Data Controller

Email address of the Data Controller: davidefrainetti@gioia-group.it

Type of Data we collect

Among the Personal Data collected by this Website, either independently or through third parties, are:

• Usage data
• Tracking tools
• unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example)
• number of Users
• session statistics
• first name
• last name
• phone number
• Data communicated during the use of the service
• responses to questions
• user content
• contents of the message or email
• profile picture
• date of the message
• time the message was sent
• message sender
• various types of Data
• username
• language

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or through specific informational texts displayed prior to the collection of the Data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during the use of this Website.
Unless otherwise specified, all Data requested by this Website is mandatory. If the User refuses to provide them, it may be impossible for this Website to provide the Service. In cases where this Website indicates certain Data as optional, Users are free to refrain from providing such Data, without any consequences on the availability of the Service or its operation.
Users who have doubts about which Data is mandatory are encouraged to contact the Data Controller.
The possible use of Cookies - or other tracking tools - by this Website or by third-party service providers used by this Website aims to provide the Service requested by the User, in addition to the further purposes described in this document and in the Cookie Policy.

The User assumes responsibility for the Personal Data of third parties obtained, published, or shared through this Website.

Methods and Location of Processing of Collected Data

Processing Methods

The Data Controller adopts appropriate security measures to prevent unauthorized access, disclosure, modification, or destruction of Personal Data.
Processing is carried out using IT and/or telematic tools, with organizational methods and logics strictly related to the purposes indicated. In addition to the Data Controller, in some cases, other parties involved in the organization of this Website (administrative, commercial, marketing personnel, legal, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) may also have access to the Data, appointed as Data Processors by the Data Controller if necessary. The updated list of Data Processors can always be requested from the Data Controller.

Location

Data is processed at the operational offices of the Data Controller and in any other location where the parties involved in the processing are located. For further information, contact the Data Controller.
User Personal Data may be transferred to a country different from the one in which the User is located. For further information on the location of processing, the User can refer to the section regarding details on the Processing of Personal Data.

Retention Period

Unless otherwise stated in this document, Personal Data are processed and retained for the time required by the purpose for which they were collected and may be retained for a longer period due to any legal obligations or based on the consent of the Users.

Purposes of Data Processing

User Data is collected to allow the Data Controller to provide the Service, comply with legal obligations, respond to requests or executive actions, protect its rights and interests (or those of Users or third parties), identify any fraudulent or malicious activities, as well as for the following purposes:

• Viewing content from external platforms
• Statistics
• Payment management
• Protection from SPAM
• Heat mapping and session recording
• Advertising
• Infrastructure monitoring
• Platform and hosting services
• Interaction with live chat platforms
• Interaction with social networks and external platforms
• Contacting the User
• Registration and authentication provided directly by this Website
• Traffic optimization and distribution
• Tag management
• Access to accounts on third-party services
• Registration and authentication
• Contact management and message sending
• Hosting and backend infrastructure
• Management of support requests and contact

Details on the Processing of Personal Data

Access to accounts on third-party services

This type of service allows this Website to retrieve Data from your accounts on third-party services and perform actions with them. These services are not activated automatically but require the User's express authorization.

Contacting the User

Contact management and message sending

This type of service allows managing a database of email contacts, phone contacts, or contacts of any other type used to communicate with the User. These services may also allow collecting data related to the date and time the messages are viewed by the User, as well as the User's interaction with them, such as information on clicks on links included in the messages.

Payment management

Unless otherwise specified, this Website processes all payments by credit card, bank transfer, or other means through external payment service providers. In general, and unless otherwise indicated, Users are requested to provide payment details and personal information directly to such payment service providers.
This Website is not involved in the collection and processing of such information: it will instead receive only a notification from the payment service provider regarding the completed payment.

Tag management

This type of service is functional for the centralized management of tags or scripts used on this Website.
The use of such services involves the flow of User Data through them and, if applicable, their retention.

Management of support requests and contact

This type of service allows this Website to manage support and contact requests received via email or through other tools, such as the contact form. The Personal Data processed depends on the information provided by the User within the messages and the tool used for communication (e.g., email address).

Heat mapping and session recording

Heat mapping services are used to identify areas of this Website that Users interact with most frequently, in order to detect which of them attract the most interest. These services allow monitoring and analyzing traffic data and serve to track User behavior.
Some of these services may record sessions and make them available for later viewing.

