Owner and Data Controller
Virbion Media LLC, a Minnesota Corporation, USA.
Owner contact email: privacy@virbion.com
Types of Data collected
Among the types of Personal Data that virbion.com collects, by itself or through third parties, there are:
Cookies; Usage Data; email address; phone number; first name; last name; username; website; various types of Data; Data communicated while using the service; company name; country; geographic position; gender; date of birth; address; profession; password; picture; About Me.
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 virbion.com.
Unless specified otherwise, all Data requested by virbion.com is mandatory and failure to provide this Data may make it impossible for virbion.com to provide its services. In cases where virbion.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 virbion.com or by the owners of third-party services used by virbion.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 virbion.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 virbion.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, Contacting the User, User database management, Managing contacts and sending messages, Commercial affiliation, Content commenting, Data transfer outside the EU, Displaying content from external platforms, Hosting and backend infrastructure, Handling payments, Interaction with live chat platforms, Interaction with external social networks and platforms, Interaction with support and feedback platforms, Location-based interactions, Managing support and contact requests, Platform services and hosting, Registration and authentication, Remarketing and behavioral targeting, SPAM protection, Tag Management and Traffic optimization and distribution.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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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 Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of virbion.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: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
HubSpot Analytics (HubSpot, Inc.)
HubSpot Analytics is an analytics service provided by HubSpot, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out .
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Commercial affiliation
This type of service allows virbion.com to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with virbion.com.
For details of which data are collected, please refer to the privacy policy of each service.
CJ Affiliate by Conversant (Conversant, Inc.)
CJ Affiliate by Conversant is a commercial affiliation service provided by Conversant, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Contacting the User
Contact form (virbion.com)
By filling in the contact form with their Data, the User authorizes virbion.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.
Phone contact (virbion.com)
Users that provided their phone number might be contacted for commercial or promotional purposes related to virbion.com, as well as for fulfilling support requests.
Personal Data processed: phone number.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of virbion.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 (virbion.com)
Virbion.com has its own internal content comment system.
Personal Data processed: Cookies; email address; first name; last name; phone number; Usage Data; username; website.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Data transfer outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e. any country not part of the EU) only pursuant to a specific legal basis. Any such Data transfer is based on one of the legal bases described below.
Users can inquire with the Owner to learn which legal basis applies to which specific service.
Data transfer abroad based on consent (virbion.com)
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via virbion.com.
Personal Data processed: various types of Data.
Data transfer abroad based on standard contractual clauses (virbion.com)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Personal Data processed: various types of Data.
Data transfer from the EU and/or Switzerland to the U.S based on Privacy Shield (virbion.com)
If this is the legal basis, the transfer of Personal Data from the EU or Switzerland to the US is carried out according to the EU - U.S. and Swiss - U.S. Privacy Shield.
In particular, Personal Data is transferred to services that self-certify under the Privacy Shield framework and therefore guarantee an adequate level of protection of such transferred Data. All services are listed within the relevant section of this document and those that adhere to Privacy Shield can be singled out by checking their privacy policy and possibly also by specifically checking for Privacy Shield adherence in the official Privacy Shield List.
Privacy Shield also specifically guarantees rights to Users which can be found in its most current form on the website run by the US Department of Commerce.
Personal Data may be transferred from within the EU or Switzerland to the U.S. to services that are not, or not anymore, part of Privacy Shield, only based on other valid legal grounds. Users can ask the Owner to learn about such legal grounds.
Personal Data processed: various types of Data.
Data transfer to countries that guarantee European standards (virbion.com)
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Personal Data processed: various types of Data.
Other legal basis for Data transfer abroad (virbion.com)
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via virbion.com.
Personal Data processed: various types of Data.
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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 virbion.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.
Google Fonts (Google Inc.)
Google Fonts is a typeface visualization service provided by Google Inc. that allows virbion.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.
YouTube video widget (Google Inc.)
YouTube is a video content visualization service provided by Google Inc. that allows virbion.com to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Handling payments
Payment processing services enable virbion.com to process payments by credit card, bank transfer or other means. To ensure greater security, virbion.com 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: United States – Privacy Policy.
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 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.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable virbion.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of virbion.com.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Google App Engine (Google LLC)
Google App Engine is a hosting service provided by Google LLC.
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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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 virbion.com.
The interaction and information obtained through virbion.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 virbion.com isn’t being connected back to the User’s profile.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Google+ +1 button and social widgets (Google Inc.)
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google Inc.
Personal Data processed: Cookies; 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: Cookies; 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: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube button and social widgets (Google Inc.)
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google Inc.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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 virbion.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: Cookies; 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 virbion.com, for contacting and being contacted by virbion.com 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.
Olark Widget (Habla, Inc.)
The Olark Widget is a service for interacting with the Olark live chat platform provided by Habla, Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
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; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
Facebook Messenger Customer Chat (Facebook, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Personal Data processed: About Me; Cookies; Data communicated while using the service; Usage Data.
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 virbion.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: company name; country; email address; first name; last name; phone number; Usage Data; username.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Non-continuous geolocation (virbion.com)
Virbion.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 virbion.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.
HubSpot Email (HubSpot, Inc.)
HubSpot Email is an email address management and message sending service provided by HubSpot, Inc.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
Mailchimp (The Rocket Science Group, LLC.)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group, LLC.
Personal Data processed: company name; country; email address; first name; last name; username.
Place of processing: United States – Privacy Policy.
Mailgun (Mailgun, Inc.)
Mailgun is an email address management and message sending service provided by Mailgun, Inc.
Personal Data processed: address; Cookies; country; date of birth; email address; first name; gender; last name; phone number; profession; Usage Data; various types of Data.
Place of processing: United States – Privacy Policy.
