PRIVACY POLICY
This Website collects some Personal Data from its Users.
This document contains a section dedicated to Californian consumers and their privacy rights.
This document contains a section dedicated to Virginia consumers and their privacy rights.
This document contains a section dedicated to Brazilian Users and their privacy rights.
This document can be printed for reference by using the print command in the settings of any browser.
Owner and Data Controller
Arper SPA - Via Lombardia, 16 31050, Monastier di Treviso (TV) Italia
Owner contact email: privacy@arper.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are: Tracker; Usage Data; device information; email address; Data communicated while using the service; Application updates; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Universally unique identifier (UUID).
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 Website. Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website 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 Website or by the owners of third-party services used by this Website 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 Website 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 unauthorised access, disclosure, modification, or unauthorised destruction of the Data. The Data processing is carried out using computers and/or IT enabled tools, following organisational 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 Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located. Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data. Users are also entitled to learn about the legal basis of Data transfers to a country outside the European Union or to any international organisation governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or enquire with the Owner using the information provided in the contact section.
Retention time
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority. Once the retention period expires, Personal Data shall be deleted. Therefore, the right of 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 Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics, Tag Management, Advertising, Remarketing and behavioural targeting, User database management, Displaying content from external platforms, Heat mapping and session recording, Interaction with external social networks and platforms, Interaction with live chat platforms, Hosting and backend infrastructure, SPAM protection and Information collection. For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising
This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
JSDELIVR (jsdelivr.com)
JSDELIVR is an advertising service provided by jsdelivr.com.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Facebook Lookalike Audience
Facebook Lookalike Audience is an advertising and behavioural targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the base of their past use of this Website or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalised ads will be shown to Users suggested by Facebook Lookalike Audience. Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of this Website and User behaviour concerning ads, products and services offered. Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Facebook Audience Network
Facebook Audience Network is an advertising service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, In order to understand Facebook's use of Data, consult Facebook's data policy. This Website may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Facebook Audience Network service. One of the ways Audience Network shows ads is by using the User's ad preferences. The User can control this in the Facebook ad settings. Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google Ads Similar audiences
Similar audiences is an advertising and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that uses Data from Google Ads Remarketing in order to display ads to Users with similar behaviour to Users who are already on the remarketing list due to their past use of this Website. On the basis of this Data, personalised ads will be shown to Users suggested by Google Ads Similar audiences. Users who don't want to be included in Similar audiences can opt out and disable the use of advertising Trackers by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
ClickWall (Click Wall Ltd.)
ClickWall is an advertising service provided by Click Wall Ltd.
Personal Data processed: Tracker; Usage Data.
Place of processing: Israel – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
LinkedIn Ads
LinkedIn Ads is an advertising service provided by LinkedIn Ireland Unlimited Company or by LinkedIn Corporation, depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt out; United States – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google DV360 (Google LLC)
Google DV360 is an advertising service provided by Google LLC that allows the Owner to manage and plan advertising campaigns. This includes designing the ads, displaying them to the right targeted audience, bidding through automated decision-making tools (called "automated bidding") and measuring the campaign's performance.
Users may decide to disable the ad personalization Trackers by going to: Google Ad Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Analytics
The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.
Google Analytics
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Facebook Ads conversion tracking (Facebook pixel)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects data from the Facebook advertising network with actions performed on this Website. The Facebook pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Audience Network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Analytics with anonymised IP
Google Analytics is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilises the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
This integration of Google Analytics anonymises your IP address. It works by shortening Users' IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Analytics for Firebase
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. In order to understand Google's use of Data, consult Google's partner policy. Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting, Authentication, Remote Config or Notifications. The User may check this privacy policy to find a detailed explanation about the other tools used by the Owner. This Website uses identifiers for mobile devices and technologies similar to cookies to run the Firebase Analytics service. Users may opt-out of certain Firebase features through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Firebase related sections of this privacy policy, if available.
