Owner and Data Controller
Mondello Roma SRL Unipersonale, Via dei Bergamaschi 49, 00186 Roma, RM, Italia
Owner contact email: privacy@mondelliani.it
Types of Data collected
Among the types of Personal Data that Soprattutto.com collects, by itself or through third parties, there are:
Tracker; Usage Data; email address; first name; last name; phone number; county; country; ZIP/Postal code; city; physical address; company name; social media accounts ; payment info; Data communicated while using the service; Universally unique identifier (UUID); geographic position; Calendar permission; Precise location permission (non-continuous); Phone permission; SMS permission; Reminders permission; Social media accounts permission; Media Library permission (Music); Photo Library permission; Siri permission; Google Assistant permission; Call permission; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); date of birth; VAT Number; Tax ID; Social Security number (SSN); profile picture; User ID; billing address; house number; language; various types of Data; operating systems.
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 Soprattutto.com.
Unless specified otherwise, all Data requested by Soprattutto.com is mandatory and failure to provide this Data may make it impossible for Soprattutto.com to provide its services. In cases where Soprattutto.com 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 Soprattutto.com or by the owners of third-party services used by Soprattutto.com 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 Soprattutto.com.
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 Soprattutto.com (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, Tag Management, Platform services and hosting, Registration and authentication, Content commenting, Contacting the User, Managing contacts and sending messages, User database management, RSS feed management, Handling payments, Managing data collection and online surveys, Managing support and contact requests, Managing landing and invitation pages, Hosting and backend infrastructure, Interaction with live chat platforms, Interaction with support and feedback platforms, Advertising, Interaction with external social networks and platforms, Location-based interactions, Traffic optimization and distribution, Device permissions for Personal Data access, SPAM protection, Registration and authentication provided directly by Soprattutto.com, Remarketing and behavioral targeting, Backup saving and management, Content performance and features testing (A/B testing) and Displaying content from external platforms.
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, Soprattutto.com 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 Soprattutto.com.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by Soprattutto.com.
Calendar permission
Used for accessing the calendar on the User's device, including the reading, adding and removing of entries.
Call permission
Used for accessing a host of typical features associated with telephony.
Google Assistant permission
Used for sending the User's Data to Google Assistant (an artificial intelligence-powered virtual assistant).
Media Library permission (Music)
Allows accessing the User's Media Library audio Data.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
Photo Library permission
Allows access to the User's Photo Library.
Precise location permission (non-continuous)
Used for accessing the User's precise device location. Soprattutto.com may collect, use, and share User location Data in order to provide location-based services.
The geographic location of the User is determined in a manner that isn't continuous. This means that it is impossible for Soprattutto.com to derive the exact position of the User on a continuous basis.
Reminders permission
Used for accessing the Reminders app on the User's device, including the reading, adding and removing of entries.
Siri permission
Used for sending the User's Data to Siri (an artificial intelligence-powered virtual assistant).
SMS permission
Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.
Social media accounts permission
Used for accessing the User's social media account profiles, such as Facebook and Twitter.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on Soprattutto.com, 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 Soprattutto.com. 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.
AddThis (Oracle Corporation)
AddThis is an advertising and behavioral targeting service provided by Oracle Corporation that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Soprattutto.com and connects the activity of Soprattutto.com with the Oracle advertising network. Users can opt out of Oracle's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Shareaholic (Shareaholic, Inc.)
Shareaholic is an advertising and behavioral targeting service provided by Shareaholic, Inc. that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Soprattutto.com. Users can opt out of Shareaholic's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
ShareThis (Sharethis Inc.)
ShareThis is an advertising and behavioral targeting service provided by Sharethis Inc. that displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Soprattutto.com. Users can opt out of ShareThis's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Direct Email Marketing (DEM) (Soprattutto.com)
Soprattutto.com uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Soprattutto.com.
Personal Data processed: email address.
Direct marketing via SMS (Soprattutto.com)
Soprattutto.com uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Soprattutto.com.
Personal Data processed: phone number.
Meta Audience Network (Meta Platforms, Inc.)
Meta Audience Network is an advertising service provided by Meta Platforms, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
Soprattutto.com may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta 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.
Google AdSense (Google Ireland Limited)
Google AdSense is an advertising service provided by Google Ireland Limited. This service uses the “DoubleClick” Cookie, which tracks use of Soprattutto.com and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
In order to understand Google's use of data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Ad Manager (Google Ireland Limited)
Google Ad Manager is an advertising service provided by Google Ireland Limited 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 understand Google's use of Data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Soprattutto.com 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: Ireland – Privacy Policy.
