Privacy Policy of AromaTech USA

This Website collects some Personal Data from its Users.


This document contains a section dedicated to Users in the United States and their privacy rights.


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

Owner and Data Controller

AromaTech Ltd.
1202 N. 54th Avenue, #105
Phoenix, AZ 85043

Owner contact email: privacy@aromatechscent.com

Types of Data collected

Among the types of Personal Data that this Website collects, by itself or through third parties, there are: email address; Tracker; Usage Data; last name; date of birth; device information; billing address; first name; purchase history; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); phone number; Universally unique identifier (UUID).

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 Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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 Website.

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 Website (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: Handling payments, Analytics, Tag Management, Managing contacts and sending messages, Advertising, Platform services and hosting, Displaying content from external platforms, User database management, Managing data collection and online surveys, Remarketing and behavioral targeting, Content performance and features testing (A/B testing) 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”.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

  • 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 Website, 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 Website. 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.

    Microsoft Advertising (Microsoft Corporation)

    Microsoft Advertising is an advertising service provided by Microsoft Corporation.

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    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 Website 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: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Facebook Audience Network (Facebook, Inc.)

    Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.

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

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

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

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

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Microsoft Advertising Universal Event Tracking (Microsoft Corporation)

    Microsoft Advertising Universal Event Tracking is an analytics service provided by Microsoft Corporation that connects data from the Microsoft Advertising network with actions performed on this Website.

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

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

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    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 Website. 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.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Google Ad Manager (Google LLC)

    Google Ad Manager is an advertising service provided by Google LLC 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 Website 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: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    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 Website.

    Personal Data processed: Trackers; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Pinterest Conversion Tag (Pinterest, Inc.)

    Pinterest Conversion Tag is an analytics service provided by Pinterest, Inc. that connects data from the Pinterest advertising network with actions performed on this Website.

    Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings or by visiting the AdChoices opt-out page.

    Personal Data processed: device information; Trackers; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Google Ads Similar audiences (Google LLC)

    Similar audiences is an advertising and behavioral targeting service provided by Google LLC that uses Data from Google Ads Remarketing in order to display ads to Users with similar behavior to Users who are already on the remarketing list due to their past use of this Website.
    On the basis of this Data, personalized 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.

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • 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.

    Google Analytics (Universal Analytics) (Google LLC)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, 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: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in the United States

    Google Analytics (Universal Analytics) with anonymized IP (Google LLC)

    Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, 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.
    This integration of Google Analytics anonymizes your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

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

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Google Analytics Advertising Reporting Features (Google LLC)

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

    Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

    Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.

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

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Google Analytics Demographics and Interests reports (Google LLC)

    Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data).

    Users can opt out of Google's use of cookies by visiting Google's Ads Settings.

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

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

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Mouseflow (Mouseflow ApS)

    Mouseflow is an analytics and heat mapping service provided by Mouseflow ApS.
    Mouseflow is used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are.

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    YouTube Analytics and Reporting API (Google LLC)

    YouTube Analytics and Reporting API is a video content analytics service provided by Google LLC.

    Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

    Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

    Personal Data processed: Tracker.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
  • Contacting the User

    Attentive/Emotive

    SMS/MMS MOBILE MESSAGING MARKETING PROGRAM
    We respect your privacy. We will only use information you provide through the
    Program to transmit your mobile messages and respond to you, if necessary.
    This includes, but is not limited to, sharing information with platform providers,
    phone companies, and other vendors who assist us in the delivery of mobile
    messages.

    WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR
    OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR
    CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO
    ANY THIRD PARTY. Nonetheless, We reserve the right at all times to disclose
    any information as necessary to satisfy any law, regulation or governmental
    request, to avoid liability, or to protect Our rights or property. When you complete
    forms online or otherwise provide Us information in connection with the Program,
    you agree to provide accurate, complete, and true information. You agree not to
    use a false or misleading name or a name that you are not authorized to use. If,
    in Our sole discretion, We believe that any such information is untrue, inaccurate,
    or incomplete, or you have opted into the Program for an ulterior purpose, We
    may refuse you access to the Program and pursue any appropriate legal
    remedies.

    California Civil Code Section 1798.83 permits Users of the Program that are
    California residents to request certain information regarding our disclosure of the
    information you provide through the Program to third parties for their direct
    marketing purposes.

