Privacy Policy

Privacy Policy

This Website collects some Personal Data from its Users.


Data Controller

Frontiniano shirt shop – Via San Tommaso 27, 10121 Turin

Owner's email address: info@frontiniano.it

Types of Data collected

Among the Personal Data collected by this Website, independently or through third parties, there are: Cookies; Usage Data; answers to questions; click; keypress events; motion sensor events; mouse movements; position relative to scroll; touch events; e-mail; first name; surname; telephone number; payment information; purchase history; billing address; shipping address; device information; password; username; Data communicated while using the service; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); geographical region; number of Users; number of sessions; duration of the session; in-app purchases; opening the Application; Application updates; throw; operating systems; date of birth; physical address; city; nation; POSTAL CODE; sex; state; business name; marital status; profession; Universally Unique Identifier (UUID); Video.

Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless otherwise specified, all Data requested by this Website are mandatory. If the User refuses to communicate them, it may be impossible for this Website to provide the Service. In cases where this Website indicates some Data as optional, Users are free to refrain from communicating such Data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which Data are mandatory are encouraged to contact the Owner.
Any use of Cookies - or other tracking tools - by this Website or by the owners of third-party services used by this Website, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the Cookie Policy, if available.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Website and guarantees that he has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.

Method and place of processing of the collected Data

Methods of treatment

The Data Controller adopts the appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and with logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other subjects involved in the organization of this Website (administrative, commercial, marketing, legal, system administrators) or external subjects (such as third party technical service providers, postal couriers) may have access to the Data. , hosting providers, IT companies, communication agencies) also appointed, if necessary, as Data Processors by the Data Controller. The updated list of Managers can always be requested from the Data Controller.

Legal basis of the treatment

The Data Controller processes Personal Data relating to the User in the event that one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User's consent or another of the legal bases specified below, as long as the User does not object ("opt-out") to such treatment. However, this is not applicable if the processing of Personal Data is governed by European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
  • the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
  • the treatment is necessary for the execution of a task of public interest or for the exercise of public powers with which the Data Controller is invested;
  • the processing is necessary for the pursuit of the legitimate interest of the Data Controller or of third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.

Place

The Data is processed at the Data Controller's operating offices and in any other place where the parties involved in the processing are located. For more information, contact the Owner.
The User's Personal Data may be transferred to a country other than the one in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.

In case of superior protection, the User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization governed by public international law or constituted by two or more countries, such as example the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.

If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the contact details indicated at the beginning.

Storage period

The Data are processed and stored for the time required by the purposes for which they were collected.

Therefore:

  • Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
  • Personal Data collected for purposes attributable to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the treatment is based on the User's consent, the Owner can keep the Personal Data for longer until said consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.

At the end of the retention period, the Personal Data will be deleted. Therefore, upon expiry of this term, the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

Purpose of the processing of the collected data

The User's Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any malicious activity or fraudulent, as well as for the following purposes: Statistics, Displaying content from external platforms, SPAM protection, Remarketing and behavioral targeting, Tag management, Registration and authentication, Payment management, Contacting the User, Platform services and hosting, Access to accounts on third party services, Advertising, Management of data collection and online surveys, Interaction with external social networks and platforms, Transfer of Data outside the EU, Heat mapping and session recording, Interaction with live chat platforms, Hosting and backend infrastructure and Content and functionality performance testing (A/B testing).

To obtain detailed information on the purposes of the processing and on the Personal Data processed for each purpose, the User can refer to the "Details on the processing of Personal Data" section.

Details on the processing of Personal Data

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

· Access to accounts on third party services

This type of service allows this Website to collect Data from your accounts on third-party services and perform actions with them.
These services are not activated automatically, but require the express authorization of the User.

Google Drive account access (Google Ireland Limited)

This service allows this Website to connect with the User's account on Google Drive, provided by Google Ireland Limited.

Personal Data processed: surname; Data communicated while using the service; Usage Data; e-mail; device information; first name; password; Tracking Tool; username.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Contact the user

Contact form (this Website)

By filling in the contact form with their Data, the User consents to their use to respond to requests for information, quotes, or any other kind indicated by the header of the form.

Personal Data processed: email.

Category of personal information collected pursuant to the CCPA: Identifiers.

· Payment management

Payment management services allow this Website to process payments by credit card, bank transfer or other instruments. The data used for payment are acquired directly by the operator of the requested payment service without being processed in any way by this Website.
Some of these services may also allow the scheduled sending of messages to the User, such as emails containing invoices or payment notifications.

paypal (paypal)

PayPal is a payment service provided by PayPal Inc., which allows the User to make payments online.

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

Category of personal information collected pursuant to the CCPA: Internet information.

