Owner and Data Controller
Cenegenics
6830 Spencer Street, Ste 102
Las Vegas, NV 89119
Owner contact email: dmca@cenegenics.com
Types of Data collected
Among the types of Personal Data that Cenegenics, and Cenegenics App collects, by itself or through third parties, there are:
Trackers; Usage Data; first name; last name; phone number; email address; ZIP/Postal code; password; picture; product interaction; number of Users; session statistics; data relating to the point of sale; device information; Data communicated while using the service.
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 Cenegenics, and Cenegenics App.
Unless specified otherwise, all Data requested by Cenegenics, and Cenegenics App is mandatory and failure to provide this Data may make it impossible for Cenegenics, and Cenegenics App to provide its services. In cases where Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App or by the owners of third-party services used by Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App.
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 Cenegenics, and Cenegenics App (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:
Advertising, Analytics, Tag Management, Remarketing and behavioral targeting, Heat mapping and session recording, Contacting the User, Interaction with external social networks and platforms, Managing contacts and sending messages, Hosting and backend infrastructure, Registration and authentication, Infrastructure monitoring, Platform services and hosting, User database management, Registration and authentication provided directly by Cenegenics, and Cenegenics App 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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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 Cenegenics, and Cenegenics App, 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 Cenegenics, and Cenegenics App. 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.
AppNexus (AppNexus Inc.)
AppNexus is an advertising service provided by AppNexus Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Salesforce (Salesforce.com, inc.)
Salesforce is an advertising service provided by Salesforce.com, inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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 Cenegenics, and Cenegenics App. 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.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) (Google LLC)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Cenegenics, and Cenegenics App, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of Cenegenics, and Cenegenics App, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: number of Users; session statistics; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on Cenegenics, and Cenegenics App.
Personal Data processed: data relating to the point of sale; email address; first name; last name.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
-
Contacting the User
Contact form (Cenegenics, and Cenegenics App)
By filling in the contact form with their Data, the User authorizes Cenegenics, and Cenegenics App 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; Trackers; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
-
Heat mapping and session recording
Heat mapping services are used to display the areas of Cenegenics, and Cenegenics App that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honors generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Cenegenics, and Cenegenics App to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Cenegenics, and Cenegenics App.
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.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Infrastructure monitoring
This type of service allows Cenegenics, and Cenegenics App to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of Cenegenics, and Cenegenics App.
Sentry (Functional Software, Inc. )
Sentry is a monitoring service provided by Functional Software, Inc. .
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
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 Cenegenics, and Cenegenics App.
The interaction and information obtained through Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App isn’t being connected back to the User’s profile.
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: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in the United States
X Post button and social widgets (X Corp.)
The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
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.
Amazon Simple Email Service (SES) (Amazon)
Amazon Simple Email Service is an email address management and message sending service provided by Amazon.com Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
- a Sale in California
- a Sharing in California
SMS/MMS Messaging
Mobile information (number collected) will NOT be shared with third parties and/or affiliates for marketing and/or promotional purposes.
All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
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Platform services and hosting
These services have the purpose of hosting and running key components of Cenegenics, and Cenegenics App, therefore allowing the provision of Cenegenics, and Cenegenics App 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.
Google Play Store (Google LLC)
Cenegenics, and Cenegenics App is distributed on the Google Play Store, a platform for the distribution of mobile apps, provided by Google LLC.
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: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
App Store Connect (Apple Inc.)
Cenegenics, and Cenegenics App is distributed on Apple's App Store, a platform for the distribution of mobile apps, provided by Apple Inc.
App Store Connect enables the Owner to manage Cenegenics, and Cenegenics App on Apple's App Store. Depending on the configuration, App Store Connect provides the Owner with analytics data on user engagement and app discovery, marketing campaigns, sales, in-app purchases, and payments to measure the performance of Cenegenics, and Cenegenics App.
App Store Connect only collects such data from Users who have agreed to share them with the Owner. Users may find more information on how to opt out via their device settings here.
Personal Data processed: product interaction; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
WP Engine (WPEngine, Inc.)
WP Engine is a hosting service provided by WPEngine, Inc.
Personal Data processed: email address; first name; last name; ZIP/Postal code.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
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Registration and authentication
By registering or authenticating, Users allow Cenegenics, and Cenegenics App 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, Cenegenics, and Cenegenics App 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.
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: email address; first name; last name; password; picture; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information; audio, electronic, visual, thermal, olfactory, or similar information.
This processing constitutes:
-
Registration and authentication provided directly by Cenegenics, and Cenegenics App
By registering or authenticating, Users allow Cenegenics, and Cenegenics App 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 (Cenegenics, and Cenegenics App)
The User registers by filling out the registration form and providing the Personal Data directly to Cenegenics, and Cenegenics App.
Personal Data processed: email address; first name; last name; phone number; ZIP/Postal code.
Category of Personal Information collected according to the CCPA: identifiers.
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Remarketing and behavioral targeting
This type of service allows Cenegenics, and Cenegenics App and its partners to inform, optimize and serve advertising based on past use of Cenegenics, and Cenegenics App 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.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioral targeting service provided by LinkedIn Corporation that connects the activity of Cenegenics, and Cenegenics App with the LinkedIn advertising network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of Cenegenics, and Cenegenics App 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: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Facebook Remarketing (Meta Platforms, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Cenegenics, and Cenegenics App with the Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Meta Custom Audience (Meta Platforms, Inc.)