    SMS/MMS MOBILE MESSAGE MARKETING PROGRAM TERMS AND
    CONDITIONS

    AromaTech, (hereinafter, “We,” “Us,” “Our”) is offering a mobile
    messaging program (the “Program”), which you agree to use and participate in
    subject to these Mobile Messaging Terms and Conditions and Privacy Policy (the
    “Agreement”). By opting in to or participating in any of our Programs, you accept
    and agree to these terms and conditions, including, without limitation, your
    agreement to resolve any disputes with us through binding, individual-only
    arbitration, as detailed in the “Dispute Resolution” section below. This
    Agreement is limited to the Program and is not intended to modify other Terms
    and Conditions or Privacy Policy that may govern the relationship between you
    and Us in other contexts.

    User Opt In: The Program allows Users to receive SMS/MMS mobile messages
    by affirmatively opting into the Program, such as through online or
    application-based enrollment forms. Regardless of the opt-in method you utilized
    to join the Program, you agree that this Agreement applies to your participation in
    the Program. By participating in the Program, you agree to receive autodialed or
    prerecorded marketing mobile messages at the phone number associated with
    your opt-in, and you understand that consent is not required to make any
    purchase from Us. While you consent to receive messages sent using an
    autodialer, the foregoing shall not be interpreted to suggest or imply that any or
    all of Our mobile messages are sent using an automatic telephone dialing system
    (“ATDS” or “autodialer”). Message and data rates may apply.

    User Opt Out: If you do not wish to continue participating in the Program or no
    longer agree to this Agreement, you agree to reply STOP, END, CANCEL,
    UNSUBSCRIBE, or QUIT to any mobile message from Us in order to opt out of
    the Program. You may receive an additional mobile message confirming your
    decision to opt out. You understand and agree that the foregoing options are the
    only reasonable methods of opting out. You also understand and agree that any
    other method of opting out, including, but not limited to, texting words other than
    those set forth above or verbally requesting one of our employees to remove you
    from our list, is not a reasonable means of opting out.

    Duty to Notify and Indemnify: If at any time you intend to stop using the mobile
    telephone number that has been used to subscribe to the Program, including
    canceling your service plan or selling or transferring the phone number to
    another party, you agree that you will complete the User Opt Out process set
    forth above prior to ending your use of the mobile telephone number. You
    understand and agree that your agreement to do so is a material part of these
    terms and conditions. You further agree that, i f you discontinue the use of
    your mobile telephone number without notifying Us of such change, you
    agree that you will be responsible for all costs (including attorneys’ fees)
    and liabilities incurred by Us, or any party that assists in the delivery of the
    mobile messages, as a result of claims brought by individual(s) who are
    later assigned that mobile telephone number. This duty and agreement shall
    survive any cancellation or termination of your agreement to participate in any of
    our Programs.

    YOU AGREE THAT YOU SHALL INDEMNIFY, DEFEND, AND HOLD US
    HARMLESS FROM ANY CLAIM OR LIABILITY RESULTING FROM YOUR
    FAILURE TO NOTIFY US OF A CHANGE IN THE INFORMATION YOU HAVE
    PROVIDED, INCLUDING ANY CLAIM OR LIABILITY UNDER THE
    TELEPHONE CONSUMER PROTECTION ACT, 47 U.S.C. § 227, et seq., OR
    SIMILAR STATE AND FEDERAL LAWS, AND ANY REGULATIONS
    PROMULGATED THEREUNDER RESULTING FROM US ATTEMPTING TO
    CONTACT YOU AT THE MOBILE TELEPHONE NUMBER YOU PROVIDED.
    Program Description: Without limiting the scope of the Program, users that opt
    into the Program can expect to receive messages concerning the marketing and
    sale of scent diffusers and scented oils.

    Cost and Frequency: Message and data rates may apply. The Program
    involves recurring mobile messages, and additional mobile messages may be
    sent periodically based on your interaction with Us.

    Support Instructions : For support regarding the Program, text “HELP” to
    the number you received messages from or email us at help@aromatechscent.com.

    Please note that the use of this email address is not an acceptable method of opting out of the program. Opt outs must be submitted in accordance with the procedures set forth above.
    MMS Disclosure: The Program will send SMS TMs (terminating messages) if
    your mobile device does not support MMS messaging.

    Our Disclaimer of Warranty: The Program is offered on an "as-is" basis and
    may not be available in all areas at all times and may not continue to work in the
    event of product, software, coverage or other changes made by your wireless
    carrier. We will not be liable for any delays or failures in the receipt of any mobile
    messages connected with this Program. Delivery of mobile messages is subject
    to effective transmission from your wireless service provider/network operator
    and is outside of Our control. T-Mobile is not liable for delayed or undelivered
    mobile messages.

