Last Updated March 10, 2024.
This Website collects some Personal Data from its Users.
This document contains a section dedicated to California users and their privacy rights.
This document contains a section dedicated to Brazilian users and their rights to privacy.
This document can be printed for consultation by using the print command in the settings of any browser.
Contact form
Types of Data Collected
Among the types of Personal Data that this Website collects, by itself or through third parties, are: Cookies; Usage Data; various types of Data; email address.
Complete information on each type of Personal Data collected is provided in the dedicated sections of this privacy policy or by specific explanatory texts displayed before the Data collection.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically when using this Website.
Unless specified otherwise, all Data requested by this Website are mandatory, and failure to provide this Data may make it impossible for this Website to provide its services. In cases where this Website specifically states that some Data are not mandatory, Users are free not to communicate this Data without consequences to the availability or the functioning of the Service.
Users who are uncertain about which Personal Data is mandatory are welcome to contact the Owner.
Any use of Cookies – or of other tracking tools – by this Website or by the owners of third-party services used by this Website serves the purpose of providing the Service required by the User, in addition to any other purposes described in the present 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 the Data to the Owner.
Method and Place of Processing the Data
The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT-enabled tools, following organizational procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some cases, the Data may be accessible to certain types of persons in charge, involved with the operation of this Website (administration, sales, marketing, legal, system administration) or external parties (such as third-party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed, if necessary, as Data Processors by the Owner. An updated list of these parties may be requested from the Owner at any time.
Place
The Data is processed at the Owner's operating offices and in any other places where the parties involved in the processing are located.
Depending on the User's location, data transfers may involve transferring the User's Data to a country other than their own. To find out more about the place of processing such transferred Data, Users can check the section containing detailed information on the processing of Personal Data.
Users also have the right to learn about the legal basis for Data transfers to a country outside the European Union or to any international organization governed by public international law or set up by two or more countries, such as the UN, and about the security measures taken by the Owner to safeguard their Data.
If any such transfer takes place, Users can find out more by checking the relevant sections of this document or inquire with the Owner using the information provided in the contact section.
Retention Period
Personal Data shall be processed and stored for as long as required by the purpose they have been collected for.
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may be obliged to retain Personal Data for a longer period whenever required to do so for the performance of a legal obligation or upon order of an authority.
Once the retention period expires, Personal Data shall be deleted. Therefore, the right to access, the right to erasure, the right to rectification, and the right to data portability cannot be enforced after the expiration of the retention period.
Purposes of Processing
The User's Data is collected to allow the Owner to provide its Services, fulfill legal obligations, respond to enforcement requests, protect its rights and interests (or those of its Users or third parties), detect any malicious or fraudulent activities, and for the following purposes: Advertising, Analytics, Remarketing and Behavioral Targeting, Tag Management, Traffic Optimization and Distribution, Data Transfer Outside the EU, and Contacting the User.
For specific information on the Personal Data used for each purpose, the User can refer to the "Detailed Information on the Processing of Personal Data" section.
Detailed Information on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Advertising
This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests. This does not mean that all Personal Data are used for this purpose. Details and conditions of use are listed below.
Some of the services listed below may use trackers to identify Users or they might use the technique of behavioral retargeting, namely displaying ads tailored to the User's interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.
In addition to any opt-out offered by any of the services listed below, Users can opt out of advertising by visiting the Network Advertising Initiative opt-out page.
Users may also opt out of certain advertising features through their device settings, such as mobile device advertising settings or other advertising network settings.
Google AdSense (Google Ireland Limited) is an advertising service that Google Ireland Limited provides. This service utilizes the "DoubleClick" Cookie to track the Website's use and User behavior in relation to advertisements, products, and services offered. Users have the option to disable all DoubleClick Cookies by visiting Google Ad Settings.
The Personal Data processed includes Trackers and Usage Data, with the processing taking place in Ireland. For more details, users can refer to the Privacy Policy and find options to Opt Out.
