(version 1.1 dated 06/05/2019)
Dear Visitor (hereinafter, "You" or the '"User"),
- By sending a registered letter with return receipt to the registered office of the Company
- By sending an e-mail to firstname.lastname@example.org
You can also contact the Data Protection Officer (RPD or DPO) of the Company, whose contact details are shown below: Mr Lapo Curini Galletti, mail email@example.com.
1 - Scope of processing
Our Company carries on the activity of digital advertising and we are a third party in relation to the website and/or a mobile app/website where you are coming from (the “Website of Origin”). Our role is to help advertisers in providing more relevant advertising to users, for example, a user that visits travel sites often, will be categorized in a “travel lover” group, in such way he will served advertisements that could be interesting for him.
Since when you visit the Website of Origin we install profile cookies on your browser, and we may deliver some service with them, we hereby aim at explaining the processing of data that we perform.
2 - Types of data processed
The Company collects and processes your personal data by means of cookies and identifiers, please note that we never process Personally Identifiable Information (PII), meaning that we will never be able to identify you. We process only pseudonymous data, the data stored are limited to information collected about your visits on websites, your tastes, your behavioural and positions.
We may collect:
- a Platform ID (an identifier that allows us to supply our services)
- IP address
- Url visited (as the Website of Origin)
- Time, hour and location
- Browser and version of the browser
- Cookie ID of our platform’s partners
Cross Device Linking and Cross App Advertising. We may also link multiple devices used by you, always in a pseudonymous way, also in partnership with technologies similar to cookies, that operate in environments that do not support cookies like mobile applications. Please note that we never collect directly data from mobile applications, when we process a mobile advertising ID, such as an Apple Advertising ID (IDFA) or an Android Advertising ID (GAID) we do it on behalf of our partners that authorized us in doing so.
For opt-out please see paragraph 4 and paragraph 6 below.
3- What cookies are and what they are for
The cookies are small text files that the websites visited by a user send directly to its terminal (usually, to the browser), where they are memorised to be transmitted to the same websites at the following visit of the same by the same user (the so called proprium first part cookies). During the web surfing of a website, a user may receive on its terminal also cookies of other websites or of other web servers (the so called third parties cookies); this happens because there may be elements on the visited website, such as images, maps, sounds, links to specific web pages of other domains that are on servers other than the server on which the requested page is placed. In other words, such cookies are set up on a website other than the one that is currently visited.
You are clearly free to block the installation of profiling cookies in any moment whatsoever and this will not compromise in any manner whatsoever the possibility to visit the Website of Origin and benefit of its contents.
Our profiling cookies are installed directly by the Company. Such cookies are lasting ones and have a maximum duration of 12 months. The first part profiling cookies used are the specified in the following table, together with the indication of the modalities to use in order to oppose to their installation:
- third party profiling cookie
For disabling such profiling cookies please amend your browser’s settings (please see paragraph 4) or use the following webpage http://www.audiencerate.com/opt-out/
The third parties that act as independent Data Controllers thought our technology are specified in the following table, together with the link to their policies:
Link to the policy
- third party profiling cookie
- third party profiling cookie
- third party profiling cookie
4 How to manage the cookies and oppose to their use
There are several options to manage, disable and remove the cookies. .
(1) Modify your browser settings
Please follow the instructions provided by your browser’s producer to discover how to manage, disable or remove all the cookies (technical, analytics and profiling):
- Explorer: http://windows.microsoft.com/it-it/windows-vista/block-or-allow-cookies
- Chrome: https://support.google.com/chrome/answer/95647?hl=it&p=cpn_cookies
- Firefox: https://support.mozilla.org/it/kb/Attivare%20e%20disattivare%20i%20cookie
- Safari: https://support.apple.com/it-it/guide/safari/manage-cookies-and-website-data-sfri11471/
- Opera: https://help.opera.com/en/latest/web-preferences/
Please be careful in making your choice. Indeed, by blocking the receipt of all the cookies indiscriminately, including the technical ones, without providing a specific exception for the Website of Origin, you might be no more able to surf on the Website of Origin or to benefit, in whole or in part, of its functionalities. Furthermore, removing all the cookies from the browser, also the technical cookies could be removed and, therefore, you could remove the preferences set up by using the Website of Origin or no more find products or services included in your basket.
