Owner and Data Controller
ARZZ International Inc.
595 Madison Avenue, 15th floor, New York, NY, 10022
Owner contact email: dataprotection@arezzousa.com
Types of Data collected
Among the types of Personal Data that this Website collects, by itself or through third parties, there are:
Usage Data; Trackers; email address; first name; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); username; password; payment info; last name; billing address; shipping address; phone number; device information; various types of Data; Data communicated while using the service; Universally unique identifier (UUID).
Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website is mandatory and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data is not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools — by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present document and in the Cookie Policy.
Users are responsible for any third-party Personal Data obtained, published or shared through this Website.
Mode and place of processing the Data
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.
Retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
The purposes of processing
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, as well as the following:
Displaying content from external platforms, Advertising, Tag Management, Traffic optimization and distribution, Managing contacts and sending messages, Analytics, Heat mapping and session recording, Remarketing and behavioral targeting, Handling payments, Platform services and hosting, Contacting the User, Interaction with online survey platforms, Interaction with data collection platforms and other third parties, Managing data collection and online surveys, Commercial affiliation, User database management, Hosting and backend infrastructure, Communication and Marketing.
For specific information about the Personal Data used for each purpose, the User may refer to the section “Detailed information on the processing of Personal Data”.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
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Advertising
This type of service allows User Data to be utilized for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Website, possibly based on User interests.
This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.
Some of the services listed below may use Trackers to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User’s interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section "How to opt-out of interest-based advertising" in this document.
Microsoft Advertising (Microsoft Corporation)
Microsoft Advertising is an advertising service provided by Microsoft Corporation.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
TikTok conversion tracking (TikTok Inc.)
TikTok conversion tracking is an analytics and behavioral targeting service provided by TikTok Inc. that connects data from the TikTok advertising network with actions performed on this Website. The TikTok pixel tracks conversions that can be attributed to TikTok ads and enables to target groups of Users on the base of their past use of this Website.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Blue (Blue)
Blue is an advertising service provided by Blue.
Personal Data processed: Trackers; Usage Data.
Place of processing: Brazil – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Criteo (Criteo SA)
Criteo is an advertising service provided by Criteo SA.
Personal Data processed: Trackers; Usage Data.
Place of processing: France – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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 this Website. 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.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Taboola (Taboola Inc.)
Taboola is an advertising service provided by Taboola Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
Havas Media (Havas Media (Artemis Alliance S.L.U.))
Havas Media is an advertising service provided by Havas Media (Artemis Alliance S.L.U.).
Personal Data processed: Trackers; Usage Data.
Place of processing: European Union – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
LiveIntent (Liveintent Inc.)
LiveIntent is an advertising service provided by Liveintent Inc.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Pinterest Ads (Pinterest, Inc.)
Pinterest Ads is an advertising service provided by Pinterest, Inc. that allows the Owner to run advertising campaigns on the Pinterest advertising network.
Users may opt out of behavioral advertising features through their device settings, their Pinterest personalization settings.
Personal Data processed: email address; Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Global (Global Media Group Services Limited)
Global is an advertising service provided by Global Media Group Services Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: United Kingdom – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
GlobalWebIndex (Trendstream Limited)
GlobalWebIndex is an advertising service provided by Trendstream Limited.
Personal Data processed: Trackers; Usage Data.
Place of processing: United Kingdom – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics 4 (Google LLC)
Google Analytics 4 is a web analysis service provided by Google LLC (“Google”). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
In Google Analytics 4, IP addresses are used at collection time and then discarded before Data is logged in any data center or server. Users can learn more by consulting Google’s official documentation.
In order to understand Google's use of Data, consult Google's partner policy.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Meta Events Manager (Meta Platforms, Inc.)
Meta Events Manager is an analytics service provided by Meta Platforms, Inc. By integrating the Meta pixel, Meta Events Manager can give the Owner insights into the traffic and interactions on this Website.
