Privacy Policy of www.empatica.com

Owner and Data Controller

Empatica s.r.l. - Via Stendhal 36 - 20144 Milan (Italy)

Owner contact email: privacy@empatica.com

Types of Data collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are: email address, first name, last name, company name, geographic position, Cookies and Usage Data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
• 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.

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.

Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or 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.

If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.

Retention time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.

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 do so for the performance of a legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to 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 purposes of processing

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the following purposes: Contacting the User, Location-based interactions, Analytics, Managing support and contact requests, Managing contacts and sending messages, Remarketing and behavioral targeting, Interaction with external social networks and platforms, Content performance and features testing (A/B testing), Interaction with support and feedback platforms, Hosting and backend infrastructure, RSS feed management, Displaying content from external platforms, User database management and Infrastructure monitoring.

Users can find further detailed information about such purposes of processing and about the specific Personal Data used for each purpose in the respective sections of this document.

Detailed information on the processing of Personal Data

Personal Data is collected for the following purposes and using the following services:

• 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.

  Analytics collected directly (This Application)

  This Application uses an internal analytics system that does not involve third parties.

  Personal Data collected: Cookies and Usage Data.

  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 this Application, to prepare reports on its activities and share them with other Google services.
  Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Facebook Ads conversion tracking (Facebook, Inc.)

  Facebook Ads conversion tracking is an analytics service provided by Facebook, Inc. that connects data from the Facebook advertising network with actions performed on this Application.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Twitter Ads conversion tracking (Twitter, Inc.)

  Twitter Ads conversion tracking is an analytics service provided by Twitter, Inc. that connects data from the Twitter advertising network with actions performed on this Application.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Yahoo Advertising conversion tracking (Yahoo! Inc.)

  Yahoo Advertising conversion tracking is an analytics service provided by Yahoo! Inc. that connects data from the Yahoo advertising network with actions performed on this Application.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  Google Ads conversion tracking (Google Inc.)

  Google Ads conversion tracking is an analytics service provided by Google Inc. that connects data from the Google Ads advertising network with actions performed on this Application.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy. Privacy Shield participant.

• Contacting the User

  Contact form (This Application)

  By filling in the contact form with their Data, the User authorizes this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

  Personal Data collected: company name, email address, first name, last name and various types of Data as specified in the privacy policy of the service.

  Mailing List or Newsletter (This Application)

  By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

  Personal Data collected: email address.

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

  The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of this Application.

  Optimizely (Optimizely, Inc.)

  Optimizely is an A/B testing service provided by Optimizely, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Displaying content from external platforms

  This type of services allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
  This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.

  Google Fonts (Google Inc.)

  Google Fonts is a typeface visualization service provided by Google Inc. that allows this Application to incorporate content of this kind on its pages.

  Personal Data collected: Usage Data and various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy. Privacy Shield participant.

• Hosting and backend infrastructure

  This type of services has the purpose of hosting data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.

  Amazon Web Services (AWS) (Amazon)

  Amazon Web Services is a hosting and backend service provided by Amazon.com Inc.

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

  Place of processing: See the Amazon privacy policy – Privacy Policy.

• Infrastructure monitoring

  This type of services allows this Application 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 this Application.

  New Relic (New Relic)

  New Relic is a monitoring service provided by New Relic Inc.
  The way New Relic is integrated means that it filters all traffic of this Application, i.e., communication between the Application and the User's browser or device, while also allowing analytical data on this Application to be collected.

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

  Place of processing: US – Privacy Policy.

• Interaction with external social networks and platforms

  This type of services allow interaction with social networks or other external platforms directly from the pages of this Application.
  The interaction and information obtained through this Application 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.

  Twitter Tweet button and social widgets (Twitter, Inc.)

  The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

  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 collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Interaction with support and feedback platforms

  This type of services allows Users to interact with third party support and feedback platforms directly from the pages of this Application.
  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)

  The Zendesk Widget is a service for interacting with the Zendesk support and feedback platform provided by Zendesk Inc.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• Location-based interactions

  Geolocation (This Application)

  This Application may collect, use, and share User location Data in order to provide location-based services.
  Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Application.

  Personal Data collected: geographic position.

• Managing contacts and sending messages

  This type of services makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
  These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.

  MailChimp (The Rocket Science Group, LLC.)

  MailChimp is an email address management and message sending service provided by The Rocket Science Group, LLC.

  Personal Data collected: email address.

  Place of processing: US – Privacy Policy.

• Managing support and contact requests

  This type of services allows this Application 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)

  Zendesk is a support and contact request management service provided by Zendesk Inc.

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

  Place of processing: US – Privacy Policy.

• Remarketing and behavioral targeting

  This type of service allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.
  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
  In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page.

  AdWords Remarketing (Google Inc.)

  AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – 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 this Application with the Facebook advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Facebook Custom Audience (Facebook, Inc.)

  Facebook Custom Audience is a Remarketing and Behavioral Targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.

  Personal Data collected: Cookies and email address.

  Place of processing: US – Privacy Policy – Opt Out.

  Twitter Remarketing (Twitter, Inc.)

  Twitter Remarketing is a Remarketing and Behavioral Targeting service provided by Twitter, Inc. that connects the activity of this Application with the Twitter advertising network.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

  Remarketing through Google Analytics for Display Advertising (Google Inc.)

  Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy – Opt Out.

• RSS feed management

  This type of services allows this Application to manage RSS feeds and the distribution of their content. Depending on the characteristics of the service used, these services may be used to insert ads within the content and to gather statistics data from them.

  Feedburner (Google Inc.)

  Feedburner is a service to manage RSS feeds provided by Google Inc. It allows the collection of statistics on what content is consumed and to insert ads in it.

  Personal Data collected: Cookies and Usage Data.

  Place of processing: US – Privacy Policy.

• User database management

  This type of services allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, 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 this Application.
  Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

  Intercom (Intercom Inc.)

  Intercom is a User database management service provided by Intercom Inc. Intercom can also be used as a medium for communications, either through email, or through messages within our product(s).

  Personal Data collected: email address and various types of Data as specified in the privacy policy of the service.

  Place of processing: US – Privacy Policy.

The rights of Users

Users may exercise certain rights regarding their Data processed by the Owner.

In particular, Users have the right to do the following:

• 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. Further details are provided in the dedicated section below.
• 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, under certain circumstances, 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, under certain circumstances, 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. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
• Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.

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 without providing any justification. 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. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.

Cookie Policy

This Application uses Cookies. To learn more and for a detailed cookie notice, the User may consult the Cookie Policy.

Additional information about Data collection and processing

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

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.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users on this page and possibly within this Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.