Google Pay (Google Ireland Limited)

Google Pay is a payment service provided by Google Ireland Limited, which allows the User to make online payments using their Google credentials.

Personal Data processed: surname; purchase history; Usage data; e-mail; billing address; shipping address; payment information; first name; telephone number; Tracking Tool; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet.

Klarna (Klarna AB)

Klarna is a payment service provided by Klarna AB.

Personal Data processed: surname; Usage Data; e-mail; billing address; shipping address; payment information; first name; telephone number; Tracking Tool; various types of Data as specified in the privacy policy of the service.

Place of processing: Sweden – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet.

PayPal Carrier Payments (Paypal)

PayPal Carrier Payments is a payment service provided by PayPal, Inc., which allows the User to make online payments using his mobile phone operator.

Personal Data processed: Tracking Tool.

Place of processing: Consult the Paypal privacy policy - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

PayPal Payments Hub (PayPal)

PayPal Payments Hub is a payment service provided by PayPal Inc.

Personal Data processed: Tracking Tool.

Place of processing: Consult the Paypal privacy policy - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Tag management

This type of service is functional for the centralized management of the tags or scripts used on this Website.
The use of these services involves the flow of User Data through them and, where appropriate, their retention.

Google Tag Manager (Google LLC)

Google Tag Manager is a tag management service provided by Google LLC.

Personal Data processed: Cookies; Usage data.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Management of data collection and online surveys

This type of service allows this Website to manage the creation, implementation, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse the Data of the responding Users.
The Personal Data collected depends on the information requested and provided by the Users in the corresponding online form.

These services can be integrated with a wide range of third-party services to allow the Owner to perform subsequent actions with the Data processed - for example, contact management, sending messages, statistics, advertising and payment processing.

Facebook Lead Ads (Facebook Ireland Ltd)

Facebook Lead Ads is an advertising and data collection service provided by Facebook Ireland Ltd that allows users to display advertisements in the form of forms that are pre-populated with Personal Data from their Facebook profiles, such as names and addresses e-mail. Depending on the type of advertisement, Users may be asked to provide additional information.

Submitting the form involves the collection and processing of these Data by the Data Controller in accordance with this privacy policy and only for the specific purpose indicated in the form and/or within this privacy policy, where provided.

The User can exercise his rights at any time, including the right to withdraw consent to the processing of his Data, as specified in the section containing information on the User's rights in this privacy policy.

Personal Data processed: CAP; city; surname; date of birth; Data communicated while using the service; Usage data; e-mail; physical address; nation; first name; telephone number; profession; business name; sex; state; marital status; Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt out .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; biometric information; information on the Internet; information relating to the employment relationship; indirect information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Heat mapping and session recording

Heat mapping services are used to identify the areas of this Website with which Users interact more frequently, in order to detect which of them attract the most interest. These services allow traffic data to be monitored and analyzed and are used to keep track of User behaviour.
Some of these services may record sessions and make them available for later viewing.

Smartlook (Smartsupp.com, sro)

Smartlook is a heat mapping and session logging service provided by Smartsupp.com, sro

Personal Data processed: Usage data; Tracking Tool; various types of Data as specified in the privacy policy of the service.

Place of processing: Czech Republic – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Hosting and backend infrastructure

This type of service has the function of hosting Data and files that allow this Website to function, allow its distribution and provide a ready-to-use infrastructure to deliver specific functions of this Website.

Some of the services listed below, if any, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

Google BigQuery (Google LLC)

Google BigQuery is a hosting and backend 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 .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Interaction with live chat platforms

This type of service allows you to interact with live chat platforms managed by third parties, directly from the pages of this Website, in order to be able to contact and be contacted by the support service of this Website.
In the event that an interaction service with live chat platforms is installed, it is possible that, even if the Users do not use the service, the same collects Usage Data relating to the pages in which it is installed. Also, live chat conversations may be recorded.

Smartsupp (Smartsupp.com, sro)

The Smartsupp Widget is an interaction service with the Smartsupp live chat and session recording platform, provided by Smartsupp.com, sro

Personal Data processed: Data communicated while using the service; Usage Data; Tracking Tool; various types of Data as specified in the privacy policy of the service; Video.

Place of processing: Czech Republic – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information; sensor-based information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Interaction with social networks and external platforms

This type of service allows interaction with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User's privacy settings relating to each social network.
This type of service could 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 of the respective services to ensure that the data processed on this Website is not reconnected to the User's profile.

