Owner and Data Controller
Il Titolare del trattamento è CULTI MILANO SpA con sede legale e operativa in via dell' Aprica 12, 20158 Milano, contattabile all’indirizzo culti@culti.com o al numero di telefono 02 49784974.
Il Responsabile della Protezione dei dati personali (DPO) è EKO Sicurezza di dott. Colonnello Francesco, contattabile all’indirizzo e-mail privacy@culti.com.
Owner contact email: culti@culti.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Tracker; email address; Usage Data; first name; last name; phone number; ZIP/Postal code; country; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); User ID; number of Users; session statistics; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; city; state; province; county; latitude (of city); longitude (of city); metro area; geography/region; IP address; device information; app information; device logs; operating systems; browser information; language; launches; number of sessions; session duration; scroll-to-page interactions; video views; browsing history; search history; page views; interaction events; page events; custom events; Application opens; gender; date of birth; physical address; username; password; VAT Number; company name; Tax ID; profession; fax number; Social Security number (SSN); picture; prefix ; profile picture; workplace; website; budget; academic background; number of employees; Twitter handle; billing address; field of activity; house number; various types of Data.
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 unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Tag Management, Contacting the User, Advertising, Displaying content from external platforms, Interaction with data collection platforms and other third parties, Interaction with support and feedback platforms, Analytics, Managing support and contact requests, Interaction with live chat platforms, Remarketing and behavioural targeting, Spam and bots protection, Traffic optimisation and distribution and Registration and authentication provided directly by this Application.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on 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 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, 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 LLC)
Google Ads conversion tracking is an analytics service provided by Google LLC 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.
Google Ads Customer Match
Google Ads Customer Match is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows matching Data that Users have shared with the Owner to existing Google accounts in order to target them or similar Users with personalised ads.
Users can opt out of Google's use of personalised advertising by visiting Google's Ads Settings.
Personal Data processed: country; email address; first name; last name; phone number; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); User ID; ZIP/Postal code.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Ads Similar audiences (Google Ireland Limited)
Similar audiences is an advertising and behavioural targeting service provided by Google Ireland Limited that uses Data from Google Ads Remarketing in order to display ads to Users with similar behaviour to Users who are already on the remarketing list due to their past use of this Application.
On the basis of this Data, personalised ads will be shown to Users suggested by Google Ads Similar audiences.
Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Meta Events Manager (Meta Platforms Ireland Limited)
Meta Events Manager is an analytics service provided by Meta Platforms Ireland Limited. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Application.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Google Analytics with anonymised IP (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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 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 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.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Cloudflare Web Analytics (Cloudflare Inc.)
Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare Inc. that gives the Owner insight into the use of this Application by Users without needing to identify them. Further information may be found here and within the service's privacy policy.
Personal Data processed: device information; language; Usage Data.
Place of processing: United States – Privacy Policy.
Google Analytics Granular location and device data collection (Google Ireland Limited)
Google Analytics on this Application has granular data collection activated which collects location and device data on a per-region basis. It allows the Owner to create and analyse User reports that rely on those metrics.
Personal Data processed: browser information; city; device information; number of Users; session statistics; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Contacting the User
Mailing list or newsletter (this Application)
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 this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.
Personal Data processed: email address.
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Instagram widget (Facebook, Inc.)
Instagram is an image visualisation service provided by Facebook, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts (Google LLC)
Google Fonts is a typeface visualisation service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Mailchimp widget (The Rocket Science Group LLC)
The Mailchimp widget is a service for interacting with the Mailchimp email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Application, in order to contact and be contacted by this Application‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Zendesk Chat (Zendesk, Inc.)
Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy.
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Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of this Application.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Zendesk Widget (Zendesk, Inc.)
The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy.
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Managing support and contact requests
This type of service allows this Application to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk 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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Registration and authentication provided directly by this Application
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (this Application)
The User registers by filling out the registration form and providing the Personal Data directly to this Application.
Personal Data processed: academic background; billing address; budget; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; Social Security number (SSN); state; Tax ID; Trackers; Twitter handle; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code.
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Remarketing and behavioural 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 behavioural targeting activity.
