Privacy Policy


Personal data collected through the website reachable at are processed as the data controller by:
Name: Mr.Who SARL
Registered office: Palais de la Scala 4° ETG étage Studio 1160, 98000, Monaco
Phone: +377 99 90 15 47


The personal data collected through the site do not have the nature of special data (as defined by art.9 of the GDPR), but are only suitable to identify the User (e.g. name, surname, tax code, residence, telephone, email).

Said information is that specified in Legislative Decree No. 109 of May 30, 2008, such as:

  • IP address used and email address and any additional identifier of the sender;
  • IP address and fully qualified domain name of the mail exchanger host (in the case of SMTP technology), or any type of host related to a different technology used for the transmission of communication;
  • e-mail address and any additional identifier of the recipient of the communication;
  • IP address and fully qualified domain name of the mail exchanger host (in the case of SMTP technology), or of any type of host (relating to a different technology used), which provided delivery of the message;
  • IP address used for the reception, i.e., consultation of e-mail messages by the recipient regardless of the technology or protocol used;
  • date and time (GMT) of the connection and disconnection of the user of the Internet e-mail service and IP address used, regardless of the technology and protocol used.


Personal data collected on the website are processed by Mr.Who SARL for the following purposes:

  • managing the registration procedure and access to the reserved area where provided;
  • operational, technical and administrative management of the services purchased by the User;
  • respond to requests for assistance or information, sent through the established communication channels ;
  • To fulfill legal, accounting and tax obligations;
  • carry out direct marketing via e-mail for services similar to those purchased or for the pursuit of the legitimate interest of Mr.Who SARL a promote products or services in which the User is reasonably interested;
  • security and prevention of fraudulent conduct.


In compliance with the provisions of Article 6 of Mr.Who SARL Processing on the basis of:

  • consent to the processing;
  • performance of a contract;
  • fulfillment of a legal obligation;
  • pursuit of the legitimate interest of the data controller.


The processing of personal data is carried out using manual, paper, computer and telematic tools with logics strictly related to the purposes specified in the privacy policy and in any case in such a way as to ensure the security and confidentiality of the data. Mr.Who SARL, internally, entrusts the processing of personal data only to formally authorized persons who have received specific instructions and training and who have undertaken to treat the data confidentially.


Personal data are retained for the duration of the contractual relationship and, in the case of revocation and/or other termination of the aforementioned relationship, for the terms established by law for the fulfillment of, for example, civil and tax obligations.

For marketing purposes, data will be retained until consent is revoked or for the period established by legislation or Measures issued by the Control Authority.

With reference to investigation and suppression of crimes, personal data related to traffic are kept by Mr.Who SARL for six years after their generation.

Data are also processed by Mr.Who SARL for ordinary business processing related to the provision of the service (e.g.: for documentation purposes in case of invoice dispute or payment claim, for fraud detection, to perform analysis on behalf of customers), under the provisions of the regulations. In this case, data are stored with stringent security measures applied in accordance with the law and subsequently deleted.


Name Company may transfer the personal data of applicants to third parties for the provision of the requested services, in accordance with the provisions of Article 49, 1 paragraph let. b), the transfer of data may also take place outside the European Economic Area.


Your Personal Data may be shared for the purposes specified above with: professional firms that provide assistance and advice in accounting, administrative, legal, tax, financial and subjects with whom it is necessary to interact for the provision of Services:

  • Subjects that provide the service of payment by credit card, (Paypal etc.) or other services instrumental to those provided by Mr.Who SARL.
  • Subjects delegated to carry out technical maintenance activities.
  • Judicial authorities for purposes of repression and investigation.


The hardware infrastructure used by Mr.Who SARL is from Nsai srl, to deliver its services is located within the data center residing in Italy ISO 27001 certified so as to ensure maximum security.


In implementation of the principle of transparency, the user may request all information regarding the processing of his personal data as well as exercise the rights recognized by the GDPR and specified in Articles 15 – 23. In particular, he/she will be able to request:

  • access to your Personal Data;
  • the rectification or erasure of the same or to object to their processing in the cases provided for in Article 20 of the Regulations;
  • the limitation of the processing in the cases provided for by Article 18 of the Regulation, as well as to obtain in a structured, commonly used and machine-readable format the data concerning you (portability), in the cases provided for by Article 20 of the Regulation.

You will be able to exercise YOUR rights independently by managing your data and preferences in the privacy center present in your Customer Area. In any case, any requests can be sent via the online form.


This privacy policy is effective as of May 25, 2018. Mr.Who SARL, following indications from Control Authorities or in case of organizational changes, may update and/or modify this document. Therefore, Users should check periodically for any changes.