Owner and Data Controller
Hospitality Leaders Holedo Technology Limited
51 Bracken Rd, Sandyford Business Park
Sandyford, Dublin D18 CV48
Ireland
Owner contact email: support@holedo.com
Types of Data collected
Among the types of Personal Data that this Application collects, by itself or through third parties, there are:
Usage Data; Trackers; language; device information; first name; last name; gender; date of birth; phone number; physical address; email address; username; password; geographic position; company name; profession; country; state; county; fax number; workplace; ZIP/Postal code; picture; profile picture; various types of Data; field of activity; number of employees; User ID; marital status; website; billing address; house number; prefix ; data relating to the point of sale; Twitter handle; budget; Data communicated while using the service; VAT Number; Tax ID; shipping address; city; IP address; current page; geography/region.
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Application.
Unless specified otherwise, all Data requested by this Application is mandatory and failure to provide this Data may make it impossible for this Application to provide its services. In cases where this Application specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Application or by the owners of third-party services used by this Application serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Application.
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 Application (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
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
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:
Displaying content from external platforms, Traffic optimisation and distribution, Analytics, Registration and authentication, Access to third-party accounts, Hosting and backend infrastructure, Managing data collection and online surveys, Interaction with data collection platforms and other third parties, Contacting the User, Managing contacts and sending messages, Collection of privacy-related preferences and Interaction with external social networks and platforms.
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”.
Facebook permissions asked by this Application
This Application may ask for some Facebook permissions allowing it to perform actions with the User's Facebook account and to retrieve information, including Personal Data, from it. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information about the following permissions, refer to the Facebook permissions documentation and to the Facebook privacy policy.
The permissions asked are the following:
About Me, Access Friend Lists, Age range, Basic information, Books Actions, Website and Work History.
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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Access to third-party accounts
This type of service allows this Application to access Data from your account on a third-party service and perform actions with it.
These services are not activated automatically, but require explicit authorisation by the User.
Facebook account access (Meta Platforms Ireland Limited)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Meta Platforms Ireland Limited.
Permissions asked: About Me; Access Friend Lists; Age range; Books Actions; Website; Work History.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; california Consumer Records Statute information; internet information; employment related information.
This processing constitutes:
LinkedIn account access (LinkedIn Corporation)
This service allows this Application to connect with the User's account on LinkedIn, provided by LinkedIn Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
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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.
Cloudflare Web Analytics (Cloudflare Inc.)
Cloudflare Web Analytics is an anonymized analytics service provided by Cloudflare Inc. that gives the Owner insight into the use of this Application by Users without needing to identify them. Further information may be found here and within the service's privacy policy.
Personal Data processed: device information; language; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information; inferred information.
This processing constitutes:
Business Contact (Italiaonline S.p.A.)
Business Contact is an analytics service provided by Italiaonline S.p.A.
Personal Data processed: Trackers; Usage Data.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
-
Collection of privacy-related preferences
This type of service allows this Application to collect and store Users’ preferences related to the collection, use, and processing of their personal information, as requested by the applicable privacy legislation.
iubenda Consent Database (iubenda srl)
The iubenda Consent Database allows to store and retrieve records of Users’ consent to the processing of Personal Data, and information and preferences expressed in relation to the provided consent.
In order to do so, it makes use of a Tracker that temporarily stores pending information on the User’s device until it is processed by the API. The Tracker (a browser feature called localStorage) is at that point deleted.
Personal Data processed: Data communicated while using the service; IP address; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
iubenda Newsletter Opt-in Booster (iubenda srl)
The iubenda Newsletter Opt-in Booster is a widget provided by iubenda s.r.l. for the collection of consent for email marketing.
If the User freely decides to provide their email address via the widget, that consent is confirmed with a double opt-in email. Thereafter, the User's consent is recorded in the “iubenda Consent Database”.
If the User withdraws their consent for email marketing using the opt-out method provided by the Owner, the Owner will update this preference in the database.
Personal Data processed: current page; email address; IP address; language; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information; inferred information.
iubenda Privacy Controls and Cookie Solution (iubenda srl)
The iubenda Privacy Controls and Cookie Solution allows the Owner to collect and store Users’ preferences related to the processing of personal information and in particular to the use of Cookies and other Trackers on this Application.
Personal Data processed: IP address; Trackers.
