Privacy Policy of ACBC SRL società Benefit

This Application collects some Personal Data from its Users.


This document can be printed for reference by using the print command in the settings of any browser.

Owner and Data Controller

ACBC SRL società Benefit - Via Guido Cavalcanti, 5 - 20127 Milano (Italia)

Owner contact email: info@acbc.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address; Tracker; Usage Data; various types of Data; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Universally unique identifier (UUID); device information; Data communicated while using 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 this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application 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 this Application or by the owners of third-party services used by this Application 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, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application.

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 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 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

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.

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: Platform services and hosting, Handling payments, Analytics, Tag Management, Displaying content from external platforms, Managing data collection and online surveys, Interaction with external social networks and platforms, Interaction with data collection platforms and other third parties, Interaction with online survey platforms, Heat mapping and session recording, Advertising, Beta Testing, Remarketing and behavioural targeting, Content performance and features testing (A/B testing), SPAM protection, Hosting and backend infrastructure, Access to third-party accounts, Managing contacts and sending messages, Infrastructure monitoring, Contacting the User, Interaction with live chat platforms and Registration and authentication.

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:

  • Access to third-party accounts

    This type of service allows this Application 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.

    Google Drive account access

    This service allows this Application to connect with the User's account on Google Drive, provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

    Personal Data processed: Tracker.

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

  • 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 this Application, 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 to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Application. 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.

    Viralize (Viralize Srl)

    Viralize is an advertising service provided by Viralize Srl.

    Personal Data processed: Tracker; Usage Data.

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

    Google Ad Manager

    Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
    In order to understand Google's use of Data, consult Google's partner policy.
    This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behaviour concerning ads, products and services offered.  

    Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

    Personal Data processed: Tracker; Usage Data.

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

    Query Click (Query Click Limited)

    Query Click is an advertising service provided by Query Click Limited.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United Kingdom – Privacy Policy.

    Shopalyst (Shopalyst Inc)

    Shopalyst is an advertising service provided by Shopalyst Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Jetpack (Jetpack Digital LLC)

    Jetpack is an advertising service provided by Jetpack Digital LLC.

    Personal Data processed: Tracker; Usage Data.

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

    VIADS ADVERTISING (VIADS ADVERTISING S.L.)

    VIADS ADVERTISING is an advertising service provided by VIADS ADVERTISING S.L.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Spain – Privacy Policy.

    Google DV360

    Google DV360 is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to manage and plan advertising campaigns. This includes designing the ads, displaying them to the right targeted audience, bidding through automated decision-making tools (called "automated bidding") and measuring the campaign's performance.
    Users may decide to disable the ad personalization Trackers by going to: Google Ad Settings.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Tracker; Usage Data.

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

    Google Ads Similar audiences

    Similar audiences is an advertising and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behaviour to Users who are already on the remarketing list due to their past use of this Application.
    On the basis of this Data, personalised ads will be shown to Users suggested by Google Ads Similar audiences.

    Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Tracker; Usage Data.

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

    Meta Audience Network (Meta Platforms Ireland Limited)

    Meta Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Meta's use of Data, consult Meta's data policy.

    This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings.

    Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

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

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

    Meta Lookalike Audience (Meta Platforms Ireland Limited)

    Meta Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Meta's Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the basis of their past use of this Application or engagement with relevant content across Meta's apps and services.
    On the basis of these Data, personalised ads will be shown to Users suggested by Meta Lookalike Audience.

    Users can opt out of Meta's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: Trackers; Usage Data.

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

  • 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.

    Matomo (this Application)

    Matomo is an analytics software used by this Application to analyse data directly without the help of third parties.

    Personal Data processed: Tracker; Usage Data.

    Google Ads conversion tracking

    Google Ads conversion tracking is an analytics 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 advertising network with actions performed on this Application.

    Personal Data processed: Tracker; Usage Data.

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

    Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)

    Hotjar is an analytics service provided by Hotjar Ltd.
    Hotjar honours generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

    Personal Data processed: Tracker; Usage Data.

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

    Twitter Ads conversion tracking (X Corp.)

    Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Application.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Google Analytics with anonymised 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 utilises the Data collected to track and examine the use of this Application, 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.

    Personal Data processed: Tracker; Usage Data.

