This Application collects certain Personal Data from its Users. The Data Controller is Orthodrome Group s.r.l., Via Margutta 33, 00187 Rome. For any information, please contact amministrazione@orthodromegroup.com
Personal Data collected for the following purposes and using the following services:
– Commercial affiliation
– Amazon Affiliation
– Personal Data: Cookies and Usage Data
– Content commenting
– Directly managed comment system
– Personal Data: last name, email address, first name, website and username
– Contacting the User
– Mailing list or newsletter
– Personal Data: last name, date of birth, email address and first name
– Contact management and message sending
– MailChimp
– Personal Data: last name, date of birth, email address and first name
– Landing page and invitation page management
– Mailchimp Landing Page
– Personal Data: last name, date of birth, email address, address, country, first name, phone number, profession and gender
– Hosting and backend infrastructure
– ArubaCloud
– Personal Data: various types of Data as specified in the service’s privacy policy
– Interaction with data collection platforms and other third parties
– MailChimp widget
– Personal Data: last name, first name, email address, job title, company name
– Interaction with social networks and external platforms
– Facebook Like Button and social widgets, Twitter Tweet Button and social widgets, and Google+ +1 Button and social widgets
– Personal Data: Cookies and Usage Data
– YouTube Button and social widgets
– Personal Data: Usage Data
– Location-based interactions
– Geolocation
– Personal Data: geographic location
– Advertising
– Amazon Mobile Ads and Google AdSense
– Personal Data: Cookies and Usage Data
– Direct Email Marketing (DEM)
– Personal Data: email address
– Facebook Audience Network
– Personal Data: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example)
– Registration and authentication
– Direct registration
– Personal Data: last name, email address, first name and website
– Remarketing and behavioral targeting
– Facebook Remarketing, Remarketing with Google Analytics for Display Advertising and AdWords Remarketing
– Personal Data: Cookies and Usage Data
– Facebook Custom Audience
– Personal Data: Cookies and email address
– Platform services and hosting
– WordPress.com
– Personal Data: various types of Data as specified in the service’s privacy policy
– Statistics
– Google Analytics
– Personal Data: Cookies and Usage Data
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Contact Information
– Data Controller
– Rinnovabili.africa – Orthodrome Group s.r.l., Via Margutta 33, Rome.
– Data Controller’s email address: amministrazione@orthodromegroup.com
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Extended Privacy Policy
Data Controller
The Data Controller is Orthodrome Group s.r.l., Via Margutta 33, 00187 Rome. For any information, please contact amministrazione@orthodromegroup.com
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Types of Data Collected
Among the Personal Data collected by this Application, either independently or through third parties, are: Cookies, Usage Data, first name, last name, email address, username, website, date of birth, gender, phone number, address, profession, country, geographic location, and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
Complete details on each type of Data collected are provided in the dedicated sections of this privacy policy or by specific informational texts displayed prior to the collection of the Data itself.
Personal Data may be freely provided by the User or, in the case of Usage Data, collected automatically during use of this Application.
Unless otherwise specified, all Data requested by this Application is mandatory. If the User refuses to provide it, it may be impossible for this Application to deliver the Service. In cases where this Application indicates certain Data as optional, Users are free to refrain from providing such Data without any consequence to the availability or functioning of the Service.
Users who are uncertain about which Data is mandatory are encouraged to contact the Data Controller.
Any use of Cookies — or other tracking tools — by this Application or by the owners of third-party services used by this Application, unless otherwise specified, is intended to provide the Service requested by the User, as well as for the additional purposes described in this document and in the Cookie Policy, if available.
The User assumes responsibility for the Personal Data of third parties obtained, published or shared through this Application, and guarantees that they have the right to communicate or disseminate them, thereby releasing the Data Controller from any liability towards third parties.
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Methods and Location of Data Processing
Methods of Processing
The Data Controller takes appropriate security measures to prevent unauthorized access, disclosure, modification or destruction of Personal Data.
Processing is carried out using IT and/or electronic tools, with organizational methods and logic strictly related to the stated purposes. In addition to the Data Controller, in some cases, other parties involved in the operation of this Application (administrative, commercial, marketing, legal personnel, system administrators) or external parties (such as third-party technical service providers, postal couriers, hosting providers, IT companies, communication agencies) — who may also be appointed as Data Processors by the Data Controller, if necessary — may have access to the Data. The updated list of Data Processors may always be requested from the Data Controller.