Under the California Consumer Privacy Act (CCPA), the category of personal information collected is internet information. The processing activities conducted by Google AdSense are considered a sale as defined under the CCPA. Users interested in opting out of such a sale can find additional information in the section of this document that details the rights of Californian consumers.
Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Ireland Limited) is a web analytics service provided by Google Ireland Limited ("Google"). Google uses the data collected to track and study the use of this Website, to prepare reports on its activities, and share them with other Google services.
Google may use the collected data to contextualize and personalize the ads of its own advertising network.
Personal Data processed: Cookies; Usage Data. Place of processing: Ireland - Privacy Policy - Opt Out.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): internet information.
This processing constitutes a sale under the CCPA's definition. In addition to the information in this clause, the User can find information regarding how to opt out of the sale in the section detailing the rights of Californian consumers.
Remarketing and Behavioral Targeting
This type of service allows this Website and its partners to inform, optimize, and serve advertising based on the User's past use of this Website.
This activity is performed by tracking Usage Data and by using Trackers to collect information, which is then transferred to the partners that manage the remarketing and behavioral targeting activity.
Some services offer the possibility of remarketing based on email address lists.
In addition to any opt-out offered by any of the services listed below, Users can opt out of advertising by visiting the Network Advertising Initiative opt-out page.
Users may also opt out of certain advertising features through their device settings, such as mobile device advertising settings or other advertising network settings.
Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited, linking the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of trackers for personalizing advertising by visiting Google Ads Settings. Personal Data processed: Cookies; Usage Data. Processing location: Ireland - Privacy Policy - Opt Out.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): internet information.
This processing is considered a sale as defined under the CCPA. In addition to the information provided in this section, the user can find information on how to opt out of the sale in the section detailing the rights of Californian consumers.
Tag Management
This type of service helps the Owner to manage the tags or scripts needed on this Website in a centralized fashion.
This results in the Users' Data flowing through these services, potentially resulting in the retention of this data.
Google Tag Manager (Google Ireland Limited) is a tag management service provided by Google Ireland Limited. Personal Data processed: Usage Data. Place of processing: Ireland - Privacy Policy.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): internet information.
This processing is considered a sale as defined under the CCPA. In addition to the information provided in this section, the User can find information on how to opt out of the sale in the section detailing the rights of Californian consumers.
Optimization and Distribution of Traffic
This type of service allows the Website to distribute its content through servers located across different countries and to optimize its performance.
Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between the Website and the User's browser.
Given the widespread distribution of this system, it is difficult to determine the locations to which contents containing the User's Personal Data are transferred.
Contacting the User
By filling in the Contact Form (this Website) with their Data, the User authorizes this Website to use these details to reply to requests for information, quotes, or any other kind of request as indicated by the form’s header.
Personal Data processed: email address.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): identifiers.
Data Transfer Outside the EU
The Owner is allowed to transfer Personal Data collected within the EU to third countries (i.e., any country not part of the EU) only based on a specific legal basis. Any such transfer of data is based on one of the legal grounds described below.
Users can inquire with the Owner to find out which legal basis applies to a specific service.
Data transfer abroad based on consent (this Website)
If this is the legal basis, Personal Data of Users can be transferred from the EU to third countries only if the User has explicitly consented to such a transfer, after having been informed of the possible risks due to the absence of an adequacy decision and appropriate safeguards.
In such cases, the Owner informs Users accordingly and obtains their explicit consent through this Website.
Personal Data processed: various types of Data.
Category of personal information collected according to the California Consumer Privacy Act (CCPA): internet information.
Additional Information about Personal Data
- Service Intended for Adults
- Users declare to be of adult age according to the legislation applicable to them. Minors may not use this Website.
- The Service is Not Intended for Children Under 18
- Users affirm they are of legal age according to the applicable legislation. Minors may use this Website only with the assistance of a parent or guardian. Under no circumstances may children under the age of 13 use this Website.
User Rights
Users may exercise certain rights regarding their Data processed by the Owner. Specifically, Users have the right to do the following:
- Withdraw their consent at any time. Users have the right to withdraw consent where they have previously given their consent to the processing of their Personal Data.