Place of processing: Italy – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
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Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorises this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data processed: city; company name; country; county; date of birth; email address; field of activity; first name; gender; last name; number of employees; phone number; physical address; profession; state; Tax ID; Trackers; Usage Data; User ID; various types of Data; VAT Number; website; ZIP/Postal code.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information; employment related information.
This processing constitutes:
- a Sale in the United States
Phone contact (this Application)
Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.
Personal Data processed: phone number.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
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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 Application and interact with them. Such services are often referred to as widgets, which are small elements placed on a website or app. They provide specific information or perform a particular function and often allow for user interaction.
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.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualisation service provided by Fonticons, Inc. that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
Instagram widget (Meta Platforms Ireland Limited)
Instagram is an image visualisation service provided by Meta Platforms Ireland Limited that allows this Application to incorporate content of this kind on its pages.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Application.
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.
Cloudinary (Cloudinary Ltd.)
Cloudinary is a hosting service provided by Cloudinary Ltd.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Israel – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
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Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Application for the purpose of saving and reusing data.
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.
Typeform widget (TYPEFORM S.L)
The Typeform widget is a service for interacting with the Typeform data collection platform provided by TYPEFORM S.L.
Personal Data processed: billing address; city; company name; country; county; Data communicated while using the service; date of birth; email address; field of activity; first name; gender; geographic position; language; last name; number of employees; phone number; physical address; picture; profession; profile picture; shipping address; state; Tax ID; Trackers; Usage Data; User ID; username; various types of Data as specified in the privacy policy of the service; VAT Number; website; workplace.
Place of processing: Spain – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information; geolocation data; sensorial information; employment related information; inferred information.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
-
Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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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 Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.
It is recommended to log out from the respective services in order to make sure that the processed data on this Application 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: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
X Post button and social widgets (X Corp.)
The X Post button and social widgets are services allowing interaction with the X social network provided by X Corp.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
Facebook Like button and social widgets (Meta Platforms Ireland Limited)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Meta Platforms Ireland Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: internet information.
This processing constitutes:
- a Sale in the United States
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Managing contacts and sending messages
This type of service makes it possible to manage a database of email contacts, phone contacts or any other contact information to communicate with the User.
These services may also collect data concerning the date and time when the message was viewed by the User, as well as when the User interacted with it, such as by clicking on links included in the message.
Sendgrid (Sendgrid)
Sendgrid is an email address management and message sending service provided by Sendgrid Inc.
Personal Data processed: company name; country; date of birth; email address; first name; gender; last name; phone number; physical address; Trackers; Usage Data; username.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information.
This processing constitutes:
- a Sale in the United States
- a Sharing in California
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Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
Firebase Notifications (Google Ireland Limited)
Firebase Notifications is a message sending service provided by Google Ireland Limited. Firebase Notifications can be integrated with Firebase Analytics to target analytics-based audiences and track opening and conversion events.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
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Managing data collection and online surveys
This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.
These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed - e.g. managing contacts, sending messages, analytics, advertising and payment processing.
Typeform (TYPEFORM S.L)
Typeform is a form builder and data collection platform provided by TYPEFORM S.L.
Personal Data processed: company name; country; Data communicated while using the service; email address; first name; geographic position; last name; number of employees; phone number; physical address; profession; Usage Data; username; various types of Data as specified in the privacy policy of the service; website.
Place of processing: Spain – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information; geolocation data; employment related information.
This processing constitutes:
- a Sale in the United States
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Registration and authentication
By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services.
Depending on what is described below, third parties may provide registration and authentication services. In this case, this Application will be able to access some Data, stored by these third-party services, for registration or identification purposes.
Some of the services listed below may also collect Personal Data for targeting and profiling purposes; to find out more, please refer to the description of each service.
Direct registration and profiling (this Application)
By registering or authenticating directly through this Application, Users allow this Application to identify them and give them access to dedicated services. The Owner may process Data collected when Users register or authenticate also for targeting and profiling purposes; to find out more, Users can contact the Owner using the contact details provided in this document.
Personal Data processed: billing address; budget; company name; country; county; data relating to the point of sale; date of birth; email address; fax number; field of activity; first name; gender; geographic position; house number; language; last name; marital status; number of employees; password; phone number; physical address; picture; prefix ; profession; profile picture; state; Twitter handle; Usage Data; User ID; username; various types of Data; website; workplace; ZIP/Postal code.
Category of Personal Information collected according to CCPA: identifiers; commercial information; internet information; geolocation data; sensorial information; employment related information; inferred information.
