E-SHOP
Privacy policy
This website collects certain personal data from its users.
This document can be printed for reference using the print command in any browser's settings.
27 rue Romarin
69001 Lyon, France
Owner's contact email address: [hello@soberspirits.com](mailto:hello@soberspirits.com)
Complete information on each type of Personal Data collected is provided in the dedicated sections of this privacy policy or via specific explanatory texts displayed before the Data is collected. 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 indicated, all Data requested by this Website is mandatory, and failure to provide this Data may make it impossible to provide the services of this Website. In cases where this Website specifies that certain Data is not mandatory, Users are free not to provide this Data, without consequence for the availability or operation of the Service. Users who are unsure which personal data is mandatory are encouraged to contact the Owner. Any use of Cookies — or other tracking tools — by this Website or by the owners of third-party services used by this Website is for the purpose of providing the Service requested by the User, in addition to any other purpose described in this document and in the Cookie Policy, if available.
Users are responsible for any third-party personal data obtained, published, or shared through this website and confirm that they have the third party's consent to provide this data to the Owner.
The Owner takes appropriate security measures to prevent any unauthorized access, disclosure, modification or destruction of the Data. Data processing is carried out using computers and/or IT tools, according to organizational procedures and methods strictly related to the stated purposes. In addition to the Owner, in some cases, the Data may be accessible to certain categories of persons responsible for the operation of this Website (administration, sales, marketing, legal, system administration) or to external parties (such as third-party technical service providers, carriers, hosting providers, IT companies, communication agencies) designated, if necessary, as Data Processors by the Owner. The updated list of these parties can be requested from the Owner at any time. Legal basis for 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 certain laws, the Owner may be permitted to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any of the other legal bases below. However, this does not apply where the processing of Personal Data is subject to European data protection law; * The provision of Data is necessary for the performance of a contract with the User and/or any pre-contractual obligation;
* The processing is necessary for compliance with a legal obligation to which the Owner is subject;
* The processing is related to a task 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 all cases, the Owner is available to clarify the legal basis applicable to the processing and, in particular, to indicate whether the provision of Personal Data constitutes a statutory or contractual requirement, or a requirement necessary for entering into a contract.
Location
The Data is processed at the Owner's operating offices as well as in any other location 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. For more information on where this transferred Data is processed, Users can consult the section containing information on the processing of personal data.
Users also have the right to know the legal basis for data transfers to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, as well as the security measures taken by the Owner to protect their data.
If such a transfer occurs, Users can learn more by consulting the relevant sections of this document or by contacting the Owner using the information provided in the contact section.
Shelf life
Personal data is processed and stored for as long as necessary for the purpose for which it was collected.
Therefore:
* Personal data collected for purposes related to the performance of a contract between the Owner and the User is retained until the full performance of said contract. * Personal Data collected for the purposes of the Owner's legitimate interests is retained for as long as necessary to achieve those purposes. Users can obtain specific information about the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner.
The Owner may be permitted to retain Personal Data for a longer period when the User has given consent to such processing, as long as that consent has not been withdrawn. Furthermore, the Owner may be required to retain Personal Data for a longer period when required to comply with a legal obligation or by order of an authority. Upon expiry of the retention period, personal data will be deleted. Consequently, the rights of access, erasure, rectification, and data portability can no longer be exercised after the expiry of the retention period.
Advertisement
This type of service allows the use of User Data for advertising purposes. These communications are displayed as banners and other advertisements on this Website, possibly based on Users' interests. This does not mean that all Personal Data is used for this purpose. Information and terms of use are provided below. Some of the services listed below may use trackers to identify users or employ behavioral retargeting techniques, i.e., display advertisements tailored to users' interests and behavior, including those detected outside this website. For more information, please consult the privacy policies of the relevant services. Services of this type generally offer the option to opt out of this tracking. In addition to any opt-out functionality offered by one of the services below, Users can learn more about how to generally opt out of interest-based advertising in the dedicated section "How to Opt Out of Interest-Based Advertising" of this document.
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 connection with external advertising networks with which, unless otherwise stated herein, the Owner has no direct relationship. To understand how Google uses your data, please see Google's Partner Policy. This service uses the "DoubleClick" cookie, which tracks the use of this website and the user's behavior regarding the advertisements, products, and services offered.