Facebook Like button and social widgets (Facebook Ireland Ltd)

The Facebook "Like" button and social widgets are services allowing interaction with the Facebook social network, provided by Facebook Ireland Ltd.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Friend Connect

Google Friend Connect is a social interaction service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· SPAM protection

This type of service analyzes the traffic of this Website, potentially containing Users' Personal Data, in order to filter it from parts of traffic, messages and contents recognized as SPAM.

Google reCAPTCHA (Google LLC)

Google reCAPTCHA is a SPAM protection service provided by Google LLC.
The use of the reCAPTCHA system is subject to the privacy policy and terms of use of Google.

Personal Data processed: clicks; Usage data; keypress events; motion sensor events; touch events; mouse movements; position relative to scroll; answers to questions; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information; indirect information.

· Advertising

This type of service allows the User's Data to be used for commercial communication purposes. These communications are shown on this Website in the form of banners and other forms of advertising, also in relation to the interests of the User.
This does not mean that all Personal Data is used for this purpose. Data and conditions of use are set out below.
Some of the services listed below may use Tracking Tools to identify Users or they may use the behavioral retargeting technique, i.e. displaying personalized advertisements based on the User's interests and behaviour, including those detected outside this Website. For more information on this, we suggest you check the privacy policies of the respective services.
Generally, services of this type offer the possibility of deactivating this tracking. In addition to any opt-out functions provided by any of the services listed in this document, the User can read more about how to opt out of interest-based advertising in the appropriate section "How to opt out of interest-based advertising" in this document. document.

Google Ad Manager (Google Ireland Limited)

Google Ad Manager is an advertising service provided by Google Ireland Limited with which the Owner can conduct advertising campaigns jointly with external advertising networks with which the Owner, unless otherwise specified in this document, has no direct relationship.
For an understanding of Google's use of Data, please review Google's partner policies .
This service uses the "DoubleClick" Cookie, which tracks use of this Website and User behavior in relation to advertisements, products and services offered.

The User can decide at any time to disable all DoubleClick cookies by going to: Ad Settings .

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Microsoft Advertising (Microsoft Corporation)

Microsoft Advertising is an advertising service provided by Microsoft Corporation.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google DV360 (Google LLC)

Google DV360 is an advertising service provided by Google LLC which allows the Owner to manage and plan advertising campaigns. This includes ad design, being able to show those ads to the right target audience, making offers based on automated decision-making processes (so-called "auto-bids"), and measuring the performance of advertising campaigns.
Users can decide to disable all Trackers for ad personalization by visiting the Google Ad Settings page .

For an understanding of Google's use of Data, please review Google's partner policies .

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Ads similar audiences

Similar Audiences is an advertising and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, which uses Google Ads Remarketing Data to show advertisements to Users with behavioral similar to those of other Users who are already on the remarketing list due to their previous use of this Website.
Based on this Data, personalized ads will be shown to Users suggested by Google Ads Similar Audiences.

Users who do not want to be included in Similar Audiences can opt-out and disable the use of Ad Trackers by visiting Google's Ad Settings .

For an understanding of Google's use of Data, please review Google's partner policies .

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt Out ; Ireland - Privacy Policy - Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Shopalyst (Shopalyst Inc)

Shopalyst is an advertising service provided by Shopalyst Inc.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

VIADS ADVERTISING (VIADS ADVERTISING SL)

VIADS ADVERTISING is an advertising service provided by VIADS ADVERTISING SL

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Spain – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Viralize (Viralize Srl)

Viralize is an advertising service provided by Viralize Srl.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Italy – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Registration and authentication

By registering or authenticating, the User allows the Application to identify him and give him access to dedicated services.
Depending on what is indicated below, the registration and authentication services could be provided with the help of third parties. If this happens, this application will be able to access some data stored by the third party service used for registration or identification.

Google OAuth (Google LLC)

Google OAuth is a registration and authentication service provided by Google LLC and 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 .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Remarketing and behavioral targeting

This type of service allows this Website and its partners to communicate, optimize and serve advertisements based on past use of this Website by the User.
This activity is facilitated by the tracking of Usage Data and by the use of Tracking Tools to collect information which is then transferred to the partners who manage the remarketing and behavioral targeting activities.
Some services offer a remarketing option based on email address lists.
In addition to the opt-out features offered by the services listed below, the User can opt-out by visiting the Network Advertising Initiative opt-out page .

Users may also choose not to participate in certain advertising features through the corresponding device configuration options, such as the mobile device advertising configuration options or the generic advertising configuration.

Facebook Remarketing (Meta Platforms, Inc.)

Facebook Remarketing is a remarketing and behavioral targeting service provided by Meta Platforms, Inc. which connects the activity of this Website with the Facebook advertising network.

Personal Data processed: Cookies; Usage data.

