Privacy Policy
This Application collects certain Personal Data from its Users.
Users may be subject to different levels of protection. Therefore, some Users enjoy a higher level of protection. Further information regarding the protection criteria can be found in the section on applicability.
Types of Data Collected
Among the types of Personal Data that this Application collects, either directly or through third parties, are: first name, last name, phone number, address, province/state, email address, ZIP/postal code, city, Cookies, and Usage Data.
Complete details on each type of collected data are provided in the dedicated sections of this privacy policy or through specific information notices displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide such Data, it may be impossible for this Application to provide its Services. In cases where this Application specifically states that some Data is optional, Users are free not to provide this Data without affecting the availability or operation of the Service.
Users who are uncertain about which Personal Data is mandatory are encouraged to contact the Owner.
Any use of Cookies — or other tracking tools — by this Application or by the owners of third-party services used by this Application, unless otherwise stated, is intended to provide the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application and confirms that they have the right to communicate or share such data, releasing the Owner from any liability toward third parties.
Methods and Place of Processing the Collected Data
Methods of Processing
The Owner adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Data processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain persons involved in the operation of this Application (administrative staff, sales staff, marketing staff, legal advisors, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) appointed, if necessary, as Data Processors by the Owner.
The updated list of these Data Processors may be requested at any time from the Data Controller.
Legal Basis for Processing
The Owner processes Personal Data relating to the User if one of the following conditions applies:
- The User has given consent for one or more specific purposes. Note: under some jurisdictions, the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other legal basis listed below. However, this does not apply whenever the processing of Personal Data is subject to European data protection law.
- Processing is necessary for the performance of a contract with the User and/or for any pre-contractual obligations.
- Processing is necessary for compliance with a legal obligation to which the Owner is subject.
- Processing is related to a task carried out in the public interest or in the exercise of official authority vested in the Owner.
- Processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help clarify the specific legal basis that applies to the processing, and in particular whether the processing is based on the law, required by a contract, or necessary to enter into a contract.
Location
The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Owner.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To find out more about the place of processing, Users may refer to the section containing details about the processing of Personal Data.
If a higher level of protection applies, Users are entitled to learn about the legal basis for Data transfers outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, as well as about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or by contacting the Owner using the information provided at the beginning of this document.
Data Retention Period
Personal Data shall be processed and stored for as long as required by the purpose for which it has been collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill those purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
When processing is based on the User’s consent, the Owner may retain Personal Data for a longer period until such consent is withdrawn. Furthermore, the Owner may be required to retain Personal Data for a longer period whenever required to fulfill a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the rights to access, erase, rectify, and transfer Data cannot be enforced after the expiration of the retention period.
Purpose of Processing the Collected Data
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The User’s Data is collected to allow the Owner to provide its Services, as well as for the following purposes: contacting the User, content commenting, contact management and message sending, payment management, remarketing and behavioral targeting, analytics, and advertising.
For more detailed information about the purposes of processing and the specific Personal Data used for each purpose, the User may refer to the relevant sections of this document.
Details on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Content Commenting
Content commenting services allow Users to make and publish comments regarding the content of this Application.
Depending on the settings chosen by the Owner, Users may also leave comments anonymously. If the User provides an email address along with the comment, it may be used to send notifications about comments on the same content. Users are responsible for the content of their own comments.
If a third-party commenting service is installed, it may still collect web traffic data for the pages where the commenting service is installed, even if Users do not use the commenting service.
Directly Managed Comment System (this Application)
This Application has its own internal content commenting system.
Personal Data collected: last name, email address, first name, and phone number.
Contacting the User
Contact Form (this Application)
By filling out the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotations, or any other request indicated by the form’s header.
Personal Data collected: ZIP/postal code, city, last name, email address, physical address, first name, phone number, and province/state.
Mailing List or Newsletter (this Application)
By registering for the mailing list or newsletter, the User’s email address will automatically be added to a contact list that may receive email messages containing information, including commercial and promotional content, related to this Application. The User’s email address may also be added to this list as a result of registering for this Application or after making a purchase.
Personal Data collected: ZIP/postal code, city, last name, email address, physical address, first name, phone number, and province/state.
Phone Contact (this Application)
Users who provide their phone number may be contacted for commercial or promotional purposes related to this Application, as well as for support requests.
Personal Data collected: phone number.
Contact Management and Message Sending
These services allow the management of a database of email contacts, phone contacts, or any other type of contact used to communicate with the User.
These services may also collect data regarding the date and time when messages are viewed by the User, as well as when the User interacts with them, such as by clicking links included in the messages.
Skebby (Skebby – Mobile Solution S.r.l.)
Skebby is a phone contact management and communication service provided by Skebby – Mobile Solution S.r.l.
Personal Data collected: phone number.
Place of processing: Italy – Privacy Policy.
Payment Management
Payment processing services enable this Application to process payments by credit card, bank transfer, or other payment methods. Payment data is collected directly by the payment service provider and is not processed by this Application.
Some payment services may also allow scheduled messages to be sent to the User, such as emails containing invoices or payment notifications.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc. that allows Users to make online payments.
Personal Data collected: various types of Data as specified in PayPal’s privacy policy.
Place of processing: See PayPal’s Privacy Policy.
Advertising
These services allow User Data to be used for advertising communication purposes in various forms, such as banners, based on the User’s interests.
This does not mean that all Personal Data is used for this purpose. Information and usage conditions are described below.
Some services listed below may use Cookies to identify Users or use behavioral retargeting techniques to display personalized ads based on the User’s interests and behavior, including behavior detected outside this Application. For more information, Users are encouraged to review the privacy policies of the respective services.
