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PRIVACY POLICY

This Application collects some Personal Data from its Users.This document can be printed for reference by using the print command in the settings of any browser.

Policy summary

Personal Data processed for the following purposes and using the following services:

    • Advertising

      • Direct Email Marketing (DEM)

        Personal Data: email address; first name; last name

      • Meta Audience Network

        Personal Data: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data

      • Meta Lookalike Audience and Google Ad Manager

        Personal Data: Trackers; Usage Data

    • Analytics

      • Google Ads conversion tracking, Google Analytics, Google Analytics with anonymised IP and Meta ads conversion tracking (Meta pixel)

        Personal Data: Trackers; Usage Data

    • Contacting the User

      • Mailing list or newsletter

        Personal Data: city; country; county; email address; first name; last name; phone number; physical address; Usage Data; ZIP/Postal code

      • Phone contact

        Personal Data: phone number

      • Contact form

        Personal Data: city; country; county; email address; first name; last name; phone number; physical address; User ID; various types of Data; ZIP/Postal code

    • Displaying content from external platforms
      Google Fonts

      • Personal Data: Trackers; Usage Data

    • Managing contacts and sending messages

      • Personal Data: country; email address; first name; last name; phone number; physical address; Usage Data; username; various types of Data

    • Managing data collection and online surveys

      • Personal Data: city; country; email address; first name; last name; phone number; physical address; Usage Data; username

    • Registration and authentication provided directly by this Application
      Direct registration

      • Personal Data: billing address; city; country; county; email address; first name; house number; last name; phone number; physical address; Usage Data; User ID; username; various types of Data; ZIP/Postal code

    • Remarketing and behavioural targeting
      Google Ads Remarketing, Facebook Remarketing and Google Ad Manager Audience Extension

      • Personal Data: Trackers; Usage Data

      • Meta Custom Audience

        Personal Data: email address; Trackers

    • SPAM protection
      Google reCAPTCHA

      • Personal Data: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data

    • Tag Management
      Google Tag Manager

      • Personal Data: Usage Data

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

Further information about the processing of Personal Data
Selling goods and services online

    • The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
      The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

Contact information
Owner and Data Controller

Full policy

Owner and Data Controller

 

Mode and place of processing the Data

Methods of processing

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification, or unauthorised destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organisational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated list of these parties may be requested from the Owner at any time.

Place

The Data is processed at the Owner’s operating offices and in any other places where the parties involved in the processing are located.

Depending on the User’s location, data transfers may involve transferring the User’s Data to a country other than their own. To find out more about the place of processing of such transferred Data, Users can check the section containing details about the processing of Personal Data.

Retention time

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: Analytics, Remarketing and behavioural targeting, Displaying content from external platforms, SPAM protection, Tag Management, Managing contacts and sending messages, Managing data collection and online surveys, Contacting the User, Advertising and Registration and authentication provided directly by this Application.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:

  • Advertising

    This type of service allows User Data to be utilised for advertising communication purposes. These communications are displayed in the form of banners and other advertisements on this Application, 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 behavioural retargeting technique, i.e. displaying ads tailored to the User’s interests and behaviour, including those detected outside this Application. For more information, please check the privacy policies of the relevant services.
    Services of this kind usually offer the possibility to opt out of such tracking. In addition to any opt-out feature offered by any of the services below, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section “How to opt-out of interest-based advertising” in this document.

    Direct Email Marketing (DEM) (this Application)

    This Application uses the User Data to propose services and products provided by third parties or unrelated to the product or service provided by this Application.

    Personal Data processed: email address; first name; last name.

    Meta Audience Network (Meta Platforms Ireland Limited)

    Meta Audience Network is an advertising service provided by Meta Platforms Ireland Limited In order to understand Meta’s use of Data, consult Meta’s data policy. This Application may use identifiers for mobile devices (including Android Advertising ID or Advertising Identifier for iOS, respectively) and technologies similar to cookies to run the Meta Audience Network service. One of the ways Audience Network shows ads is by using the User’s ad preferences. The User can control this in the Facebook ad settings. Users may opt-out of certain Audience Network targeting through applicable device settings, such as the device advertising settings for mobile phones or by following the instructions in other Audience Network related sections of this privacy policy, if available.

    Personal Data processed: Trackers; unique device identifiers for advertising (Google Advertiser ID or IDFA, for example); Usage Data.Place of processing: Ireland – Privacy Policy – Opt out.

    Meta Lookalike Audience (Meta Platforms Ireland Limited)

    Meta Lookalike Audience is an advertising and behavioural targeting service provided by Meta Platforms Ireland Limited that uses Data collected through Meta’s Custom Audience in order to display ads to Users with similar behaviour to Users who are already in a Custom Audience list on the basis of their past use of this Application or engagement with relevant content across Meta’s apps and services.
    On the basis of these Data, personalised ads will be shown to Users suggested by Meta Lookalike Audience. Users can opt out of Meta’s use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt out.