Users can choose to disable all DoubleClick cookies by visiting: Google Ad Settings.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Direct advertising (this website)
This website uses User Data to offer services or products provided by third parties, whether or not related to the product or service provided by this website.
Direct advertising may involve the use of trackers to monitor user behavior and deliver personalized ads. Users can opt out of ad personalization by going to their device settings or by following the instructions provided by YourOnlineChoices and AdChoices. In addition to the applicable device settings, the User may also exercise the rights described in the User Rights section of this Privacy Policy.
Personal data processed: device information; tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA); universally unique identifier (UUID); usage data.
Google DV360
Google DV360 is an advertising service provided by Google LLC or Google Ireland Limited, depending on the location from which this website is accessed, which allows the Owner to manage and plan advertising campaigns. This includes designing ads, delivering them to the right target audience, bidding via automated decision-making tools (known as "automatic bidding"), and measuring campaign performance. Users can choose to disable advertising personalization trackers by visiting: Google Ad Settings.
To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Ads Similar audiences (Google Ireland Limited)
Similar Audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses data from Google Ads remarketing to display ads to users whose behavior is similar to that of users already on the remarketing list due to their past use of this website. Based on this data, personalized ads will be displayed to users suggested by Google Ads Similar audiences.
Users who do not wish to be included in Similar Audiences can refuse and disable the use of advertising trackers by visiting: Google Ad Settings.
To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Analytics
The services contained in this section allow the Owner to monitor and analyze web traffic and can be used to track User behavior.
Google Analytics with anonymized IP address (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the collected data to track and examine the use of this website, compile reports on its activities, and share them with other Google services. Google may use the collected data to contextualize and personalize ads on its own advertising network. This Google Analytics integration anonymizes your IP address. This works by shortening users' IP addresses within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server and shortened in the USA. Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google Ireland Limited)
Google Analytics has enabled advertising reporting features on this website, which collect additional information from the DoubleClick cookie (web activity) and device advertising identifiers (application activity). This allows the Owner to analyze data relating to certain behaviors and interests (traffic data and user interaction data with ads) and, if enabled, demographic data (age and gender information). Users can refuse the use of cookies by Google by visiting Google's ad settings.
Personal Data processed: Tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA); various types of Data as specified in the service's privacy policy.
Place of processing: Ireland – Privacy Policy – Opt Out.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar respects generic "Do Not Track" headers. This means your browser can tell its script not to collect any of your data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data.
Place of processing: Malta – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google advertising reporting feature that provides demographic and interest data for this website within Google Analytics (demographic data includes age and gender). Users can refuse the use of cookies by Google by visiting Google's ad settings.
Personal data processed: Tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA).
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Meta advertising network with actions performed on this website. The Facebook pixel tracks conversions attributable to ads on Facebook, Instagram, and the Audience Network. Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Payment processing
Unless otherwise stated, this website processes payments by credit card, bank transfer, or other means through external payment providers. Generally, and unless otherwise stated, users must provide their payment information and personal data directly to these payment providers. This website is not involved in the collection and processing of this information; it only receives notification from the relevant provider indicating whether the payment has been successfully processed. PayPal Payments Hub (PayPal Inc.)
PayPal Payments Hub is a payment service provided by PayPal Inc.
Personal data processed: billing address; email address; first name; last name; payment information; purchase history; tracking information; various types of data as specified in the service's privacy policy.
Place of processing: see PayPal's privacy policy.
PayPal Carrier Payments (PayPal Inc.)
PayPal Carrier Payments is a payment service provided by PayPal, Inc., that allows users to make online payments through their mobile phone carrier. Personal data processed: billing address; device information; email address; first name; last name; payment information; phone number; purchase history; Tracker; Usage Data; various types of Data as specified in the service's privacy policy.
Place of processing: see PayPal's privacy policy.
Heat mapping and session recording
Heatmap services are used to display the areas of this website with which users interact most frequently. This shows where points of interest are located. These services allow us to monitor and analyze web traffic and track user behavior. Some of these services can record sessions and make them available for later visual review.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heatmap service provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; various types of data as specified in the service's privacy policy.
Place of processing: Malta – Privacy Policy – Opt Out.
Hosting and backend infrastructure
The purpose of this type of service is to host data and files that enable this website to function and be distributed, as well as to provide a ready-to-use infrastructure for running specific functionalities or parts of this website.