Legal Basis of Processing
The Data Controller processes Personal Data relating to the User when one of the following conditions applies:
– The User has given consent for one or more specific purposes. Note: in some jurisdictions, the Data Controller may be authorized to process Personal Data without the User’s consent or another legal basis specified below, unless the User objects (“opt-out”) to such processing. This does not apply, however, where the processing of Personal Data is governed by European legislation on the protection of Personal Data;
– Processing is necessary for the performance of a contract with the User and/or for the execution of pre-contractual measures;
– Processing is necessary to fulfill a legal obligation to which the Data Controller is subject;
– Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the Data Controller;
– Processing is necessary for the pursuit of the legitimate interests of the Data Controller or of third parties.
It is always possible to request that the Data Controller clarify the specific legal basis of each processing activity and, in particular, to specify whether processing is based on law, required by a contract, or necessary to enter into a contract.
Location
Data is processed at the Data Controller’s operating offices and at any other location where the parties involved in the processing are situated. For further information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than the one in which the User is located. To obtain more information about the location of processing, the User may refer to the section on details of Personal Data processing.
The User has the right to obtain information regarding the legal basis for the transfer of Data outside the European Union or to an international organization under public international law or established by two or more countries, such as the United Nations, as well as the security measures adopted by the Data Controller to protect the Data.
If any of the transfers described above take place, the User may refer to the relevant sections of this document or ask the Data Controller for information by contacting them at the details provided at the beginning of this document.
Retention Period
Data is processed and stored for the time required by the purposes for which it was collected.
Therefore:
– Personal Data collected for purposes related to the performance of a contract between the Data Controller and the User will be retained until the performance of such contract is complete.
– Personal Data collected for purposes related to the legitimate interests of the Data Controller will be retained until those interests are satisfied. The User may obtain further information regarding the legitimate interests pursued by the Data Controller in the relevant sections of this document or by contacting the Data Controller.
Where processing is based on the User’s consent, the Data Controller may retain Personal Data for a longer period until such consent is revoked. Furthermore, the Data Controller may be obliged to retain Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
Upon expiration of the retention period, Personal Data will be deleted. Therefore, upon the expiry of that period, the right of access, deletion, rectification and the right to data portability can no longer be exercised.
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Purposes of Processing the Collected Data
The User’s Data is collected to enable the Data Controller to provide its Services, as well as for the following purposes: commercial affiliation, content commenting, contacting the User, contact management and message sending, landing page and invitation page management, hosting and backend infrastructure, interaction with data collection platforms and other third parties, interaction with social networks and external platforms, location-based interactions, advertising, registration and authentication, remarketing and behavioral targeting, platform services and hosting, and statistics.
For more detailed information on the purposes of processing and the Personal Data specifically relevant to each purpose, the User may refer to the relevant sections of this document.
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Details on the Processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Commercial Affiliation
This type of service allows this Application to display advertisements for products or services offered by third parties. Ads may be displayed in the form of advertising links or as banners in various graphic formats.
Clicks on icons or banners published on this Application are tracked by the third-party services listed below and are shared with this Application.
For information on which data is collected, please refer to the privacy policies of each service.
Amazon Affiliation (Amazon)
Amazon Affiliation is a commercial affiliation service provided by Amazon.com Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – [Privacy Policy].
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Content Commenting
Commenting services allow Users to formulate and publish their own comments on the content of this Application.
Depending on the settings chosen by the Data Controller, Users may also leave comments anonymously. If the Personal Data provided by the User includes an email address, it may be used to send notifications of comments relating to the same content. Users are responsible for the content of their own comments.
If a third-party commenting service is installed, it is possible that even when Users do not use the comment service, it may still collect traffic data relating to the pages on which it is installed.
Directly Managed Comment System (this Application)
This Application has its own content commenting system.
Personal Data collected: last name, email address, first name, website and username.
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Contacting the User
Mailing List or Newsletter (this Application)
By registering for the mailing list or newsletter, the User’s email address is automatically added to a contact list to which email messages containing information — including commercial and promotional content — relating to this Application may be sent. The User’s email address may also be added to this list as a result of registering on this Application or after making a purchase.
Personal Data collected: last name, date of birth, email address and first name.
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Landing Page and Invitation Page Management
This type of service allows the creation and management of landing pages and invitation pages — i.e., pages presenting a product or service — which may allow users to enter their contact information, such as their email address.
The management of these pages entails the processing, by these services, of the Personal Data collected through such pages, including Usage Data.
Mailchimp Landing Page (The Rocket Science Group, LLC.)