Personal Data processed: Trackers; Usage Data.
Place of processing: United States – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
Google Analytics Advertising Reporting Features (Google LLC)
Google Analytics on this Website has Advertising Reporting Features activated, which collects additional information from the DoubleClick cookie (web activity) and from device advertising IDs (app activity). It allows the Owner to analyze specific behavior and interests Data (traffic Data and Users' ads interaction Data) and, if enabled, demographic Data (information about the age and gender).
Users can opt out of Google's use of cookies by visiting Google's Ads Settings.
Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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Commercial affiliation
This type of service allows this Website 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 this Website.
For details of which data are collected, please refer to the privacy policy of each service.
Rakuten Advertising Affiliate
Rakuten Advertising Affiliate is a banner commercial affiliation service provided by Rakuten Marketing LLC or by Rakuten Marketing LLC dba Rakuten Advertising, depending on how the Owner manages the Data processing.
Personal Data processed: Trackers; Universally unique identifier (UUID); Usage Data.
Place of processing: United States – Privacy Policy – Opt out; European Union – Privacy Policy – Opt out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Communication
Message Content and mobile alerts
You will receive SMS messages containing information about our latest products, promotions, events, and other updates related to our brand. These messages may include sales, marketing content, surveys, or other communications.
Message Frequency: We aim to send SMS messages only when we believe they are relevant and valuable to you. Message frequency may vary depending on promotions, events, and your engagement with our brand.
Unsubscribe/Opting Out: You have the right to opt out of receiving SMS messages from us at any time. To do so, simply reply "STOP" for 44379 to any message you receive from us. You may also contact our customer service team on customercare@schutzusa.com for assistance with opting out.
Data Security: We take the security of your personal information seriously and implement measures to protect it from unauthorized access, disclosure, alteration, or destruction.
Privacy Policy: Please review our Privacy Policy, which is incorporated into these Terms of Use and also governs your use of the Schutz Shoes site https://schutz-shoes.com/pages/privacy-policy.
By opting in to receive SMS messages from Schutz, you acknowledge that you have read, understood, and agreed to these SMS Terms & Use, as well as our Privacy Policy. If you have any questions or concerns about our SMS service or privacy practices, please contact us.
This processing constitutes:
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Contacting the User
Contact form (this Website)
By filling in the contact form with their Data, the User authorizes this Website 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: email address; first name; last name.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
Kustomer
Kustomer is a communication platform provided by Kustomer Inc. that provides a SaaS customer relationship management platform that optimizes communications and interactions by chat, e-mail, and contact form.
Personal Data processed: billing address; device information; email address; first name; last name; phone number; shipping address; Trackers; Usage Data; chat recordings.
Place of processing: United States – Privacy Policy.
This processing constitutes:
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Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Website and interact with them.
This type of service might still collect web traffic data for the pages where the service is installed, even when Users do not use it.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Website 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 the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Handling payments
Unless otherwise specified, this Website processes any payments by credit card, bank transfer or other means via external payment service providers. In general and unless where otherwise stated, Users are requested to provide their payment details and personal information directly to such payment service providers. This Website isn't involved in the collection and processing of such information: instead, it will only receive a notification by the relevant payment service provider as to whether payment has been successfully completed.
PayPal (PayPal Inc.)
PayPal is a payment service provided by PayPal Inc., which allows Users to make online payments.
Personal Data processed: email address; first name; password; payment info; username.
Place of processing: See the PayPal privacy policy – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information.
This processing constitutes:
- a Sale in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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Heat mapping and session recording
Heat mapping services are used to display the areas of this Website that Users interact with most frequently. This shows where the points of interest are. These services make it possible to monitor and analyze web traffic and keep track of User behavior.
Some of these services may record sessions and make them available for later visual playback.
Microsoft Clarity (Microsoft Corporation)
Microsoft Clarity is a session recording and heat mapping service provided by Microsoft Corporation.