Some services offer a remarketing option based on email address lists.
Services of this kind usually allow Users to opt out of such tracking. Users may learn how to opt out of interest-based advertising more generally by visiting the relevant opt-out section 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 this Application with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Spam and bots protection
This type of service analyses the traffic of this Application, potentially containing Users' Personal Data, with the purpose of filtering it from unwanted parts of traffic, messages and content that are recognised as spam or protecting it from malicious bots activities.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Cloudflare Bot Management (Cloudflare Inc.)
Cloudflare Bot Management is a malicious bot protection and management service provided by Cloudflare Inc.
Personal Data processed: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code.
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 centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy.
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Traffic optimisation and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimise their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Application and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – 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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PRIVACY POLICY PURSUANT TO ARTICLE 13 OF REGULATION EU 2016/679
This privacy policy contains information on the processing of personal data carried out by Culti Milano SpA for the registration of user accounts and/or the subscription to the newsletter in the website www.culti.com, in accordance with the current Regulation of the European Union 2016/679 (GDPR) and Italian Legislative Decree 196/2003 as amended by Italian Legislative Decree 101/2019.
The Data Controller is Culti Milano SpA, with registered office and operational headquarters at Via dell’Aprica, 12, Milan.
The Data Protection Officer (DPO) is EKO Sicurezza di Colonnello Francesco, which can be contacted at the email address francesco.colonnello@protonmail.com.
Processing of personal data
1. Personal data subject to processing and purposes
The Users’ personal data will be processed by the Controller pursuant to Article 6 of the GDPR for the following processing purposes:
A) Contractual obligations and supply of the service which, subject to consent, are accepted by the User during registration, and to fulfil specific requests of the User. The User’s data collected by the Controller for this purpose include: first name, surname and email address, residential and shipping address (country, province, town/city, post code, address), telephone number, tax identification number/VAT number (if invoice is requested), as well as all the User’s personal information that may be voluntarily published. The Controller will use the User’s personal data to check the User’s identity and avoid possible fraud or misuse, to contact the User through the website or by phone operator to provide assistance should the User have difficulty completing the order, to provide general assistance and to contact the User for service requirements only.
B) Administration and accounting purposes, i.e., to carry out organisational, administrative, financial and accounting activities, such as internal organisation activities and activities required to fulfil contractual and pre-contractual obligations.
C) Legal obligations, i.e., to fulfil obligations required by the law, an authority, a regulation or the applicable European legislation.
D) Browsing data: in normal operation the computer systems and software procedures required to operate the website gather certain personal data transmitted implicitly when using internet communication protocols. This information is not collected for the purpose of associating it with identified data subjects. However, by its very nature, it could enable user identification through processing and associations with data held by third parties. This data category includes the IP addresses or domain names of the computers used by users connecting to the website, the URI addresses of the requested resources, the time of the request, the method used to submit the request to the server, the size of the response file, the numeric code indicating the status of the response provided by the server (successful, error, etc.) and other parameters relating to the user’s operating system and computer environment. These data are only used to gather anonymous statistical information on use of the website, monitor its correct functioning and detect irregularities and misuse. The data could be used to establish liability in the event of hypothetical computer crimes against the website or third parties.
E) In addition to filling in the forms found on the website, you can also request certain services and provide your personal data – where this feature is enabled – through your Facebook, Instagram and PayPal profile. In these cases, Facebook, Instagram and PayPal could automatically send Culti Milano SpA your personal data (name, email address, mobile phone number, profile picture and invoicing data).
F) Cookies: detailed information on cookies can be found in the Cookie Policy.
The disclosure of personal data for the processing purposes A, B, and C is necessary for registering on the website and/or using the services offered by the Controller through the website (purchase of products). The personal data required to achieve the processing purposes are marked with an asterisk in the website registration form.
2. Additional processing purposes: marketing and newsletter
Certain personal data (email address) may also be processed by the Controller for direct marketing purposes (for example, for sending advertising material, commercial communications and newsletters containing news of relevance to the Controller’s business sector), but only with the User’s specific, free and voluntary consent.