Personal Data processed: Application updates.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Ads conversion tracking
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Floodlight conversion tracking (Floodlight tag)
Google Floodlight conversion tracking (Floodlight tag) is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects Data from the Google advertising services (i.e. Search Ads 360 and Campaign Manager 360) with actions performed on this Website. Depending on the setup of the service, such Data might also be used for retargeting purposes.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Analytics Advertising Reporting Features
Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyse specific behaviour and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender). Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Analytics Demographics and Interests reports
Google Analytics Demographics and Interests reports is a Google Advertising Reporting feature that makes available demographic and interests Data inside Google Analytics for this Website (demographics means age and gender Data). Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example).
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
LinkedIn conversion tracking (LinkedIn Insight Tag) (LinkedIn Corporation)
LinkedIn conversion tracking (LinkedIn Insight Tag) is an analytics and behavioural targeting service provided by LinkedIn Corporation that connects data from the LinkedIn advertising network with actions performed on this Website. The LinkedIn Insight Tag tracks conversions that can be attributed to LinkedIn ads and enables to target groups of Users on the base of their past use of this Website. Users may opt out of behavioural targeting features through their device settings, their LinkedIn account settings or by visiting the AdChoices opt-out page.
Personal Data processed: device information; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
YouTube Analytics and Reporting API
YouTube Analytics and Reporting API is a video content analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document. Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
YouTube IFrame Player
YouTube IFrame Player is a video content visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages. Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document. Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Spotify widget (Spotify AB)
Spotify is an audio content delivery service provided by Spotify AB that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: Sweden – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Instagram widget
Instagram is an image visualisation service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Google Maps widget
Google Maps is a maps visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
YouTube Data API
YouTube Data API is a video content visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate functions normally executed on YouTube so that Users can watch, find, and manage YouTube content directly on this Website. Through this Service, this Website may collect Data directly or indirectly on or from Users’ devices, including by making use of Trackers. Users may restrict such access to their Data via the security settings page provided by Google. Users may ask the Owner for further information about these privacy settings at any time through the contact details provided in this document. Data collected through the Service may also be used to help third parties deliver interest-based advertising. Users can opt out of third-party interest-based advertising through their device settings or by visiting the Network Advertising Initiative opt-out page.
Personal Data processed: Tracker.
Place of processing: United States – Privacy Policy – Opt out; Ireland – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
YouTube video widget (Privacy Enhanced Mode)
YouTube is a video content visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages. This widget is set up in a way that ensures that YouTube won't store information and cookies about Users on this Website unless they play the video.
Personal Data processed: Tracker; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
YouTube video widget
YouTube is a video content visualisation service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Heat mapping and session recording
Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyse web traffic and keep track of User behaviour.
Some of these services may record sessions and make them available for later visual playback.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heat mapping service provided by Hotjar Ltd.
Hotjar honours generic „Do Not Track” headers. This means the browser can tell its script not to collect any of the User's data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Tracker; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Microsoft Clarity
Clarity is a user behavior analytics tool which helps you understand how users are interacting with your website. Supported features include:
Session Recordings
Heatmaps (or heat maps)
ML Insights
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website. Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Iubenda Consent Solution (iubenda srl)
The iubenda Consent Solution allows to store and retrieve records of final Users’ consent to the processing of Personal Data, and preferences thereof.
Personal Data processed: Data communicated while using the service; Tracker.
Place of processing: Italy – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
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 Website.
The interaction and information obtained through this Website 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.
It is recommended to log out from the respective services in order to make sure that the processed data on this Website isn’t being connected back to the User’s profile.
LinkedIn button and social widgets (LinkedIn Corporation)
The LinkedIn button and social widgets are services allowing interaction with the LinkedIn social network provided by LinkedIn Corporation.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Facebook Like button and social widgets
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing,
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Twitter Tweet button and social widgets (Twitter, Inc.)
The Twitter Tweet button and social widgets are services allowing interaction with the Twitter social network provided by Twitter, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Pinterest “Pin it” button and social widgets (Pinterest, Inc.)
The Pinterest “Pin it” button and social widgets are services allowing interaction with the Pinterest platform provided by Pinterest Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
YouTube button and social widgets
The YouTube button and social widgets are services allowing interaction with the YouTube social network provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Interaction with live chat platforms
This type of service allows Users to interact with third-party live chat platforms directly from the pages of this Website, in order to contact and be contacted by this Website‘s support service.
