Privacy Policy
Last updated: 4 July 2025
This Privacy Policy explains how Blank S.r.l.s., an Italian company based in Sant'Ilario d'Enza (RE), Italy, VAT/C.F. 02960770358 ("Blank", "we", "us"), collects, uses, and protects personal data when you ("User", "you") use the GapFiller web application and related services ("Service"), in accordance with Regulation (EU) 2016/679 ("GDPR") and applicable Italian privacy law (Legislative Decree 196/2003 as amended).
1. Data Controller
The Data Controller is:
Blank S.r.l.s.
Via Lenin 11, 42029 Sant'Ilario d'Enza (RE), Italy
Email: info@blanksrl.ink
2. What Data We Collect
We collect and process the following categories of personal data:
Account Data:
email address, name (if provided), password (encrypted).
Usage Data:
calendar events, lesson plans, uploaded files, homework, exams, preferences.
Subscription & Billing Data:
billing name, address (if provided), transaction ID, payment status.
Technical Data:
IP address, browser, device type, usage logs, session data, error reports.
Feedback & Communication:
messages, bug reports, feature requests.
3. How We Collect Data
- When you create an account (email registration only).
- When you use the Service (e.g., creating lessons or uploading documents).
- When you contact us or submit feedback.
- Automatically, through cookies and usage tracking.
4. Why We Process Your Data (Legal Bases)
We process your data for the following purposes and legal bases:
| Purpose | Legal Basis |
|---|---|
| Providing the Service and your account | Art. 6(1)(b) GDPR – Contract performance |
| Managing subscriptions and payments | Art. 6(1)(b)/(c) GDPR – Contract / Legal obligation |
| Communicating with users (e.g. emails) | Art. 6(1)(f) GDPR – Legitimate interest |
| Improving the Service (analytics, feedback) | Art. 6(1)(f) GDPR – Legitimate interest |
| Legal compliance (e.g., invoices, security logs) | Art. 6(1)(c) GDPR – Legal obligation |
| Marketing and product updates (optional) | Art. 6(1)(a) GDPR – Consent |
7. Data Retention
We retain your personal data:
- As long as your account is active.
- For legal and administrative purposes up to 10 years (e.g., invoices).
- Uploaded documents are retained unless deleted by the user or the account is terminated.
- After termination, data may be deleted or anonymized after a reasonable retention period.
5. Data Storage and Hosting
All user data and uploaded documents are securely stored on servers provided by Amazon Web Services (AWS) within the European Economic Area (EEA). Data is encrypted in transit and at rest.
6. Sharing of Data
We do not sell your data. We may share it with:
- Payment processors (e.g., Stripe or equivalent) for billing.
- Email service providers for system notifications.
- Analytics tools for performance monitoring.
- Authorities if required by law.
All third-party providers are bound by appropriate Data Processing Agreements (DPAs) and comply with GDPR.
9. Data Security
We implement appropriate technical and organizational measures including:
- HTTPS encryption
- Encrypted passwords and storage
- Role-based access controls
- Regular backups and monitoring
8. Your Rights
As a data subject, you have the right to:
- Access your data
- Rectify inaccuracies
- Delete your data ("right to be forgotten")
- Restrict or object to processing
- Port your data to another service
- Withdraw consent (where applicable)
- Lodge a complaint with the Italian Data Protection Authority (Garante Privacy)
To exercise these rights, email: info@blanksrl.ink
10. Cookies and Tracking
We use technical and functional cookies essential for providing the Service. Analytics and optional cookies (if any) will be used only with your consent.
11. International Data Transfers
We store data in the EEA. If future processing involves transfers outside the EEA, we will ensure compliance with Chapter V of the GDPR, including Standard Contractual Clauses where required.
12. Children's Privacy
The Service is intended for users aged 18 and older. Users under 18 must use the Service only with parental or guardian consent.
13. Updates
We may update this Policy to reflect changes to our practices. We will notify users of material changes and update the "Last Updated" date.
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