PRIVACY POLICY
This Application collects a number of Personal Data items from its Users.
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Policy summary
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Personal data collected for the following purposes and using the following services:
To access accounts for third-party services
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Facebook account access
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Permissions: Access to your private data; Access to your activities; Access to your friend lists; Access to your requests
Twitter account access
Personal Data: various types of Data, based on that which is specified by the privacy policy for the service
Content comments
Facebook Comments
Personal Data: Cookie; Usage data
Contacting the User
Contact via telephone
Personal Data: telephone number
Contact form
Personal Data: Postal code; city; Tax Code; surname; email; first name; telephone number; VAT number
Social features
Public profile
Personal Data: city; surname; date of birth; email; picture; address; country; name; phone number; province
Payment management
2Checkout
Personal Data: various types of Data, based on that which is specified by the privacy policy for the service
Interaction with social networks and external platforms
Facebook's Like button and social media widgets, Twitter's Tweet button and social media widgets, VK's Like button and social media widgets, AngelList's Follow button and social media widgets, Tumblr's Follow button and social media widgets, PayPal's button and social media widgets, Google+'s and Google Friend Connect's +1 button and social media widgets
Personal Data: Cookie; Usage data
Contact information
Data Controller
SMALTO GROUP SRL,
Via G. Di Vittorio 9/16 – 38015 LAVIS (TN) Italy, VAT no. 01130540220, Tel. +39 0461245658 -
Email info@smaltogroupsrl.com
Complete Policy
Data Controller
SMALTO GROUP SRL,
Via G. Di Vittorio 9/16 – 38015 LAVIS (TN) Italy, VAT no. 01130540220, Tel. +39 0461245658 -
Email info@smaltogroupsrl.com
Types of Data collected
The types of Personal Data collected by this Application, either directly or via third parties, include the following: Cookies; Usage data; telephone number; first name; last name; VAT number; email; postal code; city; Tax Code; address; date of birth; country; province; image.
Comprehensive details regarding each type of data collected are provided in the dedicated sections of this privacy policy, or else by specific informative texts displayed prior to the collection of the data themselves.
The Personal Data can either be freely provided by the User, or, in the case of Usage Data, can be automatically collected during the use of this Application.
Unless otherwise specified, all Data requested by this Application are mandatory. Failure to provide the requested information could prevent this Application from providing the Service. In the cases in which this Application indicates certain Data items as being optional, the user is free to abstain from providing the Data in question, without this having any impact upon the availability of the Service or its functionality.
Any users who may have doubts about which Data items are mandatory are encouraged to contact the Data Controller.
If not otherwise specified, any use of Cookies, or other tracking tools, by this Application, or the owners of the third party services utilised by this Application, is carried out for the purpose of providing the Service requested by the User, as well as the other purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for any third party Personal Data obtained, posted or shared using this Application, and hereby affirms to have the right to disclose or disseminate the same, thus relieving the Data Controller of any third party liability.
Place and methods of processing the Personal Data collected
Processing methods
The Data Controller adopts appropriate security measures aimed at preventing unauthorised access to the Personal Data themselves, as well as the unauthorised disclosure, alteration, or destruction of the same.
The processing is carried out by means of computer and/or telematic tools, with organisational methods and logic strictly related to the purposes that are indicated. In addition to the Data Controller, in certain cases the Personal Data may also be accessed by other subjects involved in this Application’s organisation (administrative, sales, marketing, and legal personnel, and system administrators), or external subjects (such as third-party technical service providers, postal couriers, hosting providers, computer companies, and advertising agencies), even appointed as Data Processing Managers by the Data Controller if necessary. An updated copy of the list of Data Processors can be requested from the Data Controller at any time.
Legal basis of the data processing
The Data Controller processes the Personal Data pertaining to the User if one of the following conditions is met:
The user has given consent for one or more specific purposes. Note: in some jurisdictions, the Data Controller may be authorised to process Personal Data without the User’s explicit consent, or in the absence of one of the legal bases specified below, unless the user opts out. However, this does not apply if the processing is governed by the European legislation on personal data protection;
the processing is necessary for the execution of a contract with the User and/or pre-contractual measures;
the processing is required for compliance with a legal obligation to which the Data Controller is subject;
the processing is necessary for the performance of a task carried out in the public interest or for the exercise of official powers vested in the Data Controller;
the processing is necessary for pursuing the legitimate interests of the Data Controller or third parties.
