Privacy Policy ENG

Summary of the policy

Personal Data processed for the following purposes and using the following services:

Registration and authentication

WordPress.com Single Sign On

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

Platform and hosting services

WordPress.com

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

Statistics

WordPress Stats and Google Analytics

Personal Data: Usage Data; Tracking Tool

contact info

Data Controller

International Leather Imp. Exp. of Mazzante D. M. & C. S.N.C. – Via Purità, 163 – Monte San Giusto MC

Owner’s email address: iliesnc@tin.it

Complete policy

Data Controller

International Leather Imp. Exp. of Mazzante D. M. & C. S.N.C. – Via Purità, 163 – Monte San Giusto MC

Owner’s email address: iliesnc@tin.it

Types of Data collected

Among the Personal Data collected by this Application, independently or through third parties, there are: Tracking Tool; Usage data.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the collection of the Data itself.

Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Application.

Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to communicate them, it may be impossible for this Application to provide the Service. In cases where this Application 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 its operation.

Users who have doubts about which Data is mandatory are encouraged to contact the Owner.

Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application has the purpose of providing the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application.

Method and place of processing of the collected data

Treatment methods

The Data Controller adopts appropriate security measures aimed at preventing 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 parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, 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.

Place

The Data is processed at the Owner’s operational offices and in any other place where the parties involved in the processing are located. For further 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.

Retention period

Unless otherwise indicated in this document, Personal Data is processed and stored for the time required by the purpose for which it was collected and may be stored for a longer period due to any legal obligations or based on the consent of the Users.

Purpose of the Processing of Collected Data

The User’s Data is collected to allow the Owner to provide the Service, fulfill legal obligations, respond to requests or enforcement actions, protect their rights and interests (or those of Users or third parties), identify any malicious activities or fraudulent, as well as for the following purposes: Platform and hosting services, Statistics and Registration and authentication.

To obtain detailed information on the purposes of the processing and 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:

Registration and authentication

By registering or authenticating, the User allows this Application to identify him and give him access to dedicated services.

Depending on what is indicated below, registration and authentication services may 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.

Some of the services indicated below may also collect Personal Data for targeting and profiling purposes; To find out more, please refer to the description of each service.

WordPress.com Single Sign On

WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Data Controller manages the processing of Data, and connected to the WordPress.com network.

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

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

Category of personal information collected under the CCPA: information about activities on the Internet or other networks.

This type of treatment constitutes:

a sale under the CCPA, VCDPA, CPA, CTDPA and UCPA

targeted advertising under the CPA, CTDPA and UCPA

Platform and hosting services

These services are intended to host and operate key components of this Application, making it possible to provide this Application 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 e-commerce, for payment processing, etc. The use of these tools involves the collection and processing of Personal Data.

Some of these services work through servers that are geographically located in different locations, making it difficult to determine the exact location where Personal Data is stored.

WordPress.com

WordPress.com is a platform provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Owner manages the processing of Data, which allows the Owner to develop, operate and host this Application.

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

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

Category of personal information collected under the CCPA: information about activities on the Internet or other networks.

This type of treatment constitutes:

a sale pursuant to the CPA, CTDPA and UCPA

targeted advertising under the CPA, CTDPA and UCPA

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to keep track of the User’s behavior.

WordPress Stats

WordPress Stats is a statistics service provided by Automattic Inc. or by Aut O’Mattic A8C Ireland Ltd., depending on how the Data Controller manages the processing of Data.

Personal Data processed: Usage data; Tracking Tool.

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

Category of personal information collected under the CCPA: information about activities on the Internet or other networks.

This type of treatment constitutes:

a sale under the CCPA, VCDPA, CPA, CTDPA and UCPA

Google Analytics

Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Data Controller manages the processing of Data, (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.

Google may use 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 – Opt Out; Ireland – Privacy Policy – Opt Out.

Category of personal information collected under the CCPA: information about activities on the Internet or other networks.