If one of these services is installed, it may collect browsing and Usage Data in the pages where it is installed, even if the Users do not actively use the service. Moreover, live chat conversations may be logged.
WeChat widget (Tencent, Inc.)
The WeChat widget is a service for interacting with the WeChat live chat platform provided by Tencent, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: China – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Remarketing and behavioural targeting
This type of service allows this Website and its partners to inform, optimise and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioural targeting activity. Some services offer a remarketing option based on email address lists. In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page. Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.
LinkedIn Website Retargeting (LinkedIn Corporation)
LinkedIn Website Retargeting is a remarketing and behavioural targeting service provided by LinkedIn Corporation that connects the activity of this Website with the LinkedIn advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Facebook Remarketing
Facebook Remarketing is a remarketing and behavioural targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Facebook Custom Audience
Facebook Custom Audience is a remarketing and behavioural targeting service provided by Facebook, Inc. or by Facebook Ireland Ltd, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Facebook advertising network. Users can opt out of Facebook's use of Trackers for ads personalisation by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google Ad Manager Audience Extension
Google Ad Manager Audience Extension is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of this Website and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of Trackers for ads personalisation by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioural targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Trackers with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
Google Signals
This Website uses Google Signals, a feature of Google Analytics, which will associate the visitation information that it collects from this Website with Google information from accounts of signed-in Google-account users who have consented to this association for the purpose of ads personalisation. This Google information may include User location, search history, YouTube history and Data from sites that partner with Google – and is used to provide aggregated and anonymised insights into Users' cross device behaviours. If a User falls under the described association, they may access and/or delete such Data via My Activity provided by Google.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
- a sharing according to the CCPA
- targeted advertising according to the VCDPA
SPAM protection
This type of service analyses the traffic of this Website, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing. The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information; inferred information.
This processing constitutes:
- a sale according to the CCPA
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralised fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Category of personal information collected according to CCPA: internet information.
This processing constitutes:
- a sale according to the CCPA
User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
Pardot (Salesforce.com, inc.)
Pardot is a User database management service provided by Salesforce.com, inc. Pardot may use Trackers to recognise and track Users behaviour, as well as, to help deliver personalised ads and content. Users may opt out of Pardot’s use of Trackers for advertising purposes by visiting the Salesforce Audience Studio Opt-Out page or following the instructions provided by YourOnlineChoices and AdChoices.
Personal Data processed: Data communicated while using the service; device information; email address; Tracker; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of personal information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a sale according to the CCPA and the VCDPA
Information on opting out of interest-based advertising
In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.
Further information about the processing of Personal Data
Iubenda Cookie Solution (consent Cookie)
iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers in the local domain. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Iubenda CCPA Cookie (usprivacy)
iubenda CCPA Cookie (usprivacy) is set by the iubenda Cookie Solution and stores California consumer opt-out choices in the local domain. This processing constitutes a sale based on the definition under the CCPA. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
The rights of Users
Users may exercise certain rights regarding their Data processed by the Owner. In particular, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right, under certain circumstances, to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract which the User is part of or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection. Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To learn, whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Policy
This Website uses Trackers. To learn more, the User may consult the Cookie Policy.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Website 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 Website 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 Website and any third-party services may collect files that record interaction with this Website (System logs) or 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 Website does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honour 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 notifying its Users on this page and possibly within this Website 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.
Information for Californian consumers
This part 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 Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions 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: identifiers, internet information and inferred 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 Website 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 Website. For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate this Website, 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 Website.
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. 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.
What are the purposes for which we use your personal information?
We may use your personal information to allow the operational functioning of this Website 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.
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 Website, 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 minor 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.
Information for Virginia consumers
This part 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”). The provisions contained in this section apply 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, these provisions supersede any other possibly divergent or conflicting provisions 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, internet information and inferred 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.