- Object to processing of their Data. Users have the right to object to the processing of their Data if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section below.
- Access their Data. Users have the right to learn if Data is being processed by the Owner, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the Data undergoing processing.
- Verify and seek rectification. Users have the right to verify the accuracy of their Data and ask for it to be updated or corrected.
- Restrict the processing of their Data. Under certain circumstances, Users have the right to restrict the processing of their Data. In this case, the Owner will not process their Data for any purpose other than storing it.
- Have their Personal Data deleted or otherwise removed. Under certain circumstances, Users have the right to obtain the erasure of their Data from the Owner.
- Receive their Data and have it transferred to another controller. Users have the right to receive their Data in a structured, commonly used, and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the Data is processed by automated means and that the processing is based on the User's consent, on a contract in which the User is a party, or on pre-contractual obligations thereof.
- Lodge a complaint. Users have the right to lodge a complaint with the competent data protection authority.
These rights ensure Users can take control of their Personal Data and protect their privacy under specific conditions as outlined by applicable data protection laws.
Detailed Information on the Right to Object to Processing
When Personal Data is processed for a public interest, in the exercise of an official authority vested in the Owner, or for the purposes of the legitimate interests pursued by the Owner, Users may object to such processing by providing a ground related to their particular situation to justify the objection.
Users should note that if their Personal Data is processed for direct marketing purposes, they can object to that processing at any time without providing any justification. To ascertain whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to Exercise These Rights
Any requests to exercise User rights can be directed to the Owner through the contact details provided in this document. These requests can be exercised free of charge and will be addressed by the Owner as early as possible and always within one month.
Cookie Usage Policy
This website utilizes trackers. To learn more, Users are invited to consult the Cookie Usage Policy.
Additional Information on Data Collection and Processing
Legal Actions
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 the related Services.
The User declares to be aware that the Owner may be required to reveal personal data upon request of public authorities.
Additional Information about User's Personal Data
In addition to the information contained in this privacy policy, this Website may provide the User with additional and contextual information concerning particular Services or the collection and processing of Personal Data upon request.
System Logs and Maintenance
For operation and maintenance purposes, this Website and any third-party services may collect files that record interaction with this Website (System logs) use other Personal Data (such as the IP Address) for this purpose.
Information Not Contained in This Policy
More details concerning the collection or processing of Personal Data may be requested from the Owner at any time. Please see the contact information at the beginning of this document.
How "Do Not Track" Requests Are Handled
This Website does not support “Do Not Track” requests.
To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.
Changes to This Privacy Policy
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users on this page and possibly within this Website and/or - as far as technically and legally feasible - sending a notice to Users via any contact information available to the Owner. It is strongly recommended to check this page often, referring to the date of the last modification listed at the bottom.
If the changes affect processing activities performed on the basis of the User’s consent, the Owner shall collect new consent from the User, where required.
Information for California Consumers
This section of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity managing this website, and, if necessary, its parent company, subsidiaries, and affiliates (collectively referred to as "we", "us", "our" for the purposes of this section).
The provisions contained in this section apply to all Users who are consumers residing in the state of California, United States of America, in accordance with the "California Consumer Privacy Act of 2018" (hereinafter simply referred to as "you", "your"), and for such consumers, these provisions supersede any possibly divergent or conflicting provisions contained in the privacy policy.
In this part of the document, the term "personal information" is used in accordance with its definition in the California Consumer Privacy Act (CCPA).
Categories of Personal Information Collected, Disclosed, or Sold
In this section, we briefly outline the categories of personal information that we collect, disclose, or sell, as well as the purposes for which it is used. More details about these activities can be found in the "Detailed Information on the Processing of Personal Data" section of this document.
Information We Collect: Categories of Personal Information We Collect About You
We collect the following categories of personal information about you: identifiers and internet information.
We will not collect additional categories of personal information without notifying you.
How We Collect Information: What are the sources of the personal information we collect?
We collect the aforementioned categories of personal information directly or indirectly from you when you use this website.