Users may request that the Data Controller clarify the legal basis for each processing operation, including whether it is required by law, necessary for a contract, or essential for concluding a contract.
Place
The Personal Data are processed at the Data Controller’s operational locations, and any other places where the parties involved in the processing activities are located. For more information, contact the Data Controller.
The User's Personal data may be transferred to a country other than that in which the User is located. For further information about the data processing locations, Users can refer to the section containing the details about the Personal Data processing.
Users have the right to obtain information regarding the legal basis for Data transfers outside the European Union or to international organisations under public international law, such as the UN. They may also inquire about the security measures implemented by the Data Controller to protect their Data.
To verify whether any such transfers have occurred, users may review the relevant section of this document containing the details about the Personal Data processing, or contact the Data Controller using the contact details provided.
Retention period
The Data are processed and retained for the time necessary, based on the purposes for which they were collected.
Therefore:
Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of that contract is completed.
Personal Data collected for purposes attributable to the legitimate interests of the Data Controller will be retained until such interests are met. The User may obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document, or by contacting the Data Controller.
When the data processing is based on the User's consent, the Data Controller may retain the Personal Data for a longer period of time, until such consent is revoked. The Data Controller may also be obliged to retain the Personal Data for a longer period of time due to a legal obligation or an order issued by a competent authority.
The Personal Data shall be deleted at the end of the retention period. Therefore, once this period has expired, the rights of access, erasure, rectification, and Data portability can no longer be exercised.
Purposes of the Personal Data Processing
The User’s Personal Data are collected in order to allow the Data Controller to provide its Services, as well as for the following purposes: Access to accounts for third-party services, Payment management, Content comments, Contacting the user, Social features, and Interaction with social networks and external platforms.
For more detailed information regarding the purposes of the processing and the Personal Data relevant for each purpose, the User can refer to the relevant sections of this document.
Facebook permissions required by this Application
This Application may require certain Facebook permissions that allow it to perform actions with the User's Facebook account and collect information from it, including Personal Data. This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
For more information on the following permissions, please refer to the Facebook permissions documentation and the Facebook privacy policy.
The permissions required are the following:
Basic information
The basic information of the User registered on Facebook, which normally includes the following Data: id, name, picture, gender and language and, in some cases, Facebook "Friends". If the User has made further Data publicly available, that data will be available as well.
Access to private data
Allows access to the private data of the User and their friends.
Access to activities
Provides access to the User's activity list.
Access to friends lists
Provides access to the friends lists that the User has created.
Access to requests
Provides read access to the User's friend requests.
Details about the Personal Data processing
The Personal Data are collected for the following purposes and using the following services:
To access accounts for third-party services
These types of services allow this Application to access Data from your accounts for third party services and to perform actions with them.
These services are not activated automatically, and require the User's express authorisation.
Facebook account access (This Application)
This service allows this Application to connect with the User's account on the Facebook social network, provided by Facebook Inc.
Permissions required: Access to your private data; Access to your activities; Access to your friend lists; Access to your requests.
Place of processing: USA – Privacy Policy. Privacy Shield member.
Twitter account access (Twitter, Inc.)
This service allows this Application to connect with the User's account on the Twitter social network, provided by Twitter, Inc.
Personal Data collected: various types of Data, based on that which is specified by the privacy policy for the service.
Place of processing: USA – Privacy Policy.
Content comments
Comment services allow Users to formulate and make public their own comments concerning this Application's content.
Depending on the settings decided by the Data Controller, Users may also leave their comments anonymously. If the Personal Data provided by the User includes their email, this may 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 a third party is installed, it is possible that it will collect traffic data for the pages where the commenting service is installed, even if the Users do not use the commenting service.
Facebook Comments (Facebook, Inc.)