Some of the services listed below, where applicable, may operate via geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
Google BigQuery
Google BigQuery is a hosting and backend service provided by Google LLC or Google Ireland Limited, depending on the location from which this website is accessed.
Personal data processed: various types of data as specified in the service's privacy policy.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website in order to record and reuse data. If one of these services is installed, it can collect browsing and usage data on the pages where it is installed, even if users are not actively using the service.
Hotjar Recruit User Testers (Hotjar Ltd.)
The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; different types of data.
Place of processing: Malta – Privacy Policy – Opt Out.
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 website. Interaction and information obtained through this website are always subject to the User's privacy settings for each social network. This type of service can nevertheless collect traffic data on the pages where the service is installed, even when users are not using it. It is recommended to log out of the relevant services to ensure that the data processed on this website is not associated with the User's profile.
PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services enabling interaction with the PayPal platform provided by PayPal Inc.
Personal data processed: Tracker; Usage data.
Place of processing: see PayPal's privacy policy.
Google Friend Connect (Google Ireland Limited)
Google Friend Connect is a social interaction service provided by Google Ireland Limited.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website. If one of these services is installed, it can collect browsing and usage data on the pages where it is installed, even if users are not actively using the service.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform, provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; different types of data.
Place of processing: Malta – Privacy Policy – Opt Out.
Remarketing and behavioral targeting
This type of service allows this website and its partners to inform, optimize, and display advertisements based on the user's past use of this website. This activity is facilitated by tracking usage data and using trackers to collect information that is then transmitted to partners who manage remarketing and behavioral targeting activities. Some services offer a remarketing option based on email address lists. Services of this type generally offer the option to opt out of this tracking. In addition to any opt-out functionality offered by one of the services below, Users can learn more about how to generally opt out of interest-based advertising in the dedicated section "How to Opt Out of Interest-Based Advertising" of this document.
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks visitors to this website and allows certain selected advertising partners to display targeted ads across the web. To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this website to the Google Ads advertising network and the DoubleClick cookie.
To understand how Google uses your data, please see Google's Partner Policy.
Users can refuse the use of trackers by Google for ad personalization by visiting Google's ad settings.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Signals (Google Ireland Limited)
This website uses Google Signals, a feature of Google Analytics, which combines visit information collected on this website with Google information from users' accounts that are logged into their Google account and have consented to this association, for the purpose of advertising personalization. This Google information may include location, search history, YouTube history, and data from Google partner sites – and is used to provide aggregated and anonymized information about users' cross-device behavior. If a User is involved in this association, they can access and/or delete this Data via My Activity provided by Google.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
SPAM protection
This type of service analyzes the traffic on this website, which may contain users' personal data, in order to filter it from traffic, messages, and content recognized 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 Google's Privacy Policy and Terms of Service.
Personal data processed: answers to questions; clicks; keystroke events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
In particular, Users have the right to:
* Withdraw their consent at any time. Users have the right to withdraw their consent when they have previously given their consent to the processing of their Personal Data. * Objecting to the 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. Further details are provided in the dedicated section below. * Access their Data. Users have the right to know whether their Data is being processed by the Owner, to obtain information about certain aspects of the processing, and to obtain a copy of the Data being processed. * Verify and request correction. Users have the right to verify the accuracy of their Data and request its update or correction. * Limit the processing of their Data. Users have the right, under certain circumstances, to limit the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storage. * Obtain the deletion or removal of their Personal Data. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. * Receive their Data and have it transferred to another data controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another data controller without hindrance. This provision applies provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party, or on pre-contractual obligations. * File a complaint. Users have the right to file a complaint with the competent data protection authority.
Details on the right to object to processing
When Personal Data is processed in the public interest, in the exercise of 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 relating to their particular situation justifying the objection. Users should be aware that if their Personal Data is processed for direct marketing purposes, they can object to this processing at any time, without providing any justification. To find out if the Owner processes Personal Data for direct marketing purposes, Users can consult the relevant sections of this document. How to exercise these rights
Any request to exercise Users' rights may be addressed to the Owner using the contact details provided in this document. These requests may be made free of charge and will be processed by the Owner as soon as possible and, in any event, within one month.
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 Website or related Services. The User acknowledges that the Owner may be required to disclose personal data upon request from public authorities.
Additional information on the User's Personal Data
In addition to the information contained in this privacy policy, this website may provide the user, upon request, with additional and contextual information concerning specific services or the collection and processing of personal data.