This processing constitutes:
- a Sale in the United States
Facebook Oauth (Meta Platforms Ireland Limited)
Facebook Oauth is a registration and authentication service provided by Meta Platforms Ireland Limited and is connected to the Facebook social network.
Personal Data processed: Trackers; various types of Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in the United States
LinkedIn OAuth (LinkedIn Corporation)
LinkedIn Oauth is a registration and authentication service provided by LinkedIn Corporation and is connected to the LinkedIn social network.
Personal Data processed: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in the United States
Sign in with Apple (Apple Inc.)
Sign in with Apple is a registration and authentication service provided by Apple Inc. In cases where Users are required to provide their email address, Sign in with Apple may generate a private relay address on behalf of Users that automatically forwards messages to their verified personal email account - therefore shielding their actual email address from the Owner.
Personal Data processed: city; country; date of birth; email address; first name; geography/region; last name; password; phone number; profile picture; User ID.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; geolocation data; sensorial information.
This processing constitutes:
- a Sale in the United States
X OAuth (X Corp.)
X Oauth is a registration and authentication service provided by X Corp. and is connected to the X social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
Facebook Authentication (Meta Platforms Ireland Limited)
Facebook Authentication is a registration and authentication service provided by Meta Platforms Ireland Limited and is connected to the Facebook social network.
Personal Data processed: Trackers; various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers; internet information.
This processing constitutes:
- a Sale in the United States
Instagram Authentication (Meta Platforms Ireland Limited)
Instagram Authentication is a registration and authentication service provided by Meta Platforms Ireland Limited and is connected to the Instagram social network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
Google OAuth (Google Ireland Limited)
Google OAuth is a registration and authentication service provided by Google Ireland Limited and is connected to the Google network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
This processing constitutes:
- a Sale in the United States
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Traffic optimisation and distribution
This type of service allows this Application to distribute their content using servers located across different countries and to optimise 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 Application 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 optimisation and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Application, i.e., communication between this Application and the User's browser, while also allowing analytical data from this Application to be collected.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to CCPA: identifiers.
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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Rights for registered California Users under the age of 18
California's "Online Eraser" law, part of California's Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services targeting minors to allow registered Users who are under the age of 18 and residents of California to request removal of content they post.
If a registered User fits that description and posted content on this Application, they may request removal of such content by contacting the Owner or its privacy policy coordinator at the contact details provided in this document.
In response to this request, the Owner may make content posted by the registered User invisible to other registered Users and the public (rather than deleting it entirely), in which case the content may remain on the Owner's servers. It may also be publicly available elsewhere if a third party copied and reposted this content.
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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 Application depends on the payment system used.
Cookie Policy
This Application 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
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 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 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.
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.
Further information for Users
in the United States
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 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 information contained in this section applies to all Users (Users are referred to below, simply as “you”, “your”, “yours”), who are residents in the following states: California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana.
For such Users, this information supersedes any other possibly divergent or conflicting provisions contained in the privacy policy.
This part of the document uses the term Personal Information
(and Sensitive Personal Information).
Notice at collection
The following Notice at collection provides you with timely notice about the categories of Personal Information collected or disclosed in the past 12 months so that you can exercise meaningful control over our use of that Information.
While such categorization of Personal Information is mainly based on California privacy laws, it can also be helpful for anyone who is not a California resident to get a general idea of what types of Personal Information are collected.
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Internet or other electronic network activity information
Personal Information collected or disclosed:
Usage Data, Trackers, language, device information, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, Twitter handle, budget, About Me, Website, Work History, Access Friend Lists, Books Actions, Age range, various types of Data as specified in the privacy policy of the service, Data communicated while using the service, shipping address, city, IP address, current page
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Displaying content from external platforms
- Analytics
- Registration and authentication
- Access to third-party accounts
- Managing data collection and online surveys
- Interaction with data collection platforms and other third parties
- Contacting the User
- Managing contacts and sending messages
- Collection of privacy-related preferences
- Interaction with external social networks and platforms
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Fonticons, Inc. , Cloudflare Inc., Meta Platforms Ireland Limited, TYPEFORM S.L, Italiaonline S.p.A., Sendgrid, iubenda srl, LinkedIn Corporation, X Corp.