Hosting and backend infrastructure

This type of service is intended to host Data and files that allow this Website to function and be distributed or to provide a ready-to-use infrastructure to execute specific functionalities or parts of this Website.

Some of the services listed below, if present, may operate on geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.

Interaction with live chat platforms

This type of service allows interaction with live chat platforms managed by third parties directly from the pages of this Website, in order to contact and be contacted by the support service of this Website. In case a live chat interaction service is installed, it is possible that, even if Users do not use the service, it collects Usage Data related to the pages where it is installed. Additionally, live chat conversations may be recorded.

Interaction with social networks and external platforms

This type of service allows interactions with social networks or other external platforms directly from the pages of this Website.
The interactions and information acquired from this Website are in any case subject to the User's privacy settings related to each social network.
This type of service may still collect data on traffic for the pages where the service is installed, even when Users do not use it.
It is recommended to disconnect from the respective services to ensure that the data processed on this Website is not linked to the User's profile.

Infrastructure monitoring

This type of service allows this Website to monitor the usage and behavior of its components, to enable performance and functionality improvements, maintenance, or problem resolution.
The Personal Data processed depends on the characteristics and implementation mode of these services, which inherently filter the activity of this Website.

Traffic optimization and distribution

This type of service allows this Website to distribute its content through servers located in the territory and to optimize its performance. The Personal Data processed depends on the characteristics and implementation methods of these services, which by their nature filter communications between this Website and the User's browser. Given the distributed nature of this system, it is difficult to determine the locations to which the content is transferred, which may contain Personal Data of the User.

Protection from SPAM

This type of service analyzes the traffic of this Website, potentially containing Personal Data of Users, in order to filter it from traffic, messages, and content recognized as SPAM.

Advertising

Some of the services listed below may use Tracking Tools to identify the User, or employ behavioral retargeting techniques, meaning displaying personalized advertisements based on the User's interests and behavior, or measuring ad performance. For more information, we suggest checking the privacy policies of the respective services. Generally, such services offer the option to disable this tracking. In addition to any opt-out feature provided by any of the services listed in this document, the User can read more about how to disable interest-based advertising in the section "How to disable interest-based advertising" in this document.

Registration and authentication

By registering or authenticating, the User allows this Website to identify them and grant access to dedicated services. Depending on what is indicated below, the registration and authentication services may be provided with the assistance of third parties. If this occurs, this Website may access some Data stored by the third-party service used for registration or identification. Some of the services indicated below may also collect Personal Data for targeting and profiling purposes; for more information, please refer to the description of each service.

Registration and authentication provided directly by this Website

By registering or authenticating, the User allows this Website to identify them and grant access to dedicated services. Personal Data is collected and stored solely for the purpose of registration or identification. The Data collected is only what is necessary to provide the service requested by the User.

Platform and hosting services

These services aim to host and operate key components of this Website, making it possible to deliver this Website from a single platform. These platforms provide the Data Controller with a wide range of tools such as, for example, analytical tools, user registration management, comment and database management, e-commerce, payment processing, etc. The use of such tools involves the collection and processing of Personal Data.
Some of these services operate through servers located geographically in different places, making it difficult to determine the exact location where Personal Data is stored.

Statistics

The services contained in this section allow the Data Controller to monitor and analyze traffic data and serve to track User behavior.

Viewing 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 it.
This type of service may still collect data on web traffic related to the pages where the service is installed, even when users do not use it.

Information on how to disable interest-based advertising

In addition to any opt-out function provided by any of the services listed in this document, Users can read more about how to disable interest-based advertising in the appropriate section of the Cookie Policy.

Cookie Policy

This Website uses Tracking Tools. To learn more, Users can consult the Cookie Policy.

Further information for users in the European Union

Legal basis for processing

The Controller processes Personal Data relating to the User if one of the following conditions applies:

• The User has given consent for one or more specific purposes.
• The processing is necessary for the execution of a contract with the User and/or for the execution of pre-contractual measures;
• The processing is necessary to comply with a legal obligation to which the Controller is subject;
• The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Controller;
• the processing is necessary for the pursuit of the legitimate interest of the Data Controller or third parties.

