Owner and Data Controller
Paolo La Montagna - Corso Resistenza, 227 - 80011 Acerra (NA) - Italy
Owner contact email: paolo@thinkborderless.co
Types of Data collected
Among the types of Personal Data that thinkborderless.co collects, by itself or through third parties, there are:
Tracker; Usage Data; email address; first name; last name; country; city; website; various types of Data; username; answers to questions; name; social media accounts ; Data communicated while using the service; profile picture; language; device information; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated in order to use the Service.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using thinkborderless.co.
Unless specified otherwise, all Data requested by thinkborderless.co is mandatory and failure to provide this Data may make it impossible for thinkborderless.co to provide its services. In cases where thinkborderless.co specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by thinkborderless.co or by the owners of third-party services used by thinkborderless.co serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through thinkborderless.co.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational 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 thinkborderless.co (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 Owner at any time.
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.
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.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The purposes of processing
The Data concerning the User 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 the following:
Access to third-party accounts, Analytics, Displaying content from external platforms, Tag Management, Contacting the User, Interaction with external social networks and platforms, Content commenting, Managing contacts and sending messages, Handling payments, Handling activities related to productivity, Managing data collection and online surveys, Managing landing and invitation pages, Collection of privacy-related preferences, Registration and authentication, Registration and authentication provided directly by thinkborderless.co, Advertising, Content performance and features testing (A/B testing) and Traffic optimisation and distribution.
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”.
Facebook permissions asked by thinkborderless.co
Thinkborderless.co may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows thinkborderless.co to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
About Me, Access private data, Basic information, Contact email, Current City, Email, Photos and Website.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows thinkborderless.co to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorisation by the User.
Facebook account access (Meta Platforms, Inc.)
This service allows thinkborderless.co to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access private data; Contact email; Current City; Email; Photos; Website.
Place of processing: United States – Privacy Policy.
Linkedin account access (LinkedIn Corporation)
This service allows thinkborderless.co to connect with the User's account on Linkedin, provided by LinkedIn Corporation.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter account access (X Corp.)
This service allows thinkborderless.co to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data processed: email address; first name; last name; Tracker; username.
Place of processing: United States – Privacy Policy.
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Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on thinkborderless.co, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers for identifying Users, behavioural retargeting i.e. displaying ads tailored to the User’s interests and behaviour, or to measure ads performance. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on thinkborderless.co. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on thinkborderless.co.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on thinkborderless.co. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of thinkborderless.co.
Users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Universal Analytics) (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of thinkborderless.co, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics) with anonymised IP (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of thinkborderless.co, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for thinkborderless.co (demographics means age and gender Data).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: Ireland – Privacy Policy – Opt Out.
Wordpress Stats
Wordpress Stats is an analytics service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Analytics 4
Google Analytics 4 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 utilizes the Data collected to track and examine the use of thinkborderless.co, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: city; Trackers.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Collection of privacy-related preferences
This type of service allows thinkborderless.co to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Solution (iubenda srl)
The iubenda Consent Solution allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; Tracker.
Place of processing: Italy – Privacy Policy.
iubenda Cookie Solution (iubenda srl)
The iubenda Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information and in particular to the use of Cookies and other Trackers on thinkborderless.co.
Personal Data processed: Tracker.
Place of processing: Italy – Privacy Policy.
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Contacting the User
Mailing list or newsletter (thinkborderless.co)
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 concerning thinkborderless.co. Your email address might also be added to this list as a result of signing up to thinkborderless.co or after making a purchase.
Personal Data processed: city; country; email address; first name; last name; Tracker; website.
Contact form (thinkborderless.co)
By filling in the contact form with their Data, the User authorises thinkborderless.co 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: city; country; email address; first name; last name; various types of Data; website.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of thinkborderless.co.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Facebook Comments (Facebook Ireland Ltd)
Facebook Comments is a content commenting service provided by Facebook Ireland Ltd enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of thinkborderless.co.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("Google").
Google may use Personal Data to contextualise and personalise the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of thinkborderless.co 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 Ireland Limited)
Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows thinkborderless.co to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
YouTube IFrame Player (Google Ireland Limited)
YouTube IFrame Player is a video content visualisation service provided by Google Ireland Limited that allows thinkborderless.co to incorporate content of this kind on its pages.
Through this Service, thinkborderless.co may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.
Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Data communicated in order to use the Service; Data communicated while using the service; Tracker.
Place of processing: Ireland – Privacy Policy – Opt out.
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualisation service provided by Google Ireland Limited that allows thinkborderless.co to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Handling activities related to productivity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Gmail
Gmail is a service that manages email communication provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.
