Notice under Articles 13-14 of Regulation (EU) 2016/679 (GDPR)

Privacy Policy

This policy explains what data we collect through the Leon Excellence Club app, why we collect it, and what rights you have over it.

Last updated: July 1, 2026 Data Controller: Vivica S.r.l. Version 1.0

01Data Controller

The Data Controller is Vivica S.r.l., registered office at via XXV Aprile, 9, 36060 Pianezze (VI), Italy, VAT number 03187920248, reachable at support@vivica.com.

No Data Protection Officer (DPO) has been appointed.

02Data we collect

We collect the following personal data, grouped by the app feature it relates to:

Account registration data

DataWhy we need it
Full name To identify the user and personalize the in-app experience
Email address To create and authenticate the account, and send service communications
Phone number Account verification, credential recovery, and service-related communications

Data collected via the camera

DataWhy we need it
Data extracted from the receipt (merchant, amount, items, date) To verify the purchase and award the related loyalty points

The receipt image is captured by the camera solely to extract the necessary data and is never stored: it is deleted immediately after processing, both on the device and on our systems. We only retain the extracted text data (merchant, amount, items, date), which is needed to manage loyalty points.

Location data

DataWhy we need it
Approximate or precise GPS position of the device To show you the nearest partner stores

Data collected automatically

Like most apps, we may automatically collect technical data (device model, operating system, app identifiers, error logs) needed to keep the service running correctly and securely.

03Purposes and legal bases

PurposeLegal basis
Creating and managing the user account Performance of a contract (Art. 6(1)(b) GDPR)
Scanning receipts and awarding loyalty points Performance of a contract (Art. 6(1)(b) GDPR)
Location for nearby stores User consent (Art. 6(1)(a) GDPR), revocable at any time
Service communications (e.g. account verification) Performance of a contract / legal obligation
Promotional and marketing communications User consent (Art. 6(1)(a) GDPR)
Security, fraud prevention, legal compliance Legal obligation / legitimate interest (Art. 6(1)(c) / 6(1)(f) GDPR)

04Device permissions

The app requests a few specific permissions in order to work properly:

Camera

Used exclusively to photograph receipts for the loyalty points program. The image is processed only to extract data (merchant, amount, items, date) and is never stored: it is deleted immediately after processing. We only keep the extracted text data, which may also be used for anti-fraud checks and customer support. You can revoke this permission at any time from your device settings, but the points-collection feature will not work without it.

Location

Used to show you the partner stores closest to your location. This permission is optional: if you don't grant it, you can still search for stores manually (e.g. by city or postal code), with reduced functionality. You can revoke this permission at any time from your device settings.

Name, email, and phone number are required at registration: without this data, it is not possible to create an account or use the app.

05Data retention

  • Account data: kept for the duration of the contractual relationship. Upon account deletion, data is erased immediately, unless a longer retention period is required by law.
  • Receipt images: never stored, deleted immediately after data extraction. The extracted text data (merchant, amount, items, date) is kept only for as long as needed to process the user's loyalty points, after which it is deleted.
  • Location data: not retained beyond the usage session.

06Sharing with third parties

We do not share users' personal data with third parties, except for:

  • Technical service providers (hosting, email/SMS delivery, cloud services), who act as data processors on our behalf and are contractually bound to comply with data protection law;
  • Competent authorities, where required by law.

We do not sell users' personal data to third parties.

07Security

We adopt appropriate technical and organizational measures (encryption in transit, access controls, backups) to protect personal data from unauthorized access, loss, or improper disclosure.

08Your rights

As a data subject, you have the right at any time to:

Access
Obtain confirmation and a copy of your processed data.
Rectification
Correct inaccurate or incomplete data.
Erasure
Request deletion of your data ("right to be forgotten").
Restriction
Restrict processing in certain circumstances.
Portability
Receive your data in a structured, transferable format.
Objection
Object to processing based on legitimate interest.
Withdraw consent
Withdraw previously given consent at any time (e.g. location).
Lodge a complaint
File a complaint with the competent data protection authority.

To exercise these rights, write to support@vivica.com.

09Minors

The app is not intended for users under 14 years of age. We do not knowingly collect data from minors without the consent of a parent or legal guardian.

10Changes to this policy

This policy may be updated from time to time. In case of material changes, we will notify you via an in-app notice or email before the changes take effect.

11Contact

For any questions about this policy or about how we process your personal data, write to support@vivica.com or contact us at Vivica S.r.l., via XXV Aprile, 9, 36060 Pianezze (VI), Italy.