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Privacy

PRIVACY POLICY



WHY THIS NOTICE

This page describes how the site is managed with reference to the processing of personal data of the users who consult it. This privacy notice is also provided pursuant to Article 13 of Legislative Decree no. 196/2003, the Personal Data Protection Code, and Article 13 of EU Regulation 2016/679, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data. It is addressed to those who interact with the web services of the Personal Data Protection Authority, which are accessible electronically from the address:

www.nanapositano.it

THE "DATA CONTROLLER"

Following consultation of this site, data relating to identified or identifiable persons may be processed. The “Data Controller” is:

Anna Caiazzo
Via Pasitea 164
84017 Positano (SA) - Italy
tel: (+39) 089 811616
email: info@nanapositano.it
VAT NUMBER: 04812230656



PLACE OF DATA PROCESSING

Processing associated with the web services of this site takes place at the aforementioned office and is handled only by technical personnel of the office in charge of processing. In case of need, data related to the newsletter service may be processed by personnel at the aforementioned office.



TYPES OF DATA PROCESSED

Navigation data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols.
This information is not collected to be associated with identified interested parties, but by its very nature, it could, through processing and association with data held by third parties, allow users to be identified.
This category of data includes IP addresses or domain names of computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user's operating system and computer environment.
These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site and to check its correct functioning and are deleted immediately after processing. The data could be used to ascertain responsibility in the event of hypothetical cybercrimes against the site: except for this possibility, web contact data currently does not persist for more than seven days.

Data provided voluntarily by the user
The optional, explicit, and voluntary sending of e-mails to the addresses indicated on this site entails the subsequent acquisition of the sender’s address, which is necessary to respond to requests, as well as any other personal data included in the message. Specific summary information will be progressively reported or displayed on the pages of the site set up for particular on-demand services.



COOKIES

As clarified by the Privacy Guarantor in the FAQs of December 2012, available at www.garanteprivacy.it, cookies are "small text files" – made up of letters and numbers – "that the sites visited by the user send to their terminal (usually the browser), where they are stored to be then retransmitted to the same sites upon the next visit by the same user". Through cookies, we cannot access other information stored on your device, even if that is where the cookies are downloaded. Cookies cannot load codes of any kind, carry viruses or malware, and are not harmful to the user's terminal. When browsing our site, some information is acquired automatically for statistical or information purposes and allows for better service.



Type of Cookie

Technical/session – Technical/navigation
These are essential for the correct functioning of our site and allow the user to browse and view the content. Deactivating them would lead to site malfunctions. Generally, cookies of this type are necessary, for example, to keep a browsing session open or to allow the user to access any reserved areas. Or again, they can temporarily remember the texts entered while filling out a form, when you return to a previous page during the same session. Technical/functional (User consent is not required to issue this type of cookie) These allow the user to make the most of the site's features and to enjoy more comfortable navigation. The site works ideally if these cookies are enabled; however, it is possible to decide not to allow their activation on your device. In general, for example, cookies of this type remember which language the user prefers to view our content in, or they remember (for a limited period) the items present in the virtual shopping cart in case the session is closed before completing the purchase.

Technical/consent (User consent is not required to issue this type of cookie)
This cookie tracks the consent given by the user to the use of cookies on this site, so as not to show again – during subsequent visits – the short notice about cookies and the request to provide consent.



OPTIONAL NATURE OF DATA PROVISION

Apart from what has been specified for navigation data, the user is free to provide the personal data reported in the request forms to the Authority or otherwise indicated in contacts with the Office to request the sending of the newsletter, information material, or other communications.
Failure to provide them may make it impossible to obtain what has been requested.



PROCESSING METHODS

Personal data is processed with automated tools for the time strictly necessary to achieve the purposes for which it was collected. Specific security measures are observed to prevent the loss of data, illicit or incorrect uses, and unauthorized access.



RIGHTS OF THE INTERESTED PARTIES

The subjects to whom the personal data refers have the right at any time to obtain confirmation of the existence or otherwise of said data and to know its content and origin, verify its accuracy or request its integration or updating, or rectification (Art. 7 of Legislative Decree no. 196/2003).
Pursuant to the same article, one has the right to request the cancellation, transformation into anonymous form, or blocking of data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, its processing.
Requests should be addressed to:

  • by e-mail: info@nanapositano.it
  • by mail: Via Pasitea 164, - 84017 Positano (SA) - Italy

INTEGRATION OF THE SITE'S PRIVACY POLICY – Types of data processed

    • Navigation data The computer systems and software used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of Internet communication protocols and the TCP/IP protocol. This information does not in itself allow association with identified subjects, but by its very nature, it could, through processing and association with data held by third parties, allow users to be identified. This category of data includes IP addresses or domain names of computers used by users who connect to the site, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response given by the server (successful, error, etc.) and other parameters related to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of the site, to check the correct functioning of the services provided, or to identify the authors and responsibilities in the event of cybercrimes committed against the site.
    • Web Measurement Systems This site adopts a system for the analysis and evaluation of website traffic. For the aforementioned purposes, session cookies (which are not stored persistently on the user's computer) may be used, the use of which is strictly limited to the transmission of session identifiers. The session cookies used do not allow for the acquisition of the user's identifying personal data.


COOKIE POLICY



CONTROLLER OF PERSONAL DATA PROCESSING

Anna Caiazzo
Via Pasitea 164
84017 Positano (SA) - Italy
tel: (+39) 089 811616
email: info@nanapositano.it
VAT NUMBER: 04812230656



WHAT ARE COOKIES

Cookies are small text files (generally made up of letters and numbers) that are saved in the memory of the browser or device when you visit a site or view a message. Cookies allow a site to recognize a particular device or browser.
There are different types of cookies:
  • temporary (or session): they are used to store temporary information, allow you to link your actions during that specific session, and are removed from the computer when the browser is closed;
  • permanent (or saved): they are used to store information, such as your login name and password, to avoid the user having to retype them every time they visit a specific site; they remain stored on the computer even after closing the browser;
  • first-party: they originate from the website being viewed and can be permanent or temporary; they can be used to store information that will be reused the next time the site is visited;
  • third-party: they originate from ads from other sites, such as popups or advertising banners, present on the website being viewed; they can be used to record the use of the website for marketing purposes.


WHICH TYPES OF COOKIES WE USE

To allow the use of our site and the provision of our services, we use both so-called persistent cookies (i.e., cookies that remain in memory until they are manually deleted by the user or for which a long-term scheduled removal is planned) and so-called session cookies, which are not stored persistently on the visitor's computer and disappear when the browser is closed. We use different types of cookies with specific functions that we can classify as follows:



FIRST-PARTY COOKIES:

  • Technical session and navigation: They are fundamental for the operation of the site and allow the user to browse and view the content. Deactivating them could compromise the correct functionality of the site. Cookies of this type are necessary to keep a browsing session open or to allow the user to access any reserved areas. They can also temporarily remember the texts entered while filling out a form, when you return to a previous page during the same session. There is therefore no specific consent required from the user for their issuance.
  • Technical Functional: They allow the user to optimally use the site's features and to enjoy more comfortable navigation. The site works ideally if these cookies are enabled, but it is still possible to choose not to activate them on your device. Cookies of this type store which language the user prefers to view our content in or save (for a limited period) the items present in the virtual shopping cart in case the session is closed before completing the purchase. There is therefore no specific consent required from the user for their issuance.
  • Technical Consent: This cookie tracks the consent given by the user to the use of cookies on this site, so as not to show again during future visits the short notice about cookies. There is therefore no specific consent required from the user for their issuance.


THIRD-PARTY COOKIES:

  • Analytics Statistics (third-party) They are used to collect information on how users browse our site. This information is analyzed in aggregate form for statistical purposes only. They are not necessary, but they are of great help to us in improving our content and our services based on the information we derive from analyzing the statistics. By browsing this site, you will receive both first-party cookies and cookies from third-party sites, which may set cookies on your device on our behalf in order to provide the services they are delivering. More in-depth information on these cookies is available in the subsequent paragraphs of this document and on the respective websites of the third parties in question.


