Privacy Policy of netwalk.eu

This Application collects some Personal Data from its Users.

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

    • Access to third-party accounts

      • Stripe account access

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

    • Advertising

      • Direct Email Marketing (DEM)

        Personal Data: email address

    • Analytics

      • Wordpress Stats, Google Analytics with anonymized IP, Analytics collected directly, HubSpot Analytics and Google Analytics

        Personal Data: Cookies and Usage Data

    • Backup saving and management

      • Backup on Dropbox and Backup on Google Drive

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

    • Contacting the User

      • Phone contact

        Personal Data: phone number

      • Mailing List or Newsletter

        Personal Data: country, email address, first name, last name and phone number

      • Contact form

        Personal Data: country, email address, first name, last name, phone number and various types of Data as specified in the privacy policy of the service

    • Content commenting

      • Facebook Comments

        Personal Data: Cookies and Usage Data

    • Content performance and features testing (A/B testing)

      • Google Website Optimizer

        Personal Data: Cookies and Usage Data

    • Data transfer outside the EU

      • Other legal basis for Data transfer abroad, Data transfer abroad based on standard contractual clauses, Data transfer abroad based on consent, Data transfer to countries that guarantee European standards and Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield

        Personal Data: various types of Data

    • Displaying content from external platforms

      • Vimeo video, YouTube video widget, Google Maps widget and Instagram widget

        Personal Data: Cookies and Usage Data

      • Adobe Fonts, Google Fonts, Adobe Edge Web Fonts and Fonts.com Web Fonts

        Personal Data: Usage Data and various types of Data as specified in the privacy policy of the service

      • SoundCloud widget and YouTube video widget without cookies

        Personal Data: Usage Data

    • Handling payments

      • PayPal and Stripe

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

      • Freshbooks

        Personal Data: email address and various types of Data as specified in the privacy policy of the service

    • Hosting and backend infrastructure

      • Akamai Content Delivery Network

        Personal Data: Cookies and Usage Data

    • Infrastructure monitoring

      • Pingdom

        Personal Data: Cookies and Usage Data

      • New Relic

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

    • Interaction with external social networks and platforms

      • Facebook Like button and social widgets, Twitter Tweet button and social widgets, LinkedIn button and social widgets, ShareThis, Socialize, Pinterest “Pin it” button and social widgets, AngelList follow button and social widgets, Tumblr sharing button and social widgets, AddThis and AddToAny

        Personal Data: Cookies and Usage Data

      • YouTube button and social widgets

        Personal Data: Usage Data

    • Interaction with support and feedback platforms

      • Zendesk Widget

        Personal Data: Cookies and Usage Data

    • Managing contacts and sending messages

      • MailChimp, Sendgrid, MailUp and Mailgun

        Personal Data: email address

      • Nexmo

        Personal Data: phone number

      • Mandrill and HubSpot Email

        Personal Data: email address and Usage Data

    • Managing support and contact requests

      • Zendesk

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

    • Platform services and hosting

      • WordPress.com and Blogger

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

    • Registration and authentication

      • Direct registration

        Personal Data: country, email address, first name, last name and phone number

      • Stripe OAuth and YouTube OAuth

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

    • Social features

      • Inviting and suggesting friends

        Personal Data: Various types of Data

      • Public profile

        Personal Data: address, city, company name, country, date of birth, email address, first name, gender, geographic position, last name, phone number, picture, profession, province, state and username

    • SPAM protection

      • Akismet

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

    • Traffic optimization and distribution

      • Cloudflare

        Personal Data: Cookies and various types of Data as specified in the privacy policy of the service

    • User database management

      • HubSpot CRM

        Personal Data: email address, phone number and various types of Data as specified in the privacy policy of the service

      • HubSpot Lead Management

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

Further information about Personal Data

    • Selling goods and services online

      The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
      The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

    • Push notifications

      This Application may send push notifications to the User.

    • Analysis and predictions based on the User’s Data (“profiling”)

      The Owner may use the Personal and Usage Data collected through this Application to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
      User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more, about the profiling activities performed, Users can check the relevant sections of this document.
      The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.

    • Personal Data collected through sources other than the User

      The Owner of this Application may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
      Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.

    • User identification via a universally unique identifier (UUID)

      This Application may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.

    • Unique device identification

      This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.

    • Privacy Shield participation: data transfers from the EU and Switzerland to the United States

      The Owner participates in and complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personal Data transferred from the European Union and Switzerland to the United States. The policies and rights outlined below are therefore equally and explicitly applicable to Users from Switzerland, except if stated otherwise. The Owner has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.

      If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view the Owner’s certification, please visit https://www.privacyshield.gov/ (or find the direct link to the certification list of Privacy Shield participants maintained by the Department of Commerce https://www.privacyshield.gov/list).

      What does this mean for the European User?

      The Owner is responsible for all processing of Personal Data it receives under the Privacy Shield Framework from European Union individuals and commits to subject the processed Personal Data to the Privacy Shield Principles.

      This, most importantly, includes the right of individuals to access their personal data processed by the Owner.

      The Owner also complies with the Privacy Shield Principles for all onward transfers of Personal Data from the EU, which means that it remains liable in cases of onward transfers to third parties.

      With respect to Personal Data received or transferred pursuant to the Privacy Shield Framework, the Owner is subject to the investigatory and regulatory enforcement powers of the FTC, if not stated otherwise in this privacy policy.

      The Owner is further required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

      Dispute resolution under the Privacy Shield

      In compliance with the Privacy Shield Principles, the Owner commits to resolve complaints about its collection or use of the User’s Personal Data. European Union individuals with inquiries or complaints regarding this Privacy Shield policy should first contact the Owner at the contact details supplied at the beginning of this document referring to “Privacy Shield” and expect the complaint to be dealt with within 45 days.

      In case of failure by the Owner to provide a satisfactory or timely response, the User has the option of involving an independent dispute resolution body, free of charge.

      In this regard, the Owner has agreed to cooperate with the panel established by the EU data protection authorities (DPAs) and comply with the advice given by the panel with regard to data transferred from the EU. The User may therefore contact the Owner at the email address provided at the beginning of this document in order to be directed to the relevant DPA contacts.

      Under certain conditions – available for the User in full on the Privacy Shield website (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint) – the User may invoke binding arbitration when other dispute resolution procedures have been exhausted

    • Automated decision-making

      Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention. This Application may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document. This Application adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
      Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
      The rationale behind the automated decision making is:

      • to enable or otherwise improve the decision-making process;
      • to grant Users fair and unbiased treatment based on consistent and uniform criteria;
      • to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
      • to reduce the risk of User's failure to meet their obligation under a contract. To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within this Application, Users can check the relevant sections in this document.

      Consequences of automated decision-making processes for Users and rights of Users subjected to it

      As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
      In particular, Users have the right to:

      • obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
      • challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
      • request and obtain from the Owner human intervention on such processing. To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.

Contact information

    • Owner and Data Controller

      GAP MULTIMEDIA S.R.L.

      Owner contact email: amministrazione@gapmultimedia.eu