This type of treatment constitutes:

a sale under the CCPA, VCDPA, CPA, CTDPA and UCPA

Cookie Policy

This Application uses Tracking Tools. To find out more, Users can consult the Cookie Policy.

Further information for users

Legal basis of the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

the User has given consent for one or more specific purposes; Note: in some jurisdictions the Owner may be authorized to process Personal Data without the User’s consent or another of the legal bases specified below, until the User objects (“opt-out”) to this treatment. However, this is not applicable if the processing of Personal Data is regulated by European legislation on the protection of Personal Data;

the processing is necessary for the execution of a contract with the User and/or the execution of pre-contractual measures;

the processing is necessary to fulfill a legal obligation to which the Data Controller is subject;

the processing is necessary for the execution of a task of public interest or for the exercise of public powers vested in the Data Controller;

the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

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

Learn more about storage time

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 Owner will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.

When the processing is based on the User’s consent, the Data Controller may retain the Personal Data for longer until such consent is revoked. Furthermore, the Owner may be obliged to retain 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 deadline the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

User Rights

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

In particular, within the limits established by law, the User has the right to:

revoke your consent at any time. The User may revoke the previously expressed consent to the processing of their Personal Data.

Oppose

Details on the right to object

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

Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing at any time, free of charge and without providing any reason. If Users object to processing for direct marketing purposes, the Personal Data will no longer be processed for these purposes. To find out whether the Owner processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise your rights

To exercise their rights, Users can direct a request to the Owner’s contact details indicated in this document. The request can be filed free of charge and the Owner will respond as quickly as possible, in any case within one month, providing the User with all the information required by law. Any rectifications, cancellations or limitations of processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Owner communicates these recipients to the User if he requests it.

Additional information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, supersedes any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of the processing, the categories of recipients of the personal data, if any, the retention period and other information on the Personal Data can be found in the section entitled “Detailed information on the processing of Personal Data” within this document.

Your rights under the Federal Data Protection Act

Users can exercise some rights relating to their data within the limits of the law, including the following:

Right of access to Personal Data;

the right to object to the processing of their Personal Data (which also allows Users to request the limitation of the processing of Personal Data, the deletion or destruction of Personal Data, the prohibition on disclosure of Personal Data to third parties);

right to receive your Personal Data and to transfer it to another data controller (data portability);

right to request rectification of incorrect Personal Data.

How to exercise these rights

Any requests to exercise the User’s rights can be addressed to the Owner through the contact details provided in this document. These requests are free and the Owner will respond as quickly as possible, providing Users with the information required by law.

Additional information for Users in Brazil

This section of the document integrates and completes the information contained in the rest of the privacy policy and is provided by the entity that operates this Application and, where applicable, its parent company and its subsidiaries and affiliates (for the purposes of this section collectively referred to as “we “, “our” or “ours”).

This section applies to all Users in Brazil (such Users are referred to herein simply as “you”, “your”, “you” or “yours”), pursuant to the “Lei Geral de Proteção de Dados and, for such Users, prevails over any other potentially divergent or conflicting information contained in this privacy policy.

In this part of the document the term “personal information” as defined by the LGPD is used.

Legal bases on which we process your personal information

We process your personal information only if one of the legal bases 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 satisfy;

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 anonymized personal information;

the execution of a contract and the related pre-contractual obligations, if you are part of this contract;

the exercise of our rights in court, in administrative proceedings or in arbitration;

the defense or physical safety of you or a third party;

health protection – in the context of procedures implemented by entities or professionals in the healthcare sector;

our legitimate interests, provided that your fundamental rights and freedoms do not override such 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 process 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 the Processing of Collected Data” sections in this document.

Your privacy rights in Brazil, how to make a request and how we will handle it

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 rectification of your incomplete, inaccurate or out-of-date personal information;

obtain the anonymisation, blocking or deletion of unnecessary or excessive personal information, or that information which is processed in conflict with 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 anonymized information) to other suppliers of products or services, provided that our commercial and industrial secrets are safeguarded;

obtain the deletion 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 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 in any way suffer any treatment that is unfavorable to you, following the exercise of your rights.