Service providers or contractors: this Application
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Identifiers
Personal Information collected or disclosed:
various types of Data as specified in the privacy policy of the service, Usage Data, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, language, Twitter handle, budget, Trackers, About Me, Website, Work History, Access Friend Lists, Books Actions, Age range, Data communicated while using the service, shipping address, city, IP address, current page, geography/region
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Traffic optimisation and distribution
- Registration and authentication
- Further information about Personal Data
- Access to third-party accounts
- Hosting and backend infrastructure
- Managing data collection and online surveys
- Interaction with data collection platforms and other third parties
- Contacting the User
- Managing contacts and sending messages
- Collection of privacy-related preferences
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare Inc., Meta Platforms Ireland Limited, Cloudinary Ltd., TYPEFORM S.L, Sendgrid, iubenda srl, LinkedIn Corporation, Apple Inc., X Corp., Google Ireland Limited
Service providers or contractors: this Application
-
Inferences drawn from other personal information
Personal Information collected or disclosed:
language, Usage Data, device information, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, Twitter handle, budget, Trackers, various types of Data as specified in the privacy policy of the service, shipping address, city, Data communicated while using the service, IP address, current page
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Analytics
- Registration and authentication
- Interaction with data collection platforms and other third parties
- Collection of privacy-related preferences
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Cloudflare Inc., TYPEFORM S.L, iubenda srl
Service providers or contractors: this Application
-
Commercial information
Personal Information collected or disclosed:
Usage Data, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, language, Twitter handle, budget, various types of Data as specified in the privacy policy of the service, Data communicated while using the service, Trackers, shipping address, city
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Registration and authentication
- Managing data collection and online surveys
- Interaction with data collection platforms and other third parties
- Contacting the User
- Managing contacts and sending messages
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: TYPEFORM S.L, Sendgrid
Service providers or contractors: this Application
-
Geolocation data
Personal Information collected or disclosed:
Usage Data, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, language, Twitter handle, budget, various types of Data as specified in the privacy policy of the service, Data communicated while using the service, Trackers, shipping address, city, geography/region
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Registration and authentication
- Managing data collection and online surveys
- Interaction with data collection platforms and other third parties
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: TYPEFORM S.L, Apple Inc.
Service providers or contractors: this Application
-
Audio, electronic, visual, thermal, olfactory, or similar information
Personal Information collected or disclosed:
Usage Data, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, language, Twitter handle, budget, Trackers, various types of Data as specified in the privacy policy of the service, shipping address, city, Data communicated while using the service, geography/region
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Registration and authentication
- Interaction with data collection platforms and other third parties
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: TYPEFORM S.L, Apple Inc.
Service providers or contractors: this Application
-
Employment related information
Personal Information collected or disclosed:
Usage Data, first name, last name, gender, date of birth, phone number, physical address, email address, geographic position, company name, profession, country, state, county, fax number, workplace, ZIP/Postal code, picture, profile picture, various types of Data, field of activity, number of employees, User ID, website, billing address, house number, prefix , data relating to the point of sale, language, Twitter handle, budget, About Me, Website, Work History, Access Friend Lists, Books Actions, Age range, various types of Data as specified in the privacy policy of the service, Data communicated while using the service, Trackers, shipping address, city
Sensitive Personal Information collected or disclosed ℹ️:
username, password, marital status, VAT Number, Tax ID
Purposes:
- Registration and authentication
- Access to third-party accounts
- Managing data collection and online surveys
- Interaction with data collection platforms and other third parties
- Contacting the User
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms Ireland Limited, TYPEFORM S.L
Service providers or contractors: this Application
-
Personal information
Personal Information collected or disclosed:
About Me, Website, Work History, Access Friend Lists, Books Actions, Age range
Purposes:
- Access to third-party accounts
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Meta Platforms Ireland Limited
ℹ️ You can read the definitions of these concepts inside the “Definitions and legal references section” of the privacy policy.
To know more about your rights in particular to opt out of certain processing activities and to limit the use of your sensitive personal information (“Limit the Use of My Sensitive Personal Information”) you can refer to the “Your privacy rights under US state laws” section of our privacy policy.
For more details on the collection of Personal Information, please read the section “Detailed information on the processing of Personal Data” of our privacy policy.
We won’t process your Information for unexpected purposes, or for purposes that are not reasonably necessary to and compatible with the purposes originally disclosed, without your consent.
What are the sources of the Personal Information we collect?
We collect the above-mentioned categories of Personal Information, either directly or indirectly, from you when you use this Application.
For example, you directly provide your Personal Information when you submit requests via any forms on this Application. You also provide Personal Information indirectly when you navigate this Application, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Application and features thereof.