    Participant Requirements: You must have a wireless device of your own,
    capable of two-way messaging, be using a participating wireless carrier, and be a
    wireless service subscriber with text messaging service. Not all cellular phone
    providers carry the necessary service to participate. Check your phone
    capabilities for specific text messaging instructions.

    Age Restriction: You may not use of engage with the Platform if you are under
    thirteen (13) years of age. If you use or engage with the Platform and are
    between the ages of thirteen (13) and eighteen (18) years of age, you must have
    your parent’s or legal guardian’s permission to do so. By using or engaging with
    the Platform, you acknowledge and agree that you are not under the age of
    thirteen (13) years, are between the ages of thirteen (13) and eighteen (18) and
    have your parent’s or legal guardian’s permission to use or engage with the
    Platform, or are of adult age in your jurisdiction. By using or engaging with the
    Platform, you also acknowledge and agree that you are permitted by your
    jurisdiction’s Applicable Law to use and/or engage with the Platform.

    Prohibited Content: You acknowledge and agree to not send any prohibited
    content over the Platform. Prohibited content includes:

    - Any fraudulent, libelous, defamatory, scandalous, threatening, harassing,
    or stalking activity;
    - Objectionable content, including profanity, obscenity, lasciviousness,
    violence, bigotry, hatred, and discrimination on the basis of race, sex, religion,
    nationality, disability, sexual orientation, or age;
    - Pirated computer programs, viruses, worms, Trojan horses, or other
    harmful code;
    - Any product, service, or promotion that is unlawful where such product,
    service, or promotion thereof is received;
    - Any content that implicates and/or references personal health information
    that is protected by the Health Insurance Portability and Accountability Act
    (“HIPAA”) or the Health Information Technology for Economic and Clinical Health
    Act (“HITEC” Act); and
    - Any other content that is prohibited by Applicable Law in the jurisdiction
    from which the message is sent.

    Dispute Resolution: In the event that there is a dispute, claim, or controversy
    between you and Us, or between you and 317 LABS, INC. or any other
    third-party service provider acting on Our behalf to transmit the mobile messages
    within the scope of the Program, arising out of or relating to federal or state
    statutory claims, common law claims, this Agreement, or the breach, termination,
    enforcement, interpretation or validity thereof, including the determination of the
    scope or applicability of this agreement to arbitrate, such dispute, claim, or
    controversy will be, to the fullest extent permitted by law, determined by
    arbitration in Vancouver, British Columbia before one arbitrator.

    The parties agree to submit the dispute to binding arbitration in accordance with
    the Commercial Arbitration Rules of the American Arbitration Association (“AAA”)
    then in effect. Except as otherwise provided herein, the arbitrator shall apply the
    substantive laws of the Federal Judicial Circuit in which AromaTech's
    principle place of business is located, without regard to its conflict of laws rules.
    Within ten (10) calendar days after the arbitration demand is served upon a party,
    the parties must jointly select an arbitrator with at least five years’ experience in
    that capacity and who has knowledge of and experience with the subject matter
    of the dispute. If the parties do not agree on an arbitrator within ten (10) calendar
    days, a party may petition the AAA to appoint an arbitrator, who must satisfy the
    same experience requirement. In the event of a dispute, the arbitrator shall
    decide the enforceability and interpretation of this arbitration agreement in
    accordance with the Federal Arbitration Act (“FAA”). The parties also agree that
    the AAA’s rules governing Emergency Measures of Protection shall apply in lieu
    of seeking emergency injunctive relief from a court. The decision of the arbitrator
    shall be final and binding, and no party shall have rights of appeal except for
    those provided in section 10 of the FAA. Each party shall bear its share of the
    fees paid for the arbitrator and the administration of the arbitration; however, the
    arbitrator shall have the power to order one party to pay all or any portion of such
    fees as part of a well-reasoned decision. The parties agree that the arbitrator
    shall have the authority to award attorneys’ fees only to the extent expressly
    authorized by statute or contract. The arbitrator shall have no authority to award
    punitive damages and each party hereby waives any right to seek or recover
    punitive damages with respect to any dispute resolved by arbitration. The parties
    agree to arbitrate solely on an individual basis, and this agreement does not
    permit class arbitration or any claims brought as a plaintiff or class member in
    any class or representative arbitration proceeding. Except as may be required by
    law, neither a party nor the arbitrator may disclose the existence, content, or
    results of any arbitration without the prior written consent of both parties, unless
    to protect or pursue a legal right. If any term or provision of this Section is
    invalid, illegal, or unenforceable in any jurisdiction, such invalidity, illegality, or
    unenforceability shall not affect any other term or provision of this Section or
    invalidate or render unenforceable such term or provision in any other
    jurisdiction. If for any reason a dispute proceeds in court rather than in
    arbitration, the parties hereby waive any right to a jury trial. This arbitration
    provision shall survive any cancellation or termination of your agreement to
    participate in any of our Programs.

