Privacy Policy
This Application collects certain Personal Data from its Users.
Users may be subject to different levels of protection. Some Users may therefore enjoy greater protection. Further information regarding protection criteria can be found in the applicability section.
Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: first name; last name; phone number; address; province; email; postal code; city; Cookies; Usage Data.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information notices displayed before the data collection.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to provide the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from providing such Data without any consequences on the availability or functionality of the Service.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The use of Cookies—or other tracking tools—by this Application or by the providers of third-party services used by this Application, unless otherwise specified, 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 is responsible for the Personal Data of third parties obtained, published, or shared through this Application and guarantees that they have the right to communicate or disseminate it, releasing the Data Controller from any liability towards third parties.
Methods and Place of Processing of Collected Data
Methods of Processing
The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal 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 Data Controller, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may have access to the Data, appointed, if necessary, as Data Processors by the Data Controller. An updated list of Data Processors can always be requested from the Data Controller.
Legal Basis for Processing
- The User has given consent for one or more specific purposes; Note: In some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, until the User objects (“opt-out”) to such processing. However, this does not apply if the processing of Personal Data is governed by European data protection legislation;
- The processing is necessary for the performance of a contract with the User and/or for pre-contractual measures;
- The processing is necessary to comply with a legal obligation to which the Data Controller is subject;
- The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
- The processing is necessary for the legitimate interests pursued by the Data Controller or third parties.
It is always possible to request the Data Controller to clarify the specific legal basis for each processing and, in particular, to specify whether the processing is based on law, required by a contract, or necessary to conclude a contract.
Place
The Data is processed at the Data Controller’s operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section on details of Personal Data processing.
In cases of enhanced protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
If any of the transfers described above take place, the User can refer to the respective sections of this document or request information from the Data Controller using the contact details provided at the beginning.
Retention Period
Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the contract is fully performed.
- Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until such interests are satisfied. The User can obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
- When processing is based on the User’s consent, the Data Controller may retain Personal Data longer until such consent is revoked. Additionally, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, Personal Data will be deleted. Therefore, upon expiration of this period, the rights of access, deletion, rectification, and data portability can no longer be exercised.
Purposes of Processing Collected Data
The User’s Data is collected to enable the Data Controller 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, Statistics, and Advertising.
For more detailed information on the purposes of processing and the Personal Data relevant to each purpose, the User can refer to the relevant sections of this document.
Details on the Processing of Personal Data
Content Commenting
Commenting services allow Users to make and publish their comments regarding the content of this Application.
Users, depending on the settings chosen by the Data Controller, may leave comments anonymously. If the Personal Data provided by the User includes an email address, it may be used to send notifications about comments on the same content. Users are responsible for the content of their comments.
If a third-party commenting service is installed, it may collect traffic data related to the pages where the commenting service is installed, even if Users do not use the commenting service.
Directly Managed Commenting System (this Application)
This Application has its own content commenting system.
Personal Data collected: last name; email; first name; phone number.
Contacting the User
Contact Form (this Application)
By filling out the contact form with their Data, the User consents to its use to respond to requests for information, quotes, or any other type of request indicated in the form’s header.
Personal Data collected: postal code; city; last name; email; address; first name; phone number; province.
Mailing List or Newsletter (this Application)
By registering for the mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information, including commercial and promotional content, related to this Application may be sent. The User’s email address may also be added to this list as a result of registering with this Application or after making a purchase.
Personal Data collected: postal code; city; last name; email; address; first name; phone number; province.
Phone Contact (this Application)
Users who have provided their phone number may be contacted for commercial or promotional purposes related to this Application, as well as to fulfill support requests.
Personal Data collected: phone number.
Contact Management and Message Sending
This type of service allows 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 of message viewing by the User, as well as the User’s interaction with them, such as information on clicks on links included in the messages.
Skebby (Skebby – Mobile Solution S.r.l.)
Skebby is a service for managing phone contacts and communication provided by Skebby – Mobile Solution S.r.l.
Personal Data collected: phone number.
Place of processing: Italy – Privacy Policy.
Payment Management
Payment management services allow this Application to process payments via credit card, bank transfer, or other methods. The data used for payment is acquired directly by the requested payment service provider without being processed by this Application in any way.
Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.
PayPal (Paypal)
PayPal is a payment service provided by PayPal Inc., which allows the User to make online payments.
Personal Data collected: various types of Data as specified in the service’s privacy policy.
Place of processing: See PayPal’s privacy policy – Privacy Policy.
Advertising
This type of service allows the User’s Data to be used for commercial communication purposes in various advertising formats, such as banners, also related to the User’s interests.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are specified below.
Some of the services listed below may use Cookies to identify the User or employ behavioral retargeting techniques. In addition to the opt-out options offered below, the User can opt out via the Network Advertising Initiative.
Direct Email Marketing (DEM) (this Application)
This Application uses the User’s Data to send commercial proposals related to services and products provided by third parties or unrelated to the product or service provided by this Application.
Personal Data collected: email.