Your privacy rights under US state laws
You may exercise certain rights regarding your Personal Information. In particular, to the extent permitted by applicable law, you have:
- the right to access Personal Information: the right to know. You have the right to request that we confirm whether or not we are processing your Personal Information. You also have the right to access such Personal Information;
- the right to correct inaccurate Personal Information. You have the right to request that we correct any inaccurate Personal Information we maintain about you;
- the right to request the deletion of your Personal Information. You have the right to request that we delete any of your Personal Information;
- the right to obtain a copy of your Personal Information. We will provide your Personal Information in a portable and usable format that allows you to transfer data easily to another entity – provided that this is technically feasible;
- the right to opt out from the Sale of your Personal Information; We will not discriminate against you for exercising your privacy rights.
- the right to non-discrimination.
Additional rights for Users residing in California
In addition to the rights listed above common to all Users in the United States, as a User residing in California, you have
- The right to opt out of the Sharing of your Personal Information for cross-context behavioral advertising;
- The right to request to limit our use or disclosure of your Sensitive Personal Information to only that which is necessary to perform the services or provide the goods, as is reasonably expected by an average consumer. Please note that certain exceptions outlined in the law may apply, such as, when the collection and processing of Sensitive Personal Information is necessary to verify or maintain the quality or safety of our service.
Additional rights for Users residing in Virginia, Colorado, Connecticut, Texas, Oregon and Montana
In addition to the rights listed above common to all Users in the United States, as a User residing in Virginia, Colorado, Connecticut, Texas and Oregon, you have
- The right to opt out of the processing of your personal information for Targeted Advertising or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you;
- The right to freely give, deny or withdraw your consent for the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
Additional rights for users residing in Utah
In addition to the rights listed above common to all Users in the United States, as a User residing in Utah, you have
- The right to opt out of the processing of your Personal Information for Targeted Advertising;
- The right to opt out of the processing of your Sensitive Personal Information. Please note that certain exceptions outlined in the law may apply, such as, but not limited to, when the collection and processing of Sensitive Personal Information is necessary for the provision of a product or service specifically requested by the consumer.
How to exercise your privacy rights under US state laws
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 must know who you are. We will not respond to any request if we are unable to verify your identity and therefore confirm the Personal Information in our possession relates to you. You are not required to create an account with us to submit your request. We will use any Personal Information collected from you in connection with the verification of your request solely for 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 are an adult, you can make a request on behalf of a child under your parental authority.
How to exercise your rights to opt out
In addition to what is stated above, to exercise your right to opt-out of Sale or Sharing and Targeted Advertising you can also use the privacy choices link provided on this Application.
If you want to submit requests to opt out of Sale or Sharing and Targeted Advertising activities via a user-enabled global privacy control, such as for example the Global Privacy Control (“GPC”), you are free to do so and we will abide by such request in a frictionless manner.
How and when we are expected to handle your request
We will respond to your request without undue delay, but in all cases within the timeframe required by applicable law. Should we need more time, we will explain to you the reasons why, and how much more time we need.
Should we deny your request, we will explain to you the reasons behind our denial (where envisaged by applicable law you may then contact the relevant authority to submit a complaint).
We do not charge a fee to process or respond to your request unless such request is manifestly unfounded or excessive and in all other cases where it is permitted by the applicable law. 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 them.
Additional information about Data collection and processing
Legal action
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) 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 Application and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ Personal Information (or Information)
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.
Sensitive Personal Information
Sensitive Personal Information means any Personal Information that is not publicly available and reveals information considered sensitive according to the applicable privacy law.
Usage Data
Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, 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 Application 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 Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Application as described in the relative terms (if available) and on this site/application.
Sale
Sale means any exchange of Personal Information by the Owner to a third party, for monetary or other valuable consideration, as defined by the applicable privacy US state law. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the applicable law, does not constitute a Sale of your Personal Information.
Sharing
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 behavioural advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioural advertising for the benefit of a business in which no money is exchanged, as defined by the California privacy laws. Please note that the exchange of Personal Information with a service provider pursuant to a written contract that meets the requirements set by the California privacy laws, does not constitute sharing of your Personal Information.
Targeted advertising
Targeted advertising means displaying advertisements to a consumer where the advertisement is selected based on Personal Information obtained from that consumer’s activities over time and across nonaffiliated websites or online applications to predict such consumer’s preferences or interests, as defined by the applicable privacy US state law.
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.
This privacy policy relates solely to this Application, if not stated otherwise within this document.