    Miscellaneous: You warrant and represent to Us that you have all necessary
    rights, power, and authority to agree to these Terms and perform your obligations
    hereunder, and nothing contained in this Agreement or in the performance of
    such obligations will place you in breach of any other contract or obligation. The
    failure of either party to exercise in any respect any right provided for herein will
    not be deemed a waiver of any further rights hereunder. If any provision of this
    Agreement is found to be unenforceable or invalid, that provision will be limited or
    eliminated to the minimum extent necessary so that this Agreement will
    otherwise remain in full force and effect and enforceable. Any new features,
    changes, updates or improvements of the Program shall be subject to this
    Agreement unless explicitly stated otherwise in writing. We reserve the right to
    change this Agreement from time to time. Any updates to this Agreement shall be
    communicated to you. You acknowledge your responsibility to review this
    Agreement from time to time and to be aware of any such changes. By
    continuing to participate in the Program after any such changes, you accept this
    Agreement, as modified.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • Content performance and features testing (A/B testing)

    The services contained in this section allow 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 this Website.

    Google Optimize (Google LLC)

    Google Optimize is an A/B testing service provided by Google LLC ("Google").

    Google may use Personal Data to contextualize and personalize the ads of its own advertising network.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
  • Displaying content from external platforms

    This type of service allows you to view content hosted on external platforms directly from the pages of this Website 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.

    Font Awesome (Fonticons, Inc. )

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

    Personal Data processed: Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    YouTube IFrame Player (Google LLC)

    YouTube IFrame Player is a video content visualization service provided by Google LLC that allows this Website to incorporate content of this kind on its pages.

    Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document.

    Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.

    Personal Data processed: Tracker.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California

    Video Vimeo (Vimeo, LLC)

    Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Website to incorporate content of this kind on its pages.

    Personal Data processed: Tracker; Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
  • Handling payments

    Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.

    Apple Pay (Apple Inc.)

    Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.

    Personal Data processed: email address.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    Google Pay (Google LLC)

    Google Pay is a payment service provided by Google LLC, which allows users to make online payments using their Google credentials.

    Personal Data processed: last name.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    Stripe (Stripe Inc)

    Stripe is a payment service provided by Stripe Inc.

    Personal Data processed: billing address.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

  • Managing contacts and sending messages

    This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
    These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

    Klaviyo (Klaviyo Inc.)

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

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

    Personal Data processed: date of birth.

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

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • Managing data collection and online surveys

    This type of service allows this Website 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.

    Klaviyo Forms (Klaviyo Inc.)

    Klaviyo Forms is a form builder and data collection platform provided by Klaviyo Inc.

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

    Personal Data processed: email address; first name; last name.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California

    Facebook lead ads (Facebook, Inc.)

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

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

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

    Personal Data processed: email address; first name; last name; phone number.

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

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California
  • Platform services and hosting

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

    Shopify (Shopify Inc.)

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

    Personal Data processed: device information.

    Place of processing: Canada – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

  • Remarketing and behavioral targeting

    This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website 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.

    Klaviyo segmentation and social advertising (Klaviyo Inc.)

    Klaviyo segmentation and social advertising is a remarketing and behavioral targeting service provided by Klaviyo Inc.

    Klaviyo segmentation and social advertising makes use of tracking technologies to monitor User behavior. This Data is then used to personalize the User's experience and to provide targeted advertising. Klaviyo segmentation and social advertising may also connect the collected Data with other networks, including advertising networks, and enable these parties to track and target the User. The Owner, unless otherwise specified in this document, has no direct relationship with the third parties that Klaviyo segmentation and social advertising may be including.

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

    Personal Data processed: device information; email address; purchase history; Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Facebook Remarketing (Facebook, Inc.)

    Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Website with the Facebook advertising network.

