NAPOLII TERMS OF SERVICE AND PRIVACY POLICY     

ABOUT US 
NAPOLII (“we”, “us” or “our”) is a mobile application platform designed for connecting Traveling Executives with local culture experts with the aim of effective training and learning of local cultures in host countries within a limited time through exchange of miscellaneous audio-visual, literary aids and one-on-one consulting.
 
PLEASE READ THIS TERMS OF SERVICE AND PRIVACY POLICY DOCUMENT CAREFULLY BEFORE ACCESSING OR USING OUR MOBILE APPLICATION (THE “NAPOLII APP”). BY ACCESSING OR USING THE NAPOLII APP, YOU AGREE TO BE BOUND BY THE FOLLOWING TERMS, IN CONTRAVENTION OF WHICH YOU ARE ADVICED NOT TO CONTINUE USING THE NAPOLII APP ANY LONGER.
 
REGISTRATION OF USER ACCOUNT
In order to successfully use the NAPOLII App, you must be at least 18 years of age and must accurately complete and submit all registration details. To proceed with the registration process, you will be asked to submit your personal details and then asked to choose a user ID and password, which must be kept confidential at all times. You must not use any other person's account to access the NAPOLII App. You must not allow any other person to use your account to access the NAPOLII App. You are responsible for maintaining the confidentiality of your account login information and are fully responsible for all activities that occur under your Account. You agree to notify NAPOLII immediately of any unauthorized use, or suspected unauthorized use of your account or any other breach of security. NAPOLII cannot and will not be liable for any loss or damage arising from your failure to comply with the above requirements.
 
USER RESTRICTIONS
In order to maximize your user experience in using the NAPOLII App, and avoid, eliminate or minimize disruptive activities, we ask you to maintain the following: ensure that the information furnished by you in the registration form is accurate, true, current and complete, and maintain and update such information from time to time;do not use the NAPOLII App in any way or take any action that may undermine, disrupt, damage or manipulate the working functionality, performance, availability or accessibility of the NAPOLII App; do not copy, decompile, reverse engineer, disassemble, attempt to derive the source code of, modify or create derivative works of the NAPOLII App, or any updates or any part thereof; do not upload, distribute or otherwise publish through the NAPOLII App any content that is libellous, defamatory, obscene, pornographic, threatening, invasive of privacy or publicity rights, abusive, illegal or otherwise objectionable, or violate the rights of any party or that would otherwise give rise to liability or violate any law; do not use the NAPOLII App in any manner that is unlawful, illegal, fraudulent or harmful, or in connection with any unlawful, illegal, fraudulent or harmful purpose or activity; do not impersonate any person or entity, misrepresent any affiliation with another person, entity, or association, use false IP addresses or headers, or otherwise conceal your identity for any purpose; do not violate, plagiarize, or infringe on the rights of third parties, including without limitation copyright, trademark, trade secret, privacy, publicity or other proprietary rights; do not use data collected from the NAPOLII App for any direct marketing activity (including without limitation email marketing, SMS marketing, telemarketing and direct mailing).
 
PAYMENT TERMS 
Each audio-visual and literary aid being sold through the NAPOLII App is individually and independently priced by the respective local culture expert and is inclusive of all applicable taxes and VAT, unless specified otherwise. For a successful processing of your payment, it is your responsibility to provide NAPOLII with a current, valid, accepted method of payment and ensure that complete and instant payment can be made for the purchase by the said method of payment. On behalf of the local culture experts, NAPOLII accepts online payment in a secure environment by via credit card, debit card, or direct bank transfer. All payment handling is done by our third party payment gateway providers and successful transactions are followed up by an online receipt via email to the email address provided by you during registration. We do not store any credit/debit card details and under no circumstances accept any liability for any error in any third party payment gateway. In case you have any question about the pricing or method of payment, feel free to reach out directly to the concerned local culture expert before you make the payment. NAPOLII simply acts as the intermediary platform for local culture experts to upload and sell their respective audio-visual and literary aids and is not responsible for any pricing or payment issues regarding the same.

CANCELLATION AND REFUND POLICY
As per the UK Consumer Contracts (Information, Cancellation and Additional Charges) Regulations 2013, cancellation and return options are available to registered users up to 14 days from the date of purchase, except for digitally downloadable items including CD, DVD, software etc. If you need to request a refund for any reason, please contact the concerned local culture expert from whom the purchase was made, whose decision will be final in accepting or rejecting a cancellation and refund request. All eligible refunds shall be paid in full within 14 days from receiving the cancelled/returned item of purchase. Your acceptance of the refund shall constitute your sole and exclusive remedy related to the purchase made.