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

    Google Analytics Advertising Reporting Features

    Google Analytics on this Application has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).

    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); various types of Data as specified in the privacy policy of the service.

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

    Adgoon conversion tracking (Reklame S.r.l.)

    Adgoon conversion tracking is an analytics service provided by Reklame S.r.l. that connects data from the Adgoon advertising network with actions performed on this Application.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: Italy – Privacy Policy.

    Demandbase conversion tracking (Demandbase Ltd.)

    Demandbase conversion tracking is an analytics service provided by Demandbase Ltd. that connects data from the Demandbase advertising network with actions performed on this Application.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy – https://www.demandbase.com/privacy-policy/#information-choices.

    Google Analytics Demographics and Interests reports

    Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Application (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: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.

    Outbrain conversion tracking (Outbrain pixel) (Outbrain Inc.)

    Outbrain conversion tracking (Outbrain pixel) is an analytics service provided by Outbrain Inc. that connects data from the Outbrain advertising network with actions performed on this Application.

    Personal Data processed: device information; Tracker; Universally unique identifier (UUID); Usage Data.

    Place of processing: United States – Privacy Policy.

    Facebook Ads conversion tracking (Facebook pixel)

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

    Personal Data processed: Tracker; Usage Data.

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

    Google Floodlight conversion tracking (Floodlight tag)

    Google Floodlight conversion tracking (Floodlight tag) is an analytics 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 advertising services (i.e. Search Ads 360 and Campaign Manager 360) with actions performed on this Application. Depending on the setup of the service, such Data might also be used for retargeting purposes.

    Personal Data processed: Tracker; Usage Data.

    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 an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Beta Testing

    This type of service makes it possible to manage User access to this Application, or parts of it, for the purpose of testing a certain feature or the entire Application.
    The service provider may automatically collect data related to crashes and statistics related to the User's use of this Application in a personally identifiable form.

    Google Play Beta Testing

    Google Play Beta Testing is a beta testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

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

  • Contacting the User

    Contact form (this Application)

    By filling in the contact form with their Data, the User authorises this Application 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: email address.

  • 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 this Application.

    Google Optimize

    Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("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: United States – Privacy Policy; Ireland – Privacy Policy.

    Visual Website Optimizer (Wingify)

    Visual Website Optimizer is an A/B testing service provided by Wingify Inc.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Google Optimize 360

    Google Optimize 360 is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").

    This service allows the Owner to target groups of Users on the base of their past use of this Application. Users that opt-out of tracking by Google Analytics will not be included in experiments created in Google Optimize 360.

    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: United States – Privacy Policy; Ireland – Privacy Policy.

  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of this Application 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 typeface visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

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

    Google Site Search with AdSense

    Google Site Search is a search engine embedding service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Application to incorporate content of this kind on its pages.

    Google Site Search may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.

    Personal Data processed: Tracker; Usage Data.

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

    Font Awesome (Fonticons, Inc. )

    Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy Policy.

  • Handling payments

    Unless otherwise specified, this Application 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. This Application 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: various types of Data as specified in the privacy policy of the service.

    Place of processing: See the PayPal privacy policy – 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: various types of Data as specified in the privacy policy of the service.

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

    PayPal Payments Hub (PayPal Inc.)

    PayPal Payments Hub is a payment service provided by PayPal Inc.

    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.

    PayPal Carrier Payments (PayPal Inc.)

    PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile phone operator.

    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.

  • Heat mapping and session recording

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

    Hotjar Heat Maps & Recordings (Hotjar Ltd.)

    Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
    Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

    Personal Data processed: Tracker; Usage Data; 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

    This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.

    Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Google BigQuery

    Google BigQuery is a hosting and backend service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.

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

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

  • Infrastructure monitoring

    This type of service allows this Application to monitor the use and behaviour of its components so its performance, operation, maintenance and troubleshooting can be improved.
    Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Application.

    Datadog (Datadog, Inc.)

    Datadog is a monitoring service provided by Datadog, Inc.
    The way Datadog is integrated means that it filters all traffic of this Application, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Application 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; Germany – 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 Application for the purpose of saving and reusing data.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

    Hotjar Recruit User Testers (Hotjar Ltd.)