Place of processing: United States – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Remarketing with Google Analytics (Google LLC)

Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC which connects the tracking activity performed by Google Analytics and its Tracking Tools 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 .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Ad Manager Audience Extension (Google Ireland Limited)

Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited which tracks visitors to this Website and allows selected advertising partners to show them personalized ads on the web.

For an understanding of Google's use of Data, please review Google's partner policies .

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Ads Remarketing (Google Ireland Limited)

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.

For an understanding of Google's use of Data, please review Google's partner policies .

Users can choose not to use Google Trackers for ad personalization by visiting Google's Ad Settings .

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Facebook Custom Audience (Facebook Ireland Ltd)

Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd which connects the activity of this Website with the Facebook advertising network.

Users can choose not to use Facebook Trackers for ad personalization by visiting this opt-out page .

Personal Data processed: email; Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google signals

This Website uses Google Signals, a feature of Google Analytics that associates the information about views collected by this Website with Google information coming from the accounts of Google users who have consented to this association for the personalization of ads. This Google information may include the User's location, search history, YouTube history and Data from Google's partner sites and is used to provide aggregate and anonymous information on the transversal behavior of Users.

If a User falls within the association described above, he will be able to access and/or delete such Data through the MyActivity function provided by Google.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt Out Opt Out ; Ireland - Privacy Policy - Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Platform services and hosting

These services are intended to host and operate key components of this Website, making it possible to deliver this Website from a single platform. These platforms provide the Owner with a wide range of tools such as, for example, analytical tools, for managing user registration, for managing comments and the database, for electronic commerce, for processing payments, etc. The use of these tools involves the collection and processing of Personal Data.
Some of these services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

Shopify (Shopify Inc.)

Shopify is a platform provided by Shopify Inc. which allows the Owner to develop, operate and host a website dedicated to electronic commerce.

Personal Data processed: surname; Usage Data; e-mail; billing address; shipping address; payment information; device information; first name; telephone number; Tracking Tool.

Place of processing: Canada – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet.

· Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behaviour.

Google Analytics (Google LLC)

Google Analytics is a web analytics service provided by Google LLC ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Cookies; Usage data.

Place of processing: United States – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Facebook Ads conversion tracking (Facebook pixel) (Meta Platforms, Inc.)

Facebook Ads conversion tracking (Facebook pixel) is a statistics service provided by Meta Platforms, Inc. that connects data from the Meta advertising network with actions performed within this Website. The Facebook pixel monitors conversions that can be attributed to Facebook, Instagram and Audience Network ads.

Personal Data processed: Cookies; Usage data.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Ads (Google LLC) conversion tracking

Google Ads conversion tracking is a statistics service provided by Google LLC that connects data from the Google Ads advertising network with actions performed on this Website.

Personal Data processed: Cookies; Usage data.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Analytics with anonymized IP (Google Ireland Limited)

Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Website, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the ads of its advertising network.
This integration of Google Analytics makes your IP address anonymous. The anonymization works by shortening the IP address of the Users within the borders of the member states of the European Union or in other countries adhering to the agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server and shortened within the United States.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Advertising Reporting Features in Google Analytics (Google Ireland Limited)

Google Analytics on this Website has Advertising Reporting Features enabled, which collect additional information from the DoubleClick cookie (web activity) and device advertising IDs (application activity). This allows the Owner to analyze specific Data relating to Users' behaviors and interests (Traffic data and User interaction data with ads) and, if enabled, Demographic Data (information on age and gender).

Users can choose not to use Google cookies by visiting Google's [Ad settings] (https://adssettings.google.com/authenticated).

Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool; various types of Data as specified in the privacy policy of the service.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Analytics for Firebase (Google Ireland Limited)

Google Analytics for Firebase, or Firebase Analytics, is an analytics service provided by Google Ireland Limited.
For an understanding of Google's use of data, please see Google's partner policies .

Firebase Analytics may share Data with other services provided by Firebase including, for example, Crash Reporting, Authentication, Remote Config or Notifications. The user can consult this privacy policy for a detailed description of the other tools used by the Owner.

To allow Firebase Analytics to work, this Website uses some identifiers for mobile devices or technologies similar to cookies.

You may opt-out of certain Firebase features through your mobile device settings. For example, you can change the advertising settings available on your mobile phone, or follow the instructions applicable to Firebase that may be present in this privacy policy.

Personal Data processed: in-app purchases; Application updates; opening the Application; Usage Data; duration of the session; unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); device information; throw; number of sessions; number of Users; geographical region; operating systems; Tracking Tool.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Identifiers; commercial information; information on the Internet; geolocation data.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Analytics demographics and interests reports (Google Ireland Limited)

Google Analytics Demographics and Interests Reporting is an advertising reporting feature that makes Demographics and Interests Data available within Google Analytics for this Website (Demographics means Age and Gender Data ).