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    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 Website 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: email address; Tracker.

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

    Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    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 Website and allows selected advertising partners to display targeted ads across the web to them.

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California

    Google Ads Remarketing (Google LLC)

    Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

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

    Personal Data processed: Tracker; Usage Data.

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

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
    • a Sharing in California
  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Website 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 LLC)

    Google Tag Manager is a tag management service provided by Google LLC.

    Personal Data processed: Usage Data.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.

    This processing constitutes:

    • a Sale in California
  • User database management

    This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
    Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.

    Klaviyo CRM (Klaviyo Inc.)

    Klaviyo CRM is a User database management service provided by Klaviyo Inc.

    Klaviyo CRM can also be used as a medium for communications, either through email, or through messages within this Website.

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

    Personal Data processed: email address; first name; last name.

    Place of processing: United States – Privacy Policy.

    Category of Personal Information collected according to the CCPA: identifiers.

    This processing constitutes:

    • a Sale in California

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.

Cookie Policy

This Website uses Trackers. To learn more, Users may consult the Cookie Policy.

Further Information for Users

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.

Further information for Users in the United States

This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana.

For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.

This part of the document uses the term Personal Information.

Notice at collection

The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.

While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.

  • Identifiers

    Personal Information collected or disclosed: email address, last name, date of birth, billing address, first name, Tracker, Usage Data, device information, purchase history, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), phone number, Trackers, Universally unique identifier (UUID), various types of Data as specified in the privacy policy of the service

    Purposes:

    • Handling payments
    • Managing contacts and sending messages
    • User database management
    • Managing data collection and online surveys
    • Remarketing and behavioral targeting
    • Advertising
    • Analytics

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Apple Inc., Google LLC, Klaviyo Inc., Stripe Inc, Facebook, Inc., Microsoft Corporation

  • Internet or other electronic network activity information

    Personal Information collected or disclosed: Tracker, Usage Data, device information, purchase history, email address, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), Trackers, Universally unique identifier (UUID), various types of Data as specified in the privacy policy of the service

    Purposes:

    • Analytics
    • Tag Management
    • Advertising
    • Platform services and hosting
    • Displaying content from external platforms
    • Remarketing and behavioral targeting
    • Content performance and features testing (A/B testing)

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Google LLC, Microsoft Corporation, Shopify Inc., Fonticons, Inc. , Klaviyo Inc., Facebook, Inc., Meta Platforms, Inc., Mouseflow ApS, Vimeo, LLC, Pinterest, Inc.

  • Commercial information

    Personal Information collected or disclosed: Tracker, Usage Data, device information, purchase history, email address

    Purposes:

    • Remarketing and behavioral targeting

    Retention period: for the time necessary to fulfill the purpose

    Sold or Shared ℹ️: Yes

    Targeted Advertising: ℹ️: Yes

    Third-parties: Klaviyo Inc.

ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.

To know more about your rights in particular to opt out of certain processing activities you can refer to the “Your privacy rights under US state laws” section of our privacy policy.

For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.

We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.

What are the sources of the Personal Information we collect?

We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Website.

For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.

Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website and features thereof.

Your privacy rights under US state laws

You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:

  • the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
  • the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
  • the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
  • the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
  • the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
  • the right to non-discrimination.

Additional rights for Users residing in California

In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have:

  • The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
  • The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.

Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana

In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana you have

  • The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
  • The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

  • The right to question the results of the profiling;
  • The right to be informed of the reason that the profiling resulted in the decision; if feasible
  • The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  • The right to review personal data used in the profiling;
  • If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, you have:

  • The right to opt out of the processing of your Personal Information for Targeted Advertising;
  • The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.

How to exercise your privacy rights under US state laws

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you are an adult, you can make a request on behalf of a child under your parental authority.

How to exercise your rights to opt out

In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Website.

If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.

Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).

We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Sensitive Personal Information

Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.

Usage Data

Information collected automatically through this Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, 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 Website 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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.

This Website (or this Application)

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Website as described in the relative terms (if available) and on this site/application.

Sale

Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.

Sharing

Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.

Targeted advertising

Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User's browser.

Tracker

Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy statement has been prepared based on provisions of multiple legislations.

This privacy policy relates solely to this Website, if not stated otherwise within this document.

Latest update: March 08, 2024

This document has been created with the iubenda Privacy and Cookie Policy Generator. See also the Terms and Conditions Generator. iubenda hosts this content and only collects the Personal Data strictly necessary for it to be provided.

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