System and maintenance logs
For operational and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (system logs) or use other Personal Data (such as IP address) for this purpose.
Information not contained in this policy
Further details regarding the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact details at the beginning of this document.
Handling "Do Not Track" requests
This website does not support "Do Not Track" requests. To determine if any of the third-party services used comply with "Do Not Track" requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to modify this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or, to the extent technically and legally feasible, by sending a notification to Users via any contact information available to the Owner. It is strongly recommended that you check this page regularly, referring to the date of the last modification indicated at the bottom. If the changes affect processing activities carried out on the basis of the User's consent, the Owner will obtain 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 of a natural person.
Usage data
Information automatically collected by this Website (or by third-party services used on this Website) may include: IP addresses or domain names of the computers used by Users, 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 numerical code indicating the status of the server's response (successful result, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, various temporal details per visit (e.g., time spent on each page), and details of the path followed within the Application, with particular reference to the sequence of pages visited, as well as other parameters relating to the User's device operating system and/or IT environment.
User
The person using this Website who, unless otherwise indicated, corresponds to the Data Subject.
Person concerned
The natural person to whom the Personal Data relates.
Subcontractor (or Data Supervisor)
The natural or legal person, public authority, agency 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 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 Website. Unless otherwise indicated, the Data Controller is the Owner of this Website.
This Website (or this Application)
The means by which the User's Personal Data is collected and processed.
Service
The service provided by this Website as described in the relevant terms and conditions (if any) and on this website/application.
European Union (or EU)
Unless otherwise stated, all references to the European Union in this document include all current Member States of the European Union and the European Economic Area.
Cookie
Cookies are trackers consisting of small sets of data stored in the user's browser.
Plotter
The term Tracker refers to any technology—for example, cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that allows Users to be tracked, for example, by accessing or storing information on the User's device. Email
Provides access to the User's primary email address.
Legal information
This privacy statement has been drafted based on provisions of several laws, including Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy applies only to this website, unless otherwise stated herein.
Last updated: December 31, 2022
This document can be printed for reference using the print command in any browser's settings.
Owner and Data Controller
Sober Spirits27 rue Romarin
69001 Lyon, France
Owner's contact email address: [hello@soberspirits.com](mailto:hello@soberspirits.com)
Types of Data Collected
The types of Personal Data that this Website collects, either directly or through third parties, include: email address; first name; last name; company name; country; city; Tracker; Usage Data; User ID; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA); phone number; payment information; purchase history; billing address; device information; various types of Data; Universally Unique Identifier (UUID); Data communicated while using the service; Email; answers to questions; clicks; keypress events; motion sensor events; mouse movements; scroll position; touch events.Complete information on each type of Personal Data collected is provided in the dedicated sections of this privacy policy or via specific explanatory texts displayed before the Data is collected. 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 indicated, all Data requested by this Website is mandatory, and failure to provide this Data may make it impossible to provide the services of this Website. In cases where this Website specifies that certain Data is not mandatory, Users are free not to provide this Data, without consequence for the availability or operation of the Service. Users who are unsure which personal data is mandatory are encouraged to contact the Owner. Any use of Cookies — or other tracking tools — by this Website or by the owners of third-party services used by this Website is for the purpose of providing the Service requested by the User, in addition to any other purpose described in this document and in the Cookie Policy, if available.
Users are responsible for any third-party personal data obtained, published, or shared through this website and confirm that they have the third party's consent to provide this data to the Owner.
Methods and location of Data processing
Treatment methodsThe Owner takes appropriate security measures to prevent any unauthorized access, disclosure, modification or destruction of the Data. Data processing is carried out using computers and/or IT tools, according to organizational procedures and methods strictly related to the stated purposes. In addition to the Owner, in some cases, the Data may be accessible to certain categories of persons responsible for the operation of this Website (administration, sales, marketing, legal, system administration) or to external parties (such as third-party technical service providers, carriers, hosting providers, IT companies, communication agencies) designated, if necessary, as Data Processors by the Owner. The updated list of these parties can be requested from the Owner at any time. Legal basis for 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 certain laws, the Owner may be permitted to process Personal Data until the User objects to such processing (“opt-out”), without having to rely on consent or any of the other legal bases below. However, this does not apply where the processing of Personal Data is subject to European data protection law; * The provision of Data is necessary for the performance of a contract with the User and/or any pre-contractual obligation;
* The processing is necessary for compliance with a legal obligation to which the Owner is subject;
* The processing is related to a task 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 all cases, the Owner is available to clarify the legal basis applicable to the processing and, in particular, to indicate whether the provision of Personal Data constitutes a statutory or contractual requirement, or a requirement necessary for entering into a contract.
