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Types of Data Collected

Among the types of Personal Data that this Application collects, by itself or through third parties, there are:

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Cookies, Usage Data, phone number, address, email address and city.

Complete details on each type of Personal Data collected are provided in the dedicated sections of this

privacy policy or by specific explanation texts displayed prior to the Data collection.

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

using this Application.

Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this

Data may make it impossible for this Application to provide its services. In cases where this Application

specifically states that some Data is not mandatory, Users are free not to communicate this Data without

consequences to the availability or the functioning of the Service.

Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.

Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party services

used by this Application serves the purpose of providing the Service required by the User, in addition to any

other purposes described in the present document and in the Cookie Policy, if available.

Users are responsible for any third-party Personal Data obtained, published or shared through this

Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and Place of Processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or

unauthorized destruction of the Data.

The Data processing is carried out using computers and/or IT enabled tools, following organizational

procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases,

the Data may be accessible to certain types of persons in charge, involved with the operation of this

Application (administration, sales, marketing, legal, system administration) or external parties (such as thirdparty technical service providers, mail carriers, hosting providers, IT companies, communications agencies)

appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be

requested from the Owner at any time.

Legal basis of processing The Owner may process Personal Data relating to Users if one of the following

applies:

 Users have given their consent for one or more specific purposes. Note: Under some legislations the

Owner may be allowed to process Personal Data until the User objects to such processing (“optout”), without having to rely on consent or any other of the following legal bases. This, however, does

not apply, whenever the processing of Personal Data is subject to European data protection law;

 provision of Data is necessary for the performance of an agreement with the User and/or for any

pre-contractual obligations thereof;

 processing is necessary for compliance with a legal obligation to which the Owner is subject;

processing is related to a task that is carried out in the public interest or in the exercise of official

authority vested in the Owner;

 processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a

third party.

In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and

in particular whether the provision of Personal Data is a statutory or contractual requirement, or a

requirement necessary to enter into a contract.

Place The Data is processed at the Owner's operating offices and in any other places where the parties

involved in the processing are located.

Depending on the User's location, data transfers may involve transferring the User's Data to a country other

than their own. To find out more about the place of processing of such transferred Data, Users can check

the section containing details about the processing of Personal Data.

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

Union or to any international organization governed by public international law or set up by two or more

countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.

If any such transfer takes place, Users can find out more by checking the relevant

Retention time Personal Data shall be processed and stored for as long as required by the purpose they

have been collected for.

 

Therefore:

 Personal Data collected for purposes related to the performance of a contract between the Owner

and the User shall be retained until such contract has been fully performed.

 Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long

as needed to fulfil such purposes. Users may find specific information regarding the legitimate

interests pursued by the Owner within the relevant sections of this document or by contacting the

Owner.

The Owner may be allowed to retain Personal Data for a longer period whenever the User has given

consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be

obliged to retain Personal Data for a longer period whenever required to do so for the performance of a

legal obligation or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to

erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the

retention period.

The Purposes of Processing:

The Data concerning the User is collected to allow the Owner to provide its Services, as well as for the

following purposes: Content commenting, Interaction with external social networks and platforms and

Contacting the User.

Users can find further detailed information about such purposes of processing and about the specific

Personal Data used for each purpose in the respective sections of this document.

DETAILED INFORMATION ON THE PROCESSING OF PERSONAL DATA

Interaction with External Social Networks and Platforms

This type of service allows interaction with social networks or other external platforms directly from the pages

of this Application.

The interaction and information obtained through this Application are always subject to the User’s privacy

settings for each social network.

This type of service might still collect traffic data for the pages where the service is installed, even when

Users do not use it.

 

Facebook Like button and social widgets (Facebook, Inc.)

The Facebook Like button and social widgets are services allowing interaction with the Facebook social

network provided by Facebook, Inc.

Personal Data collected: Cookies and Usage Data.

Place of processing: United States – Privacy Policy. Privacy Shield participant.

Content Commenting

Content commenting services allow Users to make and publish their comments on the contents of this

Application.

Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an

email address among the Personal Data provided by the User, it may be used to send notifications of

comments on the same content. Users are responsible for the content of their own comments.

If a content commenting service provided by third parties is installed, it may still collect web traffic data for

the pages where the comment service is installed, even when Users do not use the content commenting

service.

Facebook Comments (Facebook, Inc.)

Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to

leave comments and share them on the Facebook platform.

Personal Data collected: Cookies and Usage Data.

The Rights of Users

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

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

 Withdraw their consent at any time. Users have the right to withdraw consent where they have

previously given their consent to the processing of their Personal Data.

 Object to processing of their Data. Users have the right to object to the processing of their Data if the

processing is carried out on a legal basis other than consent. Further details are provided in the

dedicated section below.

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 Access their Data. Users

 

 Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain

disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing

processing.

 Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to

be updated or corrected.

 Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the

processing of their Data. In this case, the Owner will not process their Data for any purpose other

than storing it.

 Have their Personal Data deleted or otherwise removed. Users have the right, under certain

circumstances, to obtain the erasure of their Data from the Owner.

 Receive their Data and have it transferred to another controller. Users have the right to receive their

Data in a structured, commonly used and machine readable format and, if technically feasible, to

have it transmitted to another controller without any hindrance. This provision is applicable provided

that the Data is processed by automated means and that the processing is based on the User's

consent, on a contract which the User is part of or on pre-contractual obligations thereof.

 Lodge a complaint. Users have the right to bring a claim before their competent data protection

authority.

Details about the right to object to processing

Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the

Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such

processing by providing a ground related to their particular situation to justify the objection.

Users must know that, however, should their Personal Data be processed for direct marketing purposes, they

can object to that processing at any time without providing any justification. To learn, whether the Owner is

processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this

document.

How to exercise these rights

Any requests to exercise User rights can be directed to the Owner through the contact details provided in

this document. These requests can be exercised free of charge and will be addressed by the Owner as

early as possible and always within one month.

 

Additional Information about Data Collection and Processing:

Legal action

The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to

possible legal action arising from improper use of this Application or the related Services.

The User declares to be aware that the Owner may be required to reveal personal data upon request of

public authorities.

Additional information about User's Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with

additional and contextual information concerning particular Services or the collection and processing of

Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that

record interaction with this Application (System logs) use other Personal Data (such as the IP Address) for this

purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at

any time. Please see the contact information at the beginning of this document.

How “Do Not Track” requests are handled

This Application does not support “Do Not Track” requests. To determine whether any of the third-party

services it uses honor the “Do Not Track” requests, please read their privacy policies.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by giving notice to its Users

on this page and possibly within this Application and/or - as far as technically and legally feasible - sending

a notice to Users via any contact information available to the Owner. It is strongly recommended to check

this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner

shall collect new consent from the User, where required.

 

DEFINITIONS AND LEGAL REFERENCES

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal

identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this

Application), which can include: the IP addresses or domain names of the computers utilized by the Users

who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the

method utilized to submit the request to the server, the size of the file received in response, the numerical

code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the

features of the browser and the operating system utilized by the User, the various time details per visit (e.g.,

the time spent on each page within the Application) and the details about the path followed within the

Application with special reference to the sequence of pages visited, and other parameters about the

device operating system and/or the User's IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Data Supervisor)

The natural or legal person, public authority, agency or other body which processes Personal Data on

behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others,

determines the purposes and means of the processing of Personal Data, including the security measures

concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the

Owner of this Application.

 

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this

site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all

current member states to the European Union and the European Economic Area.

Cookies

Small sets of data stored in the User's device.


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