Users can choose not to use Google cookies by visiting Google's [Ad settings] (https://adssettings.google.com/authenticated).

Personal Data processed: unique identifiers of advertising devices (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.

Place of processing: Ireland – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Microsoft Advertising Universal Event Tracking (Microsoft Corporation)

Microsoft Advertising Universal Event Tracking is a statistics service provided by Microsoft Corporation that connects data from the Microsoft advertising network with actions performed within this Website.

Personal Data processed: Usage data; Universally Unique Identifier (UUID); unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example); Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt Out .

Category of personal information collected pursuant to the CCPA: Identifiers; information on the Internet.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Floodlight Conversion Tracking (Floodlight Tag)

Google Floodlight conversion tracking (Floodlight tag) is a statistics service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, which connects Data from Google's advertising services (eg Search Ads 360 and Campaign Manager 360) with the actions performed within this Website. Depending on the settings of the service, this Data could also be processed for retargeting purposes.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt out ; Ireland - Privacy Policy - Opt out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Content and functionality performance testing (A/B testing)

The services contained in this section allow the Data Controller to track and analyze the response from the User, in terms of traffic or behaviour, in relation to changes to the structure, text or any other component of this Website .

Google Optimize

Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, ("Google").

Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Optimize 360

Google Optimize 360 ​​is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on the location this Website is accessed from, ("Google").

This service allows the Owner to target groups of Users based on their past use of this Website. Users who disable tracking by Google Analytics will not be included in the experiments created within Google Optimize 360.

Google may use the Personal Data to contextualize and personalize the ads of its advertising network.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy ; Ireland - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Visual Website Optimizer (Wingify)

Visual Website Optimizer is an A/B testing service provided by Wingify Inc.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

· Transfer of Data outside the EU

The Data Controller may transfer Personal Data collected within the EU to third countries (i.e. all countries outside the EU) only in accordance with a specific legal basis. Therefore, such Data transfers are performed according to one of the legal bases described below.

The User can request information from the Owner regarding the applicable legal basis that is actually applicable to each individual service.

Data transfer outside the EU

The Data Controller informs that the data will be transferred outside the EU (China) to a subject expressly appointed as data controller and with whom standard contractual clauses have been defined pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council and compliant with Commission Implementing Decision (EU) 2021/914 of 4 June 2021 (EU Official Gazette L199/31 of 7 June 2021).
The name of the manager and the clauses may be requested by communicating the contact details of the Data Controller.

· Viewing content from external platforms

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

Google Fonts (Google LLC)

Google Fonts is a font style visualization service managed by Google LLC that allows this Website to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Font Awesome (Fonticons, Inc. )

Font Awesome is a font style visualization service managed by Fonticons, Inc. which allows this Website to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Calendar Widget (Google Ireland Limited)

Google Calendar Widget is a calendar content visualization service managed by Google Ireland Limited that allows this Website to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Instagram widgets (Facebook Ireland Ltd)

Instagram is an image visualization service managed by Facebook Ireland Ltd which allows this Website to integrate such contents within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: Ireland – Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Vimeo Videos (Vimeo, LLC)

Vimeo is a video content viewing service managed by Vimeo, LLC which allows this Website to integrate such content within its pages.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States - Privacy Policy .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Google Site Search with AdSense

Google Site Search is a search engine embedding service managed by Google LLC or by Google Ireland Limited, depending on the location in which this Website is accessed, which allows this Website to integrate such contents within its pages .

Google Site Search may display AdSense advertisements. To find out what data is collected, please refer to the privacy information of this service.

Personal Data processed: Usage data; Tracking Tool.

Place of processing: United States – Privacy Policy – ​​Opt Out ; Ireland - Privacy Policy - Opt Out .

Category of personal information collected pursuant to the CCPA: Internet information.

This type of processing constitutes a “data sale” (“sale”) under the CCPA. In addition to the information contained in this clause, the User can consult the section describing the rights of Californian consumers, for information on how to opt-out from the sale.

Learn how to opt out of interest-based advertising

In addition to any opt-out function provided by any of the services listed in this document, Users can read more about how to disable interest-based advertising in the appropriate section of the Cookie Policy.

User rights

Users can exercise certain rights with reference to the Data processed by the Owner.

In case of superior protection, the User can exercise all the rights listed below. In any other case, the User can contact the owner to find out which rights are applicable in his case and how to exercise them.

