Owner and Data Controller
GOTTIFREDI MAFFIOLI S.r.l.
Via E. Wild, 2/c - 4
28100 Novara (Italy)
Owner contact email: gm@gottifredimaffioli.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; first name; last name; Cookies; Usage Data; Data communicated while using the service; gender; date of birth; phone number; address; username; company name; country; various types of Data; profession; device information; password; geographic position; VAT Number; Tax ID; state; number of employees; website; fax number; county; ZIP/Postal code; city; field of activity; User ID.
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.
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 unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the 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:
Access to third-party accounts, Advertising, Analytics, Remarketing and behavioral targeting, Tag Management, Hosting and backend infrastructure, Managing landing and invitation pages, Managing contacts and sending messages, Heat mapping and session recording, Managing data collection and online surveys, Data transfer outside the EU and Contacting the User.
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 this Application
This Application 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 this Application 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:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
About Me
Provides access to the 'About Me' section of the profile.
Access Friend Lists
Provides access to any friend lists the User created.
Access Page CTA
Provides the access to manage call to actions on User-managed Pages.
Access private data
Access the User's and friends' private data.
Access Requests
Provides read access to the User's friend requests.
Activities
Provides access to the User's list of activities.
App Notifications
Send notifications.
Birthday
Provides access to the birthday.
Books Actions
Shows when the User has rated, read, quoted from or has said they want to read a book with the app.
Business Management API
Read and write with Business Management API.
Chat
Provides applications that integrate with Facebook Chat the ability to log in Users.
Checkins
Provides read access to the authorized User's check-ins.
Contact email
Access the User's contact email address.
Create Events
Enables the application to create and modify events on the User's behalf.
Create notes
Add or modify notes.
Current City
Provides access to the User's current location.
Custom Friend Lists Access
Provides access to the names of custom lists the User has created to organize their friends.
Custom User Actions
Allows the app retrieve the actions published by another application as specified by the app namespace.
Deals
Read the deal activity.
Education History
Provides access to education history.
Email
Provides access to the User's primary email address.
Events
Provides access to the list of events the User is attending.
Export Posts
Export the posts and make them public. All posts will be exported, including status updates.
Family Members and Relationship Status
Provides access to the User's family and personal relationships and relationship status.
Fitness Actions
Shows the User's workout with the app.
Friend subscriptions
Provides access to the User's friends subscriptions associated with the app.
Friends' About Me
Provides access to the 'About Me' section of the friends' profile.
Friends' Activities
Provides access to the friends' list of activities.
Friends' birthdays
Provides access to the friends' birthdays.
Friends' Checkins
Provides read access to the friends' check-ins that the User can see.
Friends' Current Cities
Provides access to the friends' current locations.
Friends' Custom User Actions
Allows the app to retrieve the actions published by another application as specified by the app namespace.
Friends' Education History
Provides access to friends' education history.
Friends' Events
Provides access to the list of events the friends are attending.
Friends' Family Members and Relationship Status
Provides access to a friend's family and personal relationships and relationship status.
Friends' Games and App Activity
Allows the app post and retrieve game achievement activity.
Friends' Groups
Provides access to the list of groups the User's friends are a members of.
Friends' Hometown
Provides access to the friends' hometown.
Friends' Interests
Provides access to the friends' lists of interests.
Friends' Likes
Provides access to the list of all of the pages the friends have liked.
Friends' music.listens Actions
Allows the app to retrieve the actions published by all applications using the built-in music.listens action.
Friends' news.read Actions
Allows the app to retrieve the actions published by all applications using the built-in news.reads action.
Friends' Notes
Provides access to the friends' notes.
Friends' Online Presence
Provides access to the User's friend's online/offline presence.
Friends' Photos
Provides access to the photos the friends have uploaded, and photos the friends have been tagged in.
Friends' Questions
Provides access to the questions the friends have asked.
Friends' Religious and Political Views
Provides access to the friends' religious and political affiliations.
Friends' Significant Others and Relationship Details
Provides access to the friends' relationship preferences.
Friends' Statuses
Provides access to the friends' status messages and checkins.
Friends' video.watches Actions
Allows the app to retrieve the actions published by all applications using the built-in video.watches action.
Friends' Videos
Provides access to the videos the friends have uploaded and have been tagged in.
Friends' Websites
Provides access to the friends' web site URLs.
Friends' Work History
Provides access to a friend's work history.