Mailchimp Landing Page is a landing page management service provided by The Rocket Science Group, LLC., which allows this Application to collect email addresses from Users interested in its services.
Mailchimp Landing Page allows the Data Controller to track and analyze the User’s response in terms of traffic or behavior in relation to changes in the structure, text or any other component of the landing pages created.
Personal Data collected: last name, date of birth, email address, address, country, first name, phone number, profession and gender.
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Location-Based Interactions
Geolocation (this Application)
This Application may collect, use and share data relating to the User’s geographic location, in order to provide location-based services.
Most browsers and devices provide tools to deny geographic tracking by default. If the User has expressly authorized this possibility, this Application may receive information about the User’s actual geographic location.
Personal Data collected: geographic location.
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Registration and Authentication
Through registration or authentication, the User allows the Application to identify them and grant access to dedicated services.
Depending on what is described below, registration and authentication services may be provided with the assistance of third parties. Where this occurs, this Application may access certain Data stored by the third-party service used for registration or identification.
Direct Registration (this Application)
The User registers by completing the registration form and providing their Personal Data directly to this Application.
Personal Data collected: last name, email address, first name and website.
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Platform Services and Hosting
These services are intended to host and operate key components of this Application, making it possible to deliver this Application from a single platform. These platforms provide the Data Controller with a wide range of tools such as, for example, analytics tools, user registration management, comment and database management, e-commerce, payment processing, etc. The use of such tools involves the collection and processing of Personal Data. Some of these services operate through servers distributed in different geographic locations, making it difficult to determine the exact location where Personal Data is stored.
WordPress.com (Automattic Inc.)
WordPress.com is a platform provided by Automattic Inc. that allows the Data Controller to develop, operate and host this Application.
Personal Data collected: various types of Data as specified in the service’s privacy policy.
Place of processing: United States – Privacy Policy.
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Contact Management and Message Sending
This type of service allows the management of a database of email contacts, phone contacts or contacts of any other type, used to communicate with the User.
These services may also enable the collection of data relating to the date and time at which messages were viewed by the User, as well as the User’s interaction with them, such as information on clicks on links included in the messages.
MailChimp (The Rocket Science Group, LLC.)
MailChimp is an address management and email message sending service provided by The Rocket Science Group, LLC.
Personal Data collected: last name, date of birth, email address and first name.
Place of processing: United States – Privacy Policy. Privacy Shield compliant.
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Hosting and Backend Infrastructure
This type of service has the purpose of hosting the Data and files that allow this Application to operate, enabling its distribution and making available ready-to-use infrastructure to deliver specific functions of this Application.
Some of these services operate through servers distributed in different geographic locations, making it difficult to determine the exact location where Personal Data is stored.
ArubaCloud (Aruba S.p.A.)
ArubaCloud is a hosting service provided by Aruba S.p.A.
Personal Data collected: various types of Data as specified in the service’s privacy policy.
Place of processing: Italy – Privacy Policy.
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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 Application.
The interactions and information obtained by this Application are in any case subject to the User’s privacy settings for each social network.
If a service for interaction with social networks is installed, it is possible that, even when Users do not use the service, it may still collect traffic data relating to the pages on which it is installed.
Facebook Like Button and Social Widgets (Facebook, Inc.)
The Facebook “Like” button and social widgets are services for interaction with the Facebook social network, provided by Facebook, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield compliant.
Twitter Tweet Button and Social Widgets (Twitter, Inc.)
The Tweet button and Twitter social widgets are services for interaction with the Twitter social network, provided by Twitter, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield compliant.
Google+ +1 Button and Social Widgets (Google Inc.)
The +1 button and Google+ social widgets are services for interaction with the Google+ social network, provided by Google Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield compliant.
YouTube Button and Social Widgets (Google Inc.)
The YouTube button and social widgets are services for interaction with the YouTube platform, provided by Google Inc.
Personal Data collected: Usage Data.
Place of processing: United States – Privacy Policy. Privacy Shield compliant.
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Advertising
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User’s past use of this Application.
This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to which the remarketing and behavioral targeting activity is linked.
In addition to the opt-out options offered by the services listed below, the User may opt out of receiving cookies related to a third-party service by visiting the [Network Advertising Initiative opt-out page](http://optout.networkadvertising.org/).
Amazon Mobile Ads (Amazon)
Amazon Mobile Ads is an advertising service provided by Amazon.com, Inc.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy.
