Privacy Policy
Effective as of: Sept. 19, 2019, 3:55 p.m.
Last Update: June 13, 2021
1. Definitions
2. Type of Data Collected
3. Personal Data
4. Usage Data
5. Location Data
6. Tracking Cookies Data
7. Method of Processing Data
8. Place of Processing Data
9. Retention Time
10. Usage of Data Collected
11. Legal Basis for Processing Personal Data Under General Data Protection Regulation (“GDPR”) and Other
12. Transfer Of Data
13. Disclosure of Data
14. Security Of Data
15. “Do Not Track” Signals
16. Your Data Protection Rights Under GDPR and Other Privacy Laws
17. Service Providers
18. Analytics
19. Behavioral Remarketing
20. Payments
21. Links to Third Party Sites
22. Child Policy
23. Changes to this Privacy Policy
Definitions
Capitalized terms used in this Privacy Policy and not so defined, shall have the following meanings:
“Personal Data” means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
“Usage Data” means data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).
“Cookies” are small pieces of data stored on your device (computer or mobile device).
“Data Controller” means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.
“Data Processors” (or “Service Providers”) means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively.
“Data Subject” (or “User”) means any living individual who is using our Service and is the subject of Personal Data.
Type of Data Collected
We collect several different types of information for various purposes that are required to provide and improve our Service to you.
Personal Data
While using our Service, we may ask you (by request from usor our through third parties) to provide us with certain personally identifiable information that can be used to contact or identify you. Personally identifiable information may include, but is not limited to: first name, last name, gender, date of birth, passport number, nationality, phone number, country, email address, ZIP/Postal code, Cookies and Usage Data.
We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information thatmay be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
Failure to provide certain Personal Data may make it impossible for this Website to provide its services.
Users are responsible for any Personal Data of third parties obtained, published or shared through this Website and confirm that they have the third party’s consent to provide the Data to the Owner.
Usage Data
We may also collect Usage Data that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device. This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service by or through a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.
Location Data
We may use and store information about your location if you give us permission to do so (“Location Data”). We use this data to provide features of our Service, to improve and customize our Service. You can enable or disable location services when you use our Service at any time, through your device settings.
Tracking Cookies Data
We use Cookies and similar tracking technologies to track the activity on our Service and hold certain information. Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.
You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.
Examples of Cookies we use:
Session Cookies— We use Session Cookies to operate our Service.
Preference Cookies— We use Preference Cookies to remember your preferences and various settings.
Security Cookies— We use Security Cookies for security purposes.
Advertising Cookies— Advertising Cookies are used to serve you with advertisements that may be relevant to you and your interests.
Method of Processing Data
The Data Controller processes the Data of Users in a proper manner and shall take appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Data Controller, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, website developers, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Data Controller at any time.
Place of Processing Data
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, please contact the Data Controller.
Retention Time
The Data is kept for the time necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. Company will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.
Usage of Data Collected
Company uses the collected data for various purposes including but not limited to provide and maintain the Service, to send notifications regarding changes to our Service, to enable participation in interactive features of our Service when chosen to do so, to provide customer support, to gather analysis or valuable information so that we can improve our Service, to monitor the usage of our Service, to detect, prevent and address technical issues, and to provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or inquired about unless you have opted not to receive such information
We may share data with external parties at our discretion(such as, but not limited to, The Italian Government, The Spanish Government, The German Government, The French Government, Google Inc., PayPal Inc., Stripe Inc., etc.)
Legal Basis for Processing Personal Data Under General Data Protection Regulation (“GDPR”) and Other
Company legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.
Company may process your Personal Data because:
We need to perform a contract with you;
You have given us permission to do so;
The processing is in our legitimate interests and it’s not overridden by your rights;
For payment processing purposes; or
To comply with the law.
Transfer Of Data
Your information, including Personal Data, may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Company will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
Disclosure of Data
Business Transaction
If Company is involved in a merger, acquisition, consolidation or asset sale, or is (or parts of Company is) otherwise transferred by operation of law or otherwise, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, Company may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
Company may disclose your Personal Data in the good faith belief that such action is necessary to:
To comply with a legal obligation;
To protect and defend the rights or property of Company;
To prevent or investigate possible wrongdoing in connection with the Service;
To protect the personal safety of users of the Service or the public; or
To protect against legal liability.
The rights of Users Regarding Their Data
In addition to your rights under applicable data protection legislation, Users have the right, at any time, to know whether their Personal Data has been stored and can contact usto learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to the “Contact Us” information set out below.
Security Of Data
The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
“Do Not Track” Signals
We do not support “Do Not Track.” Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.
Your Data Protection Rights Under GDPR and Other Privacy Laws
If you are a resident of the EEA or other locations, you have certain data protection rights. Company aims to take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data. If you wish to be informed what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
The right to access, update or to delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
The right to object. You have the right to object to our processing of your Personal Data.
The right of restriction. You have the right to request that we restrict the processing of your personal information.
The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
The right to withdraw consent. You also have the right to withdraw your consent at any time where Company relied on your consent to process your personal information.
Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the EEA or similar governmental authority in your jurisdiction.
Service Providers
We may employ third party Service Providers to facilitate our Service, to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
Analytics
We may use third-party Service Providers to monitor and analyze the use of our Service.
Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. For more information on the privacypractices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/
Behavioral Remarketing
Company uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimize and serve ads based on your past visits to our Service.
Google AdWords. Google AdWords remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout– for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: http://www.google.com/intl/en/policies/privacy/.
Payments
We may provide paid products and/or services within the Service. In that case, we use third-party services for payment processing (e.g. payment processors). We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their Privacy Policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, Mastercard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.
The payment processors we work with are:
Stripe. Their Privacy Policy can be viewed at https://stripe.com/us/privacy.
PayPal or Braintree. Their Privacy Policy can be viewed at https://www.paypal.com/webapps/mpp/ua/privacy-full.
Links to Third Party Sites
Our Service may contain links to other sites that are not operated by us. If you click on a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.
Child Policy
Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.
Changes to this Privacy Policy
The Data Controller reserves the right to make changes to this privacy policy at any time by posting a new Privacy Policy on this page. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom. If a User objects to any of the changes to the Policy, the User must cease using this Website and can request that the Data Controller remove the Personal Data in accordance with this Privacy Policy. Unless stated otherwise, the then-current privacy policy applies to all Personal Data the Data Controller has about Users.