Remarketing and Behavioral Targeting
This type of service allows this Application and its partners to communicate, optimize, and serve advertisements based on the User’s past use of this Application. This activity is carried out by tracking Usage Data and Cookies and may be transferred to partners.
Facebook Custom Audience (Facebook, Inc.)
Personal Data collected: Cookies; email.
Place: United States – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy – Opt Out.
Remarketing with Google Analytics (Google LLC)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy – Opt Out.
Remarketing Google Ads (Google LLC)
Users can opt out of Google’s ad personalization via Google Ads Settings.
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension (Google LLC)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy – Opt Out.
Statistics
AdEspresso Conversion Tracking (Creative Web Srl)
Personal Data collected: Cookies; Usage Data.
Place: Italy – Privacy Policy.
Facebook Ads Conversion Tracking (Facebook Pixel) (Facebook, Inc.)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy.
Google Ads Conversion Tracking (Google Inc.)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy.
Twitter Ads Conversion Tracking (Twitter, Inc.)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy.
Yahoo Advertising Conversion Tracking (Yahoo! Inc.)
Personal Data collected: Cookies; Usage Data.
Place: United States – Privacy Policy.
Directly Collected Statistics (this Application)
This Application uses an internal statistics system that does not involve third parties.
Personal Data collected: Cookies; Usage Data.
Additional Information on Personal Data
Sale of Goods and Services Online
The Personal Data collected is used to provide services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to complete the payment may include credit card details, the bank account used for the transfer, or other payment methods provided. The payment data collected by this Application depends on the payment system used.
User Rights
Users may exercise certain rights with respect to the Data processed by the Data Controller.
In cases of enhanced protection, the User may exercise all the rights listed below. In any other case, the User can contact the Data Controller to find out which rights are applicable in their case and how to exercise them.
- Withdraw consent at any time. The User can withdraw consent to the processing of their Personal Data previously given.
- Object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
- Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, certain aspects of the processing, and to receive a copy of the processed Data.
- Verify and request rectification. The User can verify the accuracy of their Data and request its updating or correction.
- Obtain restriction of processing. When certain conditions are met, the User can request the restriction of the processing of their Data.
- Obtain deletion or removal of their Personal Data. When certain conditions are met, the User can request the deletion of their Data by the Data Controller.
- Receive their Data or have it transferred to another controller. The User has 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.
- Lodge a complaint. The User can lodge a complaint with the competent data protection authority or take legal action.
Details on the Right to Object
When Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object for reasons related to their particular situation.
Users are informed that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any reason.
How to Exercise Rights
To exercise their rights, Users can send a request to the contact details of the Data Controller provided in this document. Requests are processed free of charge and handled by the Data Controller as soon as possible, in any case within one month.
Applicability of Enhanced Protection Level
While most provisions of this document apply to all Users, some are expressly subject to the applicability of an enhanced level of protection for the processing of Personal Data.
This enhanced level of protection is always guaranteed when the processing:
- Is carried out by a Data Controller based in the EU; or
- Concerns Personal Data of Users located in the EU and is related to the offering of goods or services, whether paid or free, to such Users; or
- Concerns Personal Data of Users located in the EU and allows the Data Controller to monitor the behavior of such Users to the extent that such behavior takes place within the EU.
Cookie Policy
This Application uses Cookies. To learn more and view the detailed information, the User can consult the Cookie Policy.
Additional Information on Processing
Legal Defense
The User’s Personal Data may be used by the Data Controller in court or in the preparatory stages of potential legal proceedings to defend against abuses in the use of this Application or related Services by the User.
The User declares that they are aware that the Data Controller may be required to disclose Data by order of public authorities.
Specific Information Notices
Upon the User’s request, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information regarding specific Services or the collection and processing of Personal Data.
System Logs and Maintenance
For operational and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e., files that record interactions and may contain Personal Data, such as the User’s IP address.
Information Not Contained in This Policy
Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details provided.
Response to “Do Not Track” Requests
This Application does not support “Do Not Track” requests. To find out if any third-party services used support them, the User is invited to consult their respective privacy policies.
Changes to This Privacy Policy
The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Application, as well as, where technically and legally feasible, by sending a notification to Users through one of the contact details held by the Data Controller. Please check this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Definitions and Legal References
Personal Data (or Data)
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
Information collected automatically through this Application (including from third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User connecting to this Application, URI addresses, 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 status of the server’s response, the country of origin, the characteristics of the browser and operating system, the various temporal aspects of the visit, and details regarding the path followed within the Application.
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 entity that processes Personal Data on behalf of the Data Controller.
Data Controller (or Controller)
The entity that determines the purposes and means of the processing of Personal Data. Unless otherwise specified, the Data Controller is the owner of this Application.
This Application
The hardware or software tool through which the Personal Data of Users is collected and processed.
Service
The service provided by this Application.
European Union (or EU)
References extend to all current EU and EEA member states.
Cookie
A small piece of data stored on the User’s device.
Legal References
This privacy policy is drafted based on multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679 (GDPR). Unless otherwise specified, this privacy policy applies exclusively to this Application.