Location
The Data is processed at the Owner's operating offices as well as in any other location 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. For more information on where this transferred Data is processed, Users can consult the section containing information on the processing of personal data.
Users also have the right to know the legal basis for data transfers to a country outside the European Union or to any international organization governed by public international law or established by two or more countries, such as the UN, as well as the security measures taken by the Owner to protect their data.
If such a transfer occurs, Users can learn more by consulting the relevant sections of this document or by contacting the Owner using the information provided in the contact section.
Shelf life
Personal data is processed and stored for as long as necessary for the purpose for which it was collected.
Therefore:
* Personal data collected for purposes related to the performance of a contract between the Owner and the User is retained until the full performance of said contract. * Personal Data collected for the purposes of the Owner's legitimate interests is retained for as long as necessary to achieve those purposes. Users can obtain specific information about the legitimate interests pursued by the Owner in the relevant sections of this document or by contacting the Owner.
The Owner may be permitted to retain Personal Data for a longer period when the User has given consent to such processing, as long as that consent has not been withdrawn. Furthermore, the Owner may be required to retain Personal Data for a longer period when required to comply with a legal obligation or by order of an authority. Upon expiry of the retention period, personal data will be deleted. Consequently, the rights of access, erasure, rectification, and data portability can no longer be exercised after the expiry of the retention period.
Purposes of the processing
User Data is collected to enable the Owner to provide its Service, comply with its legal obligations, respond to requests from authorities, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activity, and for the following purposes: managing the User database, managing contacts and sending messages, advertising, managing support and contact requests, processing payments, interacting with external social networks and platforms, interacting with data collection platforms and other third parties, analytics, interacting with online survey platforms, heatmaps and session recording, beta testing, accessing third-party accounts, registration and authentication, remarketing and behavioral targeting, content performance and functionality testing (A/B testing), spam protection, hosting and backend infrastructure, and commercial affiliation. For specific information on the Personal Data used for each purpose, the User can 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 through the following services:Advertisement
This type of service allows the use of User Data for advertising purposes. These communications are displayed as banners and other advertisements on this Website, possibly based on Users' interests. This does not mean that all Personal Data is used for this purpose. Information and terms of use are provided below. Some of the services listed below may use trackers to identify users or employ behavioral retargeting techniques, i.e., display advertisements tailored to users' interests and behavior, including those detected outside this website. For more information, please consult the privacy policies of the relevant services. Services of this type generally offer the option to opt out of this tracking. In addition to any opt-out functionality offered by one of the services below, Users can learn more about how to generally opt out of interest-based advertising in the dedicated section "How to Opt Out of Interest-Based Advertising" of this document.
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 connection with external advertising networks with which, unless otherwise stated herein, the Owner has no direct relationship. To understand how Google uses your data, please see Google's Partner Policy. This service uses the "DoubleClick" cookie, which tracks the use of this website and the user's behavior regarding the advertisements, products, and services offered.
Users can choose to disable all DoubleClick cookies by visiting: Google Ad Settings.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Direct advertising (this website)
This website uses User Data to offer services or products provided by third parties, whether or not related to the product or service provided by this website.
Direct advertising may involve the use of trackers to monitor user behavior and deliver personalized ads. Users can opt out of ad personalization by going to their device settings or by following the instructions provided by YourOnlineChoices and AdChoices. In addition to the applicable device settings, the User may also exercise the rights described in the User Rights section of this Privacy Policy.
Personal data processed: device information; tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA); universally unique identifier (UUID); usage data.
Google DV360
Google DV360 is an advertising service provided by Google LLC or Google Ireland Limited, depending on the location from which this website is accessed, which allows the Owner to manage and plan advertising campaigns. This includes designing ads, delivering them to the right target audience, bidding via automated decision-making tools (known as "automatic bidding"), and measuring campaign performance. Users can choose to disable advertising personalization trackers by visiting: Google Ad Settings.
