Owner and Data Controller
Outlane s.r.l. SB - Via Varese 25/D - 21047 Saronno (VA)
Owner contact email: info@freedome.it
Types of Data collected
Among the types of Personal Data that freedome.it collects, by itself or through third parties, there are:
email address; first name; last name; Trackers; Usage Data; password; picture; Data communicated while using the service; various types of Data; precise location; coarse location; device information; session statistics; browser information; username; payment info; order ID; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
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 freedome.it.
Unless specified otherwise, all Data requested by freedome.it is mandatory and failure to provide this Data may make it impossible for freedome.it to provide its services. In cases where freedome.it 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 freedome.it or by the owners of third-party services used by freedome.it 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 freedome.it.
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 freedome.it (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, Contacting the User, Handling payments, Managing contacts and sending messages, Tag Management, Remarketing and behavioural targeting, Backup saving and management, Analytics, Displaying content from external platforms, Registration and authentication, Advertising, Hosting and backend infrastructure, Collection of privacy-related preferences, Infrastructure monitoring, User database management, Location-based interactions, Heat mapping and session recording and Interaction with live chat platforms.
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 freedome.it
Freedome.it 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 freedome.it 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 Friend Lists, Basic information, Contact email, Current City, Email, Fitness Actions, Friends' Current Cities, Friends' Interests, Gender, Groups, Interests, Likes and Photos.
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 freedome.it 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 freedome.it to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access Friend Lists; Contact email; Current City; Email; Fitness Actions; Friends' Current Cities; Friends' Interests; Gender; Groups; Interests; Likes; Photos.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; biometric information; internet information; sensorial information; inferred information.
This processing constitutes:
-
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 freedome.it, 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 freedome.it. 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.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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 freedome.it.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Facebook Lookalike Audience (Meta Platforms Ireland Limited)
Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of freedome.it or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook'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.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Criteo (Criteo SA)
Criteo is an advertising service provided by Criteo SA.
Personal Data processed: Trackers; Usage Data.
Place of processing: France – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
TikTok conversion tracking (TikTok Inc.)
TikTok conversion tracking is an analytics and behavioural targeting service provided by TikTok Inc., TikTok Information Technologies UK Limited or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects data from the TikTok advertising network with actions performed on freedome.it. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of freedome.it.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy; United Kingdom – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in the United States
-
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 freedome.it, 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: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
Facebook Analytics for Apps (Meta Platforms, Inc.)
Facebook Analytics for Apps is an analytics service provided by Meta Platforms, Inc.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Google Analytics 4 (Google Ireland Limited)
Google Analytics 4 is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of freedome.it, 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: browser information; device information; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Backup saving and management
This type of service allows the Owner to save and manage backups of freedome.it on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to freedome.it.
Backup on Google Drive (Google Ireland Limited)
Google Drive is a service to save and manage backups provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Collection of privacy-related preferences
This type of service allows freedome.it 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; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Contacting the User
Mailing list or newsletter (freedome.it)
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 freedome.it. Your email address might also be added to this list as a result of signing up to freedome.it or after making a purchase.
Personal Data processed: email address; first name.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Contact form (freedome.it)
By filling in the contact form with their Data, the User authorises freedome.it 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; first name; last name.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
-
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of freedome.it 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 freedome.it to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Google Maps widget (Google Ireland Limited)
Google Maps is a maps visualisation service provided by Google Ireland Limited that allows freedome.it to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Handling payments
Unless otherwise specified, freedome.it 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. Freedome.it 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.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: email address; last name; order ID; payment info; Trackers; username.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information.
-
Heat mapping and session recording
Heat mapping services are used to display the areas of freedome.it 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.
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable freedome.it to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of freedome.it.
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.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Linode (Linode, LLC.)
Linode is a hosting service provided by Linode, LLC.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Infrastructure monitoring
This type of service allows freedome.it 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 freedome.it.
Sentry (Functional Software, Inc. )
Sentry is a monitoring service provided by Functional Software, Inc. .
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of freedome.it, in order to contact and be contacted by freedome.it‘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.