In particular, the User has the right to:

  • withdraw consent at any time. The User can revoke the previously expressed consent to the processing of his Personal Data.
  • oppose the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are set out in the section below.
  • access their Data. The User has the right to obtain information on the Data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • check and ask for rectification. The User can verify the correctness of his Data and request its updating or correction.
  • obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation.
  • obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner.
  • receive their data or have them transferred to another owner. The User has the right to receive his Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain the transfer without obstacles to another holder. This provision is applicable when the Data are processed with automated tools and the processing is based on the User's consent, on a contract of which the User is a party or on contractual measures connected to it.
  • propose a complaint. The User can lodge a complaint with the competent personal data protection supervisory authority or take legal action.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are reminded that, should their Data be processed for direct marketing purposes, they may object to the processing without providing any reason. To find out if the Data Controller processes data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise the User's rights, Users can direct a request to the contact details of the Owner indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.

Applicability of the higher level of protection

While most of the provisions of this document apply to all Users, some are expressly subject to the applicability of a higher level of protection to the processing of Personal Data.

This superior level of protection is always guaranteed when the treatment:

  • is performed by a Data Controller based in the EU; that is to say
  • it concerns Personal Data of Users located in the EU and is functional to the offer of goods or services for consideration or free of charge to such Users; that is to say
  • concerns Personal Data of Users located in the EU and allows the Owner to monitor the behavior of such Users to the extent that such behavior takes place within the Union.

Cookie Policy

This Website uses Trackers. To find out more, the User can consult the Cookie Policy .

Learn more about treatment

Defense in court

The User's Personal Data may be used by the Owner in court or in the preparatory stages for its eventual establishment for the defense against abuse in the use of this Website or related Services by the User.
The User declares to be aware that the Owner may be obliged to disclose the Data by order of the public authorities.

Specific information

At the request of the User, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System and maintenance logs

For needs related to operation and maintenance, this Website and any third party services used by it may collect system logs, i.e. files that record the interactions and which may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Further information in relation to the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Response to “Do Not Track” requests

This Website does not support “Do Not Track” requests.
To find out if any third-party services used support them, the User is invited to consult the respective privacy policies.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website as well as, if technically and legally feasible, by sending a notification to Users via one of the contact information you have. Therefore, please consult this page frequently, referring to the date of the last modification indicated at the bottom.

If the changes concern treatments whose legal basis is consent, the Data Controller will collect the User's consent again, if necessary.

Information for California Consumers

This part of the document supplements and completes the information contained in the rest of the privacy policy and is provided by the company that operates this Website and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as "we ", "our" or "our").

The provisions contained in this section apply to all Users who are considered consumers who are residents of the state of California, United States of America, pursuant to the "California Consumer Privacy Act of 2018" (such Users are referred to below simply as "you ”, “your”, "you" or "your"), and, for them, these provisions prevail over any other possibly divergent or conflicting provision contained in this privacy policy.

This part of the document uses the term “personal information” as defined by the California Consumer Privacy Act (CCPA).

Categories of personal information collected, disclosed or sold

This section summarizes the categories of personal information we have collected, disclosed or “sold” under the CCPA and the related purposes of the processing. You can find detailed information on these activities in the section entitled "Details on the processing of Personal Data" in this document.

Information We Collect: The categories of personal information we collect

We have collected the following categories of personal information about you: identifiers, business information, biometric information, internet information, geolocation data, sensor-based information, employment relationship information, and indirect information.

We will not collect additional categories of personal information without first notifying you of a new policy.

How we collect information: What are the sources of the personal information we collect?

We collect the above categories of personal information, directly or indirectly, from you when you use this Website.

For example, you directly provide us with your personal information when you submit requests through any form on this Website. You also indirectly provide us with personal information when you browse this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with providing the Service or operating this Website and its features.

How we use the information collected: sharing and communicating your personal information with third parties for operational purposes.

We may disclose your personal information to third parties for operational and service purposes. In this case, we enter into a written contract with that third party which obliges the recipient of your personal information to keep that information confidential and not to use it for any purpose other than what is necessary for the performance of the contract.

We may also disclose your personal information to third parties when you ask us to or authorize us to do so in order to provide you with our Service.

For further information on the purposes of the processing, please consult the relevant section of this document.

Sale of your personal information

For the purposes of this document, the term "sale" means "to sell, assign, release, make public, disclose, disseminate, make available, transfer or otherwise communicate orally, in writing or by electronic means, a consumer's personal information by a company to another company or to third parties, either for consideration or for obtaining another type of profit”.

This means that, for example, a sale can take place whenever an application publishes advertisements, carries out statistical analyzes on its traffic or views or simply uses tools such as social network plug-ins and similar tools.

Your right to opt out of the sale of your personal information

You have the right to opt out of the sale of your personal information. This means that whenever you ask us not to sell your data, we will comply with your request.
Such requests can be made freely, at any time, and without submitting any request subject to verification, by simply following the instructions below.