How to submit a request

You can send 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 respond to your request as soon as possible.

In any case, if it is impossible for us to do so, we will make sure to communicate to you the factual or legal reasons that prevent us from immediately satisfying 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 to you the natural or legal person to whom your requests should be addressed.

In the event that you decide to submit a request for access or a request for confirmation of the existence of the processing of personal information, please be 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 full disclosure.

In the latter case, we will respond within 15 days from the time 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 processing and the purposes of such processing, while safeguarding our commercial and industrial secrets.

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

Transfer of personal information outside of Brazil where permitted by law

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

when the transfer is necessary for international legal cooperation between intelligence services, investigative and criminal procedural bodies, as provided for by the tools made available by international law;

when the transfer is necessary to defend the life or physical safety of you or third parties;

when the transfer is authorized by the ANPD;

when the transfer arises 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 related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.

Futher information for California consumers

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the business running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the state of California, United States of America, according to the ” California Consumer Privacy Act of 2018” (the “CCPA”), as updated by the “California Privacy Rights Act” (the “CPRA”) and subsequent regulations. For such consumers, this section supersedes any other possibly divergent or conflicting information contained in the privacy policy.

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

Notice at collection

Categories of personal information collected, used, sold, or shared

In this section we summarize the categories of personal information that we’ve collected, used, sold, or shared and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Personal Data” within this document.

Information we collect: the categories of personal information we collect

We have collected the following categories of personal information about you: internet or other electronic network activity information.

We do not collect sensitive personal information.

We will not collect additional categories of personal information without notifying you.

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

We may use your personal information to allow the operational functioning of this Application and features thereof (“business purposes”). In such cases, your personal information will be processed in a fashion necessary and proportionate to the business purpose for which it was collected, and strictly within the limits of compatible operational purposes.

We may also use your personal information for other reasons such as for commercial purposes (as indicated within the section “Detailed information on the processing of Personal Data” within this document), as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.

How long do we keep your personal information?

Unless stated otherwise inside the “Detailed information on the processing of Personal Data” section, we will not retain your personal information for longer than is reasonably necessary for the purpose(s) they have been collected for.

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

We collect the above-mentioned categories of personal information, either directly or indirectly, from you when you use this Application.

For example, you directly provide your personal information when you submit requests via any forms on this Application. You also provide personal information indirectly when you navigate this Application, as personal information about you is automatically observed and collected.

Finally, we may collect your personal information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

For our purposes, the word “third party” means a person who is not any of the following: a service provider or a contractor, as defined by the CCPA.

We disclose your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

Sale or sharing of your personal information

For our purposes, the word “sale” means any “selling, renting, releasing, disclosing, disseminating, making available, transferring or otherwise communicating orally, in writing, or by electronic means, a consumer’s personal information by the business to a third party, for monetary or other valuable consideration”, as defined by the CCPA.

This means that, for example, a sale can happen whenever an application runs ads, or makes statistical analyses on the traffic or views, or simply because it uses tools such as social network plugins and the like.

For our purposes, the word “sharing” means any “sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged”, as defined by the CCPA.
Please note that the exchange of personal information with a service provider pursuant to a written contract that meets the requirements set by the CCPA, does not constitute a sale or sharing of your personal information.

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

We sell or share your personal information with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.

You have the right to opt out of the sale or sharing of your personal information. This means that whenever you request us to stop selling or sharing your personal information, we will abide by your request.
Such requests can be made freely, at any time, without submitting any verifiable request.
To fully exercise your right to opt out, you can contact us at any time using the contact details provided in this document.
For a simplified opt-out method you can also use the privacy choices link provided on this Application.

If you want to submit requests to opt out of the sale or sharing of personal information via a user-enabled global privacy control, like the Global Privacy Control (“ GPC”), you are free to do so and we will abide by such request in a frictionless manner (as defined in the CPRA regulations). The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

We use any personal information collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Once you have opted out, we are required to wait at least 12 months before asking whether you have changed your mind.