Further information on retention time

Unless otherwise stated in this document, Personal Data are processed and retained for the time required by the purpose for which they were collected and may be retained for a longer period due to any legal obligations or based on the consent of the Users.

Therefore:

• Personal Data collected for purposes related to the execution of a contract between the Data Controller and the User will be retained until the execution of such contract is completed.
• Personal Data collected for purposes related to the legitimate interest of the Data Controller will be retained until such interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.

When the processing is based on the User's consent, the Data Controller may retain Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be required to retain Personal Data for a longer period to comply with a legal obligation or by order of an authority.

At the end of the retention period, Personal Data will be deleted. Therefore, upon the expiration of this term, the right of access, deletion, correction, and the right to data portability can no longer be exercised.

User rights based on the General Data Protection Regulation (GDPR)

Users can exercise certain rights regarding the Data processed by the Data Controller.

In particular, within the limits provided by law, the User has the right to:

• revoke consent at any time. The User can revoke the consent to the processing of their Personal Data previously expressed.
• object to the processing of their Data. The User can object to the processing of their Data when it occurs on a legal basis other than consent.
• access their Data. The User has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing, and to receive a copy of the processed Data.
• verify and request correction. The User can verify the accuracy of their Data and request its update or correction.
• obtain the limitation of processing. The User may request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their storage.
• obtain the deletion or removal of their Personal Data. The User may request the deletion of their Data by the Data Controller.
• receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used, and machine-readable format and, where technically feasible, to obtain its transfer without hindrance to another controller.
• file a complaint. The User may file a complaint with the competent data protection authority or take legal action.

Users have the right to obtain information regarding the legal basis for the transfer of Data abroad, including to any international organization governed by international law or established by two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect their Data.

Details on the right to object

When Personal Data is processed in the public interest, in the exercise of public powers vested in the Data Controller, or to pursue a legitimate interest of the Data Controller, Users have the right to object to the processing for reasons related to their particular situation.

Users are informed that, where their Data is processed for direct marketing purposes, they may object to the processing at any time, free of charge and without providing any justification. If Users object to the processing for direct marketing purposes, the Personal Data will no longer be processed for such purposes. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

How to exercise rights

Any requests to exercise the User's rights can be addressed to the Data Controller through the contact details provided in this document. The request is free of charge, and the Data Controller will respond as soon as possible, in any case within one month, providing the User with all the information required by law. Any corrections, deletions, or limitations on processing will be communicated by the Data Controller to each of the recipients, if any, to whom the Personal Data has been transmitted, unless this proves impossible or involves a disproportionate effort. The Data Controller will inform the User of such recipients if requested.

Further information for users in Switzerland

This section applies to Users in Switzerland and, for such Users, replaces any other possibly divergent or conflicting information contained in the privacy policy.

Further details regarding the categories of Data processed, the purposes of processing, the categories of recipients of personal data, if any, the retention period, and other information about Personal Data can be found in the section titled "Detailed Information on the Processing of Personal Data" within this document.

User rights under the Federal Personal Data Protection Act

Users can exercise certain rights regarding their data within the limits of the law, including the following:

• the right to access Personal Data;
• the right to object to the processing of their Personal Data (which also allows Users to request the restriction of the processing of Personal Data, the deletion or destruction of Personal Data, the prohibition of disclosure of Personal Data to third parties);
• the right to receive their Personal Data and transfer it to another data controller (data portability);
• the right to request the correction of inaccurate Personal Data.

How to exercise these rights

Any requests to exercise User rights can be directed to the Data Controller through the contact details provided in this document. Such requests are free of charge and the Data Controller will respond as soon as possible, providing Users with the information required by law.

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, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island 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.

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, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island 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, Oregon, Nevada, Delaware, Iowa, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island and Montana 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. In Maryland, your Sensitive Personal Information will be collected or processed only if strictly necessary to provide or maintain a specific product or service requested by you.

In Minnesota and Maryland Users also have the right to obtain a list of the specific third parties to which the controller has disclosed the consumer's personal data

* Note that in some states like Minnesota you have the following specific rights connected to profiling:

• The right to question the results of the profiling;
  
• The right to be informed of the reason that the profiling resulted in the decision; if feasible
  
• The right to be informed of what actions the consumer might have taken to secure a different decision and the actions that the consumer might take to secure a different decision in the future;
  
• The right to review personal data used in the profiling;
  
• If inaccurate, the right to have the data corrected and the profiling decision reevaluated based on the corrected data;
  

Additional rights for users residing in Utah and Iowa

In addition to the rights listed above common to all Users in the United States, as a User residing in Utah and Iowa, 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.