DISCLAIMER
By downloading and using the NAPOLII App, you hereby acknowledge and agree that such usage is at your sole risk and responsibility. To the maximum extent permitted by applicable law, NAPOLII is provided on an “as is” and “as available” basis without warranties of any kind, either expressed or implied, including, but not limited to, all warranties of merchantability, fitness for a particular purpose, title or non-infringement. NAPOLII does not warrant that the services offered in the NAPOLII App will be technically accurate or meet your specific requirements, that the NAPOLII App will be uninterrupted or error-free, that the NAPOLII App will be free from viruses or similar harmful matter or that any defects in the NAPOLII App will be immediately corrected. No oral or written communication offered by NAPOLII will create any warranty for this purpose.

COLLECTION OF YOUR INFORMATION
NAPOLII respects the privacy of our users. We will only use the information that we collect about you lawfully in accordance with the Data Protection Act 1998 and the EU General Data Protection Regulation (GDPR) 2016. Once you register and create an user account in the NAPOLII App, you will be asked to provide personal information including the following -

• your full name
• your email address
• your phone number
• your full postal address (optional)
• a profile photo showing your face (optional)
• a brief introduction about yourself (optional)

We may further request access or permission to and track location-based information from your mobile device, either continuously or while you are using the NAPOLII App, to provide location-based services. We may also request access or permission to certain features from your mobile device, including your mobile device ID number, model, and manufacturer, version of your operating system, browsing history, phone number, country, location and other features. If you wish to change our access or permissions, you may do so in your device’s settings. We do not store or collect any payment or billing information including your debit or credit card details.

USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customised experience. We will securely process your personal information and use it for administration and operation of the NAPOLII App, including but not limited to the following purposes – 
To provide quality services
To update and maintain your account with us
To personalise user experiences and troubleshooting 
To provide you with promotional material when opted-in with informed consent
To notify you about changes and modifications to our service
To improve future App development and improvement
To enable third parties to carry out technical and logistical functions on our behalf
To enforce these Terms of Service and Privacy Policy and/or any other rules, laws, regulations or guidelines that is applicable to you.

DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows: 

Third-Party Service Providers 
We may share your information with third parties that perform services for us or on our behalf, including payment processing, email delivery, hosting services, customer service, and marketing assistance. 

Third-Party Business Partners
We may disclose some non-personally identifiable information to our third-party business partners in order to facilitate some interoperable or joint offering of products and services to you from us and such partners.

Marketing Communications
With your informed consent (opt-in) we may share your information with third parties for marketing purposes, as permitted by law.

By Law or to Protect Rights 
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with our professional advisers such as lawyers and auditors when it is necessary to respond to legal process, to investigate policy violation, or to protect the rights, property, and safety of others.

We do not sell your personal information. We disclose only that personal information that is necessary for the third party to deliver their specific service and we take all reasonable measures to ensure they keep your information fully secure and not use it for any purpose other than the one under which it was disclosed. In case any of these third parties are situated outside of European Economic Area (EEA), we confirm that is done in accordance with the applicable laws with appropriate data transfer mechanisms in place.

LOCATION INFORMATION
We may collect location information from your mobile handset that is used and disclosed as set forth here. By accessing and using the NAPOLII App you hereby acknowledge and agree to our collection, use, disclosure and storage of your location information. You may withdraw your consent of such collection at any time by contacting us at _admin@NAPOLII.com__. However some or all features of the NAPOLII App may no longer be available if you withdraw such consent of our usage of your location information. You may not use the NAPOLII App to collect another individual's location information.

USE OF COOKIES
We may use cookies, tracking pixels, and other tracking technologies on the NAPOLII App to help keep track of user activities and personalise user experience by remembering relevant user information, product and service preference; by procuring aggregated usage statistics; and other related purposes. Most internet browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the NAPOLII App. Additionally, we may use third-party software to implement supplementary services, which may use cookies or similar tracking technology to help manage and optimise your online experience with us. Please note our privacy policy will not be applicable in case of any such third-party software and their associated cookies policy.

