Owner and Data Controller
Abeauty S.r.l
Via Madonna dell'olivo, 59
06081 - Assisi
Owner contact email: info@acquadispello.it
Types of Data collected
Among the types of Personal Data that Acqua di Spello collects, by itself or through third parties, there are:
Cookies; Usage Data; phone number; email address; last name; date of birth; first name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Data communicated while using the service.
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 Acqua di Spello.
Unless specified otherwise, all Data requested by Acqua di Spello is mandatory and failure to provide this Data may make it impossible for Acqua di Spello to provide its services. In cases where Acqua di Spello 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 Acqua di Spello or by the owners of third-party services used by Acqua di Spello 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 Acqua di Spello.
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 Acqua di Spello (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:
Handling payments, Commercial affiliation, Content commenting, Contacting the User, Managing contacts and sending messages, User database management, Tag Management, Managing support and contact requests, Managing landing and invitation pages, Heat mapping and session recording, Interaction with live chat platforms, Interaction with external social networks and platforms, SPAM protection, Advertising, Registration and authentication, Remarketing and behavioral targeting, Platform services and hosting, Analytics, Content performance and features testing (A/B testing), Displaying content from external platforms, Access to third-party accounts, Managing data collection and online surveys and Hosting and backend infrastructure.
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 Acqua di Spello
Acqua di Spello 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 Acqua di Spello 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:
By default, this includes certain User’s Data such as id, name, picture, gender, and their locale. Certain connections of the User, such as the Friends, are also available. If the User has made more of their Data public, more information will be available.
Email
Provides access to the User's primary email address.
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 Acqua di Spello 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 authorization by the User.
Facebook account access (Acqua di Spello)
This service allows Acqua di Spello to connect with the User's account on the Facebook social network, provided by Facebook, Inc.
Permissions asked: Email.
Place of processing: United States – Privacy Policy.
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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 Acqua di Spello, 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 Acqua di Spello. 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) (Acqua di Spello)
Acqua di Spello uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by Acqua di Spello.
Personal Data processed: email address; first name; last name.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. In order to understand Facebook's use of Data, consult Facebook's data policy.
Acqua di Spello 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: Cookies; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager
Google Ad Manager is an advertising service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
In order to opt out from being tracked by various advertising networks, Users may make use of Youronlinechoices. In order to understand Google's use of data, consult Google's partner policy.
This service uses the “DoubleClick” Cookie, which tracks use of Acqua di Spello and User behavior concerning ads, products and services offered.
Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar honors generic Do Not Track headers. This means your browser can tell its script not to collect any of your data. This is a setting that is available in all major browsers. Find Hotjar’s opt-out information here.
Personal Data processed: Trackers; Usage Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Meta ads conversion tracking (Meta pixel) (Meta Platforms, Inc.)
Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms, Inc. that connects data from the Meta Audience Network with actions performed on Acqua di Spello. The Meta pixel tracks conversions that can be attributed to ads on Facebook, Instagram and Meta Audience Network.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
AdEspresso conversion tracking (AdEspresso LLC)
AdEspresso conversion tracking is an analytics service provided by AdEspresso LLC that connects data from the Facebook advertising network with actions performed on Acqua di Spello.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy.
Google Ads conversion tracking
Google Ads conversion tracking is an analytics service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects data from the Google Ads advertising network with actions performed on Acqua di Spello.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Facebook Lookalike Audience (Facebook, Inc.)
Facebook Lookalike Audience is an advertising and behavioral targeting service provided by Facebook, Inc. that uses Data collected through Facebook Custom Audience in order to display ads to Users with similar behavior to Users who are already in a Custom Audience list on the base of their past use of Acqua di Spello or engagement with relevant content across the Facebook apps and services.
On the base of these Data, personalized ads will be shown to Users suggested by Facebook Lookalike Audience.
Users can opt out of Facebook's use of cookies for ads personalization by visiting this opt-out page.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Primis (McCann Discipline LTD)
Primis is an advertising service provided by McCann Discipline LTD.
Personal Data processed: Cookies; Usage Data.
Place of processing: Israel – Privacy Policy – Opt out.
Primo (Visarity Technologies GmbH)
Primo is an advertising service provided by Visarity Technologies GmbH.
Personal Data processed: Cookies; Usage Data.
Place of processing: Germany – 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.
Facebook Analytics for Apps (Facebook, Inc.)