If consent is not given, the possibility of pursuing the purposes set out in paragraph 1 will not be affected in any way.
If consent is given, it may be withdrawn at any time upon request to the Controller.
You may also easily object to further promotional email communications by clicking on the appropriate link for withdrawing consent, provided in each promotional email.
3. Processing methods
Data may be processed manually or electronically and will be accessed only by authorised operators, previously appointed as “Authorised Processors”. All operators accessing the computerised data will be provided with a personal password, and data access will only be permitted for purposes associated with the operator’s role and only for the time strictly necessary to achieve the purpose. Data may also be processed by external collaborators, previously appointed as “Data Processors”.
4. Data storage period
The personal data provided by you will be stored for as long as necessary to fulfil the purposes described in this Privacy Policy, as required by law, for example, for tax and accounting purposes or to ensure a better service. For example, we store your transaction history so that you can review the purchases made (and repeat orders if you wish), and the addresses to which you have requested orders to be sent. For marketing purposes your personal data will be processed, as a general rule and without prejudice to the principle of data retention proportionate to the purpose of processing, until you withdraw your consent.
5. Scope of disclosure and dissemination
Users’ personal data may be disclosed to the Controller’s employees and/or collaborators entrusted with managing the website and the e-commerce orders. These people, formally appointed by the Controller as “Authorised Processors”, will process the User’s data solely for the purposes stated in this Privacy Policy and in compliance with the provisions of the applicable legislation.
Users’ personal data may also be disclosed to third parties who process personal data on the Controller’s behalf in the capacity of “External Data Processors”, such as, for example, providers of computer and logistics services required for operating the website, providers of outsourcing or cloud computing services, professionals and consultants, forwarding agents and the like. Some of the service providers are US based companies. They are compliant with the former EU-US Privacy Shield and guarantee compliance with standard contractual clauses.
Users are entitled to obtain a list of the data processors appointed by the Controller, upon request to the Controller or the DPO.
Users’ personal data may also be disclosed to the parent company Intek Group SpA, only in order to fulfil administration and accounting purposes associated with the performance of organisational, administrative, financial and accounting activities.
6. Consequences of non-consent
The disclosure of personal data for the processing purposes referred to in paragraph 1 A, B, C is optional for browsing the website only, but is necessary for placing orders. Processing for marketing purposes (Paragraph 2) is optional and a refusal will not compromise the possibility of placing an order.
7. Data subject’s rights
Users may exercise the rights guaranteed by the legislation, contacting the Controller or the DPO by sending an email to the address francesco.colonnello@protonmail.com.
Pursuant to the applicable legislation, the Controller informs Users that they are entitled to obtain specification of:
i. the origin of the personal data;
ii. the processing purposes and methods;
iii. the logic involved when processing is carried out using electronic tools;
iv. the identification details of the controller and the processors;
v. the persons or categories of persons to whom the personal data may be disclosed or who may become aware of them in their capacity of processors or persons in charge of processing.
Users are also entitled to obtain:
a. access, update, rectification or, when it is in their interest, supplementation of their data;
b. erasure, anonymisation or blocking of data processed unlawfully, including data that do not need to be stored for the purposes for which they were collected or subsequently processed;
c. declaration that the operations referred to in points a) and b), and their content, have been brought to the attention of those to whom the data have been communicated or disclosed, unless fulfilment of this obligation proves impossible or entails an employment of resources that is clearly disproportionate to the protected right.
Users also have:
a. the right to withdraw consent at any time, when the processing is based on consent;
b. the right to data portability (right to receive all the personal data concerning them in a structured, commonly used and machine-readable format), the right to restriction of processing and the right to erasure (“right to be forgotten”);
c. the right to object:
i. in full or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
ii. in full or in part, to the processing of personal data concerning them, for the purpose of sending advertising material;
iii. if personal data are processed for direct marketing purposes, at any time, to the processing of their data for that purpose;
if they believe that the processing breaches the Regulation, the right to lodge a complaint with a supervisory authority (in the member state where they habitually reside, where they work or where the alleged breach has occurred).
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.
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 utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Application, if not stated otherwise within this document.