Facebook Comments is a service operated by Facebook, Inc. that allows the User to leave comments and share them on the Facebook platform.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
Contacting the User
Contact via telephone (This Application)
Users who have provided their telephone numbers may be contacted for commercial or promotional purposes related to this Application, as well as to carry out support requests.
Personal data collected: telephone number.
Contact form (This Application)
By filling out the contact form with his/her Data, the User consents to the use of such Data to respond to requests for information, quotations, or requests of any other nature indicated in the header of the form.
Personal Data collected: Postal code; city; Tax Code; surname; email; first name; telephone number; VAT number.
Social features
Public Profile (This Application)
Users may have a public profile that can be viewed by other Users. In addition to the Personal Data provided, this profile may also contain the User's interactions with this Application.
Personal data collected: city; surname; date of birth; email; picture; address; country; name; phone number; province.
Payment management
The payment management services allow this Application to process payments made by credit card, wire transfer, or other methods. The data used to submit the payment are acquired directly by the manager of the payment service requested, without being processed by this Application in any way.
Several of these services could also allow for the automatic sending of messages to the User, such as emails containing invoices or payment notifications.
2Checkout (2Checkout.com, Inc.)
2Checkout is a payment service provided by 2Checkout.com, Inc.
Personal Data collected: various types of Data, based on that which is specified by the privacy policy for the service.
Place of processing: USA – Privacy Policy.
Interaction with social networks and external platforms
This type of service allows for interactions with social networks or other external platforms directly from the pages of this Application.
However, the interactions and the information required by this Application are always subject to the User’s privacy settings on each individual social network.
This type of service could still collect traffic data for pages where the service is installed, even when the Users do not use it.
It is recommended that you disconnect from the respective services to ensure that the data processed on this Application is not linked back to your profile.
Facebook “Like” button and social media widgets (Facebook, Inc.)
The Facebook “Like” button and social media widgets are services provided by Facebook, Inc. for interacting with the Facebook social media network.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
Twitter "Tweet" button and social media widgets (Twitter, Inc.)
The Tweet button and social media widgets are services provided by Twitter Inc. for interacting with the Twitter social media network.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
VK "Like" button and social media widgets (VKontakte Ltd)
The VK “Like” button and social media widgets are services provided by VKontakte Ltd. for interacting with the VK social media network.
Personal Data collected: Cookies; Usage data.
Place of processing: Russia – Privacy Policy.
AngelList "Follow" button and social media widgets (AngelList, LLC.)
The AngelList "follow" button and social media widgets are services for interacting with the AngelList network, provided by AngelList, LLC.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
Tumblr button and social media widgets (Tumblr Inc.)
The Tumblr button and social media widgets are services provided by Tumblr Inc. for interacting with the Tumblr social media network.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
PayPal button and widget (Paypal)
The PayPal button and widgets are services for interacting with the PayPal platform, provided by PayPal Inc.
Personal Data collected: Cookies; Usage data.
Place of processing: See the Paypal privacy policy – Privacy Policy.
Google+ “+1” button and social media widgets (Google Inc.)
The Google+ “+1” button and social media widgets are services provided by Google Inc. for interacting with the Google+ social media network.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
Google Friend Connect (Google Inc.)
Google Friend Connect is a service for social interaction provided by Google Inc.
Personal Data collected: Cookies; Usage data.
Place of processing: USA – Privacy Policy.
User Rights
Users may exercise certain rights with regard to the Data processed by the Data Controller.
In particular, the User has the right to:
revoke consent at any time. The User may revoke his or her previously expressed consent to the processing of his or her Personal Data.
object to the processing of his or her Data. The User may object to the processing of his or her Data when it is performed on a legal basis other than consent. Further details about the right to object are provided in the section below.
access his or her Data. The User has the right to obtain information about the Data processed by the Data Controller and certain aspects of the processing, and to receive a copy of the Data processed.
verify the data and request their rectification. The User may verify the correctness of his or her Data and request that they be updated or corrected.
obtain the restriction of processing. Under certain conditions, the User may request the that the processing of his or her Data be restricted. In this case, the Data Controller will not process the Data for any purpose other than their retention.
obtain the erasure or removal of his or her Personal Data. Under certain conditions, the User may request that the Data Controller erase his or her Data.
receive his or her Data or have them transferred to another data controller. The User has the right to receive his or her data in a structured and commonly used format capable of being read by an automatic device and, where technically feasible, to obtain the unhindered transfer thereof to another data controller. This provision is applicable when the Data are processed by automated means and the processing is based on the User's consent, a contract to which the User is a party, or associated contractual measures.
lodge a complaint. The User may lodge a complaint with the competent data protection supervisory authority or take legal action.