When you opt out, we will place an opt-out cookie on your computer. This cookie tells us not to collect your information. Please note that if you block, delete or restrict cookies in any way, or if you use a different computer or Internet browser, you may need to renew your opt-out choice. To effectively opt-out users must opt-out on every device and browser using our opt-out methods described below.
(2) Use our interactive instruments
In order to disable the first part profiling cookies, which means those installed directly by us, you can simply use the use the following webpage:
(2a) Or NAI opt-out instrument.
(3) Mobile opt-out
As for any data collected through mobile application, you may autonomously deactivate the use of the advertising identifier (ID) of your Device, depending on the model, as illustrated below:
Or following these instructions: http://www.networkadvertising.org/mobile-choice.
D. Processing methods and data retention timing
Certain employees of ours and coworkers, appointed by us as persons in charge of the processor, could make maintenance operations on IT systems that host your data, without the possibility to access their actual contents. The personal data could be memorised on servers managed by third parties (for example, providers of IT systems) or may be managed by online marketing specialised subjects, acting as external data processors on the basis of a specific written appointment by the Company. We hereby inform you that, complying with the requirements and the guarantees provided under the law, your data could be transferred to Countries outside the European Economic Union that could not guarantee a level of privacy and personal data protection equal to the level of protection guaranteed by European privacy laws, but as Controller we take the utmost account of the right to security and protection of personal data of our Users, therefore we will process such transfers with all due care and guarantees. Your personal data will not be transferred to third parties, nor will be disseminated.
Your personal data will be kept for the time strictly necessary to carry out the primary purposes described in this statement, or in any case not longer than 12 (twelve months) and/or as necessary for the protection of the rights of both the interests of both Users and the Company.
E. Your rights
- registered letter with return receipt (to the following address: Winnington House 2 Woodberry Grove North Finchley N12 0DR, London,)
- by e-mail (to the following address firstname.lastname@example.org)
Pursuant to Privacy Laws, the Data Controller informs that Users have the right to obtain indication (i) of the origin of personal data; (ii) the purposes and methods of the processing; (iii) the logic applied in the event of processing carried out with the aid of electronic instruments; (iv) of the identification details of the Controllers and Processors; (v) the subjects or categories of subjects to whom the personal data may be communicated or who may come to know them as Processors.
Furthermore, Users have the right to obtain:
a) access, updating, rectification or, when interested, integration of data;
b) the cancellation, transformation into anonymous form or blocking of data processed unlawfully, including data whose retention is unnecessary for the purposes for which the data were collected or subsequently processed;
c) the attestation that the operations referred to in letters a) and b) have been brought to the attention, also as regards their content, of those to whom the data have been communicated or disseminated, except in the case where this fulfillment is it proves impossible or involves a use of means manifestly disproportionate to the protected right.
Moreover, Users have:
a) the right to withdraw consent at any time, if the processing is based on their consent;
b) (and, if its is applicable) the right to data portability (right to receive all personal data concerning them in a structured format, commonly used and readable by automatic device), the right to limit the processing of personal data and the right to cancel (" right to be forgotten ");
c) the right to oppose:
i) in whole or in part, for legitimate reasons, to the processing of personal data concerning them, even if pertinent to the purpose of the collection;
ii) in whole or in part, to the processing of personal data concerning them for the purpose of sending advertising or direct sales material or for carrying out market research or commercial communication;
d) if they believe that the processing that concerns them violates any Privacy Laws, the right to lodge a complaint with a Supervisory Authority (if a European citizen, in the Member State in which they usually reside, in the one in which they work or in the one in which the alleged violation has occurred).