To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Google Ads Similar audiences (Google Ireland Limited)
Similar Audiences is an advertising and behavioral targeting service provided by Google Ireland Limited that uses data from Google Ads remarketing to display ads to users whose behavior is similar to that of users already on the remarketing list due to their past use of this website. Based on this data, personalized ads will be displayed to users suggested by Google Ads Similar audiences.
Users who do not wish to be included in Similar Audiences can refuse and disable the use of advertising trackers by visiting: Google Ad Settings.
To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Analytics
The services contained in this section allow the Owner to monitor and analyze web traffic and can be used to track User behavior.
Google Analytics with anonymized IP address (Google Ireland Limited)
Google Analytics is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the collected data to track and examine the use of this website, compile reports on its activities, and share them with other Google services. Google may use the collected data to contextualize and personalize ads on its own advertising network. This Google Analytics integration anonymizes your IP address. This works by shortening users' IP addresses within member states of the European Union or in other states party to the Agreement on the European Economic Area. Only in exceptional cases is the full IP address transmitted to a Google server and shortened in the USA. Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Analytics Advertising Reporting Features (Google Ireland Limited)
Google Analytics has enabled advertising reporting features on this website, which collect additional information from the DoubleClick cookie (web activity) and device advertising identifiers (application activity). This allows the Owner to analyze data relating to certain behaviors and interests (traffic data and user interaction data with ads) and, if enabled, demographic data (age and gender information). Users can refuse the use of cookies by Google by visiting Google's ad settings.
Personal Data processed: Tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA); various types of Data as specified in the service's privacy policy.
Place of processing: Ireland – Privacy Policy – Opt Out.
Hotjar Form Analysis & Conversion Funnels (Hotjar Ltd.)
Hotjar is an analytics service provided by Hotjar Ltd.
Hotjar respects generic "Do Not Track" headers. This means your browser can tell its script not to collect any of your data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data.
Place of processing: Malta – Privacy Policy – Opt Out.
Google Analytics Demographics and Interests reports (Google Ireland Limited)
Google Analytics Demographics and Interests reports is a Google advertising reporting feature that provides demographic and interest data for this website within Google Analytics (demographic data includes age and gender). Users can refuse the use of cookies by Google by visiting Google's ad settings.
Personal data processed: Tracker; unique device identifiers for advertising purposes (e.g., Google Advertiser ID or IDFA).
Place of processing: Ireland – Privacy Policy – Opt Out.
Facebook Ads conversion tracking (Facebook pixel) (Facebook Ireland Ltd)
Facebook Ads conversion tracking (Facebook pixel) is an analytics service provided by Facebook Ireland Ltd that connects data from the Meta advertising network with actions performed on this website. The Facebook pixel tracks conversions attributable to ads on Facebook, Instagram, and the Audience Network. Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Payment processing
Unless otherwise stated, this website processes payments by credit card, bank transfer, or other means through external payment providers. Generally, and unless otherwise stated, users must provide their payment information and personal data directly to these payment providers. This website is not involved in the collection and processing of this information; it only receives notification from the relevant provider indicating whether the payment has been successfully processed. PayPal Payments Hub (PayPal Inc.)
PayPal Payments Hub is a payment service provided by PayPal Inc.
Personal data processed: billing address; email address; first name; last name; payment information; purchase history; tracking information; various types of data as specified in the service's privacy policy.
Place of processing: see PayPal's privacy policy.
PayPal Carrier Payments (PayPal Inc.)
PayPal Carrier Payments is a payment service provided by PayPal, Inc., that allows users to make online payments through their mobile phone carrier. Personal data processed: billing address; device information; email address; first name; last name; payment information; phone number; purchase history; Tracker; Usage Data; various types of Data as specified in the service's privacy policy.
Place of processing: see PayPal's privacy policy.
Heat mapping and session recording
Heatmap services are used to display the areas of this website with which users interact most frequently. This shows where points of interest are located. These services allow us to monitor and analyze web traffic and track user behavior. Some of these services can record sessions and make them available for later visual review.
Hotjar Heat Maps & Recordings (Hotjar Ltd.)
Hotjar is a session recording and heatmap service provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; various types of data as specified in the service's privacy policy.
Place of processing: Malta – Privacy Policy – Opt Out.
Hosting and backend infrastructure
The purpose of this type of service is to host data and files that enable this website to function and be distributed, as well as to provide a ready-to-use infrastructure for running specific functionalities or parts of this website.