Meta Custom Audience is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. that connects the activity of Cenegenics, and Cenegenics App with the Meta Audience Network.
Users can opt out of Meta's use of Trackers for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Trackers.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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 Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Cenegenics, and Cenegenics App 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: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
-
Traffic optimization and distribution
This type of service allows Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App, i.e., communication between Cenegenics, and Cenegenics App and the User's browser, while also allowing analytical data from Cenegenics, and Cenegenics App to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
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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 Cenegenics, and Cenegenics App, 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 Cenegenics, and Cenegenics App.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Cenegenics, and Cenegenics App.
Salesforce Marketing Cloud (Salesforce.com, inc.)
Salesforce Marketing Cloud is a User database management service provided by salesforce.com, inc.
Personal Data processed: email address; first name; last name; phone number; Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Pardot (Salesforce.com, Inc.)
Pardot is a User database management service provided by Salesforce.com, Inc.
Pardot may use Trackers to recognize and track Users behavior, as well as, to help deliver personalized ads and content. Users may opt out of Pardot’s use of Trackers for advertising purposes by visiting the Salesforce Audience Studio Opt-Out page or following the instructions provided by YourOnlineChoices and AdChoices.
Personal Data processed: Data communicated while using the service; device information; email address; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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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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 Cenegenics, and Cenegenics App depends on the payment system used.
Cookie Policy
Cenegenics, and Cenegenics App 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.
Further information for Users
in the United States
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running Cenegenics, and Cenegenics App and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Trackers, Usage Data, various types of Data as specified in the privacy policy of the service, first name, last name, phone number, email address, ZIP/Postal code, picture, product interaction, number of Users, session statistics, device information, Data communicated while using the service
Sensitive Personal Information collected or disclosed ℹ️:
password
Purposes:
- Advertising
- Analytics
- Tag Management
- Remarketing and behavioral targeting
- Heat mapping and session recording
- Contacting the User
- Interaction with external social networks and platforms
- Hosting and backend infrastructure
- Registration and authentication
- Infrastructure monitoring
- Platform services and hosting
- User database management
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: AppNexus Inc., Google LLC, Microsoft Corporation, Salesforce.com, inc., LinkedIn Corporation, Hotjar Ltd., Meta Platforms, Inc., Amazon Web Services, Inc., Auth0, Inc, Functional Software, Inc. , Apple Inc., Salesforce.com, Inc., X Corp.
Service providers or contractors: Cenegenics, and Cenegenics App
-
Identifiers
Personal Information collected or disclosed:
first name, last name, phone number, email address, ZIP/Postal code, Trackers, various types of Data as specified in the privacy policy of the service, picture, data relating to the point of sale, Usage Data, device information, Data communicated while using the service
Sensitive Personal Information collected or disclosed ℹ️:
password
Purposes:
- Contacting the User
- Managing contacts and sending messages
- Registration and authentication
- User database management
- Remarketing and behavioral targeting
- Registration and authentication provided directly by Cenegenics, and Cenegenics App
- Traffic optimization and distribution
- Analytics
- Platform services and hosting
- Further information about Personal Data
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Amazon, Auth0, Inc, Salesforce.com, inc., Meta Platforms, Inc., Cloudflare, Inc., Salesforce.com, Inc., WPEngine, Inc.
Service providers or contractors: Cenegenics, and Cenegenics App
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
email address, first name, last name, various types of Data as specified in the privacy policy of the service, picture, Trackers
Sensitive Personal Information collected or disclosed ℹ️:
password
Purposes:
- Registration and authentication
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Auth0, Inc
-
Commercial information
Personal Information collected or disclosed:
data relating to the point of sale, email address, first name, last name
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms, Inc.
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use Cenegenics, and Cenegenics App.
For example, you directly provide your Personal Information when you submit requests via any forms on Cenegenics, and Cenegenics App. You also provide Personal Information indirectly when you navigate Cenegenics, and Cenegenics App, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of Cenegenics, and Cenegenics App and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.
For us to respond to your request, we must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for verification and shall not further disclose the Personal Information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.
If you are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on Cenegenics, and Cenegenics App.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. In such cases, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.
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 Cenegenics, and Cenegenics App 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, Cenegenics, and Cenegenics App 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, Cenegenics, and Cenegenics App and any third-party services may collect files that record interaction with Cenegenics, and Cenegenics App (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 Cenegenics, and Cenegenics App 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)
/ Personal Information (or Information)
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.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through Cenegenics, and Cenegenics App (or third-party services employed in Cenegenics, and Cenegenics App), which can include: the IP addresses or domain names of the computers utilized by the Users who use Cenegenics, and Cenegenics App, 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 Cenegenics, and Cenegenics App 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 Cenegenics, and Cenegenics App. The Data Controller, unless otherwise specified, is the Owner of Cenegenics, and Cenegenics App.
Cenegenics, and Cenegenics App (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Cenegenics, and Cenegenics App as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
Sharing means any sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's Personal Information by the business to a third party for cross-context behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
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 statement has been prepared based on provisions of multiple legislations.
This privacy policy relates solely to Cenegenics, and Cenegenics App, if not stated otherwise within this document.