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 Soprattutto.com. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on Soprattutto.com.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
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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 (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Soprattutto.com, 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.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Wordpress Stats (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Adobe Analytics (Adobe Systems Incorporated)
Adobe Analytics is an analytics service provided by Adobe Systems Incorporated.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Alexa Metrics (Alexa Internet, Inc.)
Alexa Metrics is an analytics service provided by Alexa Internet, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
AWStats (Soprattutto.com)
AWStats is an open-source web analytics software used by Soprattutto.com to analyze Data directly without the help of third parties. AWStats allows analyzing these log files in order to examine web traffic patterns.
Personal Data processed: country; operating systems; Usage Data.
Google Analytics with anonymized IP (Google Ireland Limited)
Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes the Data collected to track and examine the use of Soprattutto.com, 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.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Audiens (Audiens S.r.l.)
Audiens is an analytics service provided by Audiens S.r.l.
Personal Data processed: Tracker; Usage Data.
Place of processing: Italy – Privacy Policy – Opt Out.
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Backup saving and management
This type of service allows the Owner to save and manage backups of Soprattutto.com on external servers managed by the service provider itself. The backups may include the source code and content as well as the data that the User provides to Soprattutto.com.
Backup on Google Drive (Google Ireland Limited)
Google Drive is a service to save and manage backups provided by Google Ireland Limited.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Contacting the User
Mailing list or newsletter (Soprattutto.com)
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 Soprattutto.com. Your email address might also be added to this list as a result of signing up to Soprattutto.com or after making a purchase.
Personal Data processed: city; company name; country; county; email address; first name; last name; phone number; physical address; ZIP/Postal code.
Phone contact (Soprattutto.com)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Soprattutto.com, as well as for fulfilling support requests.
Personal Data processed: phone number.
Integration of Freshsales with Freshdesk Messaging and/or Freshdesk (Freshworks, Inc.)
If a User provides their email address through the Freshdesk Messaging widget or a Freshdesk support ticket, the User's email address and other Data may be added to Freshsales, a customer relationship and contact management service (CRM). All services are provided by Freshworks, Inc.
The provision of the email address within Freshdesk is voluntary and serves the main purpose of being contacted for the fulfilling of requests related to support. In addition to making support requests easier to handle, the Owner can make use of the full range of the CRM features provided by Freshsales.
Personal Data processed: email address; first name; last name; phone number; social media accounts .
Place of processing: United States – Privacy Policy.
Contact form (Soprattutto.com)
By filling in the contact form with their Data, the User authorizes Soprattutto.com 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: email address; first name; last name; phone number.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Soprattutto.com.
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 (Soprattutto.com)
Soprattutto.com has its own internal content comment system.
Personal Data processed: email address; Tracker.
Facebook Comments (Meta Platforms, Inc.)
Facebook Comments is a content commenting service provided by Meta Platforms, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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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 Soprattutto.com.
Google Optimize (Google Ireland Limited)
Google Optimize is an A/B testing service provided by Google Ireland Limited ("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: Ireland – Privacy Policy.
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Device permissions for Personal Data access
Soprattutto.com requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (Soprattutto.com)
Soprattutto.com 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: Calendar permission; Call permission; Google Assistant permission; Media Library permission (Music); Phone permission; Photo Library permission; Precise location permission (non-continuous); Reminders permission; Siri permission; SMS permission; Social media accounts permission.
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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 Soprattutto.com 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.
YouTube video widget (Privacy Enhanced Mode) (Google Ireland Limited)
YouTube is a video content visualization service provided by Google Ireland Limited that allows Soprattutto.com to incorporate content of this kind on its pages.
This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on Soprattutto.com unless they play the video.
Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data.
Place of processing: Ireland – Privacy Policy.
Adobe Fonts (Adobe Systems Incorporated)
Adobe Fonts is a typeface visualization service provided by Adobe Systems Incorporated that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Fonts.com Web Fonts (Monotype Imaging Inc.)
Fonts.com Web Fonts is a typeface visualization service provided by Monotype Imaging Inc. that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Getty Images widget (Getty Images, Inc.)