Further information on processing

Defense in court

The User's Personal Data may be used by the Data Controller in court or in the preparatory stages of any potential proceedings for the defense against abuses in the use of this Website or the related Services by the User.
The User acknowledges that the Data Controller may be required to disclose Data by order of public authorities.

Specific information

At the User's request, in addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data.

System logs and maintenance

For operational and maintenance needs, this Website and any third-party services used by it may collect system logs, which are files that record interactions and may also contain Personal Data, such as the User's IP address.

Information not contained in this policy

Further information regarding the processing of Personal Data may be requested at any time from the Data Controller using the contact details.

Changes to this privacy policy

The Data Controller reserves the right to make changes to this privacy policy at any time by notifying Users on this page and, if possible, on this Website, as well as, where technically and legally feasible, sending a notification to Users through one of the contact details in its possession. Therefore, please frequently consult this page, referring to the date of the last modification indicated at the bottom.

If the changes involve processing based on consent, the Data Controller will collect the User's consent again, if necessary.

Definitions and legal references

Personal Data (or Data) / Personal Information (or Information)

Personal data is any information that, directly or indirectly, even in connection with any other information, including a personal identification number, makes an identified or identifiable natural person.

Sensitive Personal Information

Sensitive Personal Information refers to all Personal Information that is not publicly available and that reveals information considered sensitive under applicable privacy laws.

Usage Data

The information collected automatically through this Website (also from third-party applications integrated into this Website), including: the IP addresses or domain names of the computers used by the User connecting to this Website, the addresses in URI (Uniform Resource Identifier) notation, the time of the request, the method used to forward the request to the server, the size of the file obtained in response, the numerical code indicating the status of the response from the server (successful, error, etc.), the country of origin, the characteristics of the browser and operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page), and the details related to the itinerary followed within the Application, with particular reference to the sequence of pages consulted, the parameters related to the operating system, and the computing environment of the User.

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 person, legal entity, public administration, and any other body that processes personal data on behalf of the Controller, as outlined in this privacy policy.

Data Controller (or Controller)

The natural or legal person, public authority, service, or other body that, individually or jointly with others, determines the purposes and means of processing personal data and the tools adopted, including the security measures related to 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 hardware or software tool through which the Personal Data of Users is collected and processed.

Service

The Service provided by this Website as defined in the relevant terms (if any) on this site/application.

Sale

Sale refers to any exchange of Personal Information by the Owner to a third party, in exchange for money or other valuable consideration, as defined by applicable U.S. state privacy law. Please note that sharing Personal Information with a service provider under a written contract that meets the requirements set forth by applicable law does not constitute a Sale of your Personal Information.

Sharing

Sharing refers to any sharing, renting, releasing, disclosing, distributing, making available, transferring, or other communication, verbally, in writing, or by electronic means or otherwise, of a consumer's Personal Information by the company to a third party for cross-context behavioral advertising, whether in exchange for money or other valuable consideration, including transactions between a company and a third party related to cross-context behavioral advertising on behalf of a company where no money is exchanged, as defined by California privacy laws. Please note that sharing Personal Information with a service provider under a written contract that meets the requirements set forth by California privacy laws does not constitute sharing the user's Personal Information.

Targeted Advertising

Targeted Advertising refers to the display of advertisements to a consumer for which the advertisement is selected based on the Personal Information obtained from that consumer's activities over time and on non-affiliated websites or online applications to predict that consumer's preferences or interests, as defined by applicable U.S. state privacy law.

European Union (or EU)

Unless otherwise specified, any reference to the European Union contained in this document is intended to extend to all current member states of the European Union and the European Economic Area.

Cookies

Cookies are Tracking Tools that consist of small pieces of data stored within the User's browser.

Tracking Tool

Tracking Tool refers to any technology - e.g., Cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting - that allows tracking Users, for example by collecting or storing information on the User's device.

Legal References

This policy is drafted based on multiple legislative frameworks.

Unless otherwise specified, this policy applies exclusively to this Website.