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

You have the right to request that we disclose to you:

the categories of personal information that we collect about you;
the sources from which the personal information is collected;
the purposes for which we use your information;
to whom we disclose such information;
the specific pieces of personal information we have collected about you.

You also have the right to know what personal information is sold or shared and to whom. In particular, you have the right to request two separate lists from us where we disclose:

the categories of personal information that we sold or shared about you and the categories of third parties to whom the personal information was sold or shared;
the categories of personal information that we disclosed about you for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance — provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Application, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.).

If no legal exception applies, as a result of exercising your right, we will delete your personal information and notify any of our service providers and all third parties to whom we have sold or shared the personal information to do so — provided that this is technically feasible and doesn’t involve disproportionate effort.

The right to correct inaccurate personal information

You have the right to request that we correct any inaccurate personal information we maintain about you, taking into account the nature of the personal information and the purposes of the processing of the personal information.

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

You have the right to opt out of the sale or sharing of your personal information. You also have the right to request that we limit our use or disclosure of your sensitive personal information.

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

We will not discriminate against you for exercising your rights under the CCPA. This means that we will not discriminate against you, including, but not limited to, by denying goods or services, charging you a different price, or providing a different level or quality of goods or services just because you exercised your consumer privacy rights.

However, if you refuse to provide your personal information to us or ask us to delete or stop selling your personal information, and that personal information or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction.

To the extent permitted by the law, we may offer you promotions, discounts, and other deals in exchange for collecting, keeping, or selling your personal information, provided that the financial incentive offered is reasonably related to the value of your personal information.

How to exercise your rights

To exercise the rights described above, you need to submit your verifiable request to us by contacting us via the details provided in this document.

For us to respond to your request, it’s necessary that we know who you are. Therefore, you can only exercise the above rights by making a verifiable request which must:

provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative;
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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

Making a verifiable consumer request does not require you to create an account with us. We will use any personal information collected from you in connection with the verification of your request solely for the purposes of verification and shall not further disclose the personal information, retain it longer than necessary for purposes of verification, or use it for unrelated purposes.

If you cannot personally submit a verifiable request, you can authorize a person registered with the California Secretary of State to act on your behalf.

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

You can submit a maximum number of 2 requests over a period of 12 months.

How and when we are expected to handle your request

We will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

We will respond to your request within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our disclosure(s) will cover the preceding 12-month period. Only with regard to personal information collected on or after January 1, 2022, you have the right to request that we disclose information beyond the 12-month period, and we will provide them to you unless doing so proves impossible or would involve a disproportionate effort.

Should we deny your request, we will explain you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Further information for Virginia consumers

This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the controller running this Application and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the Commonwealth of Virginia, according to the “Virginia Consumer Data Protection Act” (the “VCDPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the VCDPA.

Categories of personal data processed

In this section, we summarize the categories of personal data that we’ve processed and the purposes thereof. You can read about these activities in detail in the section titled “Detailed information on the processing of Persona Data” within this document.

Categories of personal data we collect

We have collected the following categories of personal data: identifiers and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

To find out why we process your personal data, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.

We won’t process your information for unexpected purposes, or for purposes incompatible with the purposes originally disclosed, without your consent.
You can freely give, deny, or withdraw such consent at any time using the contact details provided in this document.

How we use the data we collect: sharing of your personal data with third parties

We share your personal data with the third parties listed in detail in the section titled “Detailed information on the processing of Personal Data” within this document. These third parties are grouped and categorized in accordance with the different purposes of processing.
For our purposes, the word “third party” means “a natural or legal person, public authority, agency, or body other than the consumer, controller, processor, or an affiliate of the processor or the controller” as defined by the VCDPA.

