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PRIVACY POLICY — SCIAMN

Last updated: June 16, 2026


This Privacy Notice for LEAP S.R.L.S. — SOCIETÀ A RESPONSABILITÀ LIMITATA SEMPLIFICATA (P.IVA/VAT: IT09078310728), doing business as Sciamn ("we," "us," or "our"), describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you:

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are the data controller responsible for decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@leapstudio.it.


SUMMARY OF KEY POINTS

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Users in the European Economic Area (EEA) have rights under the EU General Data Protection Regulation (GDPR). Italian users may also contact the Garante per la protezione dei dati personali (the Italian Data Protection Authority) at www.garanteprivacy.it.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us directly at info@leapstudio.it. We will consider and act upon any request in accordance with applicable data protection laws.


TABLE OF CONTENTS

  1. WHAT INFORMATION DO WE COLLECT?
  2. HOW DO WE PROCESS YOUR INFORMATION?
  3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
  4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
  5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
  6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
  7. HOW LONG DO WE KEEP YOUR INFORMATION?
  8. DO WE COLLECT INFORMATION FROM MINORS?
  9. WHAT ARE YOUR PRIVACY RIGHTS?
  10. CONTROLS FOR DO-NOT-TRACK FEATURES
  11. DO WE MAKE UPDATES TO THIS NOTICE?
  12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
  13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information we collect may include:

Sensitive Information. We do not process sensitive information as defined under Article 9 GDPR.

Payment Data. We may collect data necessary to process your payment if you choose to make purchases, such as your payment instrument number and the security code associated with your payment instrument. Payment data is processed by our payment processors and is subject to their privacy policies. We do not store full card numbers on our systems.

Application Data. If you use our application(s), we may collect the following information if you choose to provide us with access or permission:

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity but may include device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:


2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, comply with law, and for other purposes with your consent.

We process your personal information for a variety of reasons, including:


In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (legal basis) to do so under applicable law, such as consent, compliance with laws, performance of contractual obligations, protection of rights, or legitimate business interests.

We are established in Italy and our Services are directed primarily at users in the European Union. The General Data Protection Regulation (EU) 2016/679 ("GDPR"), as implemented in Italy by Legislative Decree No. 101/2018, requires us to explain the valid legal bases we rely on in order to process your personal information. We may rely on:


4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations and/or with specific third parties.

We may need to share your personal information in the following situations:


5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies, such as web beacons and pixels, to gather information when you interact with our Services. These technologies can help maintain security, prevent crashes, fix bugs, save preferences, and assist with basic service functions.

We also permit third parties and service providers to use online tracking technologies for analytics and advertising, including managing and displaying advertisements, tailoring advertisements to your interests, or sending abandoned shopping cart reminders depending on your communication preferences.

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice, available within the application.

Google Analytics

We may share your information with Google Analytics to track and analyse the use of the Services. The Google Analytics Advertising Features that we may use include Google Analytics Demographics and Interests Reporting. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. You can also opt out of Google Analytics Advertising Features through Ads Settings, Ad Settings for mobile apps, http://optout.networkadvertising.org/, and http://www.networkadvertising.org/mobile-choice. For more information, visit the Google Privacy & Terms page.


6. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies ("AI Products"). These tools are designed to enhance your experience and provide innovative solutions, for example through personalised event recommendations.

Use of AI Technologies

We provide the AI Products through third-party service providers ("AI Service Providers"), including Google Cloud AI. Your input, output, and personal information may be shared with and processed by these AI Service Providers to enable your use of our AI Products in accordance with their terms of service and privacy policies. You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with this Privacy Notice, applicable data protection law (including the GDPR), and our agreements with our AI Service Providers.

How to Opt Out

To opt out of AI-based features, you can log in to your account settings and update your user preferences. Opting out may limit the personalisation features available to you.


7. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfil the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by applicable law (for example, for tax, accounting, or legal compliance purposes). No purpose in this notice will require us to keep your personal information for longer than the period of time during which you have an active account with us, plus any additional period required by law.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymise such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.


8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly collect, solicit data from, or market to children under 18 years of age, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 years of age, or that you are the parent or legal guardian of a minor and consent to such minor's use of the Services under your supervision.

If we learn that personal information from users less than 18 years of age has been collected, we will promptly deactivate the account and take reasonable measures to delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us immediately at info@leapstudio.it.


9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In the European Economic Area (EEA), United Kingdom (UK), and Switzerland — including Italy — you have rights that allow you greater access to and control over your personal information.

Under the GDPR and applicable national implementing legislation, you have the following rights:

We will consider and act upon any request in accordance with applicable data protection laws. We will respond to verified requests within 30 days of receipt, or notify you if an extension is required.

Supervisory Authorities

If you are located in Italy or another EEA Member State and believe we are processing your personal information unlawfully, you have the right to lodge a complaint with your national supervisory authority:

If we rely on your consent to process your personal information, you have the right to withdraw your consent at any time by contacting us at info@leapstudio.it or updating your in-app preferences. This will not affect the lawfulness of processing carried out before withdrawal, or processing based on a legal ground other than consent.

Opting out of marketing and promotional communications

You can unsubscribe from marketing and promotional communications at any time by clicking the unsubscribe link in any email we send you, by adjusting your notification preferences in the application settings, or by contacting us at info@leapstudio.it. Please note that we may still send you service-related, transactional, or administrative communications.

Account Information

If you would like to review, update, or delete the information in your account, or terminate your account entirely, you can do so by logging in to your account settings. Upon request to terminate your account, we will deactivate or delete your account and personal information from our active databases, subject to any retention obligations imposed by applicable law, legitimate business interests (such as fraud prevention), or ongoing dispute resolution.

Cookies and similar technologies

Most mobile operating systems and web browsers accept cookies and tracking technologies by default. You can usually configure your device or browser to reject or remove certain cookies, but this may affect the availability of certain features or services.

For any questions about your privacy rights, please contact us at info@leapstudio.it.


10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognising and implementing DNT signals has been finalised. We do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard is adopted in the future, we will inform you in a revised version of this Privacy Notice.


11. DO WE MAKE UPDATES TO THIS NOTICE?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Last updated" date at the top of this Privacy Notice. If we make material changes, we may notify you by prominently posting a notice within the application or by sending a direct notification to your registered email address. We encourage you to review this Privacy Notice periodically to stay informed of how we protect your information.


12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

If you have questions or comments about this Privacy Notice, or wish to exercise any of your data protection rights, you may contact us at:

LEAP S.R.L.S. — SOCIETÀ A RESPONSABILITÀ LIMITATA SEMPLIFICATA P.IVA/VAT: IT09078310728 Via Castel del Monte 252 Corato (BA), 70033 Italy

Email: info@leapstudio.it Website: leapstudio.it

For dispute resolution regarding your personal data, EU-resident users may also use the European Commission's Online Dispute Resolution platform at https://ec.europa.eu/consumers/odr/.


13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, including the GDPR for EU/EEA residents, you may have the right to:

To submit a data subject access request, or to exercise any of the above rights, please contact us at info@leapstudio.it. We will respond to your request within the timeframes required by applicable law (within 30 days under the GDPR, with the possibility of a 2-month extension for complex requests). We may ask you to verify your identity before processing your request.


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