Some of the services listed below, where applicable, may operate via geographically distributed servers, making it difficult to determine the actual location where Personal Data is stored.
Google BigQuery
Google BigQuery is a hosting and backend service provided by Google LLC or Google Ireland Limited, depending on the location from which this website is accessed.
Personal data processed: various types of data as specified in the service's privacy policy.
Place of processing: United States – Privacy Policy; Ireland – Privacy Policy.
Interaction with data collection platforms and other third parties
This type of service allows Users to interact with data collection platforms or other services directly from the pages of this Website in order to record and reuse data. If one of these services is installed, it can collect browsing and usage data on the pages where it is installed, even if users are not actively using the service.
Hotjar Recruit User Testers (Hotjar Ltd.)
The Hotjar Recruit User Testers widget is a service for interacting with the Hotjar data collection platform provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; different types of data.
Place of processing: Malta – Privacy Policy – Opt Out.
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 website. Interaction and information obtained through this website are always subject to the User's privacy settings for each social network. This type of service can nevertheless collect traffic data on the pages where the service is installed, even when users are not using it. It is recommended to log out of the relevant services to ensure that the data processed on this website is not associated with the User's profile.
PayPal button and widgets (PayPal Inc.)
The PayPal button and widgets are services enabling interaction with the PayPal platform provided by PayPal Inc.
Personal data processed: Tracker; Usage data.
Place of processing: see PayPal's privacy policy.
Google Friend Connect (Google Ireland Limited)
Google Friend Connect is a social interaction service provided by Google Ireland Limited.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Interaction with online survey platforms
This type of service allows Users to interact with third-party online survey platforms directly from the pages of this Website. If one of these services is installed, it can collect browsing and usage data on the pages where it is installed, even if users are not actively using the service.
Hotjar Poll & Survey widgets (Hotjar Ltd.)
Hotjar Poll & Survey widgets are services that enable interaction with the Hotjar platform, provided by Hotjar Ltd. Hotjar respects generic "Do Not Track" headers. This means that the browser can instruct its script not to collect any user data. This setting is available in all major browsers. See Hotjar's opt-out information here.
Personal data processed: Tracker; Usage data; different types of data.
Place of processing: Malta – Privacy Policy – Opt Out.
Remarketing and behavioral targeting
This type of service allows this website and its partners to inform, optimize, and display advertisements based on the user's past use of this website. This activity is facilitated by tracking usage data and using trackers to collect information that is then transmitted to partners who manage remarketing and behavioral targeting activities. Some services offer a remarketing option based on email address lists. Services of this type generally offer the option to opt out of this tracking. In addition to any opt-out functionality offered by one of the services below, Users can learn more about how to generally opt out of interest-based advertising in the dedicated section "How to Opt Out of Interest-Based Advertising" of this document.
Google Ad Manager Audience Extension (Google Ireland Limited)
Google Ad Manager Audience Extension is a remarketing and behavioral targeting service provided by Google Ireland Limited that tracks visitors to this website and allows certain selected advertising partners to display targeted ads across the web. To understand how Google uses your data, please see Google's Partner Policy.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Ads Remarketing (Google Ireland Limited)
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this website to the Google Ads advertising network and the DoubleClick cookie.
To understand how Google uses your data, please see Google's Partner Policy.
Users can refuse the use of trackers by Google for ad personalization by visiting Google's ad settings.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
Google Signals (Google Ireland Limited)
This website uses Google Signals, a feature of Google Analytics, which combines visit information collected on this website with Google information from users' accounts that are logged into their Google account and have consented to this association, for the purpose of advertising personalization. This Google information may include location, search history, YouTube history, and data from Google partner sites – and is used to provide aggregated and anonymized information about users' cross-device behavior. If a User is involved in this association, they can access and/or delete this Data via My Activity provided by Google.
Personal data processed: Tracker; Usage data.
Place of processing: Ireland – Privacy Policy – Opt Out.
SPAM protection
This type of service analyzes the traffic on this website, which may contain users' personal data, in order to filter it from traffic, messages, and content recognized 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 Google's Privacy Policy and Terms of Service.
Personal data processed: answers to questions; clicks; keystroke events; motion sensor events; mouse movements; scroll position; touch events; Tracker; Usage data.
Place of processing: Ireland – Privacy Policy.