Microsoft processes or receives Personal Data via Microsoft Clarity, which in turn may be used for any purpose in accordance with the Microsoft Privacy Statement, including improving and providing Microsoft Advertising.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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: Trackers; Usage Data; various types of Data as specified in the privacy policy of the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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Hosting and backend infrastructure
This type of service has the purpose of hosting Data and files that enable this Website to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of this Website.
Some services among those listed below, if any, may work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Amazon Web Services (AWS) (Amazon Web Services, Inc.)
Amazon Web Services (AWS) is a hosting and backend service provided by Amazon Web Services, Inc.
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 the CCPA: identifiers.
This processing constitutes:
-
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 Website 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.
Hotjar Recruit User Testers (Hotjar Ltd.)
The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform 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: Trackers; Usage Data; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
- a Sale in California
- a Sharing in California
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Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website.
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.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
The Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform 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: Trackers; Usage Data; various types of Data.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Customerly Survey Widget (Customerly Ltd.)
The Customerly Survey Widget is a service for interacting with the Customerly online survey platform provided by Customerly Ltd.
Personal Data processed: Data communicated while using the service; Trackers; Usage Data.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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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.
Emarsys Email Marketing (Emarsys North America, Inc.)
Emarsys Email Marketing is an email address management and message-sending service provided by Emarsys North America, Inc.
Personal Data processed: email address; first name; Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
Customerly E-mail Marketing (Customerly Ltd.)
Customerly E-mail Marketing is an email address management and message sending service provided by Customerly Ltd.
Personal Data processed: email address; first name; phone number.
Place of processing: Ireland – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers.
This processing constitutes:
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Managing data collection and online surveys
This type of service allows this Website 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.
Hotjar surveys (Hotjar Ltd.)
Hotjar surveys is a survey builder and data collection platform provided by Hotjar Ltd.
Hotjar surveys may use cookies to track User behavior. Users can Opt-Out of Hotjar surveys cookie tracking by visiting this opt-out page.
Hotjar surveys respects the Do Not Track option available in most modern browsers that, if activated, sends a special signal to stop tracking User activity. Users can find more information on how to enable Do Not Track for each supported browser here.
Personal Data processed: Data communicated while using the service.
Place of processing: Malta – Privacy Policy – Opt Out.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Marketing
Sinch
Sinch is a cloud-based SMS service is provided to clients on demand over the internet from the cloud computing provider’s servers (hardware).
In general, Sinch will collect personal data from you based upon our (business) relationship, your use of the Site, Our services and Our products, as set out in the Privacy Statement below. We encourage you to read the entire statement (even if it might be a bit long) but by clicking on the various sections, you can also skip to the sections of the statement that you find most interesting. If you plan to click&skip or just accept or ignore, please do note a quick overview:
That Sinch does not sell your personal data to third parties.
That Sinch may share your personal data within the group if necessary, to provide the service that you requested or to answer your question in the best way possible.
That Sinch website is structured specifically to not attract anyone under 13, nor do We collect or maintain Personal Data on the Site from those who Sinch actually knows are under 13.
That Sinch may transfer your personal data to countries outside of the EU/EEA. If we do this, we take sufficient technical, organisational and contractual measures to ensure that an adequate level of data protection is provided.
That our recruitment website is covered by a different privacy statement that you can find on the website itself.
That Sinch has a Group Data Protection Officer, based in Stockholm, Sweden. She can be reached via DPO@sinch.com whenever you want to use the rights to access, rectification, erasure, object, revoke consent or block data or have any questions.
This processing constitutes:
- a Sharing in California
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Targeted Advertising in Virginia, Colorado, Connecticut, Utah, Texas, Oregon and Montana
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Platform services and hosting
These services have the purpose of hosting and running key components of this Website, therefore allowing the provision of this Website from within a unified platform. Such platforms provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database management, e-commerce, payment processing – that imply the collection and handling of Personal Data.
Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Shopify (Shopify Inc.)
Shopify is a platform provided by Shopify Inc. that allows the Owner to build, run and host an e-commerce website.
Personal Data processed: billing address; device information; email address; first name; last name; payment info; phone number; shipping address; Trackers; Usage Data.
Place of processing: Canada – Privacy Policy.
Category of Personal Information collected according to the CCPA: identifiers; commercial information; internet or other electronic network activity information.
This processing constitutes:
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Remarketing and behavioral targeting
This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.
This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
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.
TikTok Remarketing ( TikTok Information Technologies UK Limited )
TikTok Remarketing is a remarketing and behavioral targeting service provided by TikTok Information Technologies UK Limited that connects the activity of this Website with the TikTok advertising network.
Personal Data processed: Trackers.
Place of processing: United Kingdom – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website 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 LLC)
Google Tag Manager is a tag management service provided by Google LLC.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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Traffic optimization and distribution
This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.
Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.
Cloudflare (Cloudflare Inc.)
Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.
The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.
Personal Data processed: Trackers.
Place of processing: United States – Privacy Policy.
Category of Personal Information collected according to the CCPA: internet or other electronic network activity information.
This processing constitutes:
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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 this Website, as well as to track User activities through analytics features. This Personal Data may also be matched with publicly available information about the User (such as social networks' profiles) and used to build private profiles that the Owner can display and use for improving this Website.
Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Website.
Customerly (Customerly Ltd.)
Customerly is a User database management service provided by Customerly Ltd.
Customerly can also be used as a medium for communications, either through email, or through messages within this Website.
Personal Data processed: email address; Trackers; Usage Data; 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 the CCPA: identifiers; internet or other electronic network activity information.
This processing constitutes:
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.
Cookie Policy
This Website uses Trackers. To learn more, Users may consult the Cookie Policy.
Legal basis of processing
The Owner may process Personal Data relating to Users if one of the following applies:
- Users have given their consent for one or more specific purposes.
- provision of Data is necessary for the performance of an agreement with the User and/or for any pre-contractual obligations thereof;
- processing is necessary for compliance with a legal obligation to which the Owner is subject;
- processing is related to a task that is carried out in the public interest or in the exercise of official authority vested in the Owner;
- processing is necessary for the purposes of the legitimate interests pursued by the Owner or by a third party.
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing, and in particular whether the provision of Personal Data is a statutory or contractual requirement, or a requirement necessary to enter into a contract.
Further information about retention time
Unless specified otherwise in this document, Personal Data shall be processed and stored for as long as required by the purpose they have been collected for and may be retained for longer due to applicable legal obligation or based on the Users’ consent.
Therefore:
- Personal Data collected for purposes related to the performance of a contract between the Owner and the User shall be retained until such contract has been fully performed.
- Personal Data collected for the purposes of the Owner’s legitimate interests shall be retained as long as needed to fulfill such purposes. Users may find specific information regarding the legitimate interests pursued by the Owner within the relevant sections of this document or by contacting the Owner.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to fulfil a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the right to erasure, the right to rectification and the right to data portability cannot be enforced after expiration of the retention period.
The rights of Users based on the General Data Protection Regulation (GDPR)
Users may exercise certain rights regarding their Data processed by the Owner.
In particular, Users have the right to do the following, to the extent permitted by law:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used and machine readable format and, if technically feasible, to have it transmitted to another controller without any hindrance.
- Lodge a complaint. Users have the right to bring a claim before their competent data protection authority.
Users are also entitled to learn about the legal basis for Data transfers abroad including to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
Details about the right to object to processing
Where Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users must know that, however, should their Personal Data be processed for direct marketing purposes, they can object to that processing at any time, free of charge and without providing any justification. Where the User objects to processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To learn whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to exercise these rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Such requests are free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.
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 Website and, if the case may be, its parent, subsidiaries and affiliates (for the purposes of this section referred to collectively as “we”, “us”, “our”).