Games and App Activity
Allows the app post and retrieve game achievement activity.
Gender
Provides access to the User's gender.
Groups
Provides access to the list of groups the User is a member of.
Hometown
Provides access to the User's hometown.
Insights
Provides read access to the Insights data for pages, applications, and domains the user owns.
Interests
Provides access to the User's list of interests.
Likes
Provides access to the list of all of the pages the User has liked.
List of Friends
Provides access to the User's list of friends that also use said app.
Manage Advertisements
Provides the ability to manage ads and call the Facebook Ads API on behalf of a User.
Manage Friend Lists
Enables the app to create, delete and edit the User's friend lists.
Manage Groups
Manage the User's groups.
Manage Mailbox
Read and send messages from the User's mailbox.
Manage Notifications
Enables the app to read notifications and mark them as read.
Manage Pages
Enables the application to retrieve access_tokens for Pages and Applications that the User administrates.
Mobile Messaging on behalf of Page
Send and receive mobile messages on behalf of a Facebook Page.
music.listen Action
Allows the app to retrieve the actions published by all applications using the built-in music.listens action.
News Feed and Wall
Provides access to all the posts in the User's News Feed and enables the application to perform searches against the User's News Feed.
news.read Actions
Allows the app to retrieve the actions published by all applications using the built-in news.reads action.
Notes
Provides access to the User's notes.
Offline Access
Access the data when the User is not using the application.
Online Presence
Provides access to the User's online/offline presence.
Page Messaging
Send and receive messages through a Facebook Page.
Photos
Provides access to the photos the User has uploaded, and photos the User has been tagged in.
Post Likes to my Wall
Publish stories about things the User Likes to the Wall.
Publish App Activity
Allows the app to publish to the Open Graph using Built-in Actions, Achievements, Scores, or Custom Actions. The app can also publish other activity which is detailed in the Facebook's Publishing Permissions document.
Publish as Page
Enables the ability to post, comment and like as any of the Pages managed by the User.
Publish Checkins
Enables the app to perform checkins on behalf of the User.
Publish to the Wall
Enables the app to post content, comments, and likes to a User's stream and to the streams of the User's friends.
Questions
Provides access to the questions the User has asked.
Read Group Content
Lets the app read content in a group managed by the User.
Read Mailbox
Provides the ability to read from a user's Facebook Inbox.
Read page mailbox
Lets the app read from the page inboxes of the pages managed by the User.
Religious and Political Views
Provides access to the User's religious and political affiliations.
RSVP to Events
Enables the application to RSVP to events on the User's behalf.
Share
Share items on the User's behalf.
Show List of Managed Pages
Provides the access to show the list of the Pages that the User manages.
Significant Other and Relationship Details
Provides access to the User's relationship preferences.
Status
Provides access to the User's status messages and checkins.
Status Updates
Update the User's status.
Tagged Places
Provides access to the places the User has been tagged at in photos, videos, statuses and links.
Text Messaging
Send SMS messages to the User's phone.
Upload Photos
Add or modify user's photos.
User subscriptions
Provides access to the User's subscriptions associated with the app.
User Timeline Posts Access
Provides access to the posts on a Users's timeline.
Video upload
Add or modify User's videos.
video.watches Action
Allows the app to retrieve the actions published by all applications using the built-in video.watches action.
Videos
Provides access to the videos the User has uploaded and videos the User has been tagged in.
Website
Provides access to the User's web site URL.
Work History
Provides access to work history.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Access to third-party accounts
This type of service allows 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 authorization by the User.