Details on the right to object
When Personal Data are processed in the public interest, in the exercise of public authority vested in the Data Controller, or in pursuit of a legitimate interest of the Data Controller, the Users have the right to object to the processing of their Data on grounds relating to their particular situation.
If the Users' Data are processed for direct marketing purposes, they may object to the processing without providing any reason. To find out whether the Data Controller processes data for direct marketing purposes, the Users may refer to the relevant sections of this document.
How to exercise one's rights
In order to exercise their rights, Users may submit a request using the Data Controller's contact details indicated in this document. Requests are filed free of charge and processed by the Data Controller as quickly as possible, at most within one month.
Additional information on personal data processing
Legal defence
The User's Personal Data may be used by the Data Controller in court, or to prepare its defence in cases involving the misuse of this Application or the relative Services on the part of the User.
The User hereby declares that he/she is aware that the Data Controller may be obliged to disclose their Data by order of public authorities.
Specific policies
In addition to the information contained in this privacy policy, this Application is also capable of providing the User with additional and contextual information regarding specific Services, or the collection and processing of Personal Data, at the User’s request.
System and maintenance log
For functionality and maintenance purposes, this Application and any third party services used by the same could record system Logs, or rather files that record the User’s interactions, which also contain Personal Data, such as the User’s IP address.
Information not contained in this policy
Additional information regarding Personal Data processing can be requested from the Data Controller at any time using the contact details.
Response to "Do Not Track" requests
This Application does not support “Do Not Track” requests.
In order to determine whether any of the third party services utilised support such requests, the User is advised to refer to the relative privacy policies.
Changes to this privacy policy
The Data Controller reserves the right to make changes to this privacy policy at any time, informing the Users on this web page and, if possible, via this Application. If technically and legally feasible, a notification will also be sent to the Users using the contact details held by the Data Controller. Users are therefore kindly asked to consult this page regularly, making reference to the date of the most recent update indicated at the bottom.
If the changes affect data processing carried out on the legal basis of consent, the Data Controller will obtain the User's consent again, if necessary.
Definitions and legal references
Personal Data (or Data)
Personal data is any information that identifies or makes it possible to identify a natural person, either directly or indirectly, even in conjunction with other information, including a personal identification number.
Usage Data
The information automatically collected by this Application (or by the third party applications integrated within 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 received in response, the numeric code indicating the status of the response from the server (success, error, etc.), the country of origin, the characteristics of the web browser and operating system used by the visitor, the various temporal connotations of the visit (e.g. the time for which the visitor remained on each page), and the details regarding the itinerary followed within the Application, with particular regard to the sequence of the pages viewed, and the parameters associated with the User’s operating system and IT environment.
User
Unless otherwise specified, the Data Subject is the individual using this Application.
Data Subject
The natural person to whom the Personal Data refer.
Data Processor
A natural person, legal entity, public administration, or any other entity that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller
The natural, legal entity, public authority, service or other body that, either individually or in conjunction with other parties, determines the purposes and means of the personal data processing and the instruments adopted, including the security measures relating to the operation and use of this Application. Unless otherwise specified, the Data Controller is the owner of this Application.
This Application
The hardware or software tool through which the Users’ Personal Data are collected and processed.
Service
The Service provided by this Application, as defined in the relevant terms and conditions provided on this website/application (if applicable).
European Union (or EU)
Unless otherwise specified, any reference to the European Union in this document shall be deemed to extend to all current member states of the European Union and the European Economic Area.
Cookie
Small portions of data stored on the User’s device.
Legal references
This privacy policy has been drawn up on the basis of multiple legal regulations, including articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy policy applies exclusively to this Application.