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

• • Advertising

    • Google Ads conversion tracking, Microsoft Advertising, Google Ads Similar audiences and Google Ad Manager

      Personal Data: Trackers; Usage Data

    • Google Ads Customer Match

      Personal Data: country; email address; first name; last name; phone number; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); User ID; ZIP/Postal code

  • Analytics

    • Google Analytics

      Personal Data: Cookies; Usage Data

    • Google Analytics for Firebase

      Personal Data: Application opens; Application updates; device information; geography/region; In-app purchases; launches; number of sessions; number of Users; operating systems; session duration; Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

    • Google Analytics 4

      Personal Data: browser information; city; device information; latitude (of city); longitude (of city); number of Users; session statistics; Trackers; Usage Data

    • Google Analytics with anonymized IP and Analytics collected directly

      Personal Data: Trackers; Usage Data

    • Google Analytics Demographics and Interests reports

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

    • Cloudflare Web Analytics

      Personal Data: device information; language; Usage Data

  • Backup saving and management

    • Sectigo CodeGuard

      Personal Data: city; company name; country; Data communicated while using the service; date of birth; device information; email address; first name; gender; geographic position; language; last name; password; phone number; profession; screenshots; Usage Data; username; various types of Data; VAT Number; workplace; ZIP/Postal code

  • Contacting the User

    • Phone contact

      Personal Data: phone number

    • Mailing list or newsletter

      Personal Data: city; Cookies; country; email address; first name; gender; last name; state; Usage Data

    • Contact form

      Personal Data: address; city; company name; country; county; date of birth; email address; fax number; field of activity; first name; gender; last name; number of employees; phone number; profession; state; Tax ID; User ID; various types of Data; VAT Number; website; ZIP/Postal code

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

    • Google Optimize

      Personal Data: Trackers; Usage Data

  • Data transfer outside the EU

    • Data transfer abroad based on consent and Data transfer abroad based on standard contractual clauses

      Personal Data: various types of Data

  • Displaying content from external platforms

    • Google Fonts

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

    • Google Maps widget and Google Programmable Search Engine

      Personal Data: Trackers; Usage Data

  • Handling payments

    • Apple Pay, Android Pay, Google Pay, PayPal and Stripe

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

    • Payments processed via the Apple App Store

      Personal Data: billing address; device information; email address; first name; last name; phone number; purchase history; Trackers; Usage Data

  • Hosting and backend infrastructure

    • Amazon Web Services (AWS)

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

    • Firebase Cloud Functions

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

  • Infrastructure monitoring

    • Firebase Performance Monitoring

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

  • Location-based interactions

    • Geolocation and Non-continuous geolocation

      Personal Data: coarse location; geographic position; precise location

  • Managing contacts and sending messages

    • Amazon Simple Email Service

      Personal Data: email address

    • Mailchimp

      Personal Data: address; company name; Cookies; country; date of birth; email address; first name; gender; last name; phone number; Usage Data; username; various types of Data

    • Twilio

      Personal Data: phone number

    • Firebase Cloud Messaging and Firebase Notifications

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

  • Platform services and hosting

    • Apple App Store and Google Play Store

      Personal Data: Usage Data

  • Registration and authentication

    • Stripe OAuth and Google OAuth

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

    • Sign in with Apple

      Personal Data: city; country; date of birth; email address; first name; geography/region; last name; phone number; profile picture; User ID

    • Firebase Authentication

      Personal Data: email address; first name; last name; phone number; profile picture; social media accounts

  • Registration and authentication provided directly by Transfeero

    • Direct registration

      Personal Data: address; billing address; city; company name; Cookies; country; county; date of birth; email address; field of activity; first name; gender; house number; language; last name; number of employees; password; phone number; picture; prefix ; profession; Social Security number (SSN); state; Tax ID; Usage Data; User ID; username; various types of Data; VAT Number; website; workplace; ZIP/Postal code

  • Remarketing and behavioral targeting

    • Google Ad Manager Audience Extension, Remarketing with Google Analytics and Google Ads Remarketing

      Personal Data: Cookies; Usage Data

    • Google Signals

      Personal Data: Trackers; Usage Data

  • SPAM protection

    • Google reCAPTCHA

      Personal Data: Cookies; Usage Data

    • Cloudflare Bot Management

      Personal Data: app information; Application opens; browser information; browsing history; city; clicks; country; county; custom events; device information; device logs; geography/region; interaction events; IP address; keypress events; language; latitude (of city); launches; longitude (of city); metro area; motion sensor events; mouse movements; number of sessions; operating systems; page events; page views; province; scroll position; scroll-to-page interactions; search history; session duration; session statistics; state; touch events; Trackers; Usage Data; video views; ZIP/Postal code

  • Tag Management

    • Google Tag Manager

      Personal Data: Usage Data

  • Traffic optimization and distribution

    • Cloudflare

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

    • Google Cloud CDN, jsDelivr CDN and cdnjs

      Personal Data: Usage Data

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data

• • 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 Transfeero depends on the payment system used.

  • 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. Transfeero 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. Transfeero 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 Transfeero, 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.

  • Personal Data collected through sources other than the User

    The Owner of Transfeero 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.

  • Push notifications

    Transfeero may send push notifications to the User to achieve the purposes outlined in this privacy policy.

    Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then change those settings for Transfeero, some or all of the apps on the particular device.
    Users must be aware that disabling push notifications may negatively affect the utility of Transfeero.

  • Push notifications based on the User's geographic location

    Transfeero may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.

    Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.

    Users must be aware that disabling push notifications may negatively affect the utility of Transfeero.

  • Push notifications for direct marketing

    Transfeero may send push notifications to the User for the purpose of direct marketing (to propose services and products provided by third parties or unrelated to the product or service provided by Transfeero).

    Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for Transfeero or all of the apps on the particular device.

    Users must be aware that disabling push notifications may negatively affect the utility of Transfeero.

    Besides applicable device settings, the User may also make use of the rights described under User rights in the relevant section of this privacy policy.

  • Equal protection of User Data

    Transfeero shares User Data only with third parties carefully selected to ensure that they provide the same or equal protection of User Data as stated in this privacy policy and requested by applicable data protection laws. Further information on data processing and privacy practices by third parties can be found in their respective privacy policies.

Contact information

• • Owner and Data Controller

    Sicily Action SRL
    Via Fiuggi sn
    95037, San Giovanni La Punta (CT)
    Tel. +39 0958998743
    VAT: IT05304190878
    REA: CT-357256

    Owner contact email: info@transfeero.com