This Application collects some Personal Data from its Users.
Data Controller
Vincenzo Caffarella Ltd – Monica Glerean – VAT: GB 877 7552 62 – 67A Shirland Road, London W9 2EL (UK)
Types of Data collected
Among the Personal Data collected by this Application, either independently or through third parties, there are: email, Cookies, Usage data and name.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data are collected.
Personal Data may be freely provided by the User, or, in the case of Usage Data, collected automatically when using this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. Failure to provide this Data may make it impossible for this Application to provide its Service. In cases where this Application specifically states that some Data is optional, Users are free not to communicate this Data without any consequences on the availability or operation of the Service.
Users who are uncertain about which Data is mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by this Application or by the owners of third-party services used by this Application, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the other purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application and guarantees that he/she has the right to communicate or disseminate them, freeing the Owner from any liability towards third parties.
Methods and place of processing of the Data collected
Methods of processing
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
The processing is carried out using IT and/or telematic tools, with organizational methods and logic strictly related to the purposes indicated. In addition to the Owner, in some cases, other parties involved in the organization of this Application (administrative, commercial, marketing, legal, system administration personnel) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) may have access to the Data, also appointed, if necessary, as Data Processors by the Owner. The updated list of Data Processors may always be requested from the Data Controller.
Legal basis for processing
The Owner processes Personal Data relating to the User if one of the following applies:
the User has given consent for one or more specific purposes; Note: under some jurisdictions the Owner may be allowed to process Personal Data without the User’s consent or any other of the legal bases specified below, until the User objects (“opts-out”) to such processing. However, this does not apply, if the processing of Personal Data is regulated by European data protection law;
processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual obligations;
processing is necessary for compliance with a legal obligation to which the Owner is subject;
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 Owner;
processing is necessary for the pursuit of the legitimate interest of the Owner or third parties.
It is always possible to ask the Owner to clarify the specific legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided for by a contract or necessary to conclude a contract.
Place
The Data is processed at the Data Controller’s operating offices and in any other places where the parties involved in the processing are located. For further information, contact the Data Controller.
The User’s Personal Data may be transferred to a country other than their own. To obtain further information on the place of processing, the User can refer to the section containing details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis of Data transfers to a country outside the European Union or to an international organization governed by public international law or set up by two or more countries, such as the UN, as well as regarding the security measures taken by the Owner to safeguard the Data.
The User can verify if any of the transfers described above are taking place by checking the relevant section of this document or inquire with the Owner using the contact details provided in the opening.
Retention period
The Data is processed and stored for the time required by the purposes for which it was collected.
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 purposes related to the legitimate interest of the Owner shall be retained until such interest is fulfilled. Users may obtain further information regarding the legitimate interest pursued by the Owner within the relevant sections of this document or by contacting the Owner.
When the processing is based on the User’s consent, the Owner may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so by law or by order of an authority.
At the end of the retention period, Personal Data shall be deleted. Therefore, upon expiration of such term, the right of access, cancellation, rectification and the right to portability of the Data can no longer be exercised.
Purpose of the Processing of Collected Data
The User’s Data is collected to allow the Owner to provide its Services, as well as for the following purposes: Remarketing and behavioral targeting, Statistics, Displaying content from external platforms, SPAM protection, Contacting the User, Interaction with social networks and external platforms and Commenting on content.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.
Details on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Commenting on contents
Comment services allow Users to formulate and make public their comments regarding the content of this Application.
Depending on the settings decided by the Owner, Users can also leave comments anonymously. If among the Personal Data released by the User there is the email, this could be used to send notifications of comments regarding the same content. Users are responsible for the content of their comments.
If a commenting service provided by third parties is installed, it is possible that, even if the Users do not use the commenting service, the same collects traffic data relating to the pages in which the commenting service is installed.
Directly managed comment system (this Application)
This Application has its own content comment system.
Personal Data collected: email and name.
Interaction with social networks and external platforms
This type of service allows interaction with social networks, or other external platforms, directly from the pages of this Application.
The interactions and information acquired by this Application are in any case subject to the User’s privacy settings for each social network.
If an interaction service with social networks is installed, it is possible that, even if the Users do not use the service, it collects traffic data relating to the pages on which it is installed.
Facebook Like button and social widgets (Facebook, Inc.)
The “Like” button and Facebook social widgets are services of interaction with the social network Facebook, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.
Remarketing and behavioral targeting
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on past use of this Application by the User.
This activity is performed by tracking Usage Data and using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer a remarketing option based on email address lists.
In addition to any opt-out offered by any of the services listed below, the User may opt out of receiving third-party cookies by visiting the Network Advertising Initiative opt-out page.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and email.
Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Google Ads Remarketing (Google LLC)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google LLC that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie.