HubSpot Chat (HubSpot, Inc.)
HubSpot Chat is a service for interacting with the HubSpot live chat platform provided by HubSpot, Inc.
Personal Data processed: email address.
Place of processing: Germany – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in California
- a Sharing in California
-
Location-based interactions
Geolocation (freedome.it)
Freedome.it may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by freedome.it.
Personal Data processed: precise location.
Category of Personal Information collected according to CCPA: geolocation data.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
- a Sharing in California
-
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
Non-continuous geolocation (freedome.it)
Freedome.it may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorisation has been provided, the User’s location data may be tracked by freedome.it.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
Personal Data processed: coarse location.
Category of Personal Information collected according to CCPA: geolocation data.
This processing constitutes:
-
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.
Mailgun (Mailgun Technologies, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun Technologies, Inc.
Personal Data processed: email address; first name; Trackers.
Place of processing: Germany – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Mailchimp (Intuit Inc.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
-
Registration and authentication
By registering or authenticating, Users allow freedome.it 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, freedome.it 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.
Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed: email address; first name; last name; password; picture; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: European Union – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information; sensorial information.
This processing constitutes:
Facebook Authentication (Meta Platforms Ireland Limited)
Facebook Authentication 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 as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
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.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
Remarketing and behavioural targeting
This type of service allows freedome.it and its partners to inform, optimise and serve advertising based on past use of freedome.it 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 Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of freedome.it 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: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Remarketing (Meta Platforms, Inc.)
Facebook Remarketing is a remarketing and behavioural targeting service provided by Meta Platforms, Inc. that connects the activity of freedome.it with the Facebook advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Custom Audience (Meta Platforms, Inc.)
Facebook Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms, Inc. that connects the activity of freedome.it with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Remarketing with Google Analytics (Google Ireland Limited)
Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Criteo Dynamic Retargeting (Criteo SA)
Criteo Dynamic Retargeting is a remarketing and behavioural targeting service provided by Criteo SA., that connects the activity of freedome.it with the Criteo advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: France – Privacy Policy – Opt Out.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in California
- a Sharing in California
TikTok Remarketing ( TikTok Information Technologies UK Limited )
TikTok Remarketing is a remarketing and behavioural targeting service provided by TikTok Information Technologies UK Limited , TikTok Inc. or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects the activity of freedome.it with the TikTok advertising network.
Personal Data processed: device information; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United Kingdom – Privacy Policy; United States – Privacy Policy; Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
-
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
-
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on freedome.it 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: Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
-
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to freedome.it, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving freedome.it.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on freedome.it.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
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 freedome.it depends on the payment system used.
Cookie Policy
Freedome.it 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.
Further information for Users
in Switzerland
This section applies to Users in Switzerland, and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.
Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of the personal data, if any, the retention period and further information about Personal Data can be found in the section titled “Detailed information on the processing of Personal Data” within this document.
The rights of Users according to the Swiss Federal Act on Data Protection
Users may exercise certain rights regarding their Data within the limits of law, including the following:
- right of access to Personal Data;
- right to object to the processing of their Personal Data (which also allows Users to demand that processing of Personal Data be restricted, Personal Data be deleted or destroyed, specific disclosures of Personal Data to third parties be prohibited);
- right to receive their Personal Data and have it transferred to another controller (data portability);
- right to ask for incorrect Personal Data to be corrected.
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, providing Users with the information required by law.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running freedome.it and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
-
Identifiers
Personal Information collected or disclosed:
About Me, Groups, Interests, Friends' Interests, Likes, Current City, Friends' Current Cities, Photos, Email, Access Friend Lists, Contact email, Gender, email address, first name, last name, Trackers, various types of Data as specified in the privacy policy of the service, picture, order ID, Usage Data, device information, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Sensitive Personal Information collected or disclosed ℹ️:
Fitness Actions, password, username, payment info
Purposes:
- Access to third-party accounts
- Contacting the User
- Managing contacts and sending messages
- Remarketing and behavioural targeting
- Registration and authentication
- User database management
- Interaction with live chat platforms
- Handling payments
- Advertising
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc., Mailgun Technologies, Inc., Intuit Inc., Auth0, Inc, HubSpot, Inc., PayPal Inc., TikTok Inc., TikTok Information Technologies UK Limited
Service providers or contractors: freedome.it
-
Biometric information
Personal Information collected or disclosed:
About Me, Groups, Interests, Friends' Interests, Likes, Current City, Friends' Current Cities, Photos, Email, Access Friend Lists, Contact email, Gender
Sensitive Personal Information collected or disclosed ℹ️:
Fitness Actions
Purposes:
- Access to third-party accounts
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc.