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
For our purposes, the word "targeted advertising" means "displaying advertisements to you where the advertisement is selected based on personal data obtained from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests" as defined by the VCDPA. To find out more details on the processing of your personal data for targeted advertising purposes, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
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. 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 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 relates 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 minor 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.
Information for Users residing in Brazil
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity running this Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”). The provisions contained in this section apply to all Users who reside in Brazil, according to the "Lei Geral de Proteção de Dados" (Users are referred to below, simply as “you”, “your”, “yours”). For such Users, these provisions supersede any other possibly divergent or conflicting provisions contained in the privacy policy. This part of the document uses the term “personal information“ as it is defined in the Lei Geral de Proteção de Dados (LGPD).
The grounds on which we process your personal information
We can process your personal information solely if we have a legal basis for such processing. Legal bases are as follows:
- your consent to the relevant processing activities;
- compliance with a legal or regulatory obligation that lies with us;
- the carrying out of public policies provided in laws or regulations or based on contracts, agreements and similar legal instruments;
- studies conducted by research entities, preferably carried out on anonymised personal information;
- the carrying out of a contract and its preliminary procedures, in cases where you are a party to said contract;
- the exercising of our rights in judicial, administrative or arbitration procedures;
- protection or physical safety of yourself or a third party;
- the protection of health – in procedures carried out by health entities or professionals;
- our legitimate interests, provided that your fundamental rights and liberties do not prevail over 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 what categories of your personal information are processed, you can read the section titled “Detailed information on the processing of Personal Data” within this document.
Why we process your personal information
To find out why we process your personal information, you can read the sections titled “Detailed information on the processing of Personal Data” and “The purposes of processing” within this document.
Your Brazilian privacy rights, how to file a request and our response to your requests
Your Brazilian privacy rights
You have the right to:
- obtain confirmation of the existence of processing activities on your personal information;
- access to your personal information;
- have incomplete, inaccurate or outdated personal information rectified;
- obtain the anonymization, blocking or elimination of your unnecessary or excessive personal information, or of information that is not being processed in compliance with the LGPD;
- obtain information on the possibility to provide or deny your consent and the consequences thereof;
- obtain information about the third parties with whom we share your personal information;
- obtain, upon your express request, the portability of your personal information (except for anonymised information) to another service or product provider, provided that our commercial and industrial secrets are safeguarded;
- obtain the deletion of your personal information being processed if the processing was based upon your consent, unless one or more exceptions provided for in art. 16 of the LGPD apply;
- revoke your consent at any time;
- lodge a complaint related to your personal information with the ANPD (the National Data Protection Authority) or with consumer protection bodies;
- oppose a processing activity in cases where the processing is not carried out in compliance with the provisions of the law;
- request clear and adequate information regarding the criteria and procedures used for an automated decision; and
- request the review of decisions made solely on the basis of the automated processing of your personal information, which affect your interests. These include decisions to define your personal, professional, consumer and credit profile, or aspects of your personality.
You will never be discriminated against, or otherwise suffer any sort of detriment, if you exercise your rights.
How to file your request
You can file your express request to exercise your rights free from any charge, at any time, by using the contact details provided in this document, or via your legal representative.
How and when we will respond to your request
We will strive to promptly respond to your requests. In any case, should it be impossible for us to do so, we’ll make sure to communicate to you the factual or legal reasons that prevent us from immediately, or otherwise ever, complying with your requests. In cases where we are not processing your personal information, we will indicate to you the physical or legal person to whom you should address your requests, if we are in the position to do so. In the event that you file an access or personal information processing confirmation request, please make sure that you specify whether you’d like your personal information to be delivered in electronic or printed form.
You will also need to let us know whether you want us to answer your request immediately, in which case we will answer in a simplified fashion, or if you need a complete disclosure instead. In the latter case, we’ll respond within 15 days from the time of your request, providing you with all the information on the origin of your personal information, confirmation on whether or not records exist, any criteria used for the processing and the purposes of the processing, while safeguarding our commercial and industrial secrets. In the event that you file a rectification, deletion, anonymization or personal information blocking request, we will make sure to immediately communicate your request to other parties with whom we have shared your personal information in order to enable such third parties to also comply with your request – except in cases where such communication is proven impossible or involves disproportionate effort on our side.