Getty Images is an image delivery service provided by Getty Images, Inc. that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Google Programmable Search Engine (Google Ireland Limited)
Google Programmable Search Engine is a search engine embedding service provided by Google Ireland Limited that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
Google Programmable Search Engine with AdSense (Google Ireland Limited)
Google Programmable Search Engine is a search engine embedding service provided by Google Ireland Limited that allows Soprattutto.com to incorporate content of this kind on its pages.
Google Programmable Search Engine may display AdSense advertisements. For details of which data are collected, please refer to the privacy policy of this service.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows Soprattutto.com to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
MyFonts (Monotype Imaging Inc.)
MyFonts is a typeface visualization service provided by Monotype Imaging Inc. that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
TripAdvisor widget (TripAdvisor LLC)
TripAdvisor widget is a content visualization service provided by TripAdvisor LLC that allows Soprattutto.com to incorporate content from that external platform on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Video Vimeo (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Google Calendar widget (Google Ireland Limited)
Google Calendar widget is a calendar content visualization service provided by Google Ireland Limited that allows Soprattutto.com to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Handling payments
Unless otherwise specified, Soprattutto.com 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. Soprattutto.com 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.
Android Pay (Google LLC)
Android Pay is a payment service provided by Google LLC, which allows Users to make payments using their mobile phones.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Braintree (PayPal (Europe) S.a.r.l. et Cie, S.C.A.)
Braintree is a payment service provided by Braintree, a division of PayPal (Europe) S.a.r.l. et Cie, S.C.A.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Braintree privacy policy – Privacy Policy.
Google Pay (Google Ireland Limited)
Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Payments processed via the Apple App Store (Apple Inc.)
Soprattutto.com uses a payment service provided by Apple Inc. that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Apple, as described in the privacy policy for the App Store.
Personal Data processed: payment info.
Place of processing: United States – Privacy Policy.
Payments processed via the Google Play Store (Google Ireland Limited)
Soprattutto.com uses a payment service provided by Google Ireland Limited that allows the Owner to offer the purchase of the app itself or in-app purchases.
Personal Data processed to complete the purchases are processed by Google, as described in the privacy policy for the Google Play store.
Personal Data processed: payment info.
Place of processing: Ireland – Privacy Policy.
Payment by bank transfer (Soprattutto.com)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by Soprattutto.com, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: first name; last name; payment info.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
PayPal Carrier Payments (PayPal Inc.)
PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows Users to make online payments using their mobile phone operator.
Personal Data processed: phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
PayPal Payments Hub (PayPal Inc.)
PayPal Payments Hub is a payment service provided by PayPal Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
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: United States – Privacy Policy.
Scalapay
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Soprattutto.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Soprattutto.com.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
SiteGround Hosting (SiteGround Hosting Ltd.)
SiteGround Hosting is a hosting service provided by SiteGround Hosting Ltd.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United Kingdom – Privacy Policy.
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Interaction with external social networks and platforms
This type of service allows interaction with social networks or other external platforms directly from the pages of Soprattutto.com.
The interaction and information obtained through Soprattutto.com are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on Soprattutto.com isn’t being connected back to the User’s profile.
AddToAny (AddToAny LLC)
AddToAny is a service provided by AddToAny LLC, which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Soprattutto.com.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Data collected through the service may be used to help deliver interest-based advertising. Users can opt out of third-party interest-based advertising by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Reddit button and widgets (reddit inc.)
The reddit button and widgets are services allowing interaction with the reddit platform provided by reddit inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube button and social widgets (Google Ireland Limited)
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Ireland Limited.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
AngelList follow button and social widgets ( Venture Hacks, Inc.)
The AngelList follow button and social widgets are services allowing interaction with the AngelList network provided by Venture Hacks, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Like button and social widgets (Meta Platforms, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tweet button and social widgets (X Corp.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Pinterest “Pin it” button and social widgets (Pinterest, Inc.)
The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Socialize (Solialize Inc.)
Socialize is a service provided by Socialize, Inc., which displays a widget that allows interaction with social networks and external platforms as well as sharing the contents of Soprattutto.com.
Depending on the configuration, this service can display widgets belonging to third parties such as the managers of social networks where interactions are shared. In this case, also the third parties that provide the widget will be informed of interactions and Usage Data on the pages where this service is installed.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of Soprattutto.com, in order to contact and be contacted by Soprattutto.com‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
Facebook Messenger Customer Chat (Meta Platforms, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Meta Platforms, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Freshdesk Messaging Widget (Freshworks, Inc.)
