)(b)/(f) GDPR |
| Messages, forums, community content | Performance of the service — Art. 6(1)(b) GDPR |
| Safety, reports, blocks, moderation | Legitimate interest in protecting the community and users — Art. 6(1)(f) GDPR |
| Karma and reliability | Performance of the service and legitimate interest in community quality and safety — Art. 6(1)(b)/(f) GDPR |
| Service notifications | Performance of the service — Art. 6(1)(b) GDPR |
| Marketing, newsletters, promotions | Optional consent — Art. 6(1)(a) GDPR |
| Non-essential analytics cookies | Consent — Art. 6(1)(a) GDPR |
| Meta Pixel and advertising | Optional consent — Art. 6(1)(a) GDPR |
| Tax and legal obligations | Legal obligation — Art. 6(1)(c) GDPR |
| Legal defense and dispute management | Legitimate interest — Art. 6(1)(f) GDPR |
For children's data, processing is based on the consent of the parent or person exercising parental responsibility (Art. 8 GDPR; Italian Legislative Decree 101/2018).
Data visible to other users
Some profile information may be visible to other registered users, depending on the available settings and features used. Examples include: name or display name, profile picture, city or approximate geographic area, interests, event participation, published content, reviews or organizer role.
Data about children and minors is not made publicly visible, except for specific features required for event participation and within the limits set by the Platform.
Photos, videos and images
Users may upload profile pictures, photographic content and other visual materials within the Platform. Such content is processed to enable profile functionality, community participation and interactions between users.
During events or activities, photos or videos may be used by the Platform only within the limits indicated on a case-by-case basis and, where necessary, subject to specific consent of the data subject.
Recognizable images of minors will not be used for promotional, advertising or external communication purposes without the explicit consent of the parent or person exercising parental responsibility.
Any consent to the promotional use of images, photos or videos is optional, separate from service registration and may be withdrawn at any time, without prejudice to the lawfulness of processing carried out before withdrawal.
User-generated content
Content voluntarily published by the user — including posts, comments, reviews, images, descriptions, forum replies and information shared in events or groups — may contain personal data of the user or of third parties. Users are invited not to publish sensitive data, unauthorized third-party information, data about minors or content not necessary to the community's purposes.
Data recipients
Data may be processed by providers acting as data processors or autonomous controllers, depending on the case, belonging to the following categories:
- Hosting, database, authentication and storage services (e.g., Supabase Inc.)
- Hosting, CDN and technical infrastructure providers for delivering the Platform
- Transactional email and push notification services
- Analytics and measurement services, where active and subject to consent where required
- Meta Platforms and Coesione 360 srl, owner of the GenGle Pixel dataset, for the advertising measurement described above.
- Payment providers, digital stores (Apple App Store, Google Play) and subscription management systems, where paid services are active
- Customer care, moderation, IT security and technical maintenance providers
- Legal, tax, administrative consultants or competent authorities, in the cases provided by law
Personal data is never sold to third parties. An updated list of main providers and processing geographies can be requested at privacy@gengle.it.
Extra-EU data transfers
Some providers or sub-providers may process personal data outside the European Economic Area. In such cases, the Controller adopts adequate safeguards under Articles 44 et seq. GDPR, such as adequacy decisions, Standard Contractual Clauses approved by the European Commission or other measures provided by applicable law. An updated list of processing geographies can be requested at privacy@gengle.it.
Data retention
Retention periods vary depending on the data category and the purpose of processing:
| Category | Retention period |
|---|
| Account and profile | For the duration of membership; deletion or anonymization within 30 days of request, subject to legal obligations |
| Public community content | Until account deletion or user request, subject to retention needs for safety or disputes |
| Private messages | For the duration of the account or according to the applicable internal policy |
| Event data | For the duration of the account and as long as needed to manage disputes and safety |
| Guest data | For the time necessary to manage the event and safety, then deletion or anonymization unless disputes arise |
| Reports and moderation | As long as needed to manage safety, abuse, disputes and defense of rights |
| Karma and reliability | For the duration of the account or as long as needed for community functioning |
| Technical and security logs | For a limited period, according to the Controller's IT security policy |
| Payment and tax data | For the periods provided by applicable law |
| Consent records | 5 years or different period required by the accountability principle |
| Marketing data | Until consent is withdrawn |
Your rights
- Right of access to your personal data (Art. 15)
- Right to rectification of inaccurate data (Art. 16)
- Right to erasure — right to be forgotten (Art. 17)
- Right to restriction of processing (Art. 18)
- Right to data portability (Art. 20)
- Right to object to processing (Art. 21)
- Right to lodge a complaint with the Italian Data Protection Authority (Garante Privacy — www.garanteprivacy.it)
In relation to automated or semi-automated systems that affect profile visibility, reliability (Karma) or access to specific features, the user may request clarification, human intervention, rectification of inaccurate data or contest the decision by writing to privacy@gengle.it or through the tools available on the Platform.
Processing of children's data
Children's data is processed only to the extent necessary to allow the registered parent to use the Platform's features, participate in events, indicate the family composition relevant to the activities and ensure the organizational safety of the community. Meeters does not collect data directly from children.
The user entering data about a minor declares to be a parent, guardian or person legally authorized to provide such information and undertakes to enter only relevant and necessary data. It is forbidden to publish or share data, images or information about minors in an unauthorized manner that harms their privacy, dignity or safety.
Under Italian Legislative Decree 101/2018 (Italian adaptation of the GDPR), the threshold for autonomous digital consent is set at 14 years. For children under 14, consent — where required as a legal basis — must be provided by the parent or legal guardian.
Cookies and tracking technologies
The platform uses the following categories of cookies and similar technologies:
| Cookie | Provider | Purpose | Duration | Category |
|---|
| gengle_cookie_consent | GenGle | Store cookie preferences | Persistent | Necessary |
| sb-* | Supabase | Authentication and session | Session | Necessary |
| sidebar:state | GenGle | Sidebar state | 7 days | Functional |
| i18nextLng | GenGle | Preferred language | Persistent | Functional |
| _ga, _gid | Google | Anonymous usage statistics | 2 years / 24h | Analytics |
| _fbp, _fbc and Meta Pixel technologies | Meta Platforms | Ad measurement and audiences on public information pages after consent | See Meta settings and privacy notice | Advertising |
Analytics and Meta Pixel are optional and separate. The Pixel runs only on public information pages after advertising consent; this tag does not send profile, forum, chat or purchase data. You can change or withdraw your preferences below at any time.
In the iOS/Android app, SDKs or technical identifiers with cookie-like functions may be used, necessary for authentication, security, push notifications, analytics, crash reporting or performance measurement, according to the user's preferences and within the limits provided by applicable law. We do not use advertising identifiers for cross-app or third-party tracking.
Profiling, personalization and automated systems
The Platform may use automated or semi-automated systems to personalize the user experience, suggest events or content, sort the displayed information, improve matching, prevent abuse and calculate reliability indicators (Karma). These systems are used to improve the quality, safety and relevance of the Service.
The reliability/Karma system may be calculated based on objective on-Platform behavior, such as event participation, late cancellations, no-shows, reports or other indicators related to community quality and safety.
The Platform does not adopt decisions based solely on automated processing that produce legal effects on the user. Should automated systems significantly affect access to certain features, the user may request human intervention, obtain clarification and contest the decision within the limits of applicable law (Art. 22 GDPR).
Relationship with Terms, Community Rules, Safety and Code of Ethics
Some processing of personal data — including moderation data, reports, blocks, suspensions, reliability scores and published content — is necessary to enforce the Terms of Service, the Community Rules, the Code of Ethics and the Platform's Safety rules.