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Managing support and contact requests
This type of service allows virbion.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).
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 virbion.com, therefore allowing the provision of virbion.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 virbion.com.
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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Registration and authentication
By registering or authenticating, Users allow virbion.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, virbion.com will be able to access some Data, stored by these third-party services, for registration or identification purposes.
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: United States – Privacy Policy.
Auth0 (Auth0, Inc)
Auth0 is a registration and authentication service provided by Auth0, Inc. To simplify the registration and authentication process, Auth0 can make use of third-party identity providers and save the information on its platform.
Personal Data processed: Cookies; email address; first name; last name; password; picture; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – 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: 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: 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.
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Remarketing and behavioral targeting
This type of service allows virbion.com and its partners to inform, optimize and serve advertising based on past use of virbion.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.
In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page.
Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – 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 virbion.com with the LinkedIn advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of virbion.com with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of virbion.com with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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SPAM protection
This type of service analyzes the traffic of virbion.com, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA (Google Inc.)
Google reCAPTCHA is a SPAM protection service provided by Google Inc.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on virbion.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 LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
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Traffic optimization and distribution
This type of service allows virbion.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 virbion.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)
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 virbion.com, i.e., communication between virbion.com and the User's browser, while also allowing analytical data from virbion.com to be collected.
Personal Data processed: Cookies; 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 virbion.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 virbion.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 virbion.com.
HubSpot CRM (HubSpot, Inc.)
HubSpot CRM is a User database management service provided by HubSpot, Inc.
Personal Data processed: email address; phone number; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
HubSpot Lead Management (HubSpot, Inc.)
HubSpot Lead Management is a User database management service provided by HubSpot, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – 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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Accelo Analytics
Personal Data: Cookies and Usage Data
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Accelo CRM
Personal Data: email address, phone number and various types of Data as specified in the privacy policy of the service
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Accelo Lead Management
Personal Data: various types of Data as specified in the privacy policy of the service.
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Accelo Email
Accelo Email is an email address management and message sending service provided by Accelo, Inc.
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Accelo 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 virbion.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 virbion.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 virbion.com.
Accelo CRM (Accelo, INC.)
Accelo CRM is a User database management service provided by Accelo, Inc.
Personal Data collected: email address, phone number and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Accelo LEAD MANAGEMENT (Accelo, INC.)
Accelo Lead Management is a User database management service provided by Accelo, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Accelo 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 virbion.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 virbion.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 virbion.com.
Accelo CRM (Accelo, INC.)
Accelo CRM is a User database management service provided by Accelo, Inc.
Personal Data collected: email address, phone number and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Accelo LEAD MANAGEMENT (Accelo, INC.)
Accelo Lead Management is a User database management service provided by Accelo, Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Handling Payments - Quickbooks
Personal Data: various types of Data as specified in the privacy policy of the service
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Handling Payments
Payment processing services enable virbion.com to process payments by credit card, bank transfer or other means. To ensure greater security, virbion.com 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 collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
Quickbooks (Quickbooks INC.)
Quickbooks is a payment service provided by Quickbooks Inc., which allows Users to make online payments.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Quickbooks privacy policy – Privacy Policy.
Quickbooks PAYMENTS HUB (Quickbooks INC.)
Quickbooks Payments Hub is a payment service provided by Quickbooks Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Quickbooks privacy policy – Privacy Policy.
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HOSTING AND BACKEND INFRASTRUCTURE
This type of service has the purpose of hosting Data and files that enable virbion.com to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of virbion.com. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
GOOGLE APP ENGINE (GOOGLE INC.)
Google App Engine is a hosting service provided by Google Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
SITEGROUND HOSTING (SITEGROUND INC.)
Siteground is a hosting service provided by Siteground Inc.
Personal Data collected: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Privacy Shield participant.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through virbion.com to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Personal Data collected through sources other than the User
The Owner of virbion.com 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.
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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 virbion.com depends on the payment system used.
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Unique device identification
Virbion.com may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
Cookie Policy
Virbion.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.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on consent
If this is the legal basis, Personal Data of Users shall be transferred from the EU to third countries only if the User has explicitly consented to such transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner shall inform Users appropriately and collect their explicit consent via virbion.com.
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
Data transfer to countries that guarantee European standards
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out according to an adequacy decision of the European Commission.
The European Commission adopts adequacy decisions for specific countries whenever it considers that country to possess and provide Personal Data protection standards comparable to those set forth by EU data protection legislation. Users can find an updated list of all adequacy decisions issued on the European Commission's website.
Other legal basis for Data transfer abroad
If no other legal basis applies, Personal Data shall be transferred from the EU to third countries only if at least one of the following conditions is met:
- the transfer is necessary for the performance of a contract between the User and the Owner or of pre-contractual measures taken at the User’s request;
- the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the User between the Owner and another natural or legal person;
- the transfer is necessary for important reasons of public interest;
- the transfer is necessary for establishment, exercise or defence of legal claims;
- the transfer is necessary in order to protect the vital interests of the data subject or of other persons, where the data subject is physically or legally incapable of giving consent.
In such cases, the Owner shall inform the User about the legal bases the transfer is based on via virbion.com.
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 virbion.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, virbion.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, virbion.com and any third-party services may collect files that record interaction with virbion.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 virbion.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 virbion.com (or third-party services employed in virbion.com), which can include: the IP addresses or domain names of the computers utilized by the Users who use virbion.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 virbion.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 virbion.com. The Data Controller, unless otherwise specified, is the Owner of virbion.com.
virbion.com (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by virbion.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.
About Me
Provides access to the 'About Me' section of the profile.
Legal information
This privacy policy relates solely to virbion.com, if not stated otherwise within this document.