Owner and Data Controller
Connecting Talents Ltd
Queens Yard, Unit 6
White Post Lane,
London, England
VAT GB 235460910
Registered at the Information Commissioner's Office (ICO), the UK’s independent authority set up to uphold information rights in the public interest, promoting openness by public bodies and data privacy for individuals.
Owner contact email: kerry@connectingtalents.org
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Cookies; Usage Data; first name; last name; gender; date of birth; phone number; address; country; state; province; email address; ZIP/Postal code; various types of Data; city; Tax ID; field of activity; website; username; Precise location permission (continuous); Approximate location permission (continuous); geographic position; profession; picture.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Analytics, Contacting the User, Content commenting, Device permissions for Personal Data access, Displaying content from external platforms, Handling payments, Hosting and backend infrastructure, Interaction with data collection platforms and other third parties, Interaction with live chat platforms, Location-based interactions, Managing contacts and sending messages, Registration and authentication, Social features and Tag Management.
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”.
Device permissions for Personal Data access
Depending on the User's specific device, this Application may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Application.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Application.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. This Application may collect, use, and share User location Data in order to provide location-based services.
Precise location permission (continuous)
Used for accessing the User's precise device location. This Application may collect, use, and share User location Data in order to provide location-based services.
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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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 Inc.)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy – Opt Out.
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Contacting the User
Contact form (This Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: address; city; country; date of birth; email address; field of activity; first name; gender; last name; phone number; province; state; Tax ID; various types of Data; website; ZIP/Postal code.
Phone contact (This Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
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: Cookies; country; email address; first name; last name; Usage Data; ZIP/Postal code.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of this Application.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Comment system managed directly (This Application)
This Application has its own internal content comment system.
Personal Data processed: Cookies; email address; first name; last name; Usage Data; username.
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Device permissions for Personal Data access
This Application requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (This Application)
This Application requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Precise location permission (continuous).
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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.
Google Maps widget (Google Inc.)
Google Maps is a maps visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization 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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Handling payments
Payment processing services enable this Application to process payments by credit card, bank transfer or other means. To ensure greater security, this Application shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Braintree (PayPal Inc.)
Braintree is a payment service provided by Braintree, a division of PayPal, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
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Hosting and backend infrastructure
This type of service has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Amazon privacy policy – 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.
GetResponse widget (Implix Sp. z o.o.)
The GetResponse widget is a service for interacting with the GetResponse email address management and message sending service provided by Implix Sp. z o.o.
Personal Data processed: Cookies; email address; first name; Usage Data.
Place of processing: Poland – Privacy Policy.
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 Intuit Inc.
Personal Data processed: Cookies; email address; first name; last name; Usage Data.
Place of processing: USA – 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, for contacting and being contacted by this Application 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.
LiveChat Widget (LiveChat, Inc.)
The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: US – Privacy Policy.
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Location-based interactions
Geolocation (This Application)
This Application may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.
Personal Data processed: geographic position.
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by Intuit Inc.
Personal Data processed: email address.
Place of processing: US – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third party services, for registration or identification purposes.
Linkedin OAuth (LinkedIn Corporation)
Linkedin Oauth is a registration and authentication service provided by Linkedin Corporation and is connected to the Linkedin social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Google OAuth (Google Inc.)
Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Google OAuth (Google Inc.)
Google OAuth is a registration and authentication service provided by Google Inc. and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
Stripe OAuth (Stripe Inc)
Stripe OAuth is a registration and authentication service provided by Stripe, Inc. and is connected to the Stripe network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: US – Privacy Policy.
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Social features
Public profile (This Application)
Users may have public profiles that other Users can display. In addition to the Personal Data provided, this profile may contain Users' interactions with this Application.
Personal Data processed: country; first name; last name; picture; profession.
Inviting and suggesting friends (This Application)
This Application may use the Personal Data provided to allow Users to invite their friends - for example through the address book, if access has been provided - and to suggest friends or connections inside it.
Personal Data processed: various types of Data.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager (Google Ireland Limited)
Google Tag Manager is a tag management service provided by Google Ireland Limited.
Personal Data processed: Tracker.
Place of processing: Ireland – Privacy Policy.
Further information about the processing of Personal Data
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Connecting talents security measures
The current software architecture behind Connecting Talents website is managed by different security mechanisms and levels to secure all communications between CT servers and user web browser.
The first method is to divide personal data & Talent data both as a process and a database. The user data are protected by: a) user password encrypting with a tokenization method; b) Transport Layer Security (TLS)/SSL secured communication. The TLS protocol aims primarily to provide privacy and data integrity between two communicating computer applications. When secured by TLS, connections between a client (e.g., a web browser) and a server (e.g., connectingtalents.org) have one or more of the following properties:
- The connection is private (or secure) because symmetric cryptography is used to encrypt the data transmitted.
- The identity of the communicating parties can be authenticated using public-key cryptography.
The connection ensures integrity because each message transmitted includes a message integrity check using a message authentication code to prevent undetected loss or alteration of the data during transmission
The Talent Data are stored on a separate server and database, these data are not available directly to the browser (so they are not publically exposed), they are available only after a double authorization from the ConnectingTalent server.
The authentication works in this way:
- The client ask to Connecting Talents website to see UTC Data
- Pass the 1st level of security (described in "The user data" section)
- The server, using another TLS/SSL connection asks for a security Server-to-Server token (under JWT technology (JSON Web Tokens are an open, industry standard RFC 7519 method for representing claims securely between two parties)
- Then the UTC Server, using a TLS/SSL connection send the data to the client.
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Personal responsibility about security of data
The security of your Personal Information is important to us. We use commercially reasonable efforts to store and maintain your Personal Information in a secure environment. We also take technical, contractual, administrative, and physical security steps designed to protect Personal Information that you provide to us. We have implemented procedures designed to limit the dissemination of your Personal Information to only such designated staff as are reasonably necessary to carry out the stated purposes we have communicated to you.
You are also responsible for helping to protect the security of your Personal Information. For instance, never give out your Facebook password, and safeguard your user name, password and personal credentials when you are using the Services, so that other people will not have access to your Personal Information. Furthermore, you are responsible for maintaining the security of any personal computing device on which you utilize the Services.
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Management and retention time of data collected
The Data is kept only for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always manage, delete and export the data by accessing the"page "Data management setting". In case user wants to delete personal data, the service, if active, would be suspended.
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Contacting the ICO (the UK Data protection Supervisor)
Your Data protection matters to us.
Connecting Talents is registered at the Information Commissioner's Office. Feel free:
. to access relevant information on your rights on their website https://ico.org.uk/your-data-matters/ and/or
. contact us if you're concerned about how we are using your data by sending an e-mail to Kerry@connectingtalents.org
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Push notifications
This Application may send push notifications to the User.
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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.
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The Service is not directed to children under the age of 13
Users declare themselves to be adult according to their applicable legislation. Minors may use this Application only with the assistance of a parent or guardian. Under no circumstance persons under the age of 13 may use this Application.
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Unique device identification
This Application may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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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.
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Access the address book
This Application may request access to your address book.
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 utilized by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy policy relates solely to this Application, if not stated otherwise within this document.