Privacy policy

1. Data controller

Open Tale Asti is a project of the City of Asti built with Open Tale©, the technology of Frame Multimedia Solutions, which develops and runs the app and the website and is the controller of the data described on this page:

We are not required to appoint a Data Protection Officer: for any privacy question, write to the addresses above.

2. The app: permissions and data

The Open Tale Asti app is available for Android and iPhone. It has no accounts, does not collect data to identify you and does not sell data.

• Location (precise; in the background only if you allow it). Used to detect when you are near a place on the route and open the right content, also with a notification when the app is closed. The match between your position and the places happens only on your phone: the app downloads the list of places and asks the operating system to tell it when you enter the area around one of them. Your location is never sent to our servers and we don't keep it. Background location is used only if you choose “Allow all the time”; you can refuse and still use the app while it is open, or with QR codes. Location services are provided by the operating system (Google Play services on Android, Apple on iPhone) under their own policies.
• Camera. Used to read the QR codes on the route's panels. The image is analysed in real time on the phone, only to find the QR code, and is never stored or sent. On Android, scanning uses Google ML Kit, which runs on the device; Google may receive technical data about how the library performs (such as performance and errors), never the images.
• Notifications. Used to alert you when you reach a place. They are created by the phone itself: no push server, no device identifiers.
• Internet connection. Used to download the list of places and the content (texts, audio, audio description, sign language videos, images, Easy to Read pages) from opentale.it and caa.framems.com. Like any connection, these servers receive technical data (IP address, date and time, requested content, device type), used only to deliver the content and protect the service.
• Preferences stored on the phone. The mode you choose (audio guide, audio description, sign language, Easy to Read) and the names of the places shown in notifications. They stay on your phone and are never sent to us. We know the chosen mode may hint at an accessibility need: that is why we don't collect it, don't link it to you and don't use it for anything else. They are deleted when you uninstall the app or clear its data; if device backup is on, the operating system may include them in your account's backup.

The app contains no advertising, analytics or profiling tools.

3. The website asti.opentale.it

The server logs technical data of each visit (IP address, date and time, requested page, browser and device) to run the site and protect it from abuse. The site sets two technical cookies: opentale_mode, which remembers your chosen mode for 12 months, andopentale_visita, which lasts until you close the browser and makes the site ask for the mode again at every new visit. They need no consent; no profiling or analytics cookies are used. Accessibility preferences chosen on the site (theme, text size, spacing, motion) and the AAC sheet version stay in the browser's storage (localStorage and sessionStorage): they are never sent to the server and can be cleared from the browser settings. Pages load fonts from Google Fonts, the map from OpenStreetMap (with the Leaflet library served by unpkg.com) and Easy to Read content from caa.framems.com: your browser connects to these services directly, and they receive your IP address and technical data.

4. Purposes and legal bases

Providing the content you request: performance of the service you asked for (Art. 6(1)(b) GDPR). Location, camera and notifications: the permission you grant in the operating system, which you can revoke at any time (Art. 122 of the Italian Privacy Code); this data is used only on your phone. Server logs and security: our legitimate interest in running and protecting the service (Art. 6(1)(f) GDPR).

5. Retention

Data on the phone: until you uninstall the app or clear its data. Website cookies: 12 months (mode) or until you close the browser (visit), or until you delete them. Server logs: kept by the hosting providers only as long as necessary, normally no longer than 30 days, unless needed to investigate abuse or crime.

6. Recipients and transfers

Only the providers needed to run the app and the site: Hostinger International Ltd (Cyprus, hosting of opentale.it and asti.opentale.it); Vercel Inc. (USA, hosting of caa.framems.com); Google Ireland Limited and Google LLC (storage of Easy to Read media, fonts and, on Android, ML Kit and location services); ARASAAC (Government of Aragon, Spain, pictograms); OpenStreetMap Foundation (UK) and unpkg.com (website map); Apple and Google as app store and operating system providers, under their own policies. We never sell or share data. Some providers may process technical data outside the European Economic Area, especially in the USA, only with the safeguards of Arts. 44-49 GDPR: an adequacy decision such as the EU-US Data Privacy Framework for participating providers, or standard contractual clauses.

7. Children

The app and the site can be used by everyone, including young people and schools. They do not ask for data that identifies users, so we do not knowingly collect personal data from children.

8. Your rights

You can request access, rectification, erasure, restriction and portability, and object to processing (Arts. 15-22 GDPR), by writing to info@framems.com. Since we don't collect data that identifies you, we may be unable to link server logs to you; if so, we will tell you (Art. 11 GDPR). You can also lodge a complaint with the Italian Data Protection Authority (garanteprivacy.it).

To remove permissions: on Android, Settings › Apps › Open Tale Asti › Permissions; on iPhone, Settings › Open Tale Asti, or Settings › Privacy & Security › Location Services. Uninstalling the app deletes all the data it stored on the phone. If we change how the app or the site handle data, we will update this page and the date above.