Facebook Analytics for Apps is an analytics service provided by Facebook, Inc.
Personal Data processed: Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
Google Analytics (Universal Analytics)
Google Analytics (Universal Analytics) is a web analysis service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, (“Google”). Google utilizes the Data collected to track and examine the use of Acqua di Spello, 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.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Wordpress Stats (Automattic Inc.)
Wordpress Stats is an analytics service provided by Automattic Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Commercial affiliation
This type of service allows Acqua di Spello to display advertisements for third-party products or services. Ads can be displayed either as advertising links or as banners using various kinds of graphics.
Clicks on the icon or banner posted on the Application are tracked by the third-party services listed below, and are shared with Acqua di Spello.
For details of which data are collected, please refer to the privacy policy of each service.
ClickBank (Click Sales Inc.)
ClickBank is a banner commercial affiliation service provided by Click Sales Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Contacting the User
Phone contact (Acqua di Spello)
Users that provided their phone number might be contacted for commercial or promotional purposes related to Acqua di Spello, as well as for fulfilling support requests.
Personal Data processed: phone number.
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Content commenting
Content commenting services allow Users to make and publish their comments on the contents of Acqua di Spello.
Depending on the settings chosen by the Owner, Users may also leave anonymous comments. If there is an email address among the Personal Data provided by the User, it may be used to send notifications of comments on the same content. Users are responsible for the content of their own comments.
If a content commenting service provided by third parties is installed, it may still collect web traffic data for the pages where the comment service is installed, even when Users do not use the content commenting service.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a content commenting service provided by Facebook, Inc. enabling the User to leave comments and share them on the Facebook platform.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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Content performance and features testing (A/B testing)
The services contained in this section allow the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of Acqua di Spello.
Google Optimize
Google Optimize is an A/B testing service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, ("Google").
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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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 Acqua di Spello 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 Fonts is a typeface visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Acqua di Spello 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: United States – Privacy Policy; Ireland – Privacy Policy.
Instagram widget (Instagram, Inc.)
Instagram is an image visualization service provided by Instagram, Inc. that allows Acqua di Spello to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
Google Maps widget
Google Maps is a maps visualization service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that allows Acqua di Spello to incorporate content of this kind on its pages.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Font Awesome (Fonticons, Inc. )
Font Awesome is a typeface visualization service provided by Fonticons, Inc. that allows Acqua di Spello to incorporate content of this kind on its pages.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy.
Gravatar (Automattic Inc.)
Gravatar is an image visualization service provided by Automattic Inc. that allows Acqua di Spello to incorporate content of this kind on its pages.
Please note that if Gravatar images are used for comment forms, the commenter's email address or parts of it may be sent to Gravatar - even if the commenter has not signed up for that service.
Personal Data processed: email address; Usage Data.
Place of processing: United States – Privacy Policy.
YouTube video widget (Google LLC)
YouTube is a video content visualization service provided by Google LLC that allows Acqua di Spello to incorporate content of this kind on its pages.
Personal Data processed: Tracker; Usage Data.
Place of processing: United States – Privacy Policy.
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Handling payments
Payment processing services enable Acqua di Spello to process payments by credit card, bank transfer or other means. To ensure greater security, Acqua di Spello shares only the information necessary to execute the transaction with the financial intermediaries handling the transaction.
Some of these services may also enable the sending of timed messages to the User, such as emails containing invoices or notifications concerning the payment.
2Checkout (2Checkout.com, Inc.)
2Checkout is a payment service provided by 2Checkout.com, Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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.
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Heat mapping and session recording
Heat mapping services are used to display the areas of a page where Users most frequently move the mouse or click. 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.
Crazy Egg (Crazyegg)
Crazy Egg is a heat mapping service provided by Crazy Egg, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy.
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: Cookies; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable Acqua di Spello to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Acqua di Spello.
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.
OVHcloud (OVH Srl)
OVHcloud is a hosting and backend service provided by OVH Srl.
Personal Data processed: Usage Data.
Place of processing: Italy – 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 Acqua di Spello.
The interaction and information obtained through Acqua di Spello 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 Acqua di Spello isn’t being connected back to the User’s profile.
Google+ +1 button and social widgets
The Google+ +1 button and social widgets are services allowing interaction with the Google+ social network provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – 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 Acqua di Spello, for contacting and being contacted by Acqua di Spello 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.
Zendesk Chat (Zendesk, Inc.)