The 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.
-
Internet or other electronic network activity information
Personal Information collected or disclosed:
Usage Data, Trackers, email address, first name, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, last name, billing address, shipping address, phone number, device information, various types of Data, Data communicated while using the service, Universally unique identifier (UUID)
Sensitive Personal Information collected or disclosed ℹ️:
payment info
Purposes:
- Displaying content from external platforms
- Advertising
- Tag Management
- Traffic optimization and distribution
- Managing contacts and sending messages
- Analytics
- Heat mapping and session recording
- Remarketing and behavioral targeting
- Platform services and hosting
- Interaction with online survey platforms
- Interaction with data collection platforms and other third parties
- Managing data collection and online surveys
- Commercial affiliation
- User database management
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Google LLC, Microsoft Corporation, TikTok Inc., Blue, Cloudflare Inc., Criteo SA, Emarsys North America, Inc., Meta Platforms, Inc., TikTok Information Technologies UK Limited , Taboola Inc., Havas Media (Artemis Alliance S.L.U.), Liveintent Inc., Pinterest, Inc., Shopify Inc., Global Media Group Services Limited, Trendstream Limited, Hotjar Ltd., Rakuten Marketing LLC, Customerly Ltd.
-
Identifiers
Personal Information collected or disclosed:
email address, first name, Trackers, unique device identifiers for advertising (Google Advertiser ID or IDFA, for example), various types of Data as specified in the privacy policy of the service, Usage Data, last name, billing address, shipping address, phone number, device information, various types of Data, Universally unique identifier (UUID)
Sensitive Personal Information collected or disclosed ℹ️:
username, password, payment info
Purposes:
- Managing contacts and sending messages
- Analytics
- Handling payments
- Advertising
- Platform services and hosting
- Contacting the User
- Heat mapping and session recording
- Interaction with online survey platforms
- Interaction with data collection platforms and other third parties
- Commercial affiliation
- User database management
- Hosting and backend infrastructure
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: Emarsys North America, Inc., Google LLC, PayPal Inc., Pinterest, Inc., Shopify Inc., Hotjar Ltd., Rakuten Marketing LLC, Customerly Ltd., Amazon Web Services, Inc.
Service providers or contractors: this Website
-
Commercial information
Personal Information collected or disclosed:
first name, email address, Trackers, last name, billing address, shipping address, phone number, device information, Usage Data
Sensitive Personal Information collected or disclosed ℹ️:
username, password, payment info
Purposes:
- Handling payments
- Platform services and hosting
Retention period:
for the time necessary to fulfill the purpose
Sold or Shared ℹ️:
Yes
Targeted Advertising: ℹ️:
Yes
Third-parties: PayPal Inc., Shopify Inc.
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 Website.
For example, you directly provide your Personal Information when you submit requests via any forms on this Website. You also provide Personal Information indirectly when you navigate this Website, as Personal Information about you is automatically observed and collected.
Finally, we may collect your Personal Information from third parties that work with us in connection with the Service or with the functioning of this Website 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 Website.
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 Website or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System logs and maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) or use other Personal Data (such as the IP Address) for this purpose.
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
Changes to this privacy policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Definitions and legal references
Personal Data (or Data)
/ 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 Website (or third-party services employed in this Website), which can include: the IP addresses or domain names of the computers utilized by the Users who use this Website, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilized by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User's IT environment.
User
The individual using this Website who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Website. The Data Controller, unless otherwise specified, is the Owner of this Website.
This Website (or this Application)
The means by which the Personal Data of the User is collected and processed.
Service
The service provided by this Website as described in the relative terms (if available) and on this site/application.
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 behavioral advertising, whether for monetary or other valuable consideration, including transactions between a business and a third party for cross-context behavioral advertising for the benefit of a business in which no money is exchanged, as defined by the 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 Website, if not stated otherwise within this document.