Sale of your personal data

For our purposes, the word “sale” means any “exchange of personal data for monetary consideration by us to a third party“ as defined by the VCDPA.
Please note that according to the VCDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the VCDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.
As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal information may be considered a sale under VCDPA.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request. To fully exercise your right to opt out you can contact us at any time using the contact details provided in this document.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

We do not process your personal data for targeted advertising. If we decide to do so, we will inform you beforehand and will grant your right to opt out of the processing of your personal data for targeted advertising.

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data: the right to know. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity — provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
non-discrimination. We will not discriminate against you for exercising your rights under the VCDPA. This means that we will not, among other things, deny goods or services, charge you a different price, or provide a different level or quality of goods or services just because you exercised your consumer privacy rights. However, if you refuse to provide your personal data to us or ask us to delete or stop selling your personal data, and that personal data or sale is necessary for us to provide you with goods or services, we may not be able to complete that transaction. To the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if you have exercised your right to opt out, or our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are.

We will not respond to any request if we are unable to verify your identity using commercially reasonable efforts and therefore confirm that the personal data in our possession actually relate to you. In such cases, we may request that you provide additional information which is reasonably necessary to authenticate you and your request.

Making a consumer request does not require you to create an account with us. However, we may require you to use your existing account. We will use any personal data collected from you in connection with your request solely for the purposes of authentication, without further disclosing the personal data, retaining it longer than necessary for purposes of authentication, or using it for unrelated purposes.

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

How and when we are expected to handle your request

We will respond to your request without undue delay, but in all cases and at the latest within 45 days of its receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 60 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year. If your request is manifestly unfounded, excessive or repetitive, we may charge a reasonable fee or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind them.

Further information for Colorado consumers

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Colorado, according to the “Colorado Privacy Act” (the “CPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CPA.

Categories of personal data processed

Categories of personal data we collect

We have collected the following categories of personal data: identifiers and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

For our purposes, the word “third party” means “a person, public authority, agency, or body other than a consumer, controller, processor, or affiliate of the processor or the controller.” as defined by the CPA.

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CPA.

For our purposes, the word “sale”, “sell”, or “sold” means “the exchange of personal data for monetary or other valuable consideration by a controller to a third party” as defined by the CPA.

Please note that according to the CPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CPA.

Please note that according to the CPA, targeted advertising does not include: “advertisements directed to a consumer in response to the consumer’s request for information or feedback; advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; or processing personal data solely to measure or report advertising frequency, performance or reach”.

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

You have the right to opt out of the processing of your personal data for targeted advertising. This means that whenever you ask us to stop processing your data for targeted advertising, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Universal opt-out mechanism: Global privacy control

If you want to submit requests to opt-out of the sale of personal data or the targeted advertising via a user-enabled global privacy control, like the Global Privacy Control (“ GPC”), you are free to do so and we will abide by such request. The GPC consists of a setting or extension in the browser or mobile device and acts as a mechanism that websites can use to indicate they support the GPC signal. If you want to use GPC, you can download and enable it via a participating browser or browser extension. More information about downloading GPC is available here.

Your privacy rights under the Colorado Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.

In any case, we will not increase the cost of, or decrease the availability of, a product or service, based solely on the exercise of any of your rights and unrelated to the feasibility or the value of a service. However, to the extent permitted by the law, we may offer a different price, rate, level, quality, or selection of goods or services to you, including offering goods or services for no fee, if our offer is related to your voluntary participation in a bona fide loyalty, rewards, premium features, discounts, or club card program.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

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

How and when we are expected to handle your request

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to two requests per year.

Further information for Connecticut consumers

This section applies o all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Connecticut, according to “An Act Concerning Personal Data Privacy and Online Monitoring ” (also known as “The Connecticut Data Privacy Act” or the “CTDPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the CTDPA.

Categories of personal data processed

Categories of personal data we collect

We have collected the following categories of personal data: identifiers and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the CTDPA.

Please note that according to the CTDPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the CTDPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across non affiliated websites, applications, or online services to predict consumer preferences or interests” as defined by CTDPA.