Transfer of personal information outside of Brazil permitted by the law
We are allowed to transfer your personal information outside of the Brazilian territory in the following cases:
- when the transfer is necessary for international legal cooperation between public intelligence, investigation and prosecution bodies, according to the legal means provided by the international law;
- when the transfer is necessary to protect your life or physical security or those of a third party;
- when the transfer is authorised by the ANPD;
- when the transfer results from a commitment undertaken in an international cooperation agreement;
- when the transfer is necessary for the execution of a public policy or legal attribution of public service;
- when the transfer is necessary for compliance with a legal or regulatory obligation, the carrying out of a contract or preliminary procedures related to a contract, or the regular exercise of rights in judicial, administrative or arbitration procedures.
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 Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised 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 utilised 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 Website 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 Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
European Union (or EU)
Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.
Cookie
Cookies are Trackers consisting of small sets of data stored in the User's browser.
Tracker
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing information on the User’s device.
Legal information
This privacy statement has been prepared based on provisions of multiple legislations, including Art. 13/14 of Regulation (EU) 2016/679 (General Data Protection Regulation).This privacy policy relates solely to this Website, if not stated otherwise within this document. Latest update: 31 January 2023
Arper S.p.A. and its Branches consider the protection of personal data of third parties, in its possession, as very important and is committed to protect the privacy of said third parties included, but not limited to, its customers, when carrying on its business, and it pays particular attention to the security and confidentiality of its customers’ personal data. This Privacy Notice relates to the collection of personal data using online methods (including the Arper Group websites) and offline as specified below. Arper S.p.A. with registered office in Monastier di Treviso (Treviso - Italy) Via Lombardia 16, zip code 31050 can you you any details on the the topic sending an email to privacy@arper.com.
Arper S.p.A. and its Branches (hereinafter the "Arper Group"), in accordance with article 13 of the GDPR 679/2016, as Data Controller of the personal data collected on this website / app / web chat / competition entries/ collected during the phone call provides you with the following information.
Data that may be collected
The following categories of personal data relating to you may be collected:
- Contact data – information on your name, address, telephone number, mobile telephone number, email address;
- Interests – information you have provided regarding areas that interest you, for example products you find interesting;
- Other personal data – information you have provided regarding your date of birth, education, professional situation and household details;
- Social Log-In – information related to your Social account as well as other data you have given to the Social Network used to log in to the website, which may be disclosed according to the privacy preferences that you have set on this Social Network.
- Use of the website – information on how you use the website, how you open or forward our communications, including information acquired via cookies. Theuse of cookies allows Arper S.p.A. to improve service quality and to provide functions useful for navigation. Cookies are small text files sent by a server to a browser and then transmitted by the latter to the visitor's hard disk upon access to a website. Arper S.p.A. will therefore be able to identify users' browsers and to facilitate access to the website for the following visits. Most browsers automatically accept cookies. Users can modify the settings of their browsers in order to accept all cookies, to accept only some cookies or to decline them. Moreover users may modify their browser settings in order to receive a message any time a cookie is stored in their computers' hard disks.
Here are the links to manage your browser preferences:
- IE: http://windows.microsoft.com/it-it/windows7/block-enable-or-allow-cookies
- Safari: http://support.apple.com/kb/PH19255
- Chrome: https://support.google.com/chrome/answer/95647?hl=it-IT&hlrm=fr&hlrm=en
- Firefox: http://support.mozilla.org/it-IT/kb/enable-and-disable-cookies-website-preferences
On its website Arper Group does not use cookies for the transmission of personal information or systems for tracking users. Moreover the cookies used by Arper Group do not collect data from users' computers.
This website uses the following types of cookies:
Technical cookies:
These cookies allow us to recognize a registered user and allow them access to the services offered in dedicated areas. Technical cookies are managed and controlled by Arper Group and are necessary for the proper functioning of the website. These cookies also allow us, in accordance with the request made by the user, to recognize subsequent visits so that users do not have to enter their data on every visit.
Technical cookies also include the cookie that records whether the visitor has read the banner that informs visitors about the use of cookies.