DATA STORAGE AND SECURITY
The personal information which we hold will be held securely in accordance with our internal security policy and the appropriate UK data protection laws as and where applicable. This data may be transferred to, stored at and processed in a destination outside the EEA. By submitting your personal information, you agree to such transfer, storing or processing. We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, or unauthorised alteration or destruction. Unfortunately, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Whilst we strive to use all reasonable efforts to protect your personal information, we cannot guarantee its absolute security. We will notify you promptly in the event of any breach of your personal information which might expose you to serious risk. We will never collect sensitive information about you without your explicit and informed consent.

DATA RETENTION AND DELETION
We will retain your personal data as long as you continue to use the NAPOLII App or as required by applicable laws or regulations. We will review your personal data periodically to establish whether we are still entitled to process it. If we decide that we are not entitled to do so, we will stop processing your personal data, but may choose to retain it in an archived form in order to be able to comply with legal obligations, if any.

Under the GDPR, you have full rights:
to access your personal data
to be provided with information about how your personal data is processed
to have your personal data corrected / erased
to object to or restrict how your personal data is processed
to have your personal data transferred to yourself or to another person or business under certain circumstances.
Accordingly, you can access, review and update your personal information as collected by us; request us to delete your account and all associated personal information and/or choose to refuse sharing your personal information as indicated above by using the contact details provided below. 
 
ELECTRONIC COMMUNICATIONS
The communications between you and NAPOLII use electronic means. By installing and using or attempting to be using the NAPOLII App, you (a) consent to receive communications from NAPOLII in an electronic form; and (b) agree that all terms and conditions, agreements, notices, disclosures, and other communications that NAPOLII provides to you electronically satisfy any legal requirement that such communications would satisfy if it were in hardcopy writing. 

THIRD PARTY LINKS AND ADVERTISEMENTS 
NAPOLII may provide external links and advertisements submitted by or directed towards third party mobile app services and websites. Unless expressly stated otherwise, such advertisements do not signify that NAPOLII endorses and/or is associated with such third party apps and services in any manner including, but not limited to, the content, accuracy, quality, nature, appropriateness, decency, functionality, performance, reliability, completeness, timeliness, validity, safety, legality or any other aspect thereof. We accept no responsibility for third party advertisements contained within the NAPOLII App. If you agree to purchase goods and/or services from any third party who advertises in the NAPOLII App, you do so at your own risk and this Terms of Service and Privacy Policy document no longer remains applicable in such cases.
 
LIMITATION OF LIABILITY
Under no circumstances will NAPOLII and/or any of its directors, shareholders, employees, sub-contractors and agents be liable for any incidental, consequential, or indirect damages including, but not limited to, physical harm, business interruption, damages for loss of profit, loss of data, loss of goodwill and the like arising out of the use or inability of use of the service/ information provided on or downloaded from the NAPOLII App, or any delay in the processing of such information or services. For removal of doubt, this includes situations where there is any failure or delay in performance of any of the obligations under these Terms that is caused by events outside our reasonable control (force majeure events). Notwithstanding the above, nothing under these Terms will limit or exclude any liabilities that may not be excluded under applicable law. 
 
INDEMNIFICATION
You agree to indemnify, defend and hold harmless NAPOLII, its officers, directors, employees, agents, consultants, representatives and agents from and against all losses, damages, suits, judgments, costs and expenses (including litigation costs and reasonable attorneys' fees) arising out of or in connection with (a) your use of or inability to use the NAPOLII App (b) your violation of any provision of these Terms or your violation of any rights of a third party, or (c) your violation of any applicable laws, rules or regulations. NAPOLII reserves the right, at its own cost, to assume the exclusive defense and control of any matter otherwise subject to indemnification by you, in which event you will offer complete cooperation with NAPOLII in asserting any available defenses.
 
DISPUTE RESOLUTION
All disputes should be initially addressed and aimed for an amicable resolution directly by and between the concerned users, upon failure of which the NAPOLII administration will intervene as a third-party mediator. Notwithstanding the above, disputes between the parties that remain unresolved even after the intervention of NAPOLII administration, including disputes as to the validity, execution, performance or interpretation of this Terms of Service and Privacy Policy document will be submitted to the laws of UK and the exclusive jurisdiction of the Courts of London. Each party will bear their own respective legal costs of and incidental to the mediation, and the enforcement or attempted enforcement of respective rights, remedies and powers under the same.
CONTACT
 
We reserve the right to update and modify this Terms of Service and Privacy Policy document at any time and for any reason. You are encouraged to periodically review the same to stay informed of updates. If you have any further questions or comments, please email us at _admin@NAPOLII.com_.
 
Last updated: Sunday, December 15, 2019