Direct Email Marketing (DEM) (this Application)
This Application uses the User’s Data to send commercial proposals relating to services and products provided by third parties or unrelated to the product or service provided by this Application.
Personal Data collected: email address.
Facebook Audience Network (Facebook, Inc.)
Facebook Audience Network is an advertising service provided by Facebook, Inc. For an understanding of Facebook’s use of data, please consult Facebook’s Data Policy.
To enable Facebook Audience Network to function, this Application may use certain mobile device identifiers (including Android Advertising ID or Advertising Identifier for iOS) or similar technologies to cookies. Among the ways in which Audience Network presents advertising messages to the User is the use of that User’s advertising preferences. The User can control the sharing of their advertising preferences within Facebook’s Ad Settings.
The User may opt out of certain Audience Network targeting features through their device settings. For example, they may change the advertising settings available for mobile devices, or follow the instructions applicable to Audience Network that may be set out in this privacy policy.
Personal Data collected: Cookies, Usage Data and unique device identifiers for advertising (Google Advertiser ID or IDFA identifier, for example).
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield compliant.
Google AdSense (Google Inc.)
Google AdSense is an advertising service provided by Google Inc. This service uses the “Doubleclick” Cookie, which tracks the use of this Application and the User’s behavior in relation to advertisements, products and services offered.
The User may at any time opt out of using the Doubleclick Cookie by deactivating it at: google.com/settings/ads/onweb/optout.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield compliant.
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Remarketing and Behavioral Targeting
This type of service allows this Application and its partners to communicate, optimize and serve advertisements based on the User’s past use of this Application.
This activity is carried out through the tracking of Usage Data and the use of Cookies, information that is transferred to the partners to which the remarketing and behavioral targeting activity is linked.
In addition to the opt-out options offered by the services listed below, the User may opt out of receiving cookies related to a third-party service by visiting the [Network Advertising Initiative opt-out page](http://optout.networkadvertising.org/).
Facebook Remarketing (Facebook, Inc.)
Facebook Remarketing is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy– Opt Out. Privacy Shield compliant.
Facebook Custom Audience (Facebook, Inc.)
Facebook Custom Audience is a remarketing and behavioral targeting service provided by Facebook, Inc. that connects the activity of this Application with the Facebook advertising network.
Personal Data collected: Cookies and email address.
Place of processing: United States – Privacy Policy – Opt Out. Privacy Shield compliant.
Remarketing with Google Analytics for Display Advertising (Google Inc.)
Google Analytics for Display Advertising is a remarketing and behavioral targeting service provided by Google Inc. that connects the tracking activity carried out by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out]. Privacy Shield compliant.
AdWords Remarketing (Google Inc.)
AdWords Remarketing is a remarketing and behavioral targeting service provided by Google Inc. that connects the activity of this Application with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – Opt Out.
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Statistics
The services contained in this section allow the Data Controller to monitor and analyze traffic data and are used to track User behavior.
Google Analytics (Google Inc.)
Google Analytics is a web analytics service provided by Google Inc. (“Google”). Google uses the Personal Data collected for the purpose of tracking and examining the use of this Application, compiling reports and sharing them with other services developed by Google.
Google may use the Personal Data to contextualize and personalize the advertisements of its own advertising network.
Personal Data collected: Cookies and Usage Data.
Place of processing: United States – Privacy Policy – [Opt Out]. Privacy Shield compliant.
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User Rights
Users may exercise certain rights with regard to the Data processed by the Data Controller.
In particular, the User has the right to:
– Withdraw consent at any time. The User may revoke previously given consent to the processing of their Personal Data.
– Object to the processing of their Data. The User may object to the processing of their Data where such processing is carried out on a legal basis other than consent. Further details on the right to object are provided in the section below.
– Access their Data. The User has the right to obtain information about the Data processed by the Data Controller, about certain aspects of the processing, and to receive a copy of the Data processed.
– Verify and request rectification. The User may verify the accuracy of their Data and request that it be updated or corrected.
– Obtain restriction of processing. Where certain conditions apply, the User may request that the processing of their Data be restricted. In this case, the Data Controller will not process the Data for any other purpose other than storage.
– Obtain deletion or removal of their Personal Data. Where certain conditions apply, the User may request the deletion of their Data by the Data Controller.
– Receive their Data or have it transferred to another controller. The User has the right to receive their Data in a structured, commonly used and machine-readable format and, where technically feasible, to obtain the transfer of such Data to another controller without hindrance. This provision applies where the Data is processed by automated means and the processing is based on the User’s consent, on a contract to which the User is party, or on pre-contractual measures connected thereto.