Personal Data processed: city; country; email address; first name; last name; Tracker.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Handling payments
Unless otherwise specified, thinkborderless.co processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. Thinkborderless.co isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: email address; first name; last name; various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of thinkborderless.co.
The interaction and information obtained through thinkborderless.co are always subject to the User’s privacy settings for 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 in order to make sure that the processed data on thinkborderless.co isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook Ireland Ltd)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook Ireland Ltd
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information 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.
ConvertKit (ConvertKit LLC)
ConvertKit is an email address management and message sending service provided by ConvertKit LLC.
Personal Data processed: email address; first name; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: country; email address; first name; last name; Tracker.
Place of processing: United States – Privacy Policy.
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Managing data collection and online surveys
This type of service allows thinkborderless.co to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Data provided via online forms, managed directly (thinkborderless.co)
Thinkborderless.co makes use of online forms that can be used to collect Data about Users.
Personal Data processed: answers to questions; city; country; name; social media accounts ; Tracker.
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Mailchimp Landing Page (Intuit Inc.)
Mailchimp Landing Page is a landing page management service provided by Intuit Inc, that allows thinkborderless.co to collect the email addresses of Users interested in its service.
Mailchimp Landing Page allows the Owner to track and analyse the User response concerning web traffic or behaviour regarding changes to the structure, text or any other component of the created landing pages.
Personal Data processed: country; email address; first name; last name; Tracker.
Place of processing: United States – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow thinkborderless.co to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, thinkborderless.co will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Facebook Authentication (Facebook Ireland Ltd)
Facebook Authentication is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Facebook Oauth (Facebook Ireland Ltd)
Facebook Oauth is a registration and authentication service provided by Facebook Ireland Ltd and is connected to the Facebook social network.
Personal Data processed: Tracker; various types of Data.
Place of processing: Ireland – Privacy Policy.
Linkedin OAuth (LinkedIn Corporation)
Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Log In with PayPal (PayPal Inc.)
Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Twitter OAuth (X Corp.)
Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Registration and authentication provided directly by thinkborderless.co
By registering or authenticating, Users allow thinkborderless.co to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (thinkborderless.co)
The User registers by filling out the registration form and providing the Personal Data directly to thinkborderless.co.
Personal Data processed: city; country; email address; first name; language; last name; profile picture; Tracker; various types of Data; website.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on thinkborderless.co in a centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Traffic optimisation and distribution
This type of service allows thinkborderless.co to distribute their content using servers located across different countries and to optimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between thinkborderless.co and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through thinkborderless.co, i.e., communication between thinkborderless.co and the User's browser, while also allowing analytical data from thinkborderless.co to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Bunny CDN (BunnyWay d.o.o.)
Bunny CDN is a traffic optimization and distribution service provided by BunnyWay d.o.o.
Personal Data processed: Usage Data.
Place of processing: Slovenia – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie
Policy.
Further information about the processing of Personal Data
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through thinkborderless.co to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Preference Cookies
Preference Cookies store the User preferences detected on thinkborderless.co in the local domain such as, for example, their timezone and region.
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Personal Data collected through sources other than the User
The Owner of thinkborderless.co may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
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User identification via a universally unique identifier (UUID)
Thinkborderless.co may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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Unique device identification
Thinkborderless.co may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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Equal protection of User Data
Thinkborderless.co shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.
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Push notifications
Thinkborderless.co may send push notifications to the User to achieve the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for thinkborderless.co, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of thinkborderless.co.
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Push notifications based on the User's geographic location
Thinkborderless.co may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of thinkborderless.co.
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
Thinkborderless.co may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
Thinkborderless.co adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within thinkborderless.co, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by thinkborderless.co depends on the payment system used.
Cookie Policy
Thinkborderless.co uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- 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.
Further information about 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 fulfil 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 based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- 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 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 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 are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation 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 enquire with the Owner using the information provided in the contact section.
Details about the right to object to processing
Where Personal Data is processed for a 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.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered 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 them about those recipients.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of thinkborderless.co or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, thinkborderless.co may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, thinkborderless.co and any third-party services may collect files that record interaction with thinkborderless.co (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within thinkborderless.co and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. 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 Owner shall collect new consent from the User, where required.
Definitions and legal references
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 thinkborderless.co (or third-party services employed in thinkborderless.co), which can include: the IP addresses or domain names of the computers utilised by the Users who use thinkborderless.co, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised 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 thinkborderless.co 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 Owner)
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 thinkborderless.co. The Data Controller, unless otherwise specified, is the Owner of thinkborderless.co.
thinkborderless.co (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by thinkborderless.co as described in the relative terms (if available) and 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.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to thinkborderless.co, if not stated otherwise within this document.