Zendesk Chat is a service for interacting with the Zendesk live chat platform provided by Zendesk, Inc.
Personal Data processed: Cookies; email address; first name; last name.
Place of processing: United States – Privacy Policy.
Facebook Messenger Customer Chat (Facebook, Inc.)
The Facebook Messenger Customer Chat is a service for interacting with the Facebook Messenger live chat platform provided by Facebook, Inc.
Personal Data processed: Cookies; Data communicated while using the service; Usage Data.
Place of processing: United States – Privacy Policy.
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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.
Mailchimp (The Rocket Science Group LLC)
Mailchimp is an email address management and message sending service provided by The Rocket Science Group LLC.
Personal Data processed: Cookies; date of birth; email address; last name; Usage Data.
Place of processing: United States – Privacy Policy.
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Managing data collection and online surveys
This type of service allows Acqua di Spello 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.
Facebook lead ads (Facebook, Inc.)
Facebook lead ads is an advertising and data collection service provided by Facebook, Inc. that allows form-based ads to be shown to Users pre-populated with Personal Data from their Facebook profiles, such as names and email addresses. Depending on the type of advertisement, Users may be requested to provide further information.
Form submission results in the collection and processing of these Data by the Owner under this privacy policy, and only for the specific purpose outlined on the form and/or inside this privacy policy, where provided.
Users may exercise their rights, at any time, including the right to withdraw their consent to the processing of their Data, as specified in the section containing information about User rights in this privacy policy.
Personal Data processed: email address; first name.
Place of processing: United States – Privacy Policy – Opt out.
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Managing landing and invitation pages
This type of service helps with building and managing landing and invitation pages, i.e., pages for presenting a product or service, where you may add your contact information such as an email address.
Managing these pages means that these services will handle the Personal Data collected through the pages, including Usage Data.
Instapage (Instapage, Inc.)
Instapage is a landing page management service provided by Instapage, Inc., that allows Acqua di Spello to collect the email addresses of Users interested in its service.
Instapage allows the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.
Personal Data processed: Cookies; email address; Usage Data.
Place of processing: United States – Privacy Policy.
Mailchimp Landing Page (The Rocket Science Group LLC)
Mailchimp Landing Page is a landing page management service provided by The Rocket Science Group LLC, that allows Acqua di Spello to collect the email addresses of Users interested in its service.
Mailchimp Landing Page allows the Owner to track and analyze the User response concerning web traffic or behavior regarding changes to the structure, text or any other component of the created landing pages.
Personal Data processed: email address; first name; last name.
Place of processing: United States – Privacy Policy.
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Managing support and contact requests
This type of service allows Acqua di Spello to manage support and contact requests received via email or by other means, such as the contact form.
The Personal Data processed depend on the information provided by the User in the messages and the means used for communication (e.g. email address).
Zendesk (Zendesk, Inc.)
Zendesk is a support and contact request management service provided by Zendesk Inc.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Platform services and hosting
These services have the purpose of hosting and running key components of Acqua di Spello, therefore allowing the provision of Acqua di Spello 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.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Owner to build, run and host Acqua di Spello.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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Registration and authentication
By registering or authenticating, Users allow Acqua di Spello 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, Acqua di Spello will be able to access some Data, stored by these third-party services, for registration or identification purposes.
WordPress.com Single Sign On (Automattic Inc.)
WordPress.com Single Sign On is a registration and authentication service provided by Automattic Inc. and is connected to the WordPress.com network.
Personal Data processed: various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy.
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.
Instagram Authentication (Instagram, Inc.)
Instagram Authentication is a registration and authentication service provided by Instagram, Inc. 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: United States – Privacy Policy.
Facebook Authentication (Facebook, Inc.)
Facebook Authentication is a registration and authentication service provided by Facebook, Inc. and is connected to the Facebook 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.
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Remarketing and behavioral targeting
This type of service allows Acqua di Spello and its partners to inform, optimize and serve advertising based on past use of Acqua di Spello 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.
Remarketing with Google Analytics
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Acqua di Spello with the Facebook advertising network.
Personal Data processed: Cookies; email address.
Place of processing: United States – Privacy Policy – Opt Out.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of Acqua di Spello with the Facebook advertising network.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Google Ad Manager Audience Extension
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that tracks the visitors of Acqua di Spello and allows selected advertising partners to display targeted ads across the web to them.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing, that connects the activity of Acqua di Spello 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: Cookies; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out; Ireland – Privacy Policy – Opt Out.