COOKIE DESCRIPTION
.tripadvisor.it Cookies used for statistical purposes provide information on how the user interacts with the website, the last access to the site, the first visit, the number of visits, and the duration of the visit.
.google.com Contains information about the user and preferences related to web pages containing Google Maps and cookies related to consent for Google services.
They do not contain personal information about the user.
See more details: policies.google.com/privacy

HOW TO CONFIGURE YOUR TERMINAL

If you do not agree to the installation of cookies, you must configure your browser to disable the reception of cookies or not use this site. However, by disabling cookies, the site or some of its functions may not operate correctly.
For more information on how to set preferences regarding the use of cookies through your web browser, you can consult the relevant instructions:



DETAILS ON THE PROCESSING OF PERSONAL DATA

Personal Data is collected for the following purposes and using the following services:

Contact form
By filling in the contact form with their Data, the User consents to its use for responding to requests for information, quotes, or any other nature indicated by the form's header. The data entered in the form will be used exclusively for sending emails and will not be stored in any database or other data structures.

Google Analytics with anonymized IP (Google Inc.) Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google uses the collected Personal Data for the purpose of tracking and examining the use of this Application, compiling reports, and sharing them with other services developed by Google. Google may use the Personal Data to contextualize and personalize ads in its advertising network. This integration of Google Analytics anonymizes your IP address. Anonymization works by shortening the Users' IP address within the borders of the Member States of the European Union or other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States. Personal data collected: Cookies and Usage Data. Place of processing: USA –Privacy Policy – Opt Out



FURTHER INFORMATION ON PROCESSING

Legal defense At 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.

Information not contained in this policy More information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact information.

Exercise of rights by Users
The subjects to whom the Personal Data refers have the right at any time to obtain confirmation of the existence or otherwise of the same from the Data Controller, to know its content and origin, to verify its accuracy or request its integration, cancellation, updating, rectification, transformation into anonymous form, or blocking of Personal Data processed in violation of the law, as well as to oppose in any case, for legitimate reasons, their processing. Requests should be addressed to the Data Controller. This Application does not support “Do Not Track” requests. To find out if any third-party services used support them, consult their privacy policies.

Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page. Therefore, please consult this page often, taking as a reference the date of the last modification indicated at the bottom. In case of non-acceptance of the changes made to this privacy policy, the User is required to cease using this Application and may request the Data Controller to remove their Personal Data. Unless otherwise specified, the previous privacy policy will continue to apply to the Personal Data collected until that moment.

Information about this privacy policy The Data Controller is responsible for this privacy policy, drafted starting from modules prepared by Iubenda and stored on its servers. Finally, we inform you that, pursuant to art. 7 of the Privacy Code, every visitor is entitled to certain rights, including the right to object to the processing. For this purpose, therefore, every visitor can change their choice at any time by accessing this information again. For all those who prevent the operation of some cookies, navigation on this website will NOT be guaranteed. For more information on third-party cookies related to advertising and how to disable them, you can visit the following websites:



DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)
Personal data is any information relating to a natural person, identified or identifiable, even indirectly, by reference to any other information, including a personal identification number.

Usage Data
This is information collected automatically by this Application (or by third-party applications that this Application uses), including: the IP addresses or domain names of the computers used by the User who connects with this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used in submitting the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the features of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and details related to the path followed within the Application, with particular reference to the sequence of pages consulted, parameters related to the operating system and the User's computer environment.

User
The individual who uses this Application, who must coincide with the Data Subject or be authorized by them and whose Personal Data is the subject of processing.

Data Subject
The natural or legal person to whom the Personal Data refers.

Data Processor (or Processor) The natural or legal person, public administration, and any other body, association, or organization appointed by the Data Controller to process Personal Data in accordance with this privacy policy.

Data Controller (or Controller) The natural or legal person, public administration, and any other body, association, or organization with decision-making power, alone or jointly with another controller, regarding the purposes, methods of processing personal data, and the tools used, including security profiles, in relation to 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 Users' Personal Data is collected.

Cookie Small portion of data stored within the User's device.



LEGAL REFERENCES

This privacy policy also serves as notice pursuant to art. 13 of Legislative Decree no. 196/2003, Code regarding the protection of personal data, and for the purposes of Article 13 of EU Regulation no. 2016/679, relating to the protection of natural persons with regard to the processing of personal data and on the free movement of such data.
Notice to European Users: this privacy policy is drawn up in compliance with the obligations provided for by Art. 10 of Directive no. 95/46/EC, as well as the provisions of Directive 2002/58/EC, as updated by Directive 2009/136/EC, regarding Cookies.

This privacy policy relates exclusively to this Application.

 

Privacy Policy

The purpose of this document (hereinafter “Privacy Policy”) is to inform Users about personal data, understood as any information that allows the identification of a natural person (hereinafter “Personal Data”), collected by the website (hereinafter “Application”).

The Data Controller, as subsequently identified, may modify or simply update, in whole or in part, this Policy by informing Users. The changes and updates will be binding as soon as they are published on the Application. The User is therefore invited to read the Privacy Policy each time they access the Application.

In case of non-acceptance of the changes made to the Privacy Policy, the User is required to cease using this Application and may request the Data Controller to remove their Personal Data.

  1. Personal Data collected by the Application

The Controller collects the following types of Personal Data:

  1. Contents and information provided voluntarily by the User

- Contact data and content: these are Personal Data that the User voluntarily provides to the Application during its use, such as personal data, contact details, credentials for accessing services and/or products provided, personal interests and preferences, and other personal content, etc.

- Personal data collected from social media: Users can share data provided to social media with the Application. The User has the right to control the Personal Data to which the Application can access through the privacy settings available on the social media in question. By associating accounts managed by social media with the Application and authorizing the Controller to access such Personal Data, the User consents to their acquisition, processing, and storage in accordance with this Privacy Policy.

Failure by the User to provide Personal Data, for which there is a legal or contractual obligation, or if they constitute a necessary requirement for the use of the service or for the conclusion of the contract, will make it impossible for the Controller to provide all or part of its services.

The User who communicates third-party Personal Data to the Controller is directly and exclusively responsible for their provenance, collection, processing, communication, or dissemination.

  1. Data and content acquired automatically during the use of the Application:

Technical data: the computer systems and software procedures used to operate this Application may acquire, during their normal operation, some Personal Data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified Users, but which by its very nature could, through processing and association with data held by third parties, allow Users to be identified. This category includes IP addresses or domain names used by Users who connect to the Application, URI (Uniform Resource Identifier) addresses of the requested resources, the time of the request, the method used in submitting the request to the server, the size of the file obtained, etc.

Usage data: Personal Data relating to the User's use of the Application may also be collected, such as the pages visited, actions performed, and features and services used.

  1. Personal data collected via cookies or similar technologies:

The Application uses cookies, web beacons, unique identifiers, and other similar technologies to collect Personal Data on pages, links visited, and other actions performed when using our services. They are stored to be then retransmitted on the next visit of the same User.

  1. Purposes

The Personal Data collected may be used for the performance of contractual and pre-contractual obligations and for legal obligations, as well as for the following purposes:

External management of payments via credit card, bank transfer, or other instruments: to manage User payments through external platforms that acquire payment data without the Application owner having access.

Sending emails or newsletters and managing mailing lists: to contact the User with emails containing commercial and promotional information regarding the Application.

User registration and authentication: to allow the User to register on the Application to access and be identified.

Storage, hosting and backend infrastructure management: to manage the technical infrastructure for storing User data.

Monitoring, analysis and tracking of User behavior: to monitor and analyze how the User behaves

on the Application.

Support and contact with the User: to respond to the User's requests and assist them in case of problems.

User profiling: to group and analyze the User's characteristics or behaviors in an automated manner and provide them with personalized services or messages.

Displaying content from external platforms: to allow the User to view and share content from social networks or other external platforms (e.g., YouTube, Facebook).

  1. Methods of processing

The processing of Personal Data is carried out using computer and/or telematic tools, with organizational methods and logic strictly related to the indicated purposes.

In some cases, parties involved in the Controller's organization may also have access to the Personal Data (such as, for example, personnel management staff, sales department staff, system administrators, etc.) or external parties (such as IT companies, service providers, postal couriers, hosting providers, etc.). These parties may be appointed as Data Processors by the Controller if necessary, as well as access the Users' Personal Data whenever required, and will be contractually obliged to keep the Personal Data confidential.

The updated list of Data Processors can be requested via email at the email address

  1. Legal basis for processing

The processing of Personal Data relating to the User is based on the following legal grounds:

consent given by the User for one or more specific purposes;

processing is necessary for the performance of a contract with the User and/or for the implementation of pre-contractual measures

processing is necessary to fulfill a legal obligation to which the Controller is subject

processing is necessary for the performance of a task in the public interest or for the exercise of official authority vested in the Controller

processing is necessary for the pursuit of the legitimate interest of the Controller or third parties

processing is necessary for the pursuit of a vital interest of the Controller or third parties.

It is, in any case, always possible to ask the Controller to clarify the legal basis of each processing operation at the email address

  1. Place

Personal Data is processed at the Controller's operational offices and in any other place where the parties involved in the processing are located. For further information, contact the Controller at the following email address

Personal Data may be transferred to non-EU countries: USA.

For these countries, there is an adequacy decision by the European Commission or, in the absence of such a decision, it is possible to request more information from the Controller regarding the appropriate safeguards adopted, as well as the means to obtain a copy of such Data or the exact place where they were made available.

  1. Security measures

Processing is carried out according to methods and with tools suitable to guarantee the security and confidentiality of the Personal Data, with the Controller having adopted appropriate technical and organizational measures that guarantee, and allow to demonstrate, that the Processing is carried out in compliance with the relevant legislation.

  1. Data retention period

Personal Data will be kept for the time period necessary to fulfill the purposes for which they were collected.

In particular, Personal Data will be kept for the entire duration of the contractual relationship, for the execution of the fulfillments inherent and consequent to it, for compliance with applicable legal and regulatory obligations, as well as for defensive purposes of the Controller or third parties.

Where the processing of Personal Data is based on the User's consent, the Controller may keep the Personal Data until the consent is revoked.

Personal Data may be kept for a longer period if necessary to fulfill a legal obligation or by order of an authority.

All Personal Data will be deleted or kept in a form that does not allow the identification of the User within 30 days from the end of the retention period. Upon the expiration of this term, the right of access, cancellation, rectification and the right to the portability of Personal Data can no longer be exercised.

  1. Automated decision-making processes

All Personal Data collected will not be subject to any automated decision-making process, including profiling, that may produce legal effects for the person or that may affect them significantly.

  1. User rights

Users can exercise certain rights with reference to the Personal Data processed by the Controller. In particular, the User has the right to:

withdraw consent at any time;

object to the processing of their Personal Data;

access their Personal Data;

verify and request rectification;

obtain the restriction of processing;

obtain the cancellation of their Personal Data;

receive their Personal Data or have it transferred to another controller;

lodge a complaint with the Personal Data protection supervisory authority and/or take legal action.

To exercise their rights, Users can address a request to the contact details of the Controller indicated in this document. The requests are made free of charge and processed by the Controller as soon as possible, in any case within 30 days.

In order to offer the user Klarna's payment methods, we may transmit to Klarna at checkout the user's personal data in the form of contact details and order details, so that Klarna can assess the user's eligibility for its payment methods and customize those payment methods. The transferred personal data of the user is processed in line with Klarna's privacy policy.”

Privacy Policy

This Website collects some Personal Data of its Users.

This document can be printed using the print command present in the settings of any browser.

Policy summary

Personal Data processed for the following purposes and using the following services:

  • Contacting the User
    • Mailing list or newsletter

Personal Data: ZIP code; city; surname; date of birth; Usage Data; email; physical address; country; name; phone number; province; gender; Tracking Tools

    • Contact form

Personal Data: ZIP code; city; Tax Code; surname; date of birth; Usage Data; email; User ID; physical address; country; name; phone number; province; gender; Tracking Tools; various types of Data

    • Contact via phone

Personal Data: phone number

  • Managing contacts and sending messages
    • Klaviyo

Personal Data: various types of Data

    • Sendgrid

Personal Data: surname; date of birth; email; name; phone number; gender

  • Payment management
    • PayPal

Personal Data: surname; email; billing address; name; phone number; various types of Data as specified by the service's privacy policy

    • Apple Pay and Google Pay

Personal Data: surname; Usage Data; email; billing address; shipping address; name; phone number; various types of Data as specified by the service's privacy policy

    • Klarna

Personal Data: surname; email; billing address; shipping address; name; phone number; various types of Data as specified by the service's privacy policy

    • Stripe

Personal Data: surname; Usage Data; email; billing address; various types of Data as specified by the service's privacy policy

  • Tag management
    • Google Tag Manager

Personal Data: Usage Data; Tracking Tools

  • Managing data collection and online surveys
    • Klaviyo Forms

Personal Data: Data communicated during the use of the service

  • Hosting and backend infrastructure
    • SiteGround

Personal Data: various types of Data as specified by the service's privacy policy

  • Interaction with live chat platforms
    • Shopify Inbox

Personal Data: Data communicated during the use of the service

  • Interaction with social networks and external platforms
    • PayPal button and widgets, Linkedin social button and widgets, and Facebook Like button and widgets

Personal Data: Usage Data; Tracking Tools

  • Collection of privacy-related preferences
    • iubenda Consent Solution

Personal Data: Data communicated during the use of the service; Tracking Tools

    • iubenda Cookie Solution

Personal Data: Tracking Tools

  • Registration and authentication
    • Direct registration and profiling

Personal Data: ZIP code; Tax Code; surname; date of birth; Usage Data; email; User ID; image; profile image; billing address; shipping address; physical address; language; house number; phone number; province; gender; state; username; various types of Data

  • Registration and authentication provided directly by this Website
    • Direct registration

Personal Data: ZIP code; city; Tax Code; surname; date of birth; email; User ID; image; profile image; billing address; physical address; language; country; name; house number; phone number; prefix; province; gender; state; username; various types of Data

  • Remarketing and behavioral targeting
    • Facebook Remarketing, Remarketing with Google Analytics and Google Ads Remarketing

Personal Data: Usage Data; Tracking Tools

    • Klaviyo segmentation and social advertising

Personal Data: purchase history; Usage Data; email; device information; Tracking Tools

    • Facebook Custom Audience

Personal Data: email; Tracking Tools

  • Statistics
      • Google Analytics, Google Analytics with anonymized IP, Meta Events Manager, Facebook Ads conversion tracking (Facebook pixel), Google Ads conversion tracking

Personal Data: Usage Data; Tracking Tools

    • Google Analytics 4

Personal Data: device information; number of Users; session statistics; Tracking Tools

    • Google Analytics demographics and interests reports

Personal Data: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tools

  • Displaying content from external platforms
      • Google Fonts, Font Awesome, Instagram Widget and YouTube Video Widget

Personal Data: Usage Data; Tracking Tools

Information on how to opt-out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users can read more on how to opt-out of interest-based advertising in the appropriate section of the Cookie Policy.

Further information on the processing of Personal Data

    • Online sale of goods and services

The Personal Data collected is used for the provision of services to the User or for the sale of products, including payment and possible delivery. The Personal Data collected to process payment may be that relating to the credit card, the bank account used for the transfer or other payment tools provided. The payment data collected by this Website depends on the payment system used.

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, are: Tracking Tools; Usage Data; email; name; surname; phone number; province; country; ZIP code; gender; date of birth; city; physical address; various types of Data; Tax Code; User ID; billing address; Data communicated during the use of the service; shipping address; username; state; image; profile image; house number; language; prefix; device information; purchase history; number of Users; session statistics; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific informative texts displayed before the collection of the data itself.
Personal Data may be provided freely by the User or, in the case of Usage Data, collected automatically during the use of this Website.
Unless otherwise specified, all data requested by this Website is mandatory. If the User refuses to communicate it, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who are in doubt about which Data is mandatory are encouraged to contact the Controller.
Any use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the further 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 Website and guarantees that they have the right to communicate or disseminate it, freeing the Controller from any liability towards third parties.

Methods and place of processing the collected Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

Legal basis of processing

The Owner processes Personal Data relating to the User if one of the following applies:

  • the User has given their consent for one or more specific purposes; Note: Under some legislations 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 of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is 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 to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Place

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.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Users are also entitled to learn about the legal basis of Data transfers to a country 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, and 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 inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 such 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.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

Purposes of processing the collected Data

The User Data is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as for the following purposes: Statistics, Displaying content from external platforms, Tag Management, Contacting the User, Contact management and messaging, Interaction with support and feedback platforms, Managing payments, Heat mapping and session recording, Interaction with online survey platforms, Interaction with data collection platforms and other third parties, Managing data collection and online surveys, Managing support and contact requests, Hosting and backend infrastructure, Interaction with live chat platforms, Interaction with social networks and external platforms, Privacy preference collection, Registration and authentication, Registration and authentication provided directly by this Website, Remarketing and behavioral targeting and Platform services and hosting.

For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.

 

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • Contacting the User

Mailing list or newsletter (this Website)

By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature about this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.

Personal Data processed: ZIP/Postal code; city; surname; date of birth; Usage Data; email address; physical address; country; name; phone number; province; gender; Tracking Tools.

Contact form (this Website)

By filling in the contact form with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.

Personal Data processed: ZIP/Postal code; city; Tax ID; surname; date of birth; Usage Data; email address; User ID; physical address; country; name; phone number; province; gender; Tracking Tools; various types of Data.

Contacting by phone (this Website)

Users who provided their phone number might be contacted for commercial or promotional purposes related to this Website, as well as for fulfilling support requests.

Personal Data processed: phone number.

  • Contact management and messaging

This type of service makes it possible to manage a database of email contacts, phone contacts, or any other contact information used to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

Klaviyo (Klaviyo Inc.)

Klaviyo is an email address management and message sending service provided by Klaviyo Inc.

 

To utilize the service provided by Klaviyo, the Owner typically shares information regarding the Users (who make purchases), such as contact details and purchase history. For more information regarding the scope of such sharing, please check the information provided below under the heading “Personal Data processed”.

Personal Data processed: various types of Data.

Place of processing: United States – Privacy Policy – Opt out.

Sendgrid (Sendgrid)

Sendgrid is an email address management and message sending service provided by Sendgrid Inc.

Personal Data processed: surname; date of birth; email address; name; phone number; gender.

Place of processing: United States – Privacy Policy.

  • Managing payments

Unless otherwise specified, this Website processes any payments by credit card, bank transfer, or other means via external payment service providers. In general, and unless where otherwise indicated, Users are requested to provide payment details and personal information directly to such payment service providers.
This Website is not involved in the collection and processing of such information: instead, it will only receive a notification from the relevant payment service provider as to whether payment has been successfully completed.

PayPal (Paypal)

PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.

Personal Data processed: surname; email address; billing address; name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: See the PayPal privacy policy – Privacy Policy.

Apple Pay (Apple Inc.)

Apple Pay is a payment service provided by Apple Inc., which allows Users to make online payments using their mobile phone.

Personal Data processed: surname; Usage Data; email address; billing address; shipping address; name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

Google Pay

Google Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows Users to make online payments using their Google credentials.

Personal Data processed: surname; Usage Data; email address; billing address; shipping address; name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Klarna (Klarna AB)

Klarna is a payment service provided by Klarna AB.

Personal Data processed: surname; email address; billing address; shipping address; name; phone number; various types of Data as specified in the privacy policy of the service.

Place of processing: Sweden – Privacy Policy.

Stripe ( Stripe Technology Europe Ltd)

Stripe is a payment service provided by Stripe Technology Europe Ltd.

Personal Data processed: surname; Usage Data; email address; billing address; name; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy.

  • Tag Management

This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, of which their Data may be retained.

Google Tag Manager

Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  • Managing data collection and online surveys

This type of service allows this Website to manage the creation, implementation, administration, distribution and analysis of online forms and surveys to collect, save and reuse Data from responding Users.
The Personal Data collected depends on the information requested and provided by the Users in the corresponding online form.

These services may be integrated with a wide range of third-party services to allow the Owner to take further actions with the processed Data - for example, contact management, messaging, analytics, advertising and payment processing.

Hotjar surveys (Hotjar Ltd.)

Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
Hotjar surveys may use cookies to track User behavior. Users can opt out of Hotjar surveys cookie tracking by visiting this opt-out page.

 

Hotjar surveys respects the “Do Not Track” header available in most modern browsers, which, if enabled, sends a signal to stop tracking the User's activity. Users can find information on how to enable “Do Not Track” for each supported browser here.

Personal Data processed: Data communicated while using the service.

Place of processing: Malta – Privacy Policy – Opt Out.

Klaviyo Forms (Klaviyo Inc.)

Klaviyo Forms is a form builder and data collection platform provided by Klaviyo Inc.

 

To utilize the service provided by Klaviyo, the Owner typically shares information regarding the Users (who make purchases), such as contact details and purchase history. For more information regarding the scope of such sharing, please check the information provided below under the heading “Personal Data processed”.

Personal Data processed: Data communicated while using the service.

Place of processing: United States – Privacy Policy.

  • Heat mapping and session recording

Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.

Hotjar Heat Maps & Recordings (Hotjar Ltd.)

Hotjar is a heat mapping and session recording service provided by Hotjar Ltd.
Hotjar respects generic “Do Not Track” headers. This means the browser can tell the script not to collect any data from the User. This is a setting that is available in all major browsers. More information on opting out of Hotjar is available here.

Personal Data processed: Usage Data; Tracking Tools; various types of Data as specified in the privacy policy of the service.

Place of processing: Malta – Privacy Policy – Opt Out.

  • Hosting and backend infrastructure

The purpose of these services is to host Data and files that enable this Website to run, to allow for its distribution and to provide a ready-to-use infrastructure to provide specific features of this Website.

Some of the services listed below, if any, may function on geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

SiteGround

SiteGround is a hosting service.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: Italy – Privacy Policy.

  • Interaction with live chat platforms

This type of service allows for interaction with live chat platforms hosted by third parties, directly from the pages of this Website, in order to contact and be contacted by this Website's support service.
If a service for interacting with live chat platforms is installed, it is possible that it may collect Usage Data relating to the pages where it is installed, even if Users do not use the service. Additionally, live chat conversations may be recorded.

Spotify Inbox

Spotify Inbox is a service for interacting with the Spotify live chat platform.

Personal Data processed: Data communicated during the use of the service.

Place of processing: United States – Privacy Policy.

  • Interaction with data collection platforms and other third parties

This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website for the purpose of saving and reusing data.
If one of these services is installed, it may collect Usage Data relating to the pages where it is installed, even if Users do not use the service.

  • Interaction with social networks and external platforms

This type of service allows for interaction with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired by this Website are in any case subject to the User’s privacy settings related to each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services to ensure that the data processed on this Website is not linked back to the User's profile.

PayPal button and widgets (Paypal)

The PayPal button and widgets are services for interacting with the PayPal platform, provided by PayPal Inc.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Consult the Paypal privacy policy – Privacy Policy.

LinkedIn social buttons and widgets (LinkedIn Corporation)

The LinkedIn social buttons and widgets are services for interacting with the LinkedIn social network, provided by LinkedIn Corporation.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy.

Facebook "Like" button and social widgets

The Facebook "Like" button and social widgets are services for interacting with the Facebook social network, provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

  • Collection of privacy-related preferences

This type of service allows this Website to collect and save Users' preferences regarding the collection, use, and processing of their personal information, as required by applicable privacy legislation.

iubenda Consent Solution (iubenda srl)

The iubenda Consent Solution allows for the saving and retrieval of records of User consent to the processing of Personal Data, as well as the information and preferences expressed in relation to the consent provided.
To this end, it uses a Tracking Tool that temporarily stores pending information on the User's device until it is processed by the API. The Tracking Tool (a browser feature called localStorage) is then deleted.

Personal Data processed: Data communicated during the use of the service; Tracking Tools.

Place of processing: Italy – Privacy Policy.

iubenda Cookie Solution (iubenda srl)

The iubenda Cookie Solution allows the Owner to collect and save Users' preferences regarding the processing of personal data and in particular the use of Cookies and other Tracking Tools on this Website.

Personal Data processed: Tracking Tools.

Place of processing: Italy – Privacy Policy.

  • Registration and authentication

By registering or authenticating, the User allows this Website to identify them and give them access to dedicated services.
Depending on what is indicated below, registration and authentication services may be provided with the help of third parties. If this happens, this Website may access some Data stored by the third-party service used for registration or identification.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to learn more, please refer to the description of each service.

Direct registration and profiling (this Website)

By registering or authenticating, the User allows this Website to identify them and give them access to dedicated services. The Owner may process the Data collected at the time of registration or authentication by Users for targeting and profiling purposes; to learn more, Users can contact the Owner using the contact details provided in this document.

Personal Data processed: ZIP code; Tax ID; surname; date of birth; Usage Data; email; User ID; image; profile picture; billing address; shipping address; physical address; language; house number; phone number; province; gender; country; username; various types of Data.

  • Registration and authentication provided directly by this Website

By registering or authenticating, the User allows this Website to identify them and give them access to dedicated services. Personal Data are collected and stored solely for registration or identification purposes. The Data collected is only that which is necessary to provide the service requested by the User.

Direct registration (this Website)

The User registers by filling out the registration form and providing their Personal Data directly to this Website.

Personal Data processed: ZIP code; city; Tax ID; surname; date of birth; email; User ID; image; profile picture; billing address; physical address; language; country; name; house number; phone number; area code; province; gender; state; username; various types of Data.

  • Remarketing and behavioral targeting

This type of service allows this Website and its partners to communicate, optimize, and serve advertisements based on the User's past use of this Website.
This activity is facilitated by the tracking of Usage Data and the use of Tracking Tools to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email address lists.
Generally, services of this type offer the ability to opt out of such tracking. In addition to any opt-out feature provided by any of the services listed in this document, the User can read more about how to opt out of interest-based advertising in the appropriate section "How to opt out of interest-based advertising" in this document.

Facebook Remarketing

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Klaviyo segmentation and social advertising (Klaviyo Inc.)

Klaviyo segmentation and social advertising is a remarketing and behavioral targeting service provided by Klaviyo Inc.

Klaviyo segmentation and social advertising uses tracking technology to monitor User behavior. This Data is then used to personalize the User experience and to provide targeted advertising. Klaviyo segmentation and social advertising may also connect the accumulated Data with other networks, including advertising networks, and enable these third parties to track and target the User. Unless otherwise stated in this document, the Owner has no direct relationship with the third parties that Klaviyo segmentation and social advertising may include.

To use the service provided by Klaviyo, the Owner generally shares information regarding Users (who make purchases), such as contact details and purchase history. For further information regarding the scope of such sharing, check the indications below under “Personal Data processed”.

Personal Data processed: purchase history; Usage Data; email; device information; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt out.

Facebook Custom Audience

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network.

Users can opt out of using Facebook's Tracking Tools for ad personalization by visiting this opt-out page.

Personal Data processed: email; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Remarketing with Google Analytics

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Tracking Tools with the Google Ads advertising network and the Doubleclick Cookie.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ads Remarketing

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

For an understanding of Google's use of Data, please consult Google's partner policies.

Users can opt out of using Google's Tracking Tools for ad personalization by visiting Google's Ad Settings.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  • Platform and hosting services

These services have the purpose of hosting and running key components of this Website, making it possible to provide this Website from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for e-commerce, for payment processing, etc. The use of such tools involves the collection and processing of Personal Data.
Some of these services operate through servers located in different geographic locations, making it difficult to determine the exact place where Personal Data are stored.

WordPress.com (Automattic Inc.)

WordPress.com is a platform provided by Automattic Inc. that allows the Owner to develop, operate, and host this Website.

Personal Data processed: various types of Data as specified in the privacy policy of the service.

Place of processing: United States – Privacy Policy.

  • Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.

Google Analytics

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports, and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize ads within its own advertising network.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Analytics with anonymized IP

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
This integration of Google Analytics anonymizes your IP address. The anonymization works by shortening the Users' IP address within the borders of Member States of the European Union or in other countries participating in the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to Google's servers and shortened within the United States.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Meta Events Manager (Meta Platforms Ireland Limited)

Meta Events Manager is a statistics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can provide the Owner with information about traffic and interactions on this Website.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: Ireland – Privacy Policy.

Facebook Ads conversion tracking (Facebook pixel)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Meta ad network with actions performed within this Website. The Facebook pixel tracks conversions that can be attributed to Facebook, Instagram, and Audience Network ads.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Analytics 4

Google Analytics is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its advertising network.
In Google Analytics 4, IP addresses are used at the time of collection and then deleted before the data is recorded in any data center or server. To learn more, you can consult Google's official documentation.

Personal Data processed: device information; number of Users; session statistics; Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

Google Ads conversion tracking

Google Ads conversion tracking is a statistics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads ad network with actions performed within this Website.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Google Analytics reports on demographics and interests

Google Analytics reports on demographics and interests is an advertising reporting feature that makes demographic and interest data available within Google Analytics for this Website (Demographic Data means data about age and gender).

Users can choose not to use Google cookies by visiting Google's [Ads Settings](https://adssettings.google.com/authenticated).

Personal Data processed: unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tools.

Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

  • Displaying content from external platforms

This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when users do not use it.

Google Fonts

Google Fonts is a font style visualization service managed by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to integrate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Font Awesome (Fonticons, Inc. )

Font Awesome is a font style visualization service managed by Fonticons, Inc. that allows this Website to integrate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy.

Instagram Widget

Instagram is an image visualization service managed by Meta Platforms, Inc. or by Meta Platforms Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to integrate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

YouTube Video Widget

YouTube is a video content visualization service managed by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to integrate such content into its pages.

Personal Data processed: Usage Data; Tracking Tools.

Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.

Information on how to opt out of interest-based advertising

In addition to any opt-out functionality provided by any of the services listed in this document, Users may read more about how to opt out of interest-based advertising in the appropriate section of the Cookie Policy.

Further information on the processing of Personal Data

  • Selling goods and services online

The Personal Data collected is used to provide services to the User or to sell products, including payment and any delivery. The Personal Data collected to finalize the payment may be those related to the credit card, the bank account used for the transfer, or other provided payment instruments. The payment data collected by this Website depends on the payment system used.

User Rights

Users may exercise certain rights with reference to the Data processed by the Owner.

In particular, the User has the right to:

  • withdraw consent at any time. The User may withdraw consent to the processing of their Personal Data previously expressed.
  • object to the processing of their Data. The User may object to the processing of their Data when it is carried out on a legal basis other than consent. Further details on the right to object are indicated in the section below.
  • access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing, and to receive a copy of the Data processed.
  • verify and seek rectification. The User may verify the accuracy of their Data and request its update or correction.
  • obtain the restriction of processing. When certain conditions are met, the User may request the restriction of the processing of their Data. In this case, the Owner will not process the Data for any other purpose than their storage.
  • obtain the erasure or removal of their Personal Data. When certain conditions are met, the User may request the erasure of their Data by the Owner.
  • 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 obtain its transfer without hindrance to another controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User's consent, on a contract to which the User is a party, or on contractual measures connected to it.
  • lodge a complaint. The User may lodge a complaint with the competent data protection supervisory 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 Owner, or for the purposes of a legitimate interest pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation.

Users are informed that, should their Data be processed for direct marketing purposes, they can object to that processing without providing any justification. To learn whether the Owner is processing data for direct marketing purposes, Users may refer to the respective sections of this document.

How to exercise these rights

To exercise their rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and handled by the Owner as soon as possible, in any case within one month.

Cookie Policy

This Website uses Tracking Tools. To learn more, the User can consult the Cookie Policy.

Further information on processing

Legal defense

The User’s Personal Data may be used by the Owner in court or in the stages leading to possible legal action arising from improper use of this Website or the related Services by the User.
The User declares to be aware that the Owner may be required to reveal Personal Data upon request of public authorities.

Specific information

At the User's request, in addition to the information contained in this privacy policy, this Website 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 operation and maintenance purposes, this Website and any third-party services used by it may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Website does not support “Do Not Track” requests.
To determine whether 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 its Users on this page and, if possible, on this Website and, if technically and legally feasible, by sending a notice to Users through any contact information available to the Data Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Data Controller will collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that, directly or indirectly, including in combination with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized 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 answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the visitor, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Website who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural person, legal person, public administration, and any other entity that processes personal data on behalf of the Data Controller, in accordance with the provisions of this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including the security measures related to the operation and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool by means of which the Personal Data of Users are collected and processed.

Service

The Service provided by this Website as defined in the relative terms (if present) on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.

Cookie

Cookies are Tracking Tools consisting of small portions of data stored within the User's browser.

Tracking Tool

A Tracking Tool means any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows tracking Users, for example by collecting or saving information on the User's device.

Legal references

This privacy policy is drafted on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy policy relates exclusively to this Website.

Addenda

This information is provided in the capacity of data controller (hereinafter also "Company" or "Controller") of the personal data acquired through the website, of which the same is the owner, pursuant to the privacy and data protection legislation in force and taking into account the provisions of the Italian Data Protection Authority (hereinafter, also "Garante"), Regulation (EU) 2016/679 (hereinafter also "Regulation"), Legislative Decree no. 196/2003 and subsequent amendments (hereinafter also "Privacy Code") as well as, in general, the applicable reference legislation.

This information is provided to users who browse and use the services available on the website.
Your registration on the website is subject to prior reading and acceptance of this notice regarding the processing of personal data and your authorization for the related processing.

Source and categories of processed data
The personal data that the Company may acquire will be acquired directly from the interested user who browses the website
The data processed may be, by way of example:

Browsing data
The computer systems and software procedures used to operate this website acquire, during their normal operation, some personal data whose transmission is implicit in the use of internet communication protocols. This is information that is not collected to be associated with identified subjects, but which by its very nature could allow users to be identified. This category of data includes (i) IP addresses or domain names of the computers used by users who connect to the site, (ii) URI (Uniform Resource Identifier) addresses of the resources requested, (iii) the time of the request, (iv) the method used to submit the request to the server, (v) the size of the file obtained in response, (vi) the numeric code indicating the status of the response given by the server (successful, error) and (vii) other parameters related to the user's operating system and computer environment. These data are used for the sole purpose of obtaining anonymous statistical information on the use of this website and to check its correct functioning and are deleted immediately after processing.
This Website uses technical, analytical, and profiling cookies, both its own and from third parties,

Data provided voluntarily by the user
The optional, explicit, and voluntary sending of data by the user who browses this website and interacts with it via
• The 10€ discount form for you on the page
• The site registration form, on the page
• The purchase form on the page
• The return form on the page
• The contact form on the page

entails the acquisition and processing by the Controller of such data and any other information contained in such communications for the purposes indicated in the following paragraph.
The data that may be subject to processing are mainly identifying, contact, and personal data (by way of example, name and surname, residence address, telephone number, e-mail address, etc.). In no case will personal data of a sensitive nature (pursuant to Art. 9 of the Regulation) or judicial data (pursuant to Art. 10 of the Regulation) be processed.

Furthermore, for needs related to the functioning of this website or its maintenance, system logs might be processed, i.e., files that record interactions with the user and which may also include personal data, including the user's IP address.

Complete details on each type of data collected will be provided in the dedicated sections of this privacy policy or through specific information texts that the user will be able to view before the data collection itself.

Purpose of processing
The processing of the acquired personal data is carried out for:
a) defining the authentication profile necessary to access the site and therefore allowing the user to register on it (also for the purpose of issuing the loyalty card), implementing the site's conditions of use accepted during registration, allowing the use of the services provided by this site (by way of example, the purchase of products, the shipment of purchased products, managing any returns) following user registration, for the management of any requests made by the user via the website. The provision of data is, depending on the case, a contractual obligation or a pre-contractual measure adopted at the request of the interested party, and failure to provide it makes it impossible for the Company to exactly execute what has just been outlined;
b) fulfilling obligations provided for by laws and regulations, or executing an order from the judicial authority or other authorities to which the Controller is subject. The provision of data is a legal obligation, and failure to provide it makes it impossible for the Company to exactly fulfill the obligations just outlined;
c) allowing the Controller to carry out direct marketing activities, in order to provide the user with information on promotions, discounts, benefits, events, products, and other services from the Controller, including through the sending of appropriate advertising and/or information material (e.g., catalogs) in paper and/or electronic form, by means of a newsletter (via e-mail) or other tools (e.g., SMS, instant messaging). The provision of data is optional and requires prior, free, and specific consent from the user, and failure to provide it makes it impossible for the Company to perform the marketing activities contemplated therein (and will have no negative consequence regarding the possibility of registering or browsing the website);
d) collecting, analyzing user behavior, profiling, recording, and processing purchase data, including those related to the detail of frequency, quantity, and type of purchases (even if only potential) for the purpose of analyzing purchase propensity and, in general, user profiling to prepare and propose personalized promotions and offers, as well as for market analysis and research. The provision of data is optional and requires prior, free, and specific consent from the user, and failure to provide it makes it impossible for the Company to perform the profiling activities contemplated therein (and will have no negative consequence regarding the possibility of registering or browsing the website).
e) transferring personal data to third parties operating in the [•] sector for marketing purposes, market research or other sample research, for detecting the degree of satisfaction, to receive information, promotional, commercial, and advertising material or relating to competitions and initiatives, including through the sending of appropriate material (e.g., catalogs, flyers) in paper and/or electronic form, by means of a newsletter (e-mail) or other tools (instant messaging). The provision of data is optional and requires prior, free, and specific consent from the user, and failure to provide it makes it impossible for the Company to perform the activities contemplated therein (and will have no negative consequence regarding the possibility of registering or browsing the website).
f) allowing the Controller to register, following the user's subscription to the newsletter service or after having made a purchase through this site, their e-mail address in a contact list to which e-mails containing information, including of a commercial and promotional nature, may be sent. The provision of data is optional and requires prior, free, and specific consent from the user, and failure to provide it makes it impossible for the Company to perform the activities contemplated therein (and will have no negative consequence regarding the possibility of registering or browsing the website).

Legal basis for processing
The legal basis for data processing is provided, depending on the processing, by law, by the execution of contractual obligations or pre-contractual measures adopted at the request of the interested party, as well as by the specific consent eventually given by the same.

Methods of data processing and data retention
The processing of personal data will take place mainly using computer or telematic tools, or, as regards the use of personalized services via profiling, where the relative consent is provided, the processing will take place via an automated decision-making process using a specific algorithm that will decide which communications are most suitable for the user's profile or which could be of greater interest.
In any case, with reference to all the processing referred to herein, the Controller will adopt security measures adequate to ensure the security and confidentiality of your personal data, all in compliance with the provisions of current legislation.
In carrying out the processing activities, the Company undertakes, among other things, to:
• adopt security measures suitable for guaranteeing adequate data protection, in consideration of the potential impacts that the processing entails on the fundamental rights and freedoms of the interested party;
• notify, within the times and in the cases provided for by mandatory legislation, any personal data breaches to the interested parties;
• ensure the compliance of processing operations with applicable legal provisions.
The personal data of site users will be stored for the time strictly necessary to carry out the primary purposes illustrated in this notice, or in any case as necessary for the protection of the rights of both the interests and the users and the Company and in any case, where applicable, until the withdrawal of your consent, which may take place at any time.
Specifically, the data will be processed in compliance with the timelines established within the relative procedure, to be requested at the address privacy@.com
With specific reference to the transfer of data to third parties for the aforementioned purposes, reference is made to the specific information notice drafted by such third parties pursuant to Art. 14 of the Regulation. In any case, the user is free, even in this case, to withdraw the consent given at any time.

Scope of communication of personal data
In compliance with minimum security measures, the data may also be communicated to public security subjects and to other public and private subjects for the fulfillment of obligations provided for by law.
Furthermore, personal data will not be disseminated. However, they may be communicated to the following recipients:
• to companies that the Company uses for the performance of technical and organizational tasks (by way of example but not limited to, companies that provide information system management and communication network services, maintenance and assistance related to the website);
• third-party companies operating in the reviews sector for marketing purposes;
• third-party firms or companies in the context of assistance and consulting relationships;
• third-party companies that support the data controller for the delivery/dispatch of purchases (i.e., couriers).
• third-party companies that allow the monitoring of users in a statistical and aggregated manner (e.g., GA4)
The subjects belonging to the aforementioned categories act as Data Processors, or operate in total autonomy as separate Data Controllers.

The data processing will be carried out by employees of the Controller specifically identified as authorized data processors, who have received adequate instruction.

In compliance with the requirements and guarantees established by the Regulation, the data could be transferred to countries not belonging to the European Economic Area, including for example the United States of America (USA), which do not offer a level of privacy and personal data protection comparable to that guaranteed by Italian and European laws. Such transfers may only take place in the presence of adequate guarantees or the explicit consent of the user.

Rights of the interested party
The subjects to whom the personal data refer have the right at any time to obtain confirmation of whether or not personal data concerning them are being processed and, in that case, to obtain access to the data and the information referred to in Art. 15 of the Regulation, to obtain a copy of such data or their rectification (Arts. 15 and 16 of the Regulation).
Furthermore, interested parties have the right to request deletion, limitation of processing, data portability, as well as to lodge a complaint with the supervisory authority and to object at any time, for legitimate reasons, to their processing (Art. 17 et seq. of the Regulation) as well as, more generally, to exercise all the rights recognized to them by the current legal provisions.
The possibility of denying or withdrawing the consent previously provided at any time remains without prejudice to the lawfulness of the processing based on the consent before the withdrawal.
These rights can be exercised by written communication to be sent to: [•]

DATA CONTROLLER AND PROCESSOR


A list of External Processors is available at the registered office of the Controller.

Notice regarding minors under 14 years of age
Minors under the age of 14 cannot provide personal data. The Company will not be in any way responsible for any collection of personal data, as well as false statements, provided by the minor, and in any case, should their use be detected, the Controller will facilitate the right of access and cancellation forwarded by the legal guardian or by those exercising parental responsibility.

 

To have information about your personal data collected, the purposes, and the subjects with whom the data are shared, contact the Controller.

DATA CONTROLLER

 

TYPES OF DATA COLLECTED

The Controller does not provide a list of the types of Personal Data collected.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by means of specific information texts displayed before the collection of the Data itself.
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 communicate them, it may be impossible for this Application to provide the Service. In cases where this Application indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Controller.
Any use of Cookies - or other tracking tools - by this Application or by the owners of third-party services used by this Application is intended to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Application.

METHODS AND PLACE OF PROCESSING OF COLLECTED DATA

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Personal Data.
The processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.

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, the User can check the section containing details about the processing of Personal Data.

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

This Application uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

This section applies to all Users in the European Union, pursuant to the General Data Protection Regulation ("GDPR"), and, for such Users, supersedes any other possibly diverging or conflicting information contained in the privacy policy. Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, and further information on Personal Data are available in the section "Detailed information on the processing of Personal Data" within this document.

The Owner processes Personal Data relating to the User if one of the following applies:

  • the User has given their consent for one or more specific purposes; Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such an operation (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
  • processing is necessary for compliance with a legal obligation to which the Owner is subject;
  • processing is related to a task that is 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 to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.

Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.

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 such 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 the Personal Data longer until such consent is withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.

THE RIGHTS OF USERS

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, to the extent permitted by law, Users have the right to do the following:

  • Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
  • Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
  • Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
  • Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
  • Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
  • Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
  • Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
  • Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

Users also have the right to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

Where Personal Data is processed for the public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.

Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed, unless this proves impossible or involves disproportionate effort. At the Users' request, the Owner will inform the User about those recipients.

FURTHER INFORMATION FOR USERS IN SWITZERLAND

This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly diverging or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the Personal Data, if any, the retention period, and further information on Personal Data are available in the section titled "Detailed information on the processing of Personal Data" within this document.

THE RIGHTS OF USERS UNDER THE SWISS FEDERAL ACT ON DATA PROTECTION

Users may exercise certain rights regarding their Data to the extent permitted by law, including the following:

  • the right to access Personal Data;
  • the right to object to the processing of their Personal Data (which also allows Users to request the restriction of the processing of Personal Data, the deletion or destruction of Personal Data, and the prohibition of the disclosure of Personal Data to third parties);
  • the right to receive their Personal Data and to transfer it to another controller (data portability);
  • the right to request the correction of incorrect Personal Data.

HOW TO EXERCISE THESE RIGHTS

Any requests to exercise the User’s rights can be directed to the Owner through the contact details provided in this document. These requests are free of charge and the Owner will respond as soon as possible, providing the User with the information required by law.

FURTHER INFORMATION FOR USERS IN BRAZIL

This section of the document integrates and complements the information contained in the rest of the privacy policy and is provided by the entity operating this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section collectively referred to as “we”, “our”, “us”).
This section applies to all Users in Brazil (such Users are referred to below simply as “you”, “your”), pursuant to the "Lei Geral de Proteção de Dados" (LGPD), and, for such Users, supersedes any other possibly diverging or conflicting information contained in this privacy policy.
In this part of the document, we use the term “personal information” as defined in the LGPD.

LEGAL BASES UPON WHICH WE PROCESS YOUR PERSONAL INFORMATION

We process your personal information solely when we have a legal basis for such processing. The legal bases are the following:

  • your consent for the relevant processing activities;
  • compliance with a legal or regulatory obligation that we are subject to;
  • the carrying out of tasks provided for by law or by regulations or by contracts, agreements or similar legal instruments;
  • studies conducted by research entities, preferably carried out on anonymized personal information;
  • the performance of a contract and its preliminary procedures, in cases where you are a party to such contract;
  • the exercise of our rights in judicial, administrative or arbitration procedures;
  • the protection or safety of your physical integrity or that of a third party;
  • the protection of health – in the context of procedures carried out by health experts or entities;
  • our legitimate interests, provided that your fundamental rights and liberties do not prevail over such interests; and
  • credit protection.

 

To learn more about the legal bases, you can contact us at any time using the contact details provided in this document.

CATEGORIES OF PERSONAL INFORMATION PROCESSED

To find out which categories of your personal information are processed, you can refer to the section “Detailed information on the processing of Personal Data” in this document.

WHY WE PROCESS YOUR PERSONAL INFORMATION

To find out why we process your personal information, you can refer to the sections “Detailed information on the processing of Personal Data” and “Purposes of processing the Data collected” in this document.

YOUR PRIVACY RIGHTS UNDER BRAZILIAN LAW, HOW TO FILE A REQUEST AND HOW WE WILL RESPOND

YOUR PRIVACY RIGHTS UNDER BRAZILIAN LAW

You have the right to:

  • obtain confirmation of the existence of processing activities concerning your personal information;
  • access your personal information;
  • obtain the correction of your incomplete, inaccurate or out-of-date personal information;
  • obtain anonymization, blocking or elimination of your unnecessary or excessive personal information, or information that is not being processed in compliance with the LGPD;
  • obtain information about the possibility of providing or denying your consent and the consequences thereof;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your express request, the portability of your personal information (except for anonymized information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
  • obtain the deletion of personal information processed if the processing was based on your consent, unless one or more exceptions provided for in Article 16 of the LGPD apply;
  • withdraw your consent at any time;
  • file a complaint regarding your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
  • object to processing activities in cases where the processing is not compliant with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used for automated decision-making; and
  • request the review of decisions taken solely on the basis of the automated processing of your personal information that affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.

 

You will never be discriminated against, or suffer any kind of detrimental treatment, as a result of exercising your rights.

HOW TO FILE A REQUEST

You can file an express request to exercise your rights free of charge, at any time, by using the contact details provided in this document, or via your legal representative.

HOW AND WHEN WE WILL RESPOND TO YOUR REQUEST

We will strive to respond to your requests as soon as possible.
In any case, should it be impossible for us to do so, we will make sure to communicate to you the factual or legal grounds that prevent us from immediately complying with or fulfilling your request. In cases where we are not processing your personal information, if we are able to do so, we will indicate to you the natural or legal person to whom you should address your requests.

In the event that you decide to submit a request for access or a request for confirmation of the existence of processing of personal information, please ensure that you specify whether you prefer to receive your personal information in electronic or paper format.
You must also let us know if you wish for an immediate response, in which case you will receive a simplified response, or if you require a full report.
In the latter case, we will respond within 15 days of your request, providing you with all information regarding the origin of your personal information, confirmation or otherwise of the existence of personal information concerning you, all criteria used for processing, and the purposes of such processing, while safeguarding our trade and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization, or blocking of personal information, we will ensure that we immediately inform the other parties with whom we have shared your personal information of your request so that they may also comply with your request - except in cases where such communication proves impossible or disproportionately burdensome for us.

TRANSFER OF PERSONAL INFORMATION OUTSIDE BRAZIL IN CASES PERMITTED BY LAW

We may transfer your personal information outside of Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between intelligence, investigative, and criminal prosecution bodies, as provided for by instruments made available by international law;
  • when the transfer is necessary to defend the life or physical safety of you or third parties;
  • when the transfer is authorized by the ANPD;
  • when the transfer arises from an obligation assumed in the context of an international cooperation agreement;
  • when the transfer is necessary for the exercise of public order or for the performance of a public service;
  • when the transfer is necessary for compliance with a legal obligation, the execution of a contract and related pre-contractual duties, or the regular exercise of rights in judicial, administrative, or arbitration proceedings.

 

FUTHER INFORMATION FOR CALIFORNIA CONSUMERS

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the "California Consumer Privacy Act of 2018" (the "CCPA"), as updated by the "California Privacy Rights Act" (the "CPRA") and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal information“ as defined in the California Consumer Privacy Act (CCPA/CPRA).

NOTICE AT COLLECTION

CATEGORIES OF PERSONAL INFORMATION COLLECTED, USED, SOLD, OR SHARED

In this section we summarize the categories of personal information that we've collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

INFORMATION WE COLLECT: THE CATEGORIES OF PERSONAL INFORMATION WE COLLECT

We have collected the following categories of personal information about you: .

We do not collect sensitive personal information.

We will not collect additional categories of personal information without notifying you.

WHAT ARE THE PURPOSES FOR WHICH WE USE YOUR PERSONAL INFORMATION?

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION?

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

HOW WE COLLECT INFORMATION: WHAT ARE THE SOURCES OF THE PERSONAL INFORMATION WE COLLECT?

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.

HOW WE USE THE INFORMATION WE COLLECT: DISCLOSING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES FOR A BUSINESS PURPOSE

We do not disclose your personal information to third parties. For our purposes, the word “third party” means “a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

NO SALE OF YOUR PERSONAL INFORMATION

We do not sell or share your personal information. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.

YOUR PRIVACY RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT AND HOW TO EXERCISE THEM

THE RIGHT TO ACCESS PERSONAL INFORMATION: THE RIGHT TO KNOW AND TO PORTABILITY

You have the right to request that we disclose to you:

  • the categories of personal information that we collect about you;
  • the sources from which the personal information is collected;
  • the purposes for which we use your information;
  • to whom we disclose such information;
  • the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

  • the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
  • the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be "portable", i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

THE RIGHT TO REQUEST THE DELETION OF YOUR PERSONAL INFORMATION

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

THE RIGHT TO CORRECT INACCURATE PERSONAL INFORMATION

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

THE RIGHT TO OPT OUT OF SALE OR SHARING OF PERSONAL INFORMATION AND TO LIMIT THE USE OF YOUR SENSITIVE PERSONAL INFORMATION

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

THE RIGHT OF NO RETALIATION FOLLOWING OPT-OUT OR EXERCISE OF OTHER RIGHTS (THE RIGHT TO NON-DISCRIMINATION)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

  • provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We will not respond to any request if we are unable to verify your identity and therefore confirm the personal information in our possession actually relates to you.

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

If you are an adult, you can make a verifiable request on behalf of a child under your parental authority.

You can submit a maximum number of 2 requests over a period of 12 months.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

FURTHER INFORMATION FOR VIRGINIA CONSUMERS

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act" (the "VCDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data:

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We do not share nor disclose your personal data with third parties.

SALE OF YOUR PERSONAL DATA

We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

YOUR PRIVACY RIGHTS UNDER THE VIRGINIA CONSUMER DATA PROTECTION ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

  • access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
  • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

FURTHER INFORMATION FOR COLORADO CONSUMERS

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act" (the "CPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data:

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We do not share nor disclose your personal data with third parties.
For our purposes, the word "third party" means "a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller" as defined by the VCDPA.

For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CPA.

SALE OF YOUR PERSONAL DATA

We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CPA.

Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CPA.

Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer's request for information or feedback; advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.

YOUR PRIVACY RIGHTS UNDER THE COLORADO PRIVACY ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

  • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
  • access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year.

FURTHER INFORMATION FOR CONNECTICUT CONSUMERS

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring " (also known as "The Connecticut Data Privacy Act" or the “CTDPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CTDPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data:

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We do not share nor disclose your personal data with third parties.

For our purposes, the word "third party" means "a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller." as defined by the CTDPA.

SALE OF YOUR PERSONAL DATA

We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across non affiliated websites, applications, or online services to predict consumer preferences or interests" as defined by CTDPA.

Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller's own web sites or online applications; advertisements based on the context of a consumer's current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer's request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.

YOUR PRIVACY RIGHTS UNDER THE CONNECTICUT DATA PRIVACY ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

  • access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
  • opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to one request per year.

FURTHER INFORMATION FOR UTAH CONSUMERS

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act" (the “UCPA"), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the UCPA.

CATEGORIES OF PERSONAL DATA PROCESSED

In this section, we summarize the categories of personal data that we've processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

CATEGORIES OF PERSONAL DATA WE COLLECT

We have collected the following categories of personal data:

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

WHY WE PROCESS YOUR PERSONAL DATA

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

HOW WE USE THE DATA WE COLLECT: SHARING OF YOUR PERSONAL DATA WITH THIRD PARTIES

We do not share nor disclose your personal data with third parties.

For our purposes, the word "third party" means "a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor" as defined by the UCPA.

SALE OF YOUR PERSONAL DATA

We do not sell your personal data. In case we should decide to, we will inform you beforehand and will grant your right to opt out of such sale.

For our purposes, the word "sale", "sell", or "sold" means "the exchange of personal data for monetary or other valuable consideration by a controller to a third party" as defined by the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

PROCESSING OF YOUR PERSONAL DATA FOR TARGETED ADVERTISING

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

For our purposes, the word "targeted advertising" means "displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer's activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests" as defined by UCPA.

Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller's own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer's current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer's request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”

YOUR PRIVACY RIGHTS UNDER THE UTAH CONSUMER PRIVACY ACT AND HOW TO EXERCISE THEM

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

  • access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
  • request the deletion of your personal data. You have the right to request that we delete any of your personal data.
  • obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
  • opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

HOW TO EXERCISE YOUR RIGHTS

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request. We may retain your email address to respond to your request.

If you are an adult, you can make a request on behalf of a child under your parental authority.

HOW AND WHEN WE ARE EXPECTED TO HANDLE YOUR REQUEST

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.

We do not charge a fee to respond to your request, for up to one request per year.

FURTHER INFORMATION ON PROCESSING

The User's Personal Data may be used for legal purposes by the Controller in court or in the stages leading to possible legal action arising from improper use of this Application or the related Services by the User.
The User declares to be aware that the Controller may be required to reveal personal data upon request of public authorities.

At the request of the User, in addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data.

For operation and maintenance purposes, this Application and any third-party services used by it may collect system logs, i.e., files that record interaction—which may also contain Personal Data, such as the User's IP address.

More information concerning the processing of Personal Data may be requested at any time from the Controller using the contact details.

The Controller reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Controller. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Controller shall collect new consent from the User, where required.

PERSONAL DATA (OR DATA)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

USAGE DATA

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized 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 answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's 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 which processes Personal Data on behalf of the Controller, as described in this privacy policy.

DATA CONTROLLER (OR CONTROLLER)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

THIS APPLICATION

The means by which the Personal Data of the User is collected and processed.

SERVICE

The service provided by this Application as described in the relative terms (if available) on this site/application.

EUROPEAN UNION (OR EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.


LEGAL REFERENCES

This privacy statement has been prepared based on provisions of multiple legislations.

Unless stated otherwise, this privacy policy applies exclusively to this Application.