Privacy Policy

1. Introduction

CENTRO ("we", "our", or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform connecting athletes with mental health specialists.

We comply with the General Data Protection Regulation (GDPR) and Italian data protection laws.

2. Data Controller

CENTRO acts as the data controller for the personal data we collect. For questions about this policy or your data, contact us at: privacy@centro.it

3. Data We Collect

We collect the following categories of personal data:

• Identity Data: Name, email address, profile picture
• Account Data: Username, password (encrypted), account preferences
• Questionnaire Data: Sport information, mental health focus areas, specialist preferences
• Payment Data: Transaction history (payment details are processed by Stripe/PayPal)
• Usage Data: How you interact with our platform
• Technical Data: IP address, browser type, device information

4. Special Category Data

Our questionnaires may collect health-related information about mental wellness needs. This is considered special category data under GDPR. We process this data only with your explicit consent and for the purpose of matching you with appropriate specialists.

5. How We Use Your Data

We use your personal data to:

• Create and manage your account
• Match you with suitable specialists based on your questionnaire responses
• Process payments for sessions
• Communicate with you about your account and bookings
• Improve our services and platform
• Comply with legal obligations

6. Legal Basis for Processing

We process your data based on:

• Consent: For questionnaire data and health-related information
• Contract: To provide our matching and booking services
• Legal Obligation: To comply with applicable laws
• Legitimate Interest: To improve our services and prevent fraud

7. Data Sharing

We share your data with:

• Matched Specialists: Your relevant questionnaire responses to facilitate the match
• Payment Processors: Stripe and PayPal for payment processing
• Service Providers: Hosting and analytics providers under strict confidentiality agreements

We do not sell your personal data to third parties.

8. Data Retention

We retain your personal data for as long as your account is active or as needed to provide services. After account deletion, we may retain certain data for up to 6 years for legal and regulatory compliance.

9. Your Rights (GDPR)

Under GDPR, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data ("right to be forgotten")
• Restriction: Limit how we use your data
• Portability: Receive your data in a portable format
• Object: Object to certain processing activities
• Withdraw Consent: Withdraw consent at any time

To exercise these rights, contact us at privacy@centro.it

10. Data Security

We implement appropriate technical and organizational measures to protect your data, including:

• Encryption of data in transit and at rest
• Secure authentication mechanisms
• Regular security assessments
• Access controls and monitoring

11. International Transfers

Your data is primarily processed within the European Economic Area (EEA). If we transfer data outside the EEA, we ensure appropriate safeguards are in place, such as Standard Contractual Clauses.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or through the platform.

13. Contact Us

For questions about this Privacy Policy or to exercise your rights:

Email: privacy@centro.it
Data Protection Officer: dpo@centro.it

You also have the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali).