Owner and Data Controller
YokoYoko di Matteo Luca Luciano Cosimo Mengacci
P.Iva 11195290967
Milano, Via Valparaiso 7A
20144
Owner contact email: teo@teokaykay.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; email address; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); payment data; address; first name; last name; company name; Invoicing information; Data communicated while using the service; geographic position; Approximate location permission (continuous); Phone permission; SMS permission; password; User ID; various types of Data.
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.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this 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.
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.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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, Displaying content from external platforms, Contacting the User, Traffic optimization and distribution, Heat mapping and session recording, Platform services and hosting, Handling payments, Hosting and backend infrastructure, Interaction with live chat platforms, Interaction with external social networks and platforms, Location-based interactions, Device permissions for Personal Data access, Advertising, Registration and authentication provided directly by this Website, Remarketing and behavioral targeting, Data transfer outside the EU, Handling productivity related activity and Infrastructure monitoring.
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”.
Device permissions for Personal Data access
Depending on the User's specific device, this Website may request certain permissions that allow it to access the User's device Data as described below.
By default, these permissions must be granted by the User before the respective information can be accessed. Once the permission has been given, it can be revoked by the User at any time. In order to revoke these permissions, Users may refer to the device settings or contact the Owner for support at the contact details provided in the present document.
The exact procedure for controlling app permissions may be dependent on the User's device and software.
Please note that the revoking of such permissions might impact the proper functioning of this Website.
If User grants any of the permissions listed below, the respective Personal Data may be processed (i.e accessed to, modified or removed) by this Website.
Approximate location permission (continuous)
Used for accessing the User's approximate device location. This Website may collect, use, and share User location Data in order to provide location-based services.
Phone permission
Used for accessing a host of typical features associated with telephony. This enables, for instance, read-only access to the “phone state”, which means it enables access to the phone number of the device, current mobile network information, or the status of any ongoing calls.
SMS permission
Used for accessing features related to the User's messaging including the sending, receiving and reading of SMS.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized 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 behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, 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.
Direct Email Marketing (DEM) (this Website)
This Website uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Website.
Personal Data processed: email address.
Facebook Audience Network (Facebook Ireland Ltd)
Facebook Audience Network is an advertising service provided by Facebook Ireland Ltd 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: Ireland – Privacy Policy – Opt Out.
Google Ads conversion tracking (Google Ireland Limited)
Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
TikTok conversion tracking
TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. or by TikTok Technology Limited, depending on how the Owner manages the Data processing, that connects data from the TikTok advertising network with actions performed on this Website. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Universal Analytics) with anonymized IP (Google Ireland Limited)
Google Analytics (Universal Analytics) is a web analysis service provided by Google Ireland Limited (“Google”). Google utilizes 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 contextualize and personalize the ads of its own advertising network.
This integration of Google Analytics anonymizes 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.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google Ireland Limited)
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 analyze specific behavior 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: Ireland – Privacy Policy – Opt Out.
Heap Analytics (Heap Inc.)
Heap Analytics is an analytics service provided by Heap Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
Analytics collected directly (this Website)
This Website uses an internal analytics system that does not involve third parties.
Personal Data processed: Tracker; Usage Data.
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Contacting the User
Mailing list or newsletter (this Website)
By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Website. Your email address might also be added to this list as a result of signing up to this Website or after making a purchase.
Personal Data processed: email address.
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Device permissions for Personal Data access
This Website requests certain permissions from Users that allow it to access the User's device Data as described below.
Device permissions for Personal Data access (this Website)
This Website requests certain permissions from Users that allow it to access the User's device Data as summarized here and described within this document.
Personal Data processed: Approximate location permission (continuous); Phone permission; SMS permission.
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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.
Google Fonts (Google Ireland Limited)
Google Fonts is a typeface visualization service provided by Google Ireland Limited that allows this Website to incorporate content of this kind on its pages.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
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Handling payments
Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
Amazon Payments (Amazon)
Amazon Payments is a payment service provided by Amazon.com, Inc., which allows Users to make online payments using their Amazon credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the Amazon privacy policy – Privacy Policy.
Apple Pay (Apple Inc.)
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using their mobile phones.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Android Pay
Android Pay is a payment service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, which allows Users to make payments using their mobile phones.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Pay (Google Ireland Limited)
Google Pay is a payment service provided by Google Ireland Limited, which allows users to make online payments using their Google credentials.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Payment by bank transfer (this Website)
In the event that the chosen payment method is a direct bank transfer to the current account indicated by this Website, the Owner will collect the payment details of the User, i. e. the current account number of the sender, the SWIFT code, the bank and the name of the sender. Such data will be collected and processed exclusively within the transaction and for billing purposes only.
Personal Data processed: address; company name; first name; last name; payment data.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Stripe (Stripe Inc)
Stripe is a payment service provided by Stripe Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Coinbase (Coinbase Inc.)
Coinbase is a payment service provided by Coinbase, Inc.
Personal Data processed: payment info.
Place of processing: United States – Privacy Policy.
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Handling productivity related activity
This type of service helps the Owner to manage tasks, collaboration and, in general, activities related to productivity. In using this type of service, Data of Users will be processed and may be retained, depending on the purpose of the activity in question.
These services may be integrated with a wide range of third-party services disclosed within this privacy policy to enable the Owner to import or export Data needed for the relative activity.
Gmail (Google Ireland Limited)
Gmail is a service that manages email communication provided by Google Ireland Limited. Such email communication is not scanned by Google for advertising purposes. In addition, Google does not collect or use data inside this service for advertising purposes in any other way.
Personal Data processed: email address.
Place of processing: Ireland – Privacy Policy.
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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 analyze web traffic and keep track of User behavior.
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 honors 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.
Crazy Egg (Crazyegg)
Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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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.
Fattura24 (Fattura24 SRL)
Fattura24 is an invoicing and accounting management service provided by Fattura24 SRL that enables and facilitates the management of quotes, invoices and other types of accounting documents.
Fattura24 may also be used to enable the integration of this Website with the Italian Exchange System (ES) for the fulfillment of legal obligations. Personal Data are shared with Fattura24 for the purpose of creating electronic invoices upon the fulfillment of a payment by the User.
Personal Data processed: Invoicing information.
Place of processing: Italy – Privacy Policy.
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Infrastructure monitoring
This type of service allows this Website to monitor the use and behavior of its components so its performance, operation, maintenance and troubleshooting can be improved.
Which Personal Data are processed depends on the characteristics and mode of implementation of these services, whose function is to filter the activities of this Website.
Bugsnag (Bugsnag Inc.)
Bugsnag is a monitoring service provided by Bugsnag Inc.
Personal Data processed: email address.
Place of processing: United States – Privacy Policy.
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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.
PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services allowing interaction with the PayPal platform provided by PayPal Inc.
Personal Data processed: Tracker; Usage Data.
Place of processing: See the PayPal privacy policy – Privacy Policy.
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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.
LiveChat Widget (LiveChat, Inc.)
The LiveChat Widget is a service for interacting with the LiveChat live chat platform provided by LiveChat, Inc.
Personal Data processed: Data communicated while using the service; Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Location-based interactions
Geolocation (this Website)
This Website may collect, use, and share User location Data in order to provide location-based services.
Most browsers and devices provide tools to opt out from this feature by default. If explicit authorization has been provided, the User’s location data may be tracked by this Website.
Personal Data processed: geographic position.
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Platform services and hosting
These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Shopify
Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Canada – Privacy Policy; Ireland – Privacy Policy.
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Registration and authentication provided directly by this Website
By registering or authenticating, Users allow this Website to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.
Direct registration (this Website)
The User registers by filling out the registration form and providing the Personal Data directly to this Website.
Personal Data processed: email address; first name; last name; password; User ID; various types of Data.
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize 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 behavioral 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.
Facebook Remarketing (Facebook Ireland Ltd)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Website with the Facebook advertising network.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook Ireland Ltd)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook Ireland Ltd that connects the activity of this Website with the Facebook advertising network.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: email address; Tracker.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie.
Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings.
Personal Data processed: Tracker; Usage Data.
Place of processing: Ireland – Privacy Policy – Opt Out.