Please note that according to the CTDPA, targeted advertising does not include: “advertisements based on activities within a controller’s own web sites or online applications; advertisements based on the context of a consumer’s current search query, visit to an internet web site or online application; advertisements directed to a consumer in response to the consumer’s request for information or feedback; or processing personal data solely to measure or report advertising frequency, performance or reach”.

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Universal opt-out mechanism: Global privacy control

Your privacy rights under the Connecticut Data Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
correct inaccurate personal data. You have the right to request that we correct any inaccurate personal data we maintain about you, taking into account the nature of the personal data and the purposes of the processing of the personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

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

How and when we are expected to handle your request

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request. It is your right to appeal such decision by submitting a request to us via the details provided in this document. Within 45 days of receipt of the appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, you may contact the Attorney General to submit a complaint.

We do not charge a fee to respond to your request, for up to one request per year.

Further information for Utah consumers

This section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are consumers residing in the State of Utah, according to the “Consumer Privacy Act” (the “UCPA”), and, for such consumers, it supersedes any other possibly divergent or conflicting information contained in the privacy policy.

This part of the document uses the term “personal data” as defined in the UCPA.

Categories of personal data processed

Categories of personal data we collect

We have collected the following categories of personal data: identifiers and internet information

We do not collect sensitive data.

We will not collect additional categories of personal data without notifying you.

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

For our purposes, the word “third party” means “a person other than: the consumer, controller, or processor; or an affiliate or contractor of the controller or the processor” as defined by the UCPA.

Sale of your personal data

As specified in the “Detailed information on the processing of Personal Data” section of this document, our use of your personal data may be considered a sale under the UCPA.

Please note that according to the UCPA, the disclosure of personal data to a processor that processes personal data on behalf of a controller does not constitute a sale. In addition, other specific exceptions set forth in the UCPA may apply, such as, but not limited to, the disclosure of personal data to a third party for the provision of a product or service requested by you.

Your right to opt out of the sale of your personal data and how you can exercise it

You have the right to opt out of the sale of your personal data. This means that whenever you request us to stop selling your data, we will abide by your request.

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purpose of complying with the request.

Processing of your personal data for targeted advertising

As specified in the “Detailed information on the processing of Personal Data” section of this document, we may use your personal data for targeted advertising purposes.

For our purposes, the word “targeted advertising” means “displaying to a consumer an advertisement that is selected based on personal data obtained or inferred over time from the consumer’s activities across nonaffiliated websites, applications, or online services to predict consumer preferences or interests” as defined by UCPA.

Please note that according to the UCPA, targeted advertising does not include: “advertisements based on activities within a controller’s own websites or online applications or any affiliated website or online application; advertisements based on the context of a consumer’s current search query, visit to an web site or online application; advertisements directed to a consumer in response to the consumer’s request for information, product, a service or feedback; or processing personal data solely to measure or report advertising performance, reach or frequency.”

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

To fully exercise your right to opt out you can contact us at any time, using the contact details provided in this document.

For a simplified opt-out method you can also use the privacy choices link provided on this Application.

We use any personal data collected from you in connection with the submission of your opt-out request solely for the purposes of complying with the opt-out request.

Your privacy rights under the Utah Consumer Privacy Act and how to exercise them

You may exercise certain rights regarding your data processed by us. In particular, you have the right to do the following:

access personal data. You have the right to request that we confirm whether or not we are processing your personal data. You also have the right to access such personal data.
request the deletion of your personal data. You have the right to request that we delete any of your personal data.
obtain a copy of your personal data. We will provide your personal data in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible.
opt out of the processing of your personal data for the purposes of targeted advertising or the sale of personal data.

How to exercise your rights

To exercise the rights described above, you need to submit your request to us by contacting us via the contact details provided in this document.

For us to respond to your request, we need to know who you are and which right you wish to exercise.