In addition to any opt-out feature offered by the services below, Users may opt out of third-party service cookies by visiting the Network Advertising Initiative opt-out page.
Direct Email Marketing (DEM) (this Application)
This Application uses User Data to send commercial proposals related to services and products offered by third parties or unrelated to the services provided by this Application.
Personal Data collected: email address.
Remarketing and Behavioral Targeting
These services allow this Application and its partners to inform, optimize, and display advertising based on the User’s past use of this Application.
This activity is carried out through tracking Usage Data and using Cookies, which are transferred to partners involved in remarketing and behavioral targeting activities.
In addition to any opt-out feature offered by the services below, Users may opt out of third-party service cookies by visiting the Network Advertising Initiative opt-out page.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Statistics Collected Directly (this Application)
This Application uses an internal analytics system that does not involve third parties.
Personal Data collected: Cookies and Usage Data.
Additional Information about Personal Data
Online Sale of Goods and Services
The Personal Data collected is used to provide services to the User or to sell products, including payment processing and possible delivery.
The Personal Data collected to complete payments may include credit card details, bank account information used for transfers, or other accepted payment methods. The payment Data collected by this Application depends on the payment system used.
User Rights
Users may exercise certain rights regarding their Data processed by the Owner.
Where a higher level of protection applies, Users may exercise all the rights described below. In all other cases, Users may contact the Owner to find out which rights apply to them and how to exercise them.
In particular, Users have the right to:
- Withdraw consent at any time. Users may withdraw their previously given consent to the processing of their Personal Data.
- Object to processing of their Data. Users may object to the processing of their Data if such processing is carried out on a legal basis other than consent. Further details are provided in the section below.
- Access their Data. Users have the right to know whether Data is being processed by the Owner, obtain information regarding certain aspects of the processing, and receive a copy of the processed Data.
- Verify and request correction. Users may verify the accuracy of their Data and request updates or corrections.
- Restrict the processing of their Data. Under certain circumstances, Users may request restriction of the processing of their Data. In such cases, the Owner will not process the Data for any purpose other than storage.
- Request deletion of their Personal Data. Under certain circumstances, Users may request the deletion of their Data by the Owner.
- Receive their Data and transfer it to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to have it transferred to another controller without hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority or take legal action.
Details about the Right to Object
Where Personal Data is processed for a public interest, in the exercise of official authority vested in the Owner, or for the legitimate interests pursued by the Owner, Users may object to such processing by providing a reason related to their particular situation.
Users are informed that, if their Personal Data is processed for direct marketing purposes, they may object to such processing at any time without providing any justification. To determine whether the Owner processes Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to Exercise User Rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests are free of charge and will be addressed by the Owner as early as possible and always within one month.
Applicability of Higher Protection Standards
While most provisions of this document apply to all Users, some provisions expressly apply only when the processing of Personal Data is subject to higher protection standards.
Such higher protection standards apply whenever the processing:
- is carried out by an Owner based within the EU;
- concerns the Personal Data of Users located in the EU and relates to the offering of paid or unpaid goods or services to such Users;
- concerns the Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users within the EU.
Cookie Policy
This Application uses Cookies. To learn more and view the detailed Cookie Policy, Users may consult the Cookie Policy section.
Additional Information about Data Processing
Legal Defense
The User’s Personal Data may be used by the Owner in legal proceedings or in the preparatory stages of possible legal action arising from improper use of this Application or related Services.
The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.
Specific Information
Upon request, this Application may provide Users with additional and contextual information concerning specific Services or the collection and processing of Personal Data.
System Logs and Maintenance
For operation and maintenance purposes, this Application and any third-party services may collect system logs, which are files recording interactions and may contain Personal Data such as the User’s IP address.
Information Not Contained in This Policy
Further details concerning the collection or processing of Personal Data may be requested from the Owner at any time using the contact information provided.
“Do Not Track” Requests
This Application does not support “Do Not Track” requests.
To determine whether any third-party services used support such requests, Users are encouraged to review their respective privacy policies.
Changes to This Privacy Policy
The Owner reserves the right to make changes to this Privacy Policy at any time by notifying Users on this page and, where technically and legally feasible, sending a notice to Users through any contact information available to the Owner.
Users are strongly recommended to check this page regularly, referring to the date of the latest modification indicated at the bottom.
If the changes concern data processing whose legal basis is consent, the Owner will request the User’s consent again, if necessary.
Definitions and Legal References
Personal Data (or Data)
Personal Data means any information that, directly or indirectly, including in connection with any other information such as a personal identification number, makes a natural person identified or identifiable.
Usage Data
Usage Data refers to information collected automatically through this Application (including by third-party applications integrated into this Application), such as: IP addresses or domain names of the computers used by Users who connect to this Application, URI addresses (Uniform Resource Identifier), the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the server response status (successful, error, etc.), the country of origin, the browser and operating system features used by the visitor, the various time details of the visit (for example, the time spent on each page), and details about the path followed within the Application, especially regarding the sequence of pages visited and parameters related to the User’s operating system and IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency, or other body that processes Personal Data on behalf of the Data Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, service, or other body which, alone or jointly with others, determines the purposes and means of processing Personal Data and the tools adopted, including security measures concerning the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.
This Application
The hardware or software tool by which the Users’ Personal Data is collected and processed.
Service
The Service provided by this Application as described in the relevant terms (if available) on this website/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document includes all current member states of the European Union and the European Economic Area.
Cookie
A small piece of data stored on the User’s device.
Legal References
This privacy policy is drafted based on multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR).
Unless otherwise specified, this privacy policy applies exclusively to this Application.