Information on opting out of interest-based advertising
In addition to any opt-out functionality provided by any of the services listed in this document, Users can learn more about how to generally opt out of interest-based advertising in the dedicated section of the Cookie Policy.User Rights
Users may exercise certain rights regarding their Data processed by the Owner.In particular, Users have the right to:
* Withdraw their consent at any time. Users have the right to withdraw their consent when they have previously given their consent to the processing of their Personal Data. * Objecting to the 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. Further details are provided in the dedicated section below. * Access their Data. Users have the right to know whether their Data is being processed by the Owner, to obtain information about certain aspects of the processing, and to obtain a copy of the Data being processed. * Verify and request correction. Users have the right to verify the accuracy of their Data and request its update or correction. * Limit the processing of their Data. Users have the right, under certain circumstances, to limit the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storage. * Obtain the deletion or removal of their Personal Data. Users have the right, under certain circumstances, to obtain the erasure of their Data from the Owner. * Receive their Data and have it transferred to another data controller. Users have the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to have it transmitted to another data controller without hindrance. This provision applies provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract to which the User is a party, or on pre-contractual obligations. * File a complaint. Users have the right to file a complaint with the competent data protection authority.
Details on the right to object to processing
When Personal Data is processed in the public interest, in the exercise of 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 relating to their particular situation justifying the objection. Users should be aware that if their Personal Data is processed for direct marketing purposes, they can object to this processing at any time, without providing any justification. To find out if the Owner processes Personal Data for direct marketing purposes, Users can consult the relevant sections of this document. How to exercise these rights
Any request to exercise Users' rights may be addressed to the Owner using the contact details provided in this document. These requests may be made free of charge and will be processed by the Owner as soon as possible and, in any event, within one month.
Cookie Policy
This website uses tracking technologies. For more information, users can consult the Cookie Policy.Additional information on data collection and processing
Legal actionThe 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 Website or related Services. The User acknowledges that the Owner may be required to disclose personal data upon request from public authorities.
Additional information on the User's Personal Data
In addition to the information contained in this privacy policy, this website may provide the user, upon request, with additional and contextual information concerning specific services or the collection and processing of personal data.
System and maintenance logs
For operational and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (system logs) or use other Personal Data (such as IP address) for this purpose.
Information not contained in this policy
Further details regarding the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact details at the beginning of this document.
Handling "Do Not Track" requests
This website does not support "Do Not Track" requests. To determine if any of the third-party services used comply with "Do Not Track" requests, please read their privacy policies.
Changes to this privacy policy
The Owner reserves the right to modify this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or, to the extent technically and legally feasible, by sending a notification to Users via any contact information available to the Owner. It is strongly recommended that you check this page regularly, referring to the date of the last modification indicated at the bottom. If the changes affect processing activities carried out on the basis of the User's consent, the Owner will obtain 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 of a natural person.
Usage data
Information automatically collected by this Website (or by third-party services used on this Website) may include: IP addresses or domain names of the computers used by Users, 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 numerical code indicating the status of the server's response (successful result, error, etc.), the country of origin, the characteristics of the browser and operating system used by the User, various temporal details per visit (e.g., time spent on each page), and details of the path followed within the Application, with particular reference to the sequence of pages visited, as well as other parameters relating to the User's device operating system and/or IT environment.
User
The person using this Website who, unless otherwise indicated, corresponds to the Data Subject.
Person concerned
The natural person to whom the Personal Data relates.
Subcontractor (or Data Supervisor)
The natural or legal person, public authority, agency 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 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 Website. Unless otherwise indicated, the Data Controller is the Owner of this Website.
This Website (or this Application)
The means by which the User's Personal Data is collected and processed.
Service
The service provided by this Website as described in the relevant terms and conditions (if any) and on this website/application.
European Union (or EU)
Unless otherwise stated, all references to the European Union in this document include all current Member States of the European Union and the European Economic Area.
Cookie
Cookies are trackers consisting of small sets of data stored in the user's browser.
Plotter
The term Tracker refers to any technology—for example, cookies, unique identifiers, web beacons, embedded scripts, e-tags, and fingerprinting—that allows Users to be tracked, for example, by accessing or storing information on the User's device. Email
Provides access to the User's primary email address.
Legal information
This privacy statement has been drafted based on provisions of several laws, including Articles 13 and 14 of Regulation (EU) 2016/679 (General Data Protection Regulation). This privacy policy applies only to this website, unless otherwise stated herein.
Last updated: December 31, 2022