– Lodge a complaint. The User may lodge a complaint with the competent personal data protection supervisory authority or bring proceedings before a court.
Details on the Right to Object
Where Personal Data is processed in the public interest, in the exercise of official authority vested in the Data Controller, or to pursue the legitimate interests of the Data Controller, Users have the right to object to the processing on grounds relating to their particular situation.
Users are informed that, where their Data is processed for direct marketing purposes, they may object to such processing at any time without providing any justification. To find out whether the Data Controller processes data for direct marketing purposes, Users may refer to the relevant sections of this document.
How to Exercise Rights
To exercise their rights, Users may address a request to the contact details of the Data Controller indicated in this document. Requests are lodged free of charge and fulfilled by the Data Controller as promptly as possible, and in any case within one month.
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Cookie Policy
This Application uses Cookies. To learn more and to view the detailed policy, the User may consult the Cookie Policy.
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Additional Information on Processing
Legal Defense
The User’s Personal Data may be used by the Data Controller in legal proceedings or in the preparatory stages of their possible institution for the defense against abuses in the use of this Application or the related Services by the User.
The User declares to be aware that the Data Controller may be required to disclose the Data by order of public authorities.
Specific Notices
At the User’s request, and in addition to the information contained in this privacy policy, this Application may provide the User with additional, contextual information regarding specific Services, or the collection and processing of Personal Data.
System Logs and Maintenance
For operational and maintenance purposes, this Application and any third-party services used by it may collect system logs — i.e., files that record interactions and which may also contain Personal Data, such as the User’s IP address.
Information Not Contained in This Policy
Further information regarding the processing of Personal Data may be requested from the Data Controller at any time using the contact details provided.
Response to “Do Not Track” Requests
This Application does not support “Do Not Track” requests.
To find out whether any of the third-party services it uses support them, the User is invited to consult their respective privacy policies.
Changes to This Privacy Policy
The Data Controller reserves the right to make changes to this privacy policy at any time, by notifying Users on this page and, if possible, on this Application and, where technically and legally feasible, by sending a notification to Users through the contact details held by the Data Controller. Users are therefore kindly asked to consult this page regularly, referring to the date of last modification indicated at the bottom.
Where changes affect processing activities whose legal basis is consent, the Data Controller will collect the User’s consent again, if necessary.
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Definitions and Legal References
Personal Data (or Data)
Any information that, directly or indirectly, even in combination with any other information, including a personal identification number, renders an identified or identifiable natural person constitutes personal data.
Usage Data
Information collected automatically through this Application (including through third-party applications integrated into this Application), which may include: the IP addresses or domain names of the computers used by the User who connects to this Application, the URI (Uniform Resource Identifier) addresses, the time of the request, the method used to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server’s response (successful, error, etc.), the country of origin, the features of the browser and operating system used by the visitor, the various time-related details of the visit (such as the time spent on each page) and the details of the path followed within the Application, with particular reference to the sequence of pages visited, the parameters relating to the operating system and the User’s computer environment.
User
The individual using this Application who, unless otherwise specified, coincides with the Data Subject.
Data Subject
The natural person to whom the Personal Data refers.
Data Processor (or Processor)
The natural or legal person, public authority, agency or other body that processes personal data on behalf of the Data Controller, as set out in this privacy policy.
Data Controller (or Controller)
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 and the tools adopted, including the security measures relating to the operation and use of this Application. The Data Controller, unless otherwise specified, is the owner of this Application.
This Application
The hardware or software tool through which the Personal Data of Users is collected and processed.
Service
The Service provided by this Application as defined in the relevant terms (if any) on this site/application.
European Union (or EU)
Unless otherwise specified, any reference to the European Union contained in this document is intended to be extended to all current member states of the European Union and the European Economic Area.
Cookie
A small piece of data stored within the User’s device.
Legal References
This privacy notice is drawn up on the basis of multiple legislative frameworks, including Articles 13 and 14 of Regulation (EU) 2016/679.
Unless otherwise specified, this privacy notice applies exclusively to this Application.
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Strictly Necessary Activities for Operation
This Application uses Cookies to save the User’s session and to carry out other activities strictly necessary for the operation of this Application, for example in relation to traffic distribution.
Preference Saving, Optimization and Statistics Activities
This Application uses Cookies to save browsing preferences and to optimize the User’s browsing experience. These Cookies include, for example, those used to set the language and currency, or for the management of statistics by the site owner.