Instructions for opting out of the sale of personal information

If you would like further information or to exercise your right to opt-out in relation to any sales made from this Website, whether online or offline, you can contact us using the contact details provided herein.

What are the purposes for which we use your personal information?

We may use your personal information to allow the proper functioning of this Website and its features ("operational purposes"). In such cases, your personal information will be treated appropriately and proportionate to the purposes for which it was originally collected and strictly within the limits of compatible purposes.

We may also use your personal information for other reasons, such as for commercial purposes (as indicated in the "Details on the processing of Personal Data" section herein), as well as to comply with the law and defend our rights before the competent authorities when our rights or interests are threatened or when we suffer damage.

We will not use your personal information for different, unrelated or incompatible purposes, without first communicating to you a new information.

Your California privacy rights and how to exercise them

Right to knowledge and portability

You have the right to know the following:

  • the categories of personal information we collect about you and the sources of that information, the purposes for which we use your personal information and with whom we share it;
  • in case of sale or communication of personal information to third parties for operational purposes, we will provide you with two separate lists in which we will communicate:
    • for sale, the categories of personal information disclosed to each category of recipients; And
    • for communication to third parties for operational purposes, the categories of personal information obtained from each category of recipients;

The above information will be limited to personal information collected or used in the last 12 months.

In the event that our response is provided electronically, the information contained therein will be "portable", i.e. delivered in a compatible format so as to allow you to transmit the information to other entities without impediments - provided this is technically feasible.

Right to request deletion of your personal information

You have the right to request the deletion of any of your personal information, subject to the exceptions provided by law (such as, but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents, for purposes of protection from fraudulent or illegal activities, to exercise certain rights, etc.).

If no statutory exception applies, following the exercise of your right, we will delete your personal information and ask our suppliers to do the same.

How to exercise your rights

To exercise the rights described above, you must submit a verifiable request by contacting us using the contact details provided herein.

In order to be able to respond to your request, it is necessary for us to be able to identify you. For this you can exercise the above rights only by submitting a verifiable request which must:

  • provide sufficient information to enable us to reasonably verify that you are the individual to whom the personal information we have collected relates or an authorized representative;
  • describe your request with a degree of detail that is sufficient for us to understand, evaluate and respond correctly to what you ask us.

We will not respond to any request if we are unable to verify your identity and, therefore, confirm that the information in our possession actually refers to you.

If you cannot make a verifiable request yourself, you can designate a person registered with the California Secretary of State to do it on your behalf.

If you are an adult, you can make a verifiable request on behalf of someone under your parental authority.

It is possible to submit a maximum number of 2 requests within 12 months.

How and in what time we will handle your request

We will confirm that we have received your request within 10 days and provide you with information on how we will process it.

We will respond to the merits of the request within 45 days of receiving it. If we need more time, we'll explain why and let you know how much time we need. In this regard, please note that it may take up to 90 days to fulfill your request.

Our communications will cover the period of the previous 12 months.

If we deny your request, we will explain the reason for the refusal.

We will not charge any fees for processing or responding to your verifiable request unless it is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or deny your request. In both cases, we will notify you of our decisions and explain the reasons.

Information for Users residing in Brazil

This part of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that manages this Website and, where applicable, by its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as " we", "our" or "our").
The provisions contained in this section apply to all Users who are residents of Brazil, pursuant to the "Lei Geral de Proteção de Dados" (such Users are referred to below simply as "you", "your", "you" or "your"). For these Users, these provisions prevail over any other possibly divergent or conflicting provision contained in this privacy policy.
In this part of the document, the term “personal information” is used as defined by the Lei Geral de Proteção de Dados ( LGPD ).

Legal bases under which we process your personal information

We only process your personal information if one of the legal grounds for such processing exists. The legal bases are as follows:

  • your consent to the processing activities in question;
  • compliance with legal obligations that we are required to comply with;
  • the execution of rules dictated by laws or regulations or by contracts, agreements or other similar legal instruments;
  • studies conducted by research institutions, preferably carried out on anonymised personal information;
  • the execution of a contract and the related pre-contractual obligations, if you are a party to such a contract;
  • the exercise of our rights in court, administrative proceedings or arbitration;
  • your defense or physical safety or that of a third party;
  • health protection - in the context of procedures implemented by entities or professionals in the health sector;
  • our legitimate interest, provided your fundamental rights and freedoms do not override those interests; And
  • credit protection.

To find out more about the legal bases, you can contact us at any time using the contact details provided in this document.

Categories of personal information processed

To find out which categories of personal information are processed, you can refer to the "Details on the processing of Personal Data" section in this document.