For example, you directly provide your personal information when you submit requests via any forms on this Website. You also provide personal information indirectly when you navigate through this Website, as personal information about you is automatically observed and collected. Finally, we may collect your personal information from third parties who work with us in connection with the Services or the operation of this Website and its functionalities.
How We Use the Information We Collect: Sharing and Disclosure of Your Personal Information to Third Parties for Business Purposes
We may disclose personal information collected about you to third parties for business purposes. In such cases, we enter into a written agreement with the third party that obligates the recipient to keep the personal information confidential and not use it for any purpose other than performing the agreement.
We may also disclose your personal information to third parties if you directly request or authorize us to do so in order to provide you with our Services.
For more information on the purposes of processing, please refer to the relevant section of this document.
Selling Your Personal Information
For our purposes, the term "sale" means any "sale, rental, release, disclosure, dissemination, making available, transfer, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to another business or a third party for monetary or other valuable consideration."
This means that, for example, a sale can occur whenever an application launches an advertisement, conducts statistical analysis of traffic or views, or simply uses tools like social media plugins, etc.
Your Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information. This means that if you ask us to stop selling your data, we will comply with your request.
Such a request can be made freely, at any time, without having to submit any verified request, simply by following the instructions below.
Instructions on How to Opt-Out of the Sale of Personal Information
If you want to learn more or exercise your right to opt-out of all sales conducted by this website, both online and offline, you can contact us for further information using the contact details provided in this document.
For What Purposes Do We Use Your Personal Information?
We may use your personal information to ensure the operational functioning of this Website and its features ("business purposes"). In such cases, your personal information will be processed in a manner that is necessary and proportional to the business purpose for which it was collected, and strictly within compatible operational purposes.
We may also use your personal information for other reasons, such as for commercial purposes (as specified in the "Detailed Information on the Processing of Personal Data" section of this document), as well as to comply with the law and protect our rights before competent authorities when our rights and interests are threatened or we suffer actual harm.
We will not use your personal data for unrelated or incompatible purposes without notifying you.
Your California Privacy Rights and How to Exercise Them
Right to Information and Portability
You have the right to request that we disclose to you the information described above. The disclosure will be limited to personal information collected or used over the last 12 months.
If we provide our response electronically, the accompanying information will be "portable," meaning delivered in a readily usable format that allows you to transmit the information to another entity without hindrance - provided it is technically feasible.
Right to Request Deletion of Your Personal Information
You have the right to request that we delete any of your personal information, subject to exceptions set forth by law (for example, but not limited to, when information is used to identify and fix errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights, etc.).
If none of the statutory exceptions apply, as a result of exercising your right, we will delete your personal information and instruct our service providers to do the same.
How to Exercise Your Rights
To exercise the rights described above, you need to submit a verifiable request by contacting us using the details provided in this document.
For us to respond to your request, we need to know who you are. Therefore, you can only use the rights mentioned above by making a verifiable request that must:
We will not respond to any request if we cannot verify your identity and thus confirm that the personal information in our possession actually relates to you.
If you cannot personally submit a verifiable request, you may authorize someone registered with the California Secretary of State to act on your behalf.
If you are an adult, you may make a verifiable request on behalf of a minor under your parental guardianship.
You may make no more than 2 requests within a 12-month period.
How and When We Should Process Your Request
We will confirm receipt of your verifiable request within 10 days and provide information on how we will process your request.
We will respond to your request within 45 days of receiving it. If we need more time, we will explain the reasons and how much more time we need. Please note that processing your request may take up to 90 days.
The disclosure will cover the past 12-month period.
If we deny your request, we will explain the reasons for the denial.
We do not charge a fee for processing or responding to your verifiable request unless it is clearly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to fulfill the request. We will inform you of our decision and explain the reasons.
Information for Users Residing in Brazil
This part of the document integrates with and supplements the information contained in the rest of the privacy policy and is provided by the entity managing this website, and, if necessary, its parent company, subsidiaries, and affiliates (collectively referred to as "we", "us", "our" for the purposes of this section).