First-party and third-party analytics cookies:
They are used to collect data in aggregate form about users' browsing habits on the website. Arper Group uses the results of these analyses anonymously and exclusively for statistical purposes and only if the service provider uses cookies in connection to the browser or other devices used to navigate on our site. To disable analytics cookies and prevent Google Analytics from collecting your navigation data, you can download the browser add-on for Google Analytics: https://tools.google.com/dlpage/gaoptout?hl=en.
Cookies to integrate products and functions of third-party software
This type of cookie incorporates features developed by third parties within the pages of the site, in order to share the contents of the site or for the use of third-party software services. These cookies are sent from third-party domains that offer their functionality within the pages of the site. Nonetheless the www.arper.com website - due to its technology - might not function properly or its pages might be loaded slowly if browsers are not set to accept cookies. Users may clear from their hard disk both the cache-memory and cookies collected at the end of each browsing session.
Please visit the following website in English www.allaboutcookies.org for further information on cookies and on how to prevent them from being installed.
How we collect your personal data
Arper Group. collects and processes your personal data in the following circumstances:
- if you register on our website / download our App to use its functionalities; also through the Social Log-in;
- if you contact us to request pre-sales or after-sales assistance;
- if you respond to our marketing activities, for example when you complete a reply card or submit your data online on one of our websites;
- if you fill out paper forms of registration that are collected in various ways (during fairs, promotions or events);
- if other Group Companies as well as our business partners provide data about you in a manner that is permitted.
If you provide personal data on behalf of someone else, you must first ensure they have read this Privacy Policy. Kindly help us to keep your personal data up-to-date by informing us of any changes. Any change in address should be promptly communicated to Arper in order to avoid problems in the use of our services.
For what purposes can your personal data be used
The processing of personal data must be justified by one of the legal basis established by existing data protection regulations, as described below.
a) Establishment and execution of contractual obligation and resulting obligations, including communications regarding services (for example to perform after-sales services).
Arper Group may process your Contact data in order to establish and execute a contractual relationship, to provide services requested or to respond to reports or complaints.
Arper Group may also use your contact details, particularly your email address, to provide you with information concerning the service.
Legal bases for the processing: performance of a contract.
The provision of data is mandatory to enable us to manage the contractual relationship; in the absence of the data, we will be unable to put the contract into effect.
b) Operational management and strictly-related purposes, for access to the website, particularly secure areas.
Arper Group may process the contact details to enable you to complete the registration procedure on the site and allow you to access your Personal Area in order to: (i) download from your Personal Area documents relating to the services you are allowed to; (ii) process the other requests made through the website.
Legal bases for the processing: performance of a contract.
To allow you to register on the site, personal login name and Password will be provided.
c) Customer Satisfaction and other surveys.
Arper Group may use your Contact data to carry out surveys aimed at measuring customer satisfaction in relation to the service provided.
Legal bases for the processing: legitimate interest of the Arper Group to verify and improve the quality of their services.
d) Marketing to meet your needs or to inform you of promotions, also based on your preferences (we have also included profiled marketing).
Arper Group may processes your Contact data for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration. Arper Group may also processes your Contact data, Interests and Other personal data, in order to send you advertising communication, based on a specific customer profile designed on your personal preferences and interests, if you give us a specific consent and within the limits of the consent.
Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship.
Your consent may be revoked at any time by sending an email to privacy@arper.com.
e) Communication to other Arper Group companies for marketing purposes too.
Arper Group may communicate your Contact data to other Arper Group companies for activities strictly connected to the treatments referred to in points a) b) c) above.
Legal bases for the processing:the assumptions of the mentioned points are recalled.
Arper Group may communicate your Contact data to other Arper Group companies for marketing and advertising purposes, to inform you of promotional sales initiatives via automated means of contact (email, SMS and other mass communication tools, etc.) and traditional contact methods (e.g. by telephone), such as for market research and statistical surveys, if you give us your consent and within the limits of the consent declaration.
Legal bases for the processing: consent, a failure to give consent in no way affects the contractual relationship.