The Freshdesk Messaging Widget is a service for interacting with the Freshdesk live chat platform provided by Freshworks, Inc.
Personal Data processed: Data communicated while using the service; email address; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Zendesk Chat (Zendesk, Inc.)
Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
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Interaction with support and feedback platforms
This type of service allows Users to interact with third-party support and feedback platforms directly from the pages of Soprattutto.com.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service.
Zendesk Widget (Zendesk, Inc.)
The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Non-continuous geolocation (Soprattutto.com)
Soprattutto.com 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 Soprattutto.com.
The geographic location of the User is determined in a manner that isn't continuous, either at the specific request of the User or when the User doesn't point out its current location in the appropriate field and allows the application to detect the position automatically.
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.
SendinBlue Email (SendinBlue SAS)
SendinBlue is an email address management and message sending service provided by SendinBlue SAS.
Personal Data processed: email address; Tracker; Usage Data.
Place of processing: France – Privacy Policy.
SendinBlue SMS (SendinBlue SAS)
SendinBlue is a phone numbers management and communication service provided by SendinBlue SAS.
Personal Data processed: phone number; Tracker; Usage Data.
Place of processing: France – Privacy Policy.
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Managing data collection and online surveys
This type of service allows Soprattutto.com 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.
SurveyMonkey (SurveyMonkey Europe UC)
SurveyMonkey is a survey builder and data collection platform provided by SurveyMonkey Europe UC.
Personal Data processed: Data communicated while using the service; email address; first name; last name.
Place of processing: European Union – Privacy Policy.
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Mailchimp Landing Page (Intuit Inc.)
Mailchimp Landing Page is a landing page management service provided by Intuit Inc, that allows Soprattutto.com to collect the email addresses of Users interested in its service.
Mailchimp Landing Page allows 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 the created landing pages.
Personal Data processed: email address; first name; last name; phone number; Usage Data.
Place of processing: United States – Privacy Policy.
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Managing support and contact requests
This type of service allows Soprattutto.com to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Freshdesk (Freshworks, Inc.)
Freshdesk is a support and contact request management service provided by Freshworks, Inc.
Personal Data processed: Data communicated while using the service; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of Soprattutto.com, therefore allowing the provision of Soprattutto.com 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.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host Soprattutto.com.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Play Store (Google Ireland Limited)
Soprattutto.com is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google Ireland Limited.
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share aggregate information with the Owner. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: Ireland – Privacy Policy.
Apple App Store (Apple Inc.)
Soprattutto.com is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting features that enables the Owner to view usage analytics data and measure the performance of Soprattutto.com. Much of this information is processed on an opt-in basis.
Users may opt-out of this analytics feature directly through their device settings. More information on how to manage analysis settings can be found on this page.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Shopify
Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.
Place of processing: Canada – Privacy Policy; Ireland – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow Soprattutto.com 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, Soprattutto.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
WordPress.com Single Sign On (Automattic Inc.)
WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and is connected to the WordPress.com network.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Facebook Authentication (Meta Platforms, Inc.)
Facebook Authentication is a registration and authentication service provided by Meta Platforms, Inc. and is connected to the Facebook social network.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Instagram Authentication (Meta Platforms, Inc.)
Instagram Authentication is a registration and authentication service provided by Meta Platforms, Inc. and is connected to the Instagram social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Log In with PayPal (PayPal Inc.)
Log In with PayPal is a registration and authentication service provided by PayPal Inc. and is connected to the PayPal network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Login with Amazon (Amazon)
Login with Amazon is a registration and authentication service provided by Amazon.com, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Mailchimp OAuth (Intuit Inc.)
Mailchimp OAuth is a registration and authentication service provided by Intuit Inc. and is connected to the Mailchimp service.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Twitter OAuth (X Corp.)
Twitter Oauth is a registration and authentication service provided by Twitter, Inc. and is connected to the Twitter social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Windows Live Connect (Microsoft Corporation)
Microsoft Live Connect is a registration and authentication service provided by Microsoft Corporation and is connected to the Microsoft network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
YouTube OAuth (Google Ireland Limited)
YouTube OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the YouTube network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Registration and authentication provided directly by Soprattutto.com
By registering or authenticating, Users allow Soprattutto.com to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (Soprattutto.com)
The User registers by filling out the registration form and providing the Personal Data directly to Soprattutto.com.