The provisions contained in this section apply to all Users residing in Brazil, in accordance with the "Lei Geral de Proteção de Dados" (hereinafter simply referred to as "you", "your"). For such Users, these provisions take precedence over any other possibly divergent or contradictory provisions contained in the privacy policy.
In this part of the document, the term "personal information" is used in accordance with its definition in the Lei Geral de Proteção de Dados (LGPD).
Bases on Which We Process Your Personal Information
We may process your personal information only if we have legal grounds to do so. The legal bases are listed below:
- Consent: when you have given consent to the processing of your personal information for one or more specific purposes.
- Compliance with a legal or regulatory obligation: when the processing is necessary for compliance with a legal or regulatory obligation to which we are subject.
- Execution of policies provided by law or regulation: when the processing is necessary for the execution of policies provided by law or regulation, carried out by public policy entities or bodies.
- Performance of a contract or preliminary procedures related to a contract: when the processing is necessary for the performance of a contract to which you are a party, or for the execution of pre-contractual measures at your request.
- Legitimate interest: when we have a legitimate interest that is not overridden by your data protection rights, such as for improving our services, protecting our legal rights, and marketing activities.
To learn more about the legal grounds, you can contact us at any time using the contact information provided in this document.
To find out which categories of your personal information are processed, you can read the "Detailed Information on the Processing of Personal Data" section in this document.
To understand why we process your personal data, you can refer to the "Detailed Information on the Processing of Personal Data" and "Purposes of Processing" sections in this document.
Your Brazilian Privacy Rights, How to Submit a Request, and Our Response to Your Requests
Your Brazilian Privacy Rights
You have the right to:
- Confirm the existence of data processing.
- Access your data.
- Correct incomplete, inaccurate, or outdated data.
- Anonymize, block, or delete unnecessary or excessive data or data processed in noncompliance with the LGPD.
- Data portability to another service or product provider, upon express request, in accordance with the regulation of the national authority, subject to commercial and industrial secrets.
- Delete personal data processed with the consent of the data subject.
- Information about public and private entities with which the controller has shared data.
- Information about the possibility of denying consent and the consequences of such denial.
- Revoke consent.
You will never be subject to discrimination or any other detriment if you exercise your rights.
How to Submit Your Request
You can make your direct request to exercise your rights for free, at any time, using the contact details provided in this document or through your legal representative.
How and When We Will Respond to Your Request
We aim to respond promptly to your requests.
In any case, if it is impossible for us, we will surely inform you of the factual or legal reasons that prevent us from immediately or otherwise fulfilling your requests. In cases where we do not process your personal information, we will direct you to the physical or legal person to whom you should address your requests, if we are able to do so.
If you make a request for confirmation of access or processing of personal information, please specify whether you want your personal information to be provided in electronic or printed form.
You will also need to let us know if you want us to respond to your request immediately, in which case we will provide a simplified response, or if you require a full disclosure instead.
In the latter case, we will respond within 15 days from your request, providing you with all information regarding the origin of your personal information, confirmation of whether records exist, any criteria used for processing, and the purposes of processing, while preserving our commercial and industrial secrecy.
If you submit a request for correction, deletion, anonymization, or blocking of personal information, we will ensure to immediately notify other entities with whom we have shared your personal information, to allow such third parties to also fulfill your request – except in cases where such notification is proven to be impossible or requires disproportionate effort on our part.
The transfer of personal information outside of Brazil is permitted by law in the following cases:
- When the transfer is necessary for international legal cooperation between public intelligence, investigation, and prosecution bodies in accordance with the legal mechanisms provided by international law.
- When the transfer is necessary to protect your life or physical safety or the safety of third parties.
- When the transfer is authorized by the National Data Protection Authority.
- When the transfer results from a commitment taken in an international cooperation agreement.
- When the transfer is necessary to execute a public policy or legal assignment of public service.
- When the transfer is necessary to comply with legal or regulatory obligations, to execute a contract or pre-contractual procedures related to a contract, or to exercise regular rights in judicial, administrative, or arbitration procedures.