Your consent may be revoked at any time by sending an email to infoweb@arper.com.
f) Compliance with legally-binding requests by the legal authorities to discharge obligations of law, regulations or provisions.
Arper Group collects your personal data to comply with legal obligations.
Legal bases for the processing: legal obligations with which the Arper Group must comply.
How we keep your personal data safe
The Arper Group uses a wide range of security measures to improve protection and maintain the security, integrity and accessibility of your personal data. All your personal data are stored on our secure servers (or on secure paper copies) or on those of our suppliers or commercial partners, and may be accessed and used based on our standards and our security policies (or equivalent standards for our suppliers or commercial partners). The security measures we have adopted include:
- severe restrictions on access to your personal data, based on necessity and solely for the purposes communicated;
- perimeter security systems to prevent unauthorised external access;
- permanent monitoring of access to IT systems to identify and stop the misuse of personal data;
- tracking of access to your personal data by internal personnel and verification of the related purpose;
- using encrypted means via Secure Socket Layer (SSL) technology for transactions on our website that require the entering of personal data.
- Where we have provided you with (or you have chosen) a password to allow you to access our website, application or services, you are responsible for keeping this password secret and for complying with any other security procedure we inform you of. Please do not share your password with anyone.
How long do we store your information for
We will keep your personal data only for the length of time necessary to achieve the purposes for which they were collected or for any other related and lawful purpose. Therefore, if your personal data is processed for two different purposes, we will keep the data until the lengthier purpose is achieved. However, we will cease to process the personal data collected for the purpose whose retention period has expired. We limit access to your personal data to only those individuals who need to use them for the appropriate purposes. When your personal data are no longer required, or when there is no longer any legal pre-condition for keeping them, they will be irreversibly anonymized (and in such a way may be stored) or securely destroyed. The retention periods relating to the different purposes described above are indicated to follow:
a) Compliance with contractual obligations: data processed to comply with any contractual obligation may be kept for the duration of the contract and in any case no longer than the subsequent 10 years; in order to verify any outstanding issues including accounting documents (e.g. invoices).
b) Operational management and strictly-related purposes for access to the website: data processed for these purposes may be kept for the duration of the contract and in any case no longer than the subsequent 10 years.
c) Customer Satisfaction surveys: data processed for these purposes may be kept for 5 years from the personal data collection date (except where you decline to receive further communications).
d) For marketing purposes, including profiled marketing: data processed for marketing purposes may be kept for 5 years from the date on which you provided your consent for this purpose (except where you decline to receive further communications); for profiled marketing purposes, data will be kept for 12 months.
e) In the event of disputes: should it be necessary for us to defend ourselves or take action or bring claims against you or third parties, we may keep the personal data we deem reasonably necessary for such purposes, for the length of time it takes to pursue the claim.
Who we can share your personal data with
Your personal data may be accessed by duly-authorised employees and by external suppliers, appointed, if necessary, as data processors, who support us in providing services. For the purposes of the performance of their activities and to follow up on the above mentioned purposes your personal data may also be accessed by other Arper Group companies.
Contacts
The contact details for Arper Group, in its capacity as Data Controller, may be found at Arper S.p.A. Monastier di Treviso (Treviso - Italy) Via Lombardia 16, zip code 31050 or via the email privacy@arper.com address. Should you have any questions regarding our processing of your personal data you can rely to above email address.
Your personal data protection rights and your right to file complaints before the supervisory authorities
On certain conditions, you are entitled to request:
- access to your personal data,
- a copy of the personal data you have provided to us, and to request the Arper Group to transmit your Data to another controller,
- the adjustment of data in our possession,
- the deletion of any data for which the legal precondition for processing no longer exists,
- to deny processing for direct marketing purposes,
- to revoke your consent, in cases where the processing is based on consent,
- to limit the way in which we process your personal data.
The exercising of the above rights is subject to certain exceptions that are intended to safeguard the public interest (e.g. the prevention or identification of crimes) and our interests (e.g. maintaining professional secrecy). Should you wish to exercise any of the above rights, we will check that you are entitled to do so and will usually respond within one month.
07/10/2021 15:04:16