    Google Ad Manager (Google Ireland Limited)

    Google Ad Manager is an advertising service provided by Google Ireland Limited that allows the Owner to run advertising campaigns in conjunction with external advertising networks that the Owner, unless otherwise specified in this document, has no direct relationship with.
    In order to understand Google’s use of Data, consult Google’s partner policy.
    This service uses the “DoubleClick” Cookie, which tracks use of this Application and User behaviour concerning ads, products and services offered.   Users may decide to disable all the DoubleClick Cookies by going to: Google Ad Settings.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy.

  • Analytics

    The services contained in this section enable the Owner to monitor and analyse web traffic and can be used to keep track of User behaviour.

    Google Ads conversion tracking (Google Ireland Limited)

    Google Ads conversion tracking is an analytics service provided by Google Ireland Limited that connects data from the Google Ads advertising network with actions performed on this Application.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy.

    Google Analytics (Google Ireland Limited)

    Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.

    Google Analytics with anonymised IP (Google Ireland Limited)

    Google Analytics is a web analysis service provided by Google Ireland Limited (“Google”). Google utilises the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
    Google may use the Data collected to contextualise and personalise the ads of its own advertising network.
    This integration of Google Analytics anonymises your IP address. It works by shortening Users’ IP addresses within member states of the European Union or in other contracting states to the Agreement on the European Economic Area. Only in exceptional cases will the complete IP address be sent to a Google server and shortened within the US.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.

    Meta ads conversion tracking (Meta pixel) (Meta Platforms Ireland Limited)

    Meta ads conversion tracking (Meta pixel) is an analytics service provided by Meta Platforms Ireland Limited that connects data from the Meta Audience Network with actions performed on this Application. 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: Ireland – Privacy Policy – Opt out.

  • Contacting the User

    Mailing list or newsletter (this Application)

    By registering on the mailing list or for the newsletter, the User’s email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning this Application. Your email address might also be added to this list as a result of signing up to this Application or after making a purchase.

    Personal Data processed: city; country; county; email address; first name; last name; phone number; physical address; Usage Data; ZIP/Postal code.

    Phone contact (this Application)

    Users that provided their phone number might be contacted for commercial or promotional purposes related to this Application, as well as for fulfilling support requests.

    Personal Data processed: phone number.

    Contact form (this Application)

    By filling in the contact form with their Data, the User authorises this Application to use these details to reply to requests for information, quotes or any other kind of request as indicated by the form’s header.

    Personal Data processed: city; country; county; email address; first name; last name; phone number; physical address; User ID; various types of Data; ZIP/Postal code.

  • 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.
    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 Ireland Limited)

    Google Fonts is a typeface visualisation service provided by Google Ireland Limited that allows this Application to incorporate content of this kind on its pages.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy.

  • 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.

    Klaviyo (Klaviyo Inc.)

    Klaviyo is an email address management and message sending service provided by Klaviyo Inc. To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

    Personal Data processed: country; email address; first name; last name; phone number; physical address; Usage Data; username; various types of Data.Place of processing: United States – Privacy Policy – Opt out.

  • Managing data collection and online surveys

    This type of service allows this Application to manage the creation, deployment, administration, distribution and analysis of online forms and surveys in order to collect, save and reuse Data from any responding Users.
    The Personal Data collected depend on the information asked and provided by the Users in the corresponding online form.These services may be integrated with a wide range of third-party services to enable the Owner to take subsequent steps with the Data processed – e.g. managing contacts, sending messages, analytics, advertising and payment processing.

    Klaviyo Forms (Klaviyo Inc.)

    Klaviyo Forms is a form builder and data collection platform provided by Klaviyo Inc. To take advantage of the service provided by Klaviyo, the Owner typically shares information about (purchasing) Users, such as for example contact details and shopping histories. Check the indication at “Personal Data processed“ below for an explanation of the extent of the sharing.

    Personal Data processed: city; country; email address; first name; last name; phone number; physical address; Usage Data; username.Place of processing: United States – Privacy Policy.

  • Registration and authentication provided directly by this Application

    By registering or authenticating, Users allow this Application to identify them and give them access to dedicated services. The Personal Data is collected and stored for registration or identification purposes only. The Data collected are only those necessary for the provision of the service requested by the Users.

    Direct registration (this Application)

    The User registers by filling out the registration form and providing the Personal Data directly to this Application.

    Personal Data processed: billing address; city; country; county; email address; first name; house number; last name; phone number; physical address; Usage Data; User ID; username; various types of Data; ZIP/Postal code.

  • Remarketing and behavioural targeting

    This type of service allows this Application and its partners to inform, optimise and serve advertising based on past use of this Application 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 behavioural 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.

    Google Ads Remarketing (Google Ireland Limited)

    Google Ads Remarketing is a remarketing and behavioural targeting service provided by Google Ireland Limited that connects the activity of this Application with the Google Ads advertising network and the DoubleClick Cookie. In order to understand Google’s use of Data, consult Google’s partner policy. Users can opt out of Google’s use of Trackers for ads personalisation by visiting Google’s Ads Settings.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.

    Meta Custom Audience (Meta Platforms Ireland Limited)

    Meta Custom Audience is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network. Users can opt out of Meta’s use of Trackers for ads personalisation by visiting this opt-out page.