    The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd.
    Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

    Personal Data processed: Tracker; Usage Data; various types of Data.

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

  • 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 this Application.
    The interaction and information obtained through this Application 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 this Application isn’t being connected back to the User’s profile.

    PayPal button and widgets (PayPal Inc.)

    The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.

    Personal Data processed: Tracker; Usage Data.

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

    Google Friend Connect

    Google Friend Connect is a social interaction service provided by Google LLC or by Google Ireland Limited, 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.

    Facebook Like button and social widgets (Meta Platforms Ireland Limited)

    The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms Ireland Limited

    Personal Data processed: Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Interaction with live chat platforms

    This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.

    Facebook Messenger Customer Chat (Meta Platforms Ireland Limited)

    The Facebook Messenger Customer Chat is a service for interacting with the Messenger instant messaging app and platform provided by Meta Platforms Ireland Limited.

    Personal Data processed: Data communicated while using the service; Trackers; Usage Data.

    Place of processing: Ireland – Privacy Policy.

  • Interaction with online survey platforms

    This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Application.
    If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.

    Hotjar Poll & Survey widgets (Hotjar Ltd.)

    The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform provided by Hotjar Ltd.
    Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.

    Personal Data processed: Tracker; Usage Data; various types of Data.

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

  • 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.

    Klaviyo (Klaviyo Inc.)

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

    To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

    Personal Data processed: various types of Data.

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

  • Managing data collection and online surveys

    This type of service allows this Application 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.

    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 behaviour. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.

    Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.

    Personal Data processed: Tracker.

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

    Meta lead ads (Meta Platforms Ireland Limited)

    Meta lead ads is an advertising and data collection service provided by Meta Platforms Ireland Limited that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.

    Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.

    Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.

    Personal Data processed: Trackers.

    Place of processing: Ireland – Privacy Policy – Opt out.

  • Platform services and hosting

    These services have the purpose of hosting and running key components of this Application, therefore allowing the provision of this Application from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
    Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

    Shopify

    Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.

    Personal Data processed: email address.

    Place of processing: Canada – Privacy Policy; Singapore – Privacy Policy.

  • Registration and authentication

    By registering or authenticating, Users allow this Application 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, this Application 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 Oauth (Meta Platforms Ireland Limited)

    Facebook Oauth is a registration and authentication service provided by Meta Platforms Ireland Limited and is connected to the Facebook social network.

    Personal Data processed: Trackers; various types of Data.

    Place of processing: Ireland – Privacy Policy.

  • Remarketing and behavioural targeting

    This type of service allows this Application and its partners to inform, optimise and serve advertising based on past use of this Application by the User.
    This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity.
    Some services offer a remarketing option based on email address lists.
    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.

    Google Ad Manager Audience Extension

    Google Ad Manager Audience Extension is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.

    In order to understand Google's use of Data, consult Google's partner policy.

    Personal Data processed: Tracker; Usage Data.

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

    Google Ads Remarketing

    Google Ads Remarketing is a remarketing and behavioural 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 Application with the Google Ads advertising network and the DoubleClick Cookie.

    In order to understand Google's use of Data, consult Google's partner policy.

    Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.

    Personal Data processed: Tracker; Usage Data.

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

    Google Signals

    This Application uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Application with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalisation. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymised insights into Users' cross device behaviours.

    If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.

    Personal Data processed: Tracker; Usage Data.

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

    Meta Custom Audience (Meta Platforms Ireland Limited)

    Meta Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network.

    Users can opt out of Meta's use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: email address; Trackers.

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

    Facebook Remarketing (Meta Platforms Ireland Limited)

    Facebook Remarketing is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network.

    Personal Data processed: Trackers; Usage Data.

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

  • SPAM protection

    This type of service analyses the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

    Google reCAPTCHA

    Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
    The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

    Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.

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

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Application 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 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: Tracker.

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

  • 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 this Application depends on the payment system used.

This Application uses Trackers. To learn more, the User 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. 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.

Further information about retention time

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.

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.

The rights of Users

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 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.

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. These requests can be exercised 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 this Application 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, this Application 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, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

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 this Application 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.

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 utilised by the Users who use this Application, 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 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 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 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) 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 this Application, if not stated otherwise within this document.

Latest update: 16 March 2023

iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

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