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
About Me, Groups, Interests, Friends' Interests, Likes, Current City, Friends' Current Cities, Photos, Email, Access Friend Lists, Contact email, Gender, various types of Data as specified in the privacy policy of the service, email address, Trackers, first name, Usage Data, last name, picture, Data communicated while using the service, various types of Data, device information, session statistics, browser information, order ID, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example)
Sensitive Personal Information collected or disclosed ℹ️:
Fitness Actions, password, username, payment info
Purposes:
- Access to third-party accounts
- Handling payments
- Managing contacts and sending messages
- Tag Management
- Remarketing and behavioural targeting
- Backup saving and management
- Analytics
- Displaying content from external platforms
- Registration and authentication
- Advertising
- Hosting and backend infrastructure
- Collection of privacy-related preferences
- Further information about Personal Data
- Infrastructure monitoring
- Heat mapping and session recording
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc., Stripe Inc, Mailgun Technologies, Inc., Google Ireland Limited, Auth0, Inc, Meta Platforms Ireland Limited, Amazon Web Services, Inc., Linode, LLC., iubenda srl, Functional Software, Inc. , HubSpot, Inc., Microsoft Corporation, Criteo SA, PayPal Inc., TikTok Inc., TikTok Information Technologies UK Limited
Service providers or contractors: freedome.it
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
About Me, Groups, Interests, Friends' Interests, Likes, Current City, Friends' Current Cities, Photos, Email, Access Friend Lists, Contact email, Gender, email address, first name, last name, various types of Data as specified in the privacy policy of the service, picture, Trackers
Sensitive Personal Information collected or disclosed ℹ️:
Fitness Actions, password
Purposes:
- Access to third-party accounts
- Registration and authentication
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc., Auth0, Inc
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
About Me, Groups, Interests, Friends' Interests, Likes, Current City, Friends' Current Cities, Photos, Email, Access Friend Lists, Contact email, Gender
Sensitive Personal Information collected or disclosed ℹ️:
Fitness Actions
Purposes:
- Access to third-party accounts
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc.
-
Geolocation data
Personal Information collected or disclosed:
coarse location
Sensitive Personal Information collected or disclosed ℹ️:
precise location
Purposes:
- Location-based interactions
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Service providers or contractors: freedome.it
-
Commercial information
Personal Information collected or disclosed:
Trackers, last name, email address, order ID
Sensitive Personal Information collected or disclosed ℹ️:
username, payment info
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: PayPal Inc.
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use freedome.it.
For example, you directly provide your Personal Information when you submit requests via any forms on freedome.it. You also provide Personal Information indirectly when you navigate freedome.it, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of freedome.it and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.
In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data
* Note that in some states like Minnesota you have the following specific rights connected to profiling:
- The right to question the results of the profiling;
- The right to be informed of the reason that the profiling resulted in the decision; if feasible
- The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
- The right to review personal data used in the profiling;
- If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
Additional rights for users residing in Utah and Iowa
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on freedome.it.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
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 freedome.it 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, freedome.it 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, freedome.it and any third-party services may collect files that record interaction with freedome.it (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 freedome.it 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)
/ Personal Information (or Information)
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.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through freedome.it (or third-party services employed in freedome.it), which can include: the IP addresses or domain names of the computers utilised by the Users who use freedome.it, 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 freedome.it 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 freedome.it. The Data Controller, unless otherwise specified, is the Owner of freedome.it.
freedome.it (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by freedome.it as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioural advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
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 statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to freedome.it, if not stated otherwise within this document.