    Personal Data processed: email address; Trackers.Place of processing: Ireland – Privacy Policy – Opt out.

    Facebook Remarketing (Meta Platforms Ireland Limited)

    Facebook Remarketing is a remarketing and behavioural targeting service provided by Meta Platforms Ireland Limited that connects the activity of this Application with the Meta Audience Network.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.

    Google Ad Manager Audience Extension (Google Ireland Limited)

    Google Ad Manager Audience Extension is a remarketing and behavioural targeting service provided by Google Ireland Limited that tracks the visitors of this Application and allows selected advertising partners to display targeted ads across the web to them. In order to understand Google’s use of Data, consult Google’s partner policy.

    Personal Data processed: Trackers; Usage Data.Place of processing: Ireland – Privacy Policy – Opt Out.

  • SPAM protection

    This type of service analyses the traffic of this Application, potentially containing Users’ Personal Data, with the purpose of filtering it from parts of traffic, messages and content that are recognised as SPAM.

    Google reCAPTCHA (Google Ireland Limited)

    Google reCAPTCHA is a SPAM protection service provided by Google Ireland Limited.
    The use of reCAPTCHA is subject to the Google privacy policy and terms of use.

    Personal Data processed: answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events; Trackers; Usage Data.Place of processing: Ireland – Privacy Policy.

  • Tag Management

    This type of service helps the Owner to manage the tags or scripts needed on this Application in a centralised fashion.
    This results in the Users’ Data flowing through these services, potentially resulting in the retention of this Data.

    Google Tag Manager (Google Ireland Limited)

    Google Tag Manager is a tag management service provided by Google Ireland Limited.

    Personal Data processed: Usage Data.Place of processing: Ireland – Privacy Policy.

Information on opting out of interest-based advertising

In addition to any opt-out feature provided by any of the services listed in this document, Users may learn more on how to generally opt out of interest-based advertising within the dedicated section of the Cookie Policy.

 

Further information about the processing of Personal Data

  • Selling goods and services online

    The Personal Data collected are used to provide the User with services or to sell goods, including payment and possible delivery.
    The Personal Data collected to complete the payment may include the credit card, the bank account used for the transfer, or any other means of payment envisaged. The kind of Data collected by this Application depends on the payment system used.

Cookie Policy

This Application uses Trackers. To learn more, the User may consult the Cookie Policy.

Further Information for Users

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. Note: Under some legislations the Owner may be allowed to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any other of the following legal bases. This, however, does not apply, whenever the processing of Personal Data is subject to European data protection law;
  • 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 do so for the performance of 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

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. These requests can be exercised free of charge and will be answered by the Owner as early as possible and always within one month, providing Users with the information required by law. Any rectification or erasure of Personal Data or restriction of processing will be communicated by the Owner to each recipient, if any, to whom the Personal Data has been disclosed unless this proves impossible or involves disproportionate effort. At the Users’ request, the Owner will inform them about those recipients.

 

Additional information about Data collection and processing

Legal action

The User’s Personal Data may be used for legal purposes by the Owner in Court or in the stages leading to possible legal action arising from improper use of this Application or the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.

Additional information about User’s Personal Data

In addition to the information contained in this privacy policy, this Application may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.

System logs and maintenance

For operation and maintenance purposes, this Application and any third-party services may collect files that record interaction with this Application (System logs) or use other Personal Data (such as the IP Address) for this purpose.

Information not contained in this policy

More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.

Changes to this privacy policy

The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Application and/or – as far as technically and legally feasible – sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.

Should the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.

Definitions and legal references

Personal Data (or Data)

Any information that directly, indirectly, or in connection with other information — including a personal identification number — allows for the identification or identifiability of a natural person.

Usage Data

Information collected automatically through this Application (or third-party services employed in this Application), which can include: the IP addresses or domain names of the computers utilised by the Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the request, the method utilised to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s answer (successful outcome, error, etc.), the country of origin, the features of the browser and the operating system utilised by the User, the various time details per visit (e.g., the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited, and other parameters about the device operating system and/or the User’s IT environment.

User

The individual using this Application who, unless otherwise specified, coincides with the Data Subject.

Data Subject

The natural person to whom the Personal Data refers.

Data Processor (or Processor)

The natural or legal person, public authority, agency or other body which processes Personal Data on behalf of the Controller, as described in this privacy policy.

Data Controller (or Owner)

The natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of Personal Data, including the security measures concerning the operation and use of this Application. The Data Controller, unless otherwise specified, is the Owner of this Application.

This Application

The means by which the Personal Data of the User is collected and processed.

Service

The service provided by this Application as described in the relative terms (if available) and on this site/application.

European Union (or EU)

Unless otherwise specified, all references made within this document to the European Union include all current member states to the European Union and the European Economic Area.

Cookie

Cookies are Trackers consisting of small sets of data stored in the User’s browser.

Tracker

Tracker indicates any technology – e.g Cookies, unique identifiers, web beacons, embedded scripts, e-tags and fingerprinting – that enables the tracking of Users, for example by accessing or storing information on the User’s device.


Legal information

This privacy policy relates solely to this Application, if not stated otherwise within this document.

Latest update: 6 March 2024