MyOwnSMS - Privacy Policy for myownsms.com

Version: 2026-04-03

1. Scope of this notice

This notice describes the processing of personal data through the commercial website https://myownsms.com/.

The scope includes in particular:

• browsing the website;
• contact and pre-sales requests;
• purchase of the MyOwnSMS license through the eCommerce checkout;
• customer account and order management;
• commercial administration of the relationship;
• support requests related to the website or the purchase.

This notice does not replace any specific notices related to:

• the plugin running on the merchant's website;
• the Android app used by the merchant;
• cookies and other tracking tools, which must be covered by a dedicated cookie policy.

2. Data controller

The data controller is:

• TS1 di Marco Franceschi
• C.F. FRNMRC75S18G628M
• P.IVA 01891780460 (IT)
• VIA DELLA GUIDICCIONA EST, 35/E - 55049 VIAREGGIO (LU - IT)
• PEC: ts-1.net@pec.it
• email: marcofranceschi.ts1@gmail.com

3. Categories of data processed

In the context of myownsms.com, the following data may be processed:

• browsing data and technical data of the site, including logs, IP address, user agent, timestamps, and security-related technical events;
• data voluntarily provided through forms, email, or contact requests, such as name, surname, company, email, phone number, and message content;
• data related to the customer account and restricted area, such as personal details, credentials or account identifiers, order history, and profile data strictly necessary for the web service;
• data necessary for checkout and order management, such as personal details, billing details, customer email, purchased products, order ID, and payment status;
• transaction and payment data handled through PayPal, limited to the information returned to the site to confirm or record the payment;
• data related to licensing and license management, such as the license itself, activation status, expiry, purchased product, and strictly necessary administrative references;
• data contained in support requests, including screenshots, logs, the relevant domain, plugin/app version, and order or license references;
• data collected through analytics tools, within the limits of the actual configuration used on the site.

Unless the user voluntarily includes such data in a support request, the commercial site is not intended to routinely collect the SMS recipients' data of the merchant's end customers.

4. Purposes of processing

Personal data are processed to:

• enable browsing and the technical operation of the site;
• handle contact forms, information requests, demos, pre-sales, and support;
• allow registration, access, and use of the customer account area;
• manage checkout, license sales, and related administrative, accounting, and tax obligations;
• receive and record PayPal payment outcomes for correct order handling;
• manage the purchased license, including activation, verification, renewal, administrative renewals, support, and internal audit;
• generate aggregate statistics or measurements about website usage through Google Analytics, within the limits of the actual configuration and applicable law;
• prevent abuse, fraud, unauthorized access, and improper use of the website or service;
• defend the controller's rights in or out of court;
• comply with legal obligations or requests from competent authorities.

5. Legal basis

Depending on the case, the processing may rely on one or more of the following legal bases:

• performance of pre-contractual measures requested by the data subject;
• performance of the contract or services connected to the purchase of the license;
• compliance with legal, administrative, accounting, and tax obligations;
• the controller's legitimate interest in site security, abuse prevention, technical licensing management, and protection of its rights;
• consent, where required by applicable law, in particular for any non-essential cookies or tracking tools, including analytics if configured in a way that requires consent.

6. Order and license management

When a user purchases a license on myownsms.com, the data strictly necessary to manage the order and the license may be processed for administrative, accounting, and support purposes.

In particular:

• the eCommerce site records the order and its related administrative and commercial data;
• PayPal handles the payment under its own role and privacy terms;
• the controller manages the purchased license and its operational, administrative, and support aspects;
• the information that is necessary may be retained in the order and customer account context for management, support, and operational traceability purposes.

This processing is carried out only to the extent strictly necessary for the sale of the license and the related service.

7. Nature of providing data

Providing the data marked as necessary in contact forms, checkout, the customer account area, or licensing-related procedures is required in order to:

• respond to the user's request;
• create or manage the customer account;
• complete the purchase;
• issue or manage the license;
• provide support.

If the necessary data are not provided, the request, account, or order may be wholly or partially impossible to process.

8. Processing methods

Data are processed using adequate electronic and organizational measures, in accordance with the principles of lawfulness, fairness, transparency, minimization, confidentiality, integrity, and availability.

Access to the data is restricted to authorized persons who need it for the stated purposes.

9. Recipients and categories of recipients

Within the limits relevant to the stated purposes, data may be disclosed or made accessible to:

• hosting, infrastructure, maintenance, and security providers;
• providers of the eCommerce, account, and order-management components actually used on the site;
• PayPal, for payment handling and transaction-related obligations;
• Google, for analytics services actually enabled on the site;
• administrative, tax, legal, or technical consultants;
• parties supporting technical assistance or operational continuity;
• authorities, institutions, or persons legally entitled to access the data.

Any external party processing data on behalf of the controller must be classified, where necessary, as a processor or an independent controller according to its actual role.

10. Transfers outside the EEA

Some third-party providers or services used on the site, including PayPal and Google, may involve data transfers outside the EEA.

In such cases, the processing must take place in accordance with the conditions and safeguards required by applicable law.

11. Retention period

Data are retained for as long as strictly necessary for the purposes for which they were collected and, subsequently, for the periods required or permitted by law, by the contractual relationship, by the defense of the controller's rights, and by security, audit, and operational continuity needs.

In particular:

• contact and pre-sales data are retained for the time needed to handle the request and any related follow-up;
• account, order, licensing, and support data are retained for the duration of the relationship and for the additional period required for administration, disputes, renewals, security, and support;
• technical and security logs are retained according to minimization criteria and internal technical policies;
• data collected through Google Analytics follow the retention and configuration of that service, which must be aligned with the cookie policy.

12. Data subject rights

Where provided by applicable law, the data subject may exercise the rights to:

• access personal data;
• rectification of inaccurate or incomplete data;
• erasure of data;
• restriction of processing;
• objection to processing;
• data portability, where applicable;
• withdraw consent, without affecting the lawfulness of processing based on consent before withdrawal.

Requests may be sent to the controller using the contact details listed in this notice.

13. Complaint to the supervisory authority

The data subject also has the right to lodge a complaint with the Italian Data Protection Authority (Garante per la protezione dei dati personali), in accordance with applicable law.

14. Cookies and other tracking tools

The site uses or may use:

• strictly necessary technical cookies and tools;
• analytics tools attributable to Google Analytics;
• any additional cookies or tools related to the site, customer account, checkout, or PayPal.

Any non-essential cookies or tools must be activated only when and as permitted by applicable law and described in docs/legal/SITE-COOKIE-POLICY-MYOWNSMS-COM-EN.md, which must be read together with this notice.

15. Updates

This notice may be updated over time to reflect legal, organizational, or technical changes to myownsms.com, the checkout, the customer account area, or the licensing flow.

16. Points to confirm before publication

Before final publication, verify and complete:

the final links to the cookie policy and PayPal privacy policy, if you want the site page to be more complete.

whether Google Analytics is configured with IP anonymization, Consent Mode, or equivalent settings;

the exact list of cookies and scripts actually loaded on the site, the customer account area, and the checkout;

more granular retention periods, if you decide to publish them explicitly;