Facebook account access (Facebook, Inc.)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: About Me; Access Friend Lists; Access Page CTA; Access private data; Access Requests; Activities; App Notifications; Birthday; Books Actions; Business Management API; Chat; Checkins; Contact email; Create Events; Create notes; Current City; Custom Friend Lists Access; Custom User Actions; Deals; Education History; Email; Events; Export Posts; Family Members and Relationship Status; Fitness Actions; Friend subscriptions; Friends' About Me; Friends' Activities; Friends' birthdays; Friends' Checkins; Friends' Current Cities; Friends' Custom User Actions; Friends' Education History; Friends' Events; Friends' Family Members and Relationship Status; Friends' Games and App Activity; Friends' Groups; Friends' Hometown; Friends' Interests; Friends' Likes; Friends' music.listens Actions; Friends' news.read Actions; Friends' Notes; Friends' Online Presence; Friends' Photos; Friends' Questions; Friends' Religious and Political Views; Friends' Significant Others and Relationship Details; Friends' Statuses; Friends' video.watches Actions; Friends' Videos; Friends' Websites; Friends' Work History; Games and App Activity; Gender; Groups; Hometown; Insights; Interests; Likes; List of Friends; Manage Advertisements; Manage Friend Lists; Manage Groups; Manage Mailbox; Manage Notifications; Manage Pages; Mobile Messaging on behalf of Page; music.listen Action; News Feed and Wall; news.read Actions; Notes; Offline Access; Online Presence; Page Messaging; Photos; Post Likes to my Wall; Publish App Activity; Publish as Page; Publish Checkins; Publish to the Wall; Questions; Read Group Content; Read Mailbox; Read page mailbox; Religious and Political Views; RSVP to Events; Share; Show List of Managed Pages; Significant Other and Relationship Details; Status; Status Updates; Tagged Places; Text Messaging; Upload Photos; User subscriptions; User Timeline Posts Access; Video upload; video.watches Action; Videos; Website; Work History.
Place of processing: United States – Privacy Policy.
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: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Twitter account access (X Corp.)
This service allows this Application to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Advertising
This type of service allows User Data to be utilized 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 behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, 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.
Direct Email Marketing (DEM) (this Application)
This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application.
Personal Data processed: email address; first name; last name.
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 opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. 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 behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on this Application. 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: United States – Privacy Policy – Opt out.
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: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioral targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Application. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Application.
Users may opt out of behavioral targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Lookalike Audience (Facebook, Inc.)
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of this Application or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
User ID extension for Google Analytics
Google Analytics on this Application makes use of a feature called User ID. This setup allows for a more accurate tracking of Users by associating that User with the same ID over various sessions and devices. It is set up in a way that doesn’t allow Google to personally identify an individual or permanently identify a particular device.
The User ID extension might make it possible to connect Data from Google Analytics with other Data about the User collected by this Application.
The opt-out link below will only opt you out for the device you are on, but not from tracking performed independently by the Owner. Contact the Owner via the email address provided in this privacy policy to object to the aforementioned tracking as well.
Personal Data processed: Cookies.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Analytics (Universal Analytics)
Google Analytics (Universal 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 utilizes 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 contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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Contacting the User
Phone contact (this Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes 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: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code.
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (this Application)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List.
Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
Data transfer to countries that guarantee European standards (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Personal Data processed: various types of Data.
Data transfer abroad based on consent (this Application)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Personal Data processed: various types of Data.
Data transfer abroad based on standard contractual clauses (this Application)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
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Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors 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: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
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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.
iubenda Consent Solution (iubenda srl)
iubenda Consent Solution is a service that facilitates the collection and management of proofs of consent provided by iubenda srl.
Personal Data processed: Data communicated while using the service.
Place of processing: Italy – Privacy Policy.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data.
Place of processing: United States – Privacy Policy.
MailUp (MailUp)
MailUp is an email address management and message sending service provided by MailUp SpA.
Personal Data processed: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; username; various types of Data.
Place of processing: Italy – Privacy Policy.
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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.
SurveyMonkey
SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Inc., SurveyMonkey Brasil Internet Ltda. or by SurveyMonkey Europe UC, depending on how the Owner manages the Data processing.
Personal Data processed: address; company name; Cookies; country; Data communicated while using the service; date of birth; email address; first name; gender; geographic position; last name; number of employees; password; phone number; profession; state; Tax ID; Usage Data; username; VAT Number; website.
Place of processing: United States – Privacy Policy; Brazil – Privacy Policy; European Union – Privacy Policy.
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Leadpages (Avenue 81, Inc.)
Leadpages is a landing page management service provided by Avenue 81, Inc., that allows this Application to collect the email addresses of Users interested in its service.
Leadpages allows the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.
Personal Data processed: email address; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Remarketing and behavioral targeting
This type of service allows this Application and its partners to inform, optimize 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 behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension (Google LLC)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of this Application with the LinkedIn advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy – Opt Out.
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; 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 behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized 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: Usage Data.
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
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
Cookie Policy
This Application 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
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 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 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. 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.
Transfer of Personal Data outside of the European Union
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via this Application.
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
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.
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.
Definitions and legal references
Personal Data (or Data)
Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or 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.