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

How and when we are expected to handle your request

Should we deny your request, we will explain to you the reasons behind our denial without undue delay, but in all cases and at the latest within 45 days of receipt of the request.

We do not charge a fee to respond to your request, for up to one request per year.

Definitions and legal references

Personal Data (or Data)

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 constitutes personal data.

Usage Data

This is the information collected automatically through this Application (also by third-party applications integrated into this Application), including: IP addresses or domain names of the computers used by the User who connects with this Application, addresses in URI notation ( Uniform Resource Identifier), 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 the sequence of pages consulted, the parameters relating to the operating system and the User’s IT environment.

User

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

Interested

The natural person to whom the Personal Data refers.

Data Controller (or Manager)

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

Data Controller (or Data Controller)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data and the tools adopted, including security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.

This Application

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

Service

The Service provided by this Application as defined in the relative terms (if available) on this site/application.

European Union (or EU)

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

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

Tracking Tool

Tracking Tool means any technology – e.g. Cookies, unique identifiers, web beacons, integrated scripts, e-tags and fingerprinting – which allows Users to be tracked, for example by collecting or saving information on the User’s device.

Legal references

This privacy policy is drawn up on the basis of multiple legislative systems.

Unless otherwise specified, this privacy policy applies exclusively to this Application.

Last modified: December 3, 2023

iubenda hosts this content and collects only the Personal Data strictly necessary for its provision.

when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.Futher information for California consumers

Notice at collection

Categories of personal information collected, used, sold, or shared

Information we collect: the categories of personal information we collect

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

How long do we keep your personal information?

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

How we use the information we collect: disclosing of your personal information with third parties for a business purpose

Sale or sharing of your personal information

Your right to opt out of the sale or sharing of your personal information and how you can exercise it

Your privacy rights under the California Consumer Privacy Act and how to exercise them

The right to access personal information: the right to know and to portability

The right to request the deletion of your personal information

The right to correct inaccurate personal information

The right to opt out of sale or sharing of personal information and to limit the use of your sensitive personal information

The right of no retaliation following opt-out or exercise of other rights (the right to non-discrimination)

How to exercise your rights

How and when we are expected to handle your request

Further information for Virginia consumers

Categories of personal data processed

Categories of personal data we collect

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

Sale of your personal data

Your right to opt out of the sale of your personal data and how you can exercise it

Processing of your personal data for targeted advertising

Your privacy rights under the Virginia Consumer Data Protection Act and how to exercise them

How to exercise your rights

How and when we are expected to handle your request

Further information for Colorado consumers

Categories of personal data processed

Categories of personal data we collect

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

Sale of your personal data

Your right to opt out of the sale of your personal data and how you can exercise it

Processing of your personal data for targeted advertising

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

Universal opt-out mechanism: Global privacy control

Your privacy rights under the Colorado Privacy Act and how to exercise them

How to exercise your rights

How and when we are expected to handle your request

Further information for Connecticut consumers

Categories of personal data processed

Categories of personal data we collect

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

Sale of your personal data

Your right to opt out of the sale of your personal data and how you can exercise it

Processing of your personal data for targeted advertising

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

Universal opt-out mechanism: Global privacy control

Your privacy rights under the Connecticut Data Privacy Act and how to exercise them

How to exercise your rights

How and when we are expected to handle your request

Further information for Utah consumers

Categories of personal data processed

Categories of personal data we collect

Why we process your personal data

How we use the data we collect: sharing of your personal data with third parties

Sale of your personal data

Your right to opt out of the sale of your personal data and how you can exercise it

Processing of your personal data for targeted advertising

Your right to opt out of the processing of your personal data for targeted advertising and how you can exercise it

Your privacy rights under the Utah Consumer Privacy Act and how to exercise them

How to exercise your rights

How and when we are expected to handle your request

when the transfer is necessary for the fulfillment of a legal obligation, the execution of a contract and related pre-contractual obligations, or the normal exercise of rights in judicial, administrative or arbitration proceedings.

Futher information for California consumers