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SPAM protection
This type of service analyzes the traffic of Acqua di Spello, potentially containing Users' Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognized as SPAM.
Google reCAPTCHA
Google reCAPTCHA is a SPAM protection service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
The use of reCAPTCHA is subject to the Google privacy policy and terms of use.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Cookies; Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on Acqua di Spello in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this Data.
Google Tag Manager
Google Tag Manager is a tag management service provided by Google LLC or by Google Ireland Limited, depending on how the Owner manages the Data processing.
Personal Data processed: Usage Data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
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User database management
This type of service allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to Acqua di Spello, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving Acqua di Spello.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on Acqua di Spello.
ActiveCampaign (ActiveCampaign, Inc.)
ActiveCampaign is a User database management service provided by ActiveCampaign, Inc.
Personal Data processed: Cookies; email address; 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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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 Acqua di Spello depends on the payment system used.
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Analysis and predictions based on the User’s Data (“profiling”)
The Owner may use the Personal and Usage Data collected through Acqua di Spello to create or update User profiles. This type of Data processing allows the Owner to evaluate User choices, preferences and behaviour for the purposes outlined in the respective section of this document.
User profiles can also be created through the use of automated tools like algorithms, which can also be provided by third parties. To find out more about the profiling activities performed, Users can check the relevant sections of this document.
The User always has a right to object to this kind of profiling activity. To find out more about the User's rights and how to exercise them, the User is invited to consult the section of this document outlining the rights of the User.
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Personal Data collected through sources other than the User
The Owner of Acqua di Spello 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.
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User identification via a universally unique identifier (UUID)
Acqua di Spello may track Users by storing a so-called universally unique identifier (or short UUID) for analytics purposes or for storing Users' preferences. This identifier is generated upon installation of this Application, it persists between Application launches and updates, but it is lost when the User deletes the Application. A reinstall generates a new UUID.
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Unique device identification
Acqua di Spello may track Users by storing a unique identifier of their device, for analytics purposes or for storing Users' preferences.
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Automated decision-making
Automated decision-making means that a decision which is likely to have legal effects or similarly significant effects on the User, is taken solely by technological means, without any human intervention.
Acqua di Spello may use the User's Personal Data to make decisions entirely or partially based on automated processes according to the purposes outlined in this document.
Acqua di Spello adopts automated decision-making processes as far as necessary to enter into or perform a contract between User and Owner, or on the basis of the User’s explicit consent, where such consent is required by the law.
Automated decisions are made by technological means – mostly based on algorithms subject to predefined criteria – which may also be provided by third parties.
The rationale behind the automated decision making is:
- to enable or otherwise improve the decision-making process;
- to grant Users fair and unbiased treatment based on consistent and uniform criteria;
- to reduce the potential harm derived from human error, personal bias and the like which may potentially lead to discrimination or imbalance in the treatment of individuals etc.;
- to reduce the risk of User's failure to meet their obligation under a contract.
To find out more about the purposes, the third-party services, if any, and any specific rationale for automated decisions used within Acqua di Spello, Users can check the relevant sections in this document.
Consequences of automated decision-making processes for Users and rights of Users subjected to it
As a consequence, Users subject to such processing, are entitled to exercise specific rights aimed at preventing or otherwise limiting the potential effects of the automated decisions taken.
In particular, Users have the right to:
- obtain an explanation about any decision taken as a result of automated decision-making and express their point of view regarding this decision;
- challenge a decision by asking the Owner to reconsider it or take a new decision on a different basis;
- request and obtain from the Owner human intervention on such processing.
To learn more about the User’s rights and the means to exercise them, the User is invited to consult the section of this document relating to the rights of the User.
Cookie Policy
Acqua di Spello 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.
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 Acqua di Spello 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, Acqua di Spello 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, Acqua di Spello and any third-party services may collect files that record interaction with Acqua di Spello (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 Acqua di Spello 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 Acqua di Spello (or third-party services employed in Acqua di Spello), which can include: the IP addresses or domain names of the computers utilized by the Users who use Acqua di Spello, 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 Acqua di Spello 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 Acqua di Spello. The Data Controller, unless otherwise specified, is the Owner of Acqua di Spello.
Acqua di Spello (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by Acqua di Spello 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 Acqua di Spello, if not stated otherwise within this document.