Why we treat your personal information

To find out why we process your personal information, please refer to the "Details on the processing of personal data" and "Purpose of processing the collected data" sections in this document.

Your privacy rights in Brazil, how to make a request and how it will be handled by us

Your privacy rights in Brazil

You have the right to:

  • obtain confirmation of the existence of processing activities concerning your personal information;
  • access your personal information;
  • obtain the rectification of your incomplete, inaccurate or outdated personal information;
  • obtain the anonymization, blocking or deletion of unnecessary or excessive personal information, or of that information that is treated contrary to the provisions of the LGPD;
  • obtain information regarding the possibility of giving or refusing your consent and the related consequences;
  • obtain information about the third parties with whom we share your personal information;
  • obtain, upon your explicit request, the portability of your personal information (with the exception of anonymised information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;
  • obtain the cancellation of the personal information processed if the processing was carried out on the basis of your consent, unless one or more of the exceptions provided for in Article 16 of the LGPD apply;
  • withdraw your consent at any time;
  • lodge a complaint regarding your personal information with the ANPD (National Data Protection Authority) or a consumer protection body;
  • oppose processing activities in cases where such processing is not carried out in compliance with the provisions of the law;
  • request clear and adequate information regarding the criteria and procedures used in the context of automated decision-making processes; And
  • request the review of decisions that harm your interests, made exclusively on the basis of automated decision-making processes of your personal information. These include decisions to shape your personal, professional, consumer or creditor profile, or other aspects of your personality.

You will never be discriminated against, nor will you suffer any treatment that is unfavorable to you in any way, following the exercise of your rights.

How to submit a request

You can submit an explicit request to exercise your rights free of charge, at any time, using the contact details in this document or through your legal representative.

How and in what time we will handle your request

We will do our best to answer your request as soon as possible.
In any case, if it is impossible for us to do so, we will make sure to inform you of the factual or legal reasons which prevent us from immediately complying or following up on your request. If your personal information is not processed by us, if we are able to do so, we will indicate the natural or legal person to whom to address your requests.

In the event that you decide to submit an access request or a request for confirmation of the existence of the processing of personal information, please make sure to specify whether you prefer to receive your personal information in electronic or paper format.
You will also need to let us know if you want an immediate response, in which case you will receive a simplified response, or if you require complete disclosure.
In the latter case, we will respond within 15 days from the moment of your request, providing you with all the information regarding the origin of your personal information, confirmation or not of the existence of personal information concerning you, all the criteria used for the treatment and the purposes of such processing, while safeguarding our commercial and industrial secrets.

In the event that you decide to submit a request for rectification, deletion, anonymization or blocking of personal information , we will make sure to immediately inform the other parties with whom we have shared your personal information of your request so that they can in turn satisfy your request - except in cases where such communication is impossible or excessively burdensome for us.

Transfer of personal information outside Brazil in cases permitted by law

We may transfer your personal information outside the Brazilian territory in the following cases:

  • when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedure bodies, as required by the tools made available by international law;
  • when the transfer is necessary to defend the life or limb of you or a third party;
  • when the transfer is authorized by the ANPD;
  • when the transfer results from an obligation assumed in the context of an international cooperation agreement;
  • when the transfer is necessary for the exercise of public order or for the performance of a public service;
  • when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and the related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.

Definitions and legal references

Personal Data (or Data)

Personal data is any information which, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.

Usage Data

This is information collected automatically through this Website (also by third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User who connects with this Website, the addresses in URI (Uniform Resource Identifier) ​​notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc. .) the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of the pages consulted, to the parameters relating to the operating system and the IT environment of the User.

User

The individual who uses this Website who, unless otherwise specified, coincides with the interested party.

Interested

The natural person to whom the Personal Data refer.

Data Processor (or Manager)

The natural person, legal person, public administration and any other body that processes personal data on behalf of the Data Controller, according to what is set out in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, service or other body which, individually or together with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures relating to the functioning and use of this Website. The Data Controller, unless otherwise specified, is the owner of this Website.

This Website (or this Application)

The hardware or software tool through which the Personal Data of Users are collected and processed.

Service

The Service provided by this Website as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools that consist of small portions of data stored in the User's browser.

Tracking Tool

Tracker means any technology - e.g. Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - which allows tracking Users, for example by collecting or saving information on the User's device.

Video

Provides access to the videos that the user has uploaded and those in which he has been tagged.

Legal references

This privacy statement has been prepared on the basis of multiple legislative systems, including articles 13 and 14 of Regulation (EU) 2016/679.

Unless otherwise specified, this privacy statement applies exclusively to this Website.