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Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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
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Abandoned Cart
Once you have arrived at the checkout and entered in the email, in case of abandonment of the site without completing the purchase, the system will automatically send an automatic email with the resume of the abandoned cart after a period of time varying between 1 hour and 24 hours to the possibility for customers to conclude the purchase of the chosen products at a later time .
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Cookies List, Functionality and Duration
The length of time that a cookie remains on your computer or mobile device depends on whether it is a “persistent” or “session” cookie. Session cookies last until you stop browsing and persistent cookies last until they expire or are deleted. Most of the cookies we use are persistent and will expire between 30 minutes and two years from the date they are downloaded to your device. See the section below on how to control cookies for more information on removing them before they expire.
Cookies Necessary for the Functioning of the Store:
Cookies Necessary for the Functioning of the Store:
Name Function Duration
_ab Used in connection with access to admin. 2y
_secure_session_id Used in connection with navigation through a storefront. 24h
_shopify_country Used in connection with checkout. session
_shopify_m Used to managing customer privacy settings. 1y
_shopify_tm Used to managing customer privacy settings. 30m
_shopify_tw Used to managing customer privacy settings. 2w
_storefront_u Used to facilitate updating customer account information. 1 minute
_tracking_consent Tracking preferences 1y
Cart Used in connection with shopping cart. 2w
cart_currency Used in connection with shopping cart. 2w
cart_sig Used in connection with checkout. 2w
cart_ts Used in connection with checkout. 2w
cart_ver Used in connection with shopping cart. 2w
checkout Used in connection with checkout. 4w
checkout_token Used in connection with checkout. 1y
master_device_id Used in connection with merchant login. 2y
previous_checkout_token Used in connection with checkout. 1y
previous_step Used in connection with checkout. 1y
remember_me Used in connection with checkout. 1y
secure_customer_sig Used in connection with customer login. 20y
storefront_digest Used in connection with customer login. 2y
tracked_start_checkout Used in connection with checkout. 1y
Reporting and Analytics
Name Function Duration
_landing_page Track landing pages. 2w
_orig_referrer Track landing pages. 2w
_s Shopify analytics. 30m
_shopify_d Shopify analytics. session
_shopify_fs Shopify analytics. 30m
_shopify_s Shopify analytics. 30m
_shopify_sa_p Shopify analytics relating to marketing & referrals. 30m
_shopify_sa_t Shopify analytics relating to marketing & referrals. 30m
_shopify_y Shopify analytics. 1y
_y Shopify analytics. 1y
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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.
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Preference Cookies
Preference Cookies store the User preferences detected on this Website in the local domain such as, for example, their timezone and region.
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iubenda Cookie Solution (remote consent Cookie)
Remote iubenda consent Cookie (_iub_cs-X) is set by the iubenda Cookie Solution and stores User preferences related to Trackers under the .iubenda.com domain.
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The Service is intended for adults
Users declare themselves to be adult according to their applicable legislation. Minors may not use this Website.
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Push notifications based on the User's geographic location
This Website may use the User's geographic location to send push notifications for the purposes outlined in this privacy policy.
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such as the notification settings for mobile phones, and then changing those settings for some or all of the apps on the particular device.
Users must be aware that disabling push notifications may negatively affect the utility of this Website.
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Selling goods and services online
The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Website depends on the payment system used.
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Personal Data collected through sources other than the User
The Owner of this Website may have legitimately collected Personal Data relating to Users without their knowledge by reusing or sourcing them from third parties on the grounds mentioned in the section specifying the legal basis of processing.
Where the Owner has collected Personal Data in such a manner, Users may find specific information regarding the source within the relevant sections of this document or by contacting the Owner.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
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.
- 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.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
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 fulfil 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 rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- 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.
- 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 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 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.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
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, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. 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. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
Transfer of Personal Data outside of the European Union
Data transfer abroad based on standard contractual clauses
If this is the legal basis, the transfer of Personal Data from the EU to third countries is carried out by the Owner according to “standard contractual clauses” provided by the European Commission.
This means that Data recipients have committed to process Personal Data in compliance with the data protection standards set forth by EU data protection legislation. For further information, Users are requested to contact the Owner through the contact details provided in the present document.
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.
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.
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.
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 utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
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 policy relates solely to this Website, if not stated otherwise within this document.