Personal Data processed: billing address; city; country; county; date of birth; email address; first name; house number; language; last name; phone number; physical address; profile picture; Social Security number (SSN); Tax ID; Tracker; User ID; various types of Data; VAT Number; ZIP/Postal code.
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Remarketing and behavioral targeting
This type of service allows Soprattutto.com and its partners to inform, optimize and serve advertising based on past use of Soprattutto.com 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.
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.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of Soprattutto.com with the Google Ads advertising network and the DoubleClick Cookie.
In order to understand Google's use of Data, consult Google's partner policy.
Users can opt out of Google's use of Trackers for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Remarketing with Google Analytics (Google Ireland Limited)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Remarketing (Meta Platforms, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Soprattutto.com with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks the visitors of Soprattutto.com and allows selected advertising partners to display targeted ads across the web to them.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Signals (Google Ireland Limited)
Soprattutto.com uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from Soprattutto.com with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalization. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymized insights into Users' cross device behaviors.
If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Soprattutto.com with the LinkedIn advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Custom Audience (Meta Platforms, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Soprattutto.com with the Facebook advertising network.
Users can opt out of Facebook's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy – Opt Out.
Twitter Remarketing (X Corp.)
Twitter Remarketing is a remarketing and behavioral targeting service provided by Twitter, Inc. that connects the activity of Soprattutto.com with the Twitter advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Twitter Tailored Audiences (X Corp.)
Twitter Tailored Audiences is a remarketing and behavioral targeting service provided by X Corp. that connects the activity of Soprattutto.com with the Twitter advertising network.
Users can opt out from interest-based ads by going to: Personalization and Data.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy.
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RSS feed management
This type of service allows Soprattutto.com to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.
FeedPress (Beta Et Compagnie Sarl)
FeedPress is a service to manage RSS feeds provided by Beta Et Compagnie Sarl. It allows the collection of statistics on what content is consumed.
Personal Data processed: Usage Data.
Place of processing: France – Privacy Policy.
Feedburner (Google LLC)
Feedburner is a service to manage RSS feeds provided by Google LLC. It allows the collection of statistics on what content is consumed and to insert ads in it.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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SPAM protection
This type of service analyzes the traffic of Soprattutto.com, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Akismet (Automattic Inc.)
Akismet is a SPAM protection service provided by Automattic Inc.
Place of processing: United States – Privacy Policy.
Google reCAPTCHA (Google Ireland Limited)
Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Soprattutto.com 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: Usage Data.
Place of processing: Ireland – Privacy Policy.
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Traffic optimization and distribution
This type of service allows Soprattutto.com to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Soprattutto.com and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through Soprattutto.com, i.e., communication between Soprattutto.com and the User's browser, while also allowing analytical data from Soprattutto.com to be collected.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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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 Soprattutto.com, 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 Soprattutto.com.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Soprattutto.com.
SendinBlue Marketing Automation (SendinBlue SAS)
SendinBlue is a User database management service provided by SendinBlue SAS.
Personal Data processed: email address; Tracker; Usage Data.
Place of processing: France – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by
any of the services listed in this document, Users may learn more on
how to generally opt out of interest-based advertising within the
dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
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User identification via a universally unique identifier (UUID)
Soprattutto.com 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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Unique device identification
Soprattutto.com may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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Push notifications
Soprattutto.com 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 Soprattutto.com, some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Soprattutto.com.
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Push notifications based on the User's geographic location
Soprattutto.com 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 Soprattutto.com.
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Push notifications for direct marketing
Soprattutto.com 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 Soprattutto.com).
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 Soprattutto.com or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of Soprattutto.com.
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.
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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.
Soprattutto.com 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.
Soprattutto.com 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 Soprattutto.com, 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.
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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 Soprattutto.com depends on the payment system used.
Cookie Policy
Soprattutto.com 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 Soprattutto.com 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, Soprattutto.com 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, Soprattutto.com and any third-party services may collect files that record interaction with Soprattutto.com (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 Soprattutto.com 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 Soprattutto.com (or third-party services employed in Soprattutto.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use Soprattutto.com, 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 Soprattutto.com 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 Soprattutto.com. The Data Controller, unless otherwise specified, is the Owner of Soprattutto.com.
Soprattutto.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Soprattutto.com 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 Soprattutto.com, if not stated otherwise within this document.