Personal Data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Remarketing with Google Analytics (Google LLC)
Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google LLC that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield participant.
Displaying content from external platforms
This type of service allows you to view content hosted on external platforms directly from the pages of this Application and interact with them.
If a service of this type is installed, it is possible that, even if Users do not use the service, it collects traffic data relating to the pages in which it is installed.
Google Fonts (Google LLC)
Google Fonts is a typeface visualization service provided by Google LLC that allows this Application to incorporate content of this kind on its pages.
Personal Data collected: Usage data and various types of Data as specified in the privacy policy of the service.
Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.
Vimeo Video (Vimeo, LLC)
Vimeo is a video content visualization service provided by Vimeo, LLC that allows this Application to integrate such content within its pages.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.
Contacting the User
Contact form (this Application)
By filling in the contact form with their Data, the User authorizes this Application to use these details to respond to requests for information, quotes or any other kind of request as indicated by the form’s header.
Personal Data collected: email and name.
SPAM Protection
This type of service analyzes the traffic of this Application, potentially containing Personal Data of Users, in order to filter it from parts of traffic, messages and contents recognized as SPAM.
Google reCAPTCHA (Google LLC)
Google reCAPTCHA is a SPAM protection service provided by Google LLC.
The use of the reCAPTCHA system is subject to the privacy policy and terms of use of Google.
Personal Data collected: Cookies and Usage data.
Place of processing: United States – Privacy Policy. Subject adhering to the Privacy Shield.
Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to keep track of User behavior.
Google Analytics (Google LLC)
Google Analytics is a web analysis service provided by Google LLC (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use Personal Data to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Subject adhering to the Privacy Shield.
User Rights
Users may exercise certain rights regarding the Data processed by the Owner.
In particular, the User has the right to:
- revoke consent at any time. The User may revoke consent to the processing of their Personal Data previously expressed.
- object to the processing of their Data. The User may object to the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are provided in the section below.
- access their Data. The User has the right to obtain information on the Data processed by the Owner, on certain aspects of the processing and to receive a copy of the Data processed.
- verify and request rectification. The User can verify the accuracy of their Data and request that it be updated or corrected.
- obtain the limitation of the processing. When certain conditions apply, the User may request the limitation of the processing of their Data. In this case, the Owner will not process the Data for any purpose other than its conservation.
- obtain the deletion or removal of their Personal Data. When certain conditions apply, the User may request the deletion of their Data by the Owner.
- receive your 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 the transfer without hindrance to another controller. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it.
- file a complaint. The User can file a complaint with the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data is processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that, if their Data is processed for direct marketing purposes, they can object to the processing without providing any justification. To find out whether the Owner is processing data for direct marketing purposes, Users can refer to the relevant sections of this document.
How to exercise your rights
To exercise the User’s rights, Users can direct a request to the Owner’s contact details provided in this document. The requests are filed free of charge and processed by the Owner as soon as possible, in any case within one month.
Cookie Policy
This Application uses Cookies. To learn more and to view the detailed information, the User can consult the Cookie Policy.
Further information on processing
Defense in court
The User’s Personal Data may be used by the Owner in court or in the preparatory stages of its possible establishment for the defense against abuse in the use of this Application or related Services by the User.
The User declares to be aware that the Owner may be required to reveal the Data by order of public authorities.
Specific information
Upon request of the User, in addition to the information contained in this privacy policy, this Application 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 operation and maintenance purposes, this Application 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 in relation to the processing of Personal Data may be requested from the Data Controller at any time using the contact details.
Responding to “Do Not Track” requests
This Application does not support “Do Not Track” requests.
To find out whether any third-party services used support them, the User is invited to consult their respective privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time by giving notice to Users on this page and, if possible, on this Application and, if technically and legally feasible, by sending a notification to Users through one of the contact methods available to the Owner. Please therefore consult this page regularly, referring to the date of the last modification indicated at the bottom.
If the changes affect processing whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that, directly or indirectly, also in connection with any other information, including a personal identification number, makes a natural person identified or identifiable.
Usage Data
This information is collected automatically through this Application (also from third-party applications integrated into this Application), including: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit 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 the operating system used by the visitor, the various temporal connotations of the visit (for example, the time spent on each page) and the details relating to the itinerary followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the operating system and the IT environment of the User.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Data Supervisor)
The natural person, legal person, public administration or any other body which processes Personal Data on behalf of the Data Controller, as described in this privacy policy.
Data Controller (or Owner)
The natural person, 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 and the tools used, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.
This Application
The hardware or software tool by which the Personal Data of Users is collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.
Cookie
Small portion of data stored within the User’s device.
Legal references
This privacy policy has